Anonymous Comment

Comments on the U.S. AbilityOne Commission Draft Strategic Plan FY 2026–2030 Docket ID: CPPBSD-2026-0034 Thank you for the opportunity to comment on the Draft Strategic Plan. The Plan appropriately emphasizes accountability, transparency, and quality employment for individuals who are blind or have significant disabilities. However, two important elements of accountability are absent from the proposed performance measures. 1. Include Workplace Safety as a Strategic Accountability Measure Strategic Objective 2 seeks to "Drive value, efficiency, and accountability across the AbilityOne Program." While the Plan measures customer satisfaction, compliance, compensation, and career mobility, it contains no performance measures addressing workplace safety or compliance with federal workplace safety laws. A safe workplace is fundamental to quality employment. Without consistent reporting of workplace safety data, the Commission cannot effectively identify risks, evaluate program performance, or determine whether participating nonprofit agencies (NPAs) are providing safe working conditions. The Strategic Plan should require participating NPAs to annually report: * OSHA inspections, citations, penalties, and abatement status; * Department of Labor investigations and enforcement actions; * OSHA recordable injury and lost-time injury rates; and * Corrective actions implemented following significant safety findings. The Commission should publish aggregate program-wide safety metrics and incorporate this information into a risk-based oversight program. These measures would strengthen accountability while providing objective data to identify trends and direct compliance resources where they are most needed. 2. Strengthen Transparency in Governance and Stewardship The Plan also omits meaningful oversight of executive compensation, governance, subcontracting practices, and conflicts of interest. Because AbilityOne NPAs benefit from a unique statutory program supported by mandatory-source federal contracts, transparency in the stewardship of program resources is essential to maintaining public confidence. The Commission should require annual reporting of: * Executive compensation and board documentation supporting its reasonableness; * Related-party transactions involving executives, board members, or affiliated entities; * Significant subcontracting arrangements supporting AbilityOne contracts; * Whether subcontractors were selected through a competitive procurement process or another documented, objective methodology; and * Organizational conflict-of-interest disclosures. Greater transparency is particularly important where subcontracting practices may create the appearance that AbilityOne work is routinely directed to preferred vendors without meaningful competition. Even where no misconduct exists, a lack of transparency can undermine confidence that program resources are being managed in a manner consistent with the AbilityOne Program's mission. The Commission should also evaluate whether subcontracting arrangements maximize employment opportunities for individuals with disabilities and ensure that program funds are not unnecessarily diverted from that mission. Recommendation The final Strategic Plan should add performance measures requiring annual reporting of workplace safety, labor law compliance, executive compensation, governance, subcontracting activity, and conflict-of-interest disclosures. The Commission should use these data to support risk-based oversight and publish aggregate program-wide results. These recommendations are consistent with the Plan's stated commitment to accountability, transparency, and quality employment. Collecting and reporting these data will improve oversight, strengthen public confidence, and help ensure that the AbilityOne Program continues to fulfill its statutory mission while protecting the employees it exists to serve. Thank you for considering these comments.