OMB Releases Guidance to Realign U.S. Foreign Assistance to Make America “Safer, Stronger, and More Prosperous”

The Office of Management and Budget (OMB) put out Budget Data Request (BDR) No. 25-08 to “assess alignment of the US Government’s (USG) foreign assistance with the President’s America First foreign policy, which requires that each dollar of foreign assistance makes America safer, stronger, and more prosperous.” Agencies that received this BDR from OMB Resource Management Offices (RMOs) should then identify for their RMO who will respond on behalf of their agency.  

Background on this BDR regarding US Foreign Assistance:  

“The United States foreign aid industry and bureaucracy must be aligned with American interests and promote American values. It is the policy of this Administration that all foreign assistance must make the American people safer, stronger, and more prosperous. 

Safer: Foreign assistance must prioritize the security of the American people by preventing threats before they reach U.S. borders, ensuring aid supports national defense, and promoting deterrence by preventing funds from benefiting hostile entities or emboldening adversaries. 

Stronger: Foreign assistance should strengthen America’s global leadership by … increasing negotiating power; advancing America’s interests on the world stage; and directly supporting U.S. national security and foreign policy objectives. A stronger America means prioritizing our national defense…”  

Agencies are to first determine whether they fund foreign assistance programs. If an agency does not have programs that meet the scope of this definition, they should email their OMB RMO point of contact, and be prepared to share information about that determination. For agencies with foreign assistance programs, this BDR has the following requirements: 

1. Department and Agency Reviews, including outreach to implementing partners. Foreign assistance programs should be reviewed against Executive Order 14169 Reevaluating and Realigning United States Foreign Aid, with data shared with both the Department of State and OMB. 
2. Program determinations. Each responsible Department and Agency head shall make a recommendation on whether to continue, modify, or cease each foreign assistance program. 
3. Agency or Department Summary of their overarching foreign assistance activities, which should be written in a manner that could be made available to the public, and submitted to State and OMB by March 17.

Some of the questions included in the form to be completed by implementing partners of these foreign assistance programs by March 17 are: 

• Can you confirm that your agency has not collaborated with, had any accusations or investigations of working with an entity on the terrorism watch list, cartels, narco/human traffickers…? 

• Does your organization conduct regular counterterrorism vetting of its employees, sub-awardees, etc.? 

• Does your organization have a clear policy prohibiting any collaboration, funding, or support for entities that advocate or implement policies contrary to U.S. government interests, national security, and sovereignty? 

• Can you confirm that your organization has not received ANY funding from the PRC (including Confucius Institutes and/or partnered with Chinese state or non-state actors), Russia, Cuba, or Iran? 

• Does this project fulfill a national security need that cannot be fulfilled without this entity? 

Previously exempted categories and projects are part of this foreign assistance review, and Departments and Agencies will need to report on exempted as well as non-exempted categories and/or projects. The Intelligence Community (IC) is exempt from providing information via OMB Collect (go.max.gov/FARBDR). However, if an IC Department and Agency head determines that this BDR applies, they should contact their RMO point of contact to respond to this BDR through appropriate classification channels to ensure proper security and compliance protocols.  

“OMB’s attached guidance, distributed to Federal agencies this week, creates the standards and process for the realignment of foreign assistance. This guidance should help organizations to anticipate which foreign assistance programs will be funded going forward and to plan accordingly,” stated government contracting expert Robert Nichols, Chair of Nichols Liu LLP, when sharing his thoughts about this BDR and the future of foreign assistance via LinkedIn. “We have already had some success with gaining waivers under the ongoing program review process. With this new guidance in hand, we will continue advocating for clients whose programs have a chance of continued funding.”