UC Comment Letters

This comment letter responds to OMB's request for comments on OMB's Proposed Rule on Guidance for Grants and Agreements issued on February 9, 2023. UC supports OMB’s implementation of Build America, Buy America requirements but said the proposed guidance lacks clarity on when BABA applies to federal awards that are not primarily infrastructure projects. UC recommends adding language specifying that BABA applies only to infrastructure-project spending under covered awards, not to non-infrastructure spending, to reduce compliance costs, avoid conflicting “Buy America” rules, and prevent project delays.