The CCD sign on comment letter strongly opposes the OMB proposed rule and describes how the OMB’s prohibition on diversity, equity, inclusion and accessibility (DEIA) and disparate impact liability by making this grounds for grant denials runs afoul of existing disability rights laws such as the Americans with Disabilities Act; the Individuals with Disabilities Education Act, and the Fair Housing Act Amendments. Grantees and subgrantees would find it very confusing and hard to comply with the existing laws and OMB’s proposed rules. The sign on comment letter discusses the disruption, uncertainty and administrative burden on nonprofits serving disabled people. It also talks about the proposed prohibition on viewpoint discrimination and suppression of speech in the rules interfering with the ability of grant recipients to direct and maintain attention re disability services and supports for disabled constituents.
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