|
Background: The Office of Management and Budget (OMB) has proposed a federal rule change that, if enacted, could affect how Perkins Funds can support CTSOs. A rule change is the formal process by which the federal government changes a regulation. The process requires public feedback via comments that must be considered. We’re asking stakeholders who may be impacted to submit a public comment.
Why it matters: If enacted, the proposed rule change to federal grants (the Uniform Guidance) could make it harder for Perkins V-funded programs to support student participation and engagement in CTSOs, including conferences, CDEs/LDEs, and organizational membership. We recognize that Perkins funds are utilized differently in each state and at the local level. Therefore, communicating the local impact will be beneficial information for their consideration.
To submit: Click this link to view the public comment portal. Or go to regulations.gov and search for “OMB-2026-0034-0001.” Please note that this rule change is very broad and not specific to Perkins Funds solely, so specificity around your concerns will be essential. The government will flag generic comments, or ones that use nearly the same language consistently, so providing an individualized response is essential. All comments are public.
Our key ask: NAAE and National FFA support accountability and responsible stewardship of federal funds. Yet several provisions create uncertainty about whether the costs that enable students to participate in CTSOs remain allowable. That uncertainty could negatively impact our students and the communities we serve. We ask OMB to fix this for formula programs like Perkins V by, at the very least, exempting them from the provisions regarding conferences and membership.
Key Points to raise:
- Competitions (CDEs and LDEs) allow students to showcase career-readiness skills, support student growth and development, and add a friendly competitive element to drive engagement.
- Congress authorized CTSO support, and adding additional layers of approval could cast doubt to school districts and how they operate.
- If Perkins is unable to be carved out of areas of concern, extending the deadline would be beneficial to allow local schools to reallocate budgeted funds.
Keep it local. Use local, specific examples of how students have benefited from Perkins funds. This is an opportunity to advocate on behalf of your students and community; use their stories. Keep it concise. Submitting no more than a page is beneficial; be sure to sign your name.
|
