Comment-Watching: On Simmer So Far

April 22, 2013 | By Jerry Ashworth | Post a Comment

941544_home_cooking_-_comida_caseiraLike the old saying, “A watched pot never boils,” the same can almost be said for the comments site for the Office of Management and Budget’s proposed grants reform guidance.

Several times last week, and again today, I checked the site to see how many comments had been submitted on the proposal. With each passing week, I expect to see more and more comments, with greater detail, showing up in the electronic docket. However, as of this morning, the site shows that only 39 comments have been submitted (and only 27 of those are visible on the site). Thirty-nine? That’s all? We’re entering the 12th week of the comment period, and this is all we’ve got?

I addressed this topic at the beginning of the month when I noted that only 36 comments had been submitted. So we’ve added three comments in the course of three weeks. That’s essentially a comment a week. Hmm, I’m not sure I like that ratio.

Now that OMB has extended the comment period deadline to June 2, I understand that folks out there are taking advantage of the extra time to review the proposal and likely will submit comments closer to the end of the comment period. The advanced notice of proposed rulemaking last year received more than 300 comments. This proposal could very well achieve the same response — eventually. However, the grants community better get busy during May if we’re going to achieve a similar response.

What I think is interesting is that several of the comments so far have not come from grantees, but from grantor institutions. A few universities have submitted comments, but I’m expecting the bulk of those to come later in support of comments from university lobbying organizations.

The OMB proposal contains many sweeping changes, and this is a huge deal for grants stakeholders. I would hope you are in the process of reviewing the proposal now and plan to make your concerns and comments known. I think I’ll take my eye off this pot for a couple of weeks and check back next month and see where we stand. Hopefully, we’ll start seeing things heating up by then.

If you plan to submit comments, what areas concern you in the proposal?


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