Administrative and Public Comments
The Lawyers’ Committee for Civil Rights Under Law regularly provides legal and policy analysis through rulemaking and public comment procedures to administrative agencies and other government entities. Our public comments and submissions highlight how policy proposals that touch on issues across our project areas would impact Black communities and other communities of color.
These submissions reflect our commitment to ensuring that laws and regulations preserve civil rights, protect against discrimination, and advance equal opportunity.
Below you can explore our recent public comments and policy submissions.
Review our Administrative and Public Comments: 2025 | 2026
July 2026
Comment Opposing the Office of Management Budget’s Proposal to Overhaul Federal Grantmaking
July 13, 2026 – The Lawyers’ Committee for Civil Rights Under Law has submitted a comment urging the Office of Management and Budget (OMB) to withdraw a proposed rule that would make sweeping, government-wide changes to how federal agencies award and terminate grants. OMB’s rule, proposed alongside 41 other federal agencies and grantmaking entities, would replace merit-based processes for selecting grant recipients with politicized reviews by administration appointees. It would impose vague restrictions on using federal funds for activities disfavored by this administration, and empower agencies to terminate awards that do not align with administration priorities. The comment explains that OMB does not have the authority to remake government-wide grantmaking in this way, and that neither OMB nor any of the 41 participating agencies have adequately explained their reasons for issuing the rule. If finalized, the rule would suppress ideas, organizations, and activities that the administration disfavors, including lawful practices that support diversity, equity, and inclusion and critical research into racial disparities. As the Lawyers’ Committee explains, the burdens and harms of this rule would fall with particular weight on Black communities and other communities of color.
Comment Opposing USPS Proposed Amendments to Ballot Mail Standards for Federal Elections
July 2, 2026 – The Lawyers’ Committee for Civil Rights Under Law submitted comments opposing the U.S. Postal Service’s proposed amendments to ballot mail standards for federal elections. The comment argues that the proposed rule would create unnecessary, burdensome, and unlawful barriers to absentee and mail voting by requiring states to submit voter names, addresses, and barcode identifiers into a new federal portal and by allowing USPS to reject ballot mail based on technical, list-matching, envelope, or barcode requirements. It further argues that the rule exceeds USPS’s authority, interferes with state election administration, and creates an unworkable federal approval system that could deny eligible voters access to mail ballots because of government, vendor, or technical errors outside of their control. The comment emphasizes that these burdens would fall especially hard on Black voters and other voters of color, who are already more likely to face administrative barriers, under-resourced election systems, transportation challenges, housing instability, and other obstacles to voting. The comment urges USPS to drop the proposed rule and return to its proper role: delivering election mail promptly, reliably, and without discrimination.
April 2026
Comment Opposing American Bar Association Proposal to Repeal Diversity and Inclusion Standard 206
April 13, 2026 – The Lawyers’ Committee for Civil Rights Under Law, in collaboration with the Howard University School of Law Civil Rights Clinic, submitted comments opposing the American Bar Association’s proposed repeal of Standard 206, which supports diversity and inclusion in legal education. The comment argues that repeal is legally unnecessary, would undermine access to the legal profession, and would further chill diversity-related efforts at law schools. It also emphasizes that diversity and inclusion strengthen the legal profession, expand access to opportunity, and are essential to building a justice system that reflects and serves an increasingly diverse society. The comment urges the ABA to preserve Standard 206 as an important safeguard for equal opportunity, inclusion, and integrity of the legal profession.
March 2026
Comment Opposing General Services Administration Proposal Affecting Applicants for Federal Grants
March 30, 2026 – The Lawyers’ Committee for Civil Rights Under Law submitted comments opposing the General Services Administration’s (GSA) proposed changes to System for Award Management (SAM) registration requirements. The proposal would impose new certification obligations—including a provision related to diversity, equity, and inclusion (DEI)—on entities seeking federal funding. The Lawyers’ Committee argues that the proposed anti-DEI provision exceeds GSA’s authority, violates the Paperwork Reduction Act, and would impose vague and legally unsupported new requirements.The comment also highlights the significant burdens and chilling effects the proposal would impose on nonprofit organizations and communities that seek and rely on federal funding, ultimately urging GSA to withdraw the proposed rule.