Comment from Bromme Hampton Cole
Bromme Hampton ColeSupportIndividual
Summary: Bromme Hampton Cole, an independent nonprofit executive, supports the AbilityOne Commission's Draft Strategic Plan while providing specific recommendations to address structural vulnerabilities. The commenter argues that the plan should be strengthened by including performance measures for governance reform, legislative mandates, and financial sustainability to ensure long-term credibility.
These comments are submitted by Bromme Hampton Cole, an independent nonprofit executive with extensive leadership experience in the IDD sector and research in AbilityOne Program governance, Commission alignment, and nonprofit accountability within the federal disability employment ecosystem.
Two documents are attached to this submission. The first is a formal public comment addressing the Draft Strategic Plan directly, organized by commendations and substantive concerns, with specific recommendations for the final document. The second is a companion analytical paper, "SourceAmerica at an Inflection Point: Governance, Commission Alignment and Nexgen II" (May 2026), which provides the research foundation for the positions advanced in the public comment.
The Draft Strategic Plan reflects genuine institutional progress. The revised mission statement, the Buy American compliance mandate, the commitment to annual employment outcome data publication, the endorsement of competition as a durable strategic direction, and the decision to open this document to public comment all represent meaningful advances. The Commission deserves recognition for each of them.
The substantive concerns raised in the attached comment address six areas the Draft Plan does not reach: the governance requirements embedded in the Commission's own NexGen Cooperative Agreement and their relationship to False Claims Act compliance; the three unimplemented recommendations from the Section 898 Panel's December 2021 report to Congress; the Section 14(c) sub-minimum wage elimination trajectory and its structural threat to the NPA workforce model; the Intergovernmental Support Agreement bypass of the mandatory source preference at military installations; the absence of a quality differentiation framework within the April 2025 competition structure; and the financial sustainability of the CNA infrastructure against a backdrop of sustained program revenue decline.
These concerns are not offered in opposition to the Commission's direction. They are offered in support of it. A five-year strategic plan that addresses the program's genuine vulnerabilities directly is a plan that will be credible to federal customers, congressional oversight bodies, and the disability community whose members depend on its commitments. The attached documents are intended to contribute to that outcome.