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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.

Humentum and Bond Letter to DFID on Covid-19 and civil society organizational resilience

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.  

Humentum’s Feedback on USDOS COVID-19 Guidance for Implementers 

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.  

Comments on USAID Proposed Information Collection, 84 FED.REG.46933-4

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.

Humentum’s Submission of Written Evidence to the UK International Development Committee’s Inquiry on the Philosophy and Culture of Aid 

Humentum discusses cultural and philosophical issues in the international aid regime, including barriers to localisation, restrictive funding practices, and lack of internal harmonization. (March 18, 2021)