Is fielding tanks including New Equipment Training and Materail Fielding Training a New Start if we haven't done this before for National Guard units?
: First, I strongly recommend you consult your Comptroller/BFM/Legal Office for additional clarification and guidance. You mention the Financial Management Regulation (FMR) 7000.14-R Volume 3 Chapter 6 Paragraph 4.1.5 which states: Due to the characteristics of Military Personnel and Operation and Maintenance programs, new starts seldom occur in those appropriations. New starts in these appropriations would be significant new programs, efforts, or activities that have not been explicitly justified to the Congress in budget justification material.
As you can see from the FMR language an OMA new start could be programs, efforts or activities that have not been explicitly justified to Congress in budget justification material. The situation requires that you see if this task has already been Authorized and Appropriated in previous Acts. This may be a new effort for your organization but an effort that has been ongoing over the years. The Congressional Research Service has a report located at https://crsreports.congress.gov/product/pdf/R/R46953 which is an Overview of Continuing Appropriations for FY2022 (P.L. 117-43). I would also review the actual Continuing Appropriations Act FY 2022 to see if there is any language which would allow this effort to begin.