Comment from Anonymous

Several of the proposed revisions would significantly expand agencies' discretion to modify, suspend, or terminate awards while reducing the predictability nonprofit organizations depend upon to responsibly administer federal funding. The National Council of Nonprofits has identified these changes as creating substantial uncertainty by expanding agency discretion over awards and permitting changes to grant terms during performance. Nonprofits already operate under rigorous financial, programmatic, and audit requirements. Accountability should remain a cornerstone of federal grantmaking, but accountability and predictability are complementary—not competing—objectives. The widespread federal funding disruptions beginning in early 2025 demonstrated the real-world consequences of uncertainty. Across the country, organizations experienced delayed payments, frozen awards, terminated agreements, staff reductions, postponed programs, and diminished services. Even temporary uncertainty can significantly impair an organization's ability to fulfill its mission and derail its effectiveness. These changes would permanently impair nonprofits and their effectiveness, and I urge you to not pass these regulations without substantial changes to improve the predictability nonprofits must have to operate effectively.