Since the President issued an Executive Order on December 12, 2002, requiring equal treatment of faith-based and secular organizations when applying for federal grants, three agencies have taken action to fill in the details with provisions that look very much like H.R. 7, the controversial version of charitable choice that passed the House of Representatives in 2001. Both the Department of Health and Human Services (HHS) and Housing and Urban Development (HUD) are seeking public comments on their proposed new grant regulations.

OMB has proposed a policy requiring all federal agencies to use a common identifying number for all federal grant applicants and grantees. Our comments support this concept, but oppose proposed use of Dun and Bradstreet's system for this purpose. You can download the original copy of our comments, or read the summary here: December 30, 2002 Sandra R. Swab Office of Federal Financial Management, OMB Room 6025 New Executive Office Building Washington, D.C. 20503 RE: DUNS Comments Proposed Policy of Use of a Universal Identifier by Grant Applicants Dear Ms. Swab,

After two years of trying and failing to win congressional approval of its plan to increase the number of faith-based organizations receiving government grants for social services programs, the Bush Administration took matters into its own hands and implemented several of the most controversial provisions in Executive Order: Equal Protection of the Laws for Faith-based and Community Organizations.

If the CARE Act on charitable giving is not passed in the lame duck session, it will have to be re-introduced in the next Congress, and re-considered by the Senate Finance Committee, which as a result of last week's elections, will have a new Republican chairman, Sen. Charles Grassley (IA).