APTA Provides Comments to OMB on Proposed Guidance

APTA sent a letter to the Office of Management and Budget (OMB) Dec. 4 offering comments on the agency’s recent proposed Guidance for Grants and Agreements published in the Federal Register on Oct. 5 regarding the Common Grant Rule. The rule provides federal agencies with broad discretion on when to apply pre-award authority.

APTA recommends that OMB clarify its final rule to ensure that pre-award authority starts at the beginning of the federal fiscal year in which the relevant authorization is enacted, when such costs are necessary and timely to performing the grant’s scope of work.

Currently, the timing for eligibility for pre-award authority within USDOT is applied differently, depending on the modal administration and/or grant program.

APTA noted that providing pre-award authority will also help the public transportation industry address ongoing supply chain and material shortage issues. In a September 2023 Associated General Contractors of America survey, two-thirds of construction contractors identified the shortage of materials as a significant factor in project delay.