ILAB Web Chat on FY 2012 Solicitations for Grant Applications — August 16, 2012
Question:
Hi, I'm writing from a UN agency. Our office in Liberia is interested in applying for SGA 12-05 given our work in this area and strong collaboration with the Liberian Ministry of Labor.
I see from the solicitation that Public International Organizations are eligible to apply. However, as a Public International Organization, UNICEF is unable to meet the audit and counter-terrorism requirements as they are listed in the solicitation. Is DOL able to use different grant provisions for PIOs? In our extensive work with the Department of State, USAID, CDC, and other US Government agencies, each uses a grant template for UNICEF and other PIOs that is different than the one used for US-based organizations. But we have not found reference to PIO provisions in the DOL grant guidelines.
Answer:
Public International Organization (PIOs), as defined by the International Organizations Immunities Act, 22 U.S.C. § 288, et. seq, are eligible to apply for this award. If the PIO is selected for award, all legal requirements attached to USDOL funding or otherwise required by US law will be included in the cooperative agreement. However, in negotiating an award to a PIO, USDOL will acknowledge the rights and privileges established under US law and has discretion to consider alternative language to resolve conflicts between PIO policy and grant requirements.
Question:
For the Liberia SGA, Annex G "must contain audit reports of the Applicant and any proposed subgrantes and/or subcontractors (as applicable). Must all sugrantees and subcontractors submit an audit report? Can an applicant propose as subgrantees local organizations who haven't yet had an external audit at the time of proposal submission?
Answer:
Applicants may propose as subgrantees local organizations that haven't yet had an external audit at the time of submission. However, Applicants must confirm that its subgrantee(s) will initiate such as audit within six (6) months of award.
Question:
Regarding (SGA-04), is there any difference between how ILAB considers subgrantees vs. subcontractors? Does this have any implications in terms of how the entities are involved in the project?
Answer:
Provisions that delegate responsibility to implement a program or core programmatic responsibilities with limited input, oversight and authorization from the grantee are generally indicative of a subgrant. A subcontract generally assigns to the subcontractor specific, tangible and clearly defined tasks that the grantee requires and should identify required points of review and approval by the grantee. A subcontract should describe in detail all service conditions, deliverables quantities, cost/pricing information, quality standards and deliverable timetables that the subcontractor will be accountable for meeting. Administratively speaking, DOL Grantees are responsible for advising and monitoring their subrecipients' (subgrantees or subcontractors) compliance with requirements imposed on them by Federal laws, regulations, and the provisions of the cooperative agreement as well as ensuring that Federal awards are used for authorized purposes and that performance goals are achieved. Grantees are also expected to ensure that subrecipients expending $500,000 or more in Federal awards during the subrecipient's fiscal year have met the stated audit requirements, and follow up on any necessary corrective actions.
Question:
Because of its PIO status, the International Organization for Migration (IOM) does not have a NICRA, but instead has an Administrative Payment for indirect costs. Can you confirm if this exempts IOM from an attestation engagement?
Answer:
If OMB Circular A-122 (2 CFR 230) cost principles does not apply to an organization, the Applicants must explain in their cost proposal the basis of the administrative payment for indirect and the regulatory support for it. Including:
A. Whether the rate is based on incurred costs and who approves it?
B. Whether the rate is based on a flat admin rate? If so, the Applicant must explain on what basis this flat administrative rate would be applied? For example, is the rate applied to the total grant costs? Is the rate applied to total direct costs or modified total direct costs? Is the flat admin rate negotiable and who approves it?
The Applicant should note its administrative payment for indirect costs on its 424 and 424a.
Question:
In regards to the PIO guidelines, one additional query, IOM will be submitting its Financial Report for the Year Ended December 31, 2011 which will include the Opinion of the External Auditor letter on page 3. Please confirm if this fulfills DOL/ILABs requirements
Answer:
For the purpose of submitting the application, yes, this fulfills the SGA requirement. Any post-award audit requirements as outlined in the SGA must be met at that time.
Question:
In the proposal submission, where is the best place to insert information about the organization (IOM) Administrative Payment Policy and Audit Policy?
Answer:
Information about your administrative payment and audit policies should be included in the Annex section of the cost proposal.
Question:
Re Ag. Value Chain RFA: If targeted at risk youth are part of a group that migrates seasonally from neighboring countries to the country where the value chain is located it is permissible to program activities in their country of origin?
Answer:
Applicants must submit proposals that focus on one agricultural product in a minimum of one country.
While project activities (e.g., awareness raising) may occur in the country of origin for at-risk youth that migrate, the focus of the project must be tied to the implementation of the guidelines at place of production.
Question:
Does IOM need to fill out the Indirect Cost Form? A-C do not apply to IOM.
Answer:
Yes. If an Applicant doesn't have a NICRA with USG at this time, this should be stated in the Application with an indication of the Applicant's proposed indirect cost rate for the award. In the case of PIOs, please include your administrative payment policy as an indirect cost.
Question:
So, "As stated in the SGA on page 6, Section I.C (Project Target), Applicants must target children under the age of 18 engaged in or at-risk of involvement in child labor in various sectors including agriculture, fishing and fisheries/aquaculture and domestic service.¯ As such, Applicants are required to address child labor in each of these sectors...." So cover all these sectors it is necessary to cover both sea and freshwater fishing? Or Would only freshwater suffice?
Answer:
Applicants must propose to address child labor in fishing and fisheries/aquaculture. The category of fishing and fisheries/aquaculture may include addressing child labor in freshwater and/or sea fishing. The SGA does not require applicants to address child labor in both freshwater and sea fishing; however, applicants may propose to do so.
Question:
Cambodia - Page 21 e 2: What is a certificate of direct costs? What happens if a LNGO does not yet have a NICRA?
Answer:
The certificate of direct costs is required to be filled out for those organizations not claiming indirect costs. This is included in the indirect cost form that is part of the Background Materials of the SGA (http://www.dol.gov/ilab/grants/Indirect-Cost-Form.pdf). On this form, the grantee must certify that all costs charged to the grant are direct costs as defined by the cost principles. Please see the Q&As on the indirect cost form for more information.
If the organization does not have a NICRA, it is required to submit an indirect cost proposal within 90 days of grant award. This is stated in OMB Circular A122, Attachment A, E, 2. b:
"A non-profit organization which has not previously established an indirect cost rate with a Federal agency shall submit its initial indirect cost proposal immediately after the organization is advised that an award will be made and, in no event, later than three months after the effective date of the award."
Question:
SGA 12-05: What is the process for collaborating with external evaluation partners post-award? Would evaluation partners be subcontracted as part of this award or be funded separately? Is there a preference for methodology of evaluation (eg, are randomized control trials welcome?).
Answer:
As stated in the SGA on page 31, "USDOL will award a contract(s), independent of this SGA, to an external evaluator to complete these interim and final [implementation] evaluations" and that "...the external evaluators will design and implement the evaluations." USDOL will provide detailed information about the process for collaborating with an external evaluator after award. Separately, as mentioned in the SGA on page 31, "Grantees must propose research and/or data collection to assist in determining the outcomes of one or more interventions identified in the logic model/CMEP where the project believes it will have an effect… Research/data collection methodology can include qualitative, quantitative, and/or mixed-methods" including randomized control trials.
