Day 5 of WHSA's 20-Day Comment Challenge: administrative cost cap

Day 5 of the 20-Day Public Comment Challenge: Administrative Cost Cap

Today’s Prompt:

The cap on administrative costs would drop from 15 percent of the grant to 5 percent. If you know your program’s current rate, or what that money pays for, say what a cut that size would mean in practice. ACF analyzed a 10 percent cap and an exemption for grants serving 200 or fewer children, then chose neither. Ask ACF to explain why it rejected both, and to publish what the 5 percent cap would require of programs currently operating above it. 

Day 5 Prompts for the Action Alert

Staff: “I am a [role] at [program], where our administrative rate runs about [percent]. A 5 percent cap would force us to cut or reclassify [dollar amount or number of positions], which pays for [payroll, enrollment records, compliance staff, name it].” 

Parent: “I do not see the budget. When [program] lost [a position or a service], [what changed for my family]. A cut this deep sounds like more of the same.” 

Community Partner: “As [title] at [organization], we work with [program]’s office staff on [the shared work]. A 5 percent cap could mean that position is gone.” 

Where it says that: The current cap is at 45 CFR 1303.5(a)(1). The proposed rule lowers it to 5 percent, at proposed § 1301.14. The Regulatory Impact Analysis (RIA) discussion runs under Section VI, Regulatory Process Matters (91 Fed. Reg. 51248). 

This is one of 20 daily prompts. You don’t have to wait, browse them all and submit on any prompt that fits your situation, anytime between now and October 6. See the rest on the 20-Day Comment Challenge page.

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You don’t need to be a policy expert to submit a strong comment, and you don’t need to cover every issue in the proposal. In fact, a comment that focuses on one thing is often more powerful than one that tries to address everything.

  1. Focus on one area of the proposal you feel most passionate about.
  2. Add a short, real story about how that change would affect you, your child, or your classroom.
  3. Submit it before October 6, 2026.

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