Comments on Regulations
View Humentum’s comments on regulations
The documents below can also be found via our Resources page.
Humentum Comments on USAID’s Draft Local Capacity Development Policy (January 31, 2022)
Humentum appreciates the opportunity to submit these comments in response to USAID’s draft
Local Capacity Development (LCD) Policy. In its request for comments, USAID asked the public to identify the sections or statements that it deems essential to the policy; where clarification is needed; and any major gaps or inaccuracies.
Humentum’s Submission of Written Evidence to the UK International Development Committee’s Inquiry on the Philosophy and Culture of Aid (March 18, 2021)
Humentum discusses cultural and philosophical issues in the international aid regime, including barriers to localisation, restrictive funding practices, and lack of internal harmonization.
Comments on USAID Proposed Information Collection, 84 FED.REG.46933-4 (February 19, 2021)
Humentum submitted several concerns regarding gathering data using the Partner Information Form (PIF) to ensure that USAID funds, activities, and resources are not used to support organizations or individuals determined to pose a risk to US national security. Humentum recommended that USAID: (1) reconsider the procedure itself; and (2) clarify the scope, scale, and applicability of the proposed form.
Comments on USAID Notice of Proposed Information Collection–Development Information Solution, as published at 85 Fed. Reg.83027 (December 21, 2020)
Humentum advocates for a revision of the notice which inadequately provides a basis upon which the public can assess the reasonableness of the estimated burden on respondents or the utility of the collection in meeting USAID/M/OAA’s stated objectives.
Humentum’s Feedback on USDOS COVID-19 Guidance for Implementers (April 13, 2020)
Humentum leveraged member comments to make recommendations to the USDOS regarding inconsistencies in the Agency’s approach and response to requests from implementers for the flexibilities outlined in OMB Memo M-20-17.
Humentum and Bond Letter to DFID on Covid-19 and civil society organisational resilience (April 9, 2020)
In partnership with BOND, Humentum submitted recommendations to DFID regarding civil society organisational resilience. They argued that DFID must pivot and re-programme existing awards and portfolios to respond to COVID-19.
Comments on OMB Notice of Proposed Revision, OMB-2019-0005, as published at 85 Fed.Reg. 3766-3809 (January 22, 2020)
Humentum submits revisions to the OMB proposal to amend and/or add to 2 CFR §§ 200, 25, 170 and 183. These revisions would further needed policy improvements that will advance OMB objectives of risk management, burden reduction, and emphasis on performance.
Comments on Proposed Extension of Currently Approved Information Collection: PEPFAR Program Expenditures, DOS-2019-0041, OMB Control Number: 1405–0208, Form Number: DS–4213, as noticed at 85 Fed. Reg. 2227 (January 14, 2020)
Humentum urged the USDOS to revisit their proposed collection of PEPFAR Program expenditures due to an underestimated true reporting burden on PEPFAR funding recipients.
Comments on USDOS ECA Notice of Information Collection: SAMS-Domestic Results Performance Module (SAMS-D RPM), DOS-2019-0017, as noticed at 84 Fed. Reg. 67333-4 (December 9, 2019)
Humentum urged the Department of State to provide more detailed and clear information regarding the SAMS-Domestic Results Performance Module to assess the burden on organizations adequately. Humentum also informed the DOS that the burden response time may be significantly higher than originally estimated, putting a strain on organizations.
Comments on USAID Proposed Information Collection (Education Cost Form), 84 Fed. Reg. 232 (December 9, 2019) & as Corrected, in 84 Fed. Reg. 243 (December 18, 2019)
In response to a notice regarding the collection of educational cost data, Humentum submitted three key issues for member organizations to USAID. Humentum expressed concerns regarding the use of the information collection beyond USAID funding, the quality and utility of the information collected, and the burden that collection would place on organizations.