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Humentum Comments on USAID’s Policy Framework

Humentum appreciates the opportunity to submit these comments in response to USAID’s draft Policy Framework.

Advocacy Advisor – July 2022

Operationalizing locally-led development: The sector waits for USAID to issue its long-promised plans. Check out this quarter’s Advocacy Advisor for the latest updates.

Advocacy Advisor – April 2022

What is one of the most impactful ways funders can reshape the global development and humanitarian assistance sector to be more equitable, accountable, and resilient?

Humentum Comments on USAID’s Draft Local Capacity Development 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 has divided its comments accordingly.

Advocacy Advisor – Final Update of 2021

As we move into 2022, the sector must also continue to engage the administration and Congress on the procurement and compliance policy reforms that will enable a development ecosystem supportive of and conducive to locally-led development. Humentum stands at the ready to do so.

Comments on USAID Proposed Information Collection (Education Cost Form), 84 Fed. Reg. 232 (December 9, 2019) & as Corrected, in 84 Fed. Reg. 243 

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.

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 

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 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 

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 OMB Notice of Proposed Revision, OMB-2019-0005, as published at 85 Fed.Reg. 3766-3809

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 USAID Notice of Proposed Information Collection–Development Information Solution, as published at 85 Fed. Reg.83027 

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.