Questions: 1 Geographic code:
(a) Will the geographic code of 937 apply to the award itself? (i.e. could the Recipient be a UK-based entity?)
(b) Will the geographic code of 937 apply to home office staff/employees of the Recipient, if the Recipient is a UK-based entity? Our understanding of USG regulations is that the code would not apply, as long as 50% of employees are citizens of the authorized code and also are not be from a prohibited country.
(c) Will the geographic code of 937 apply to individuals who are contracted as consultants (not employees) to provide services to the Recipient, if the Recipient it a UK-based entity?
(d) Will the geographic code of 937 apply to procured home office costs (rent, utilities, communication services, etc) if the Recipient is a UK-based entity?
(e) If the answer to any of the above four questions is yes , would USAID consider a waiver to code 935 for the relevant elements; and what process should an applicant undertake to request such a waiver?
USAID Response: For Geographic codes related to Source and Nationality Requirements for Procurement of Commodities and Services Financed by USAID, see ADS 310, Source and Nationality Requirements for Procurement of Commodities and Services Financed by USAID.
Questions: 2 Staffing
Should the organizational chart and staffing matrix include only the main applicant's personnel, or is it also required to include sub-awardees' personnel?
USAID Response: Include both main applicant and subawardee personnel
Questions: 3 Certification
Are certificates of incorporation and registration required for all sub-awardees, or only for the main applicant?
USAID Response:
Provide certificate of incorporation and registration for the prime applicant and verify for the subawardees. Also verify the following for the subawardees:
- Name of organization
- DUNS Number
- Confirmation that the subrecipient does not appear on the Treasury Department's Office of Foreign Assets Control (OFAC) list
- Confirmation that the subrecipient does not have active exclusions in the System for Award Management (SAM)
- Confirmation that the subrecipient is not listed in the United Nations Security designation list
- Confirmation that the subrecipient is not suspended or debarred
- Confirmation that the applicant has completed a risk assessment of the subrecipient, in accordance with 2 CFR 200.331(b)
- Any negative findings as a result of the risk assessment and the applicant's plan for mitigation.
Questions: 4. -- Cost application
Precisely which elements of the cost application are required at this stage in the process? Our interpretation of the NOFO is that only the 424A is required at this stage and that other elements (certifications & assurances, full budget and narrative, proposed sub-awards, history of financial performance) are NOT required at this stage but will be requested from the ASA at a later stage. Please confirm our understanding is correct?
USAID Response: The application will be evaluated for possible award depending on availability of funds.
The Detailed Budget must contain the following budget categories and information, at a minimum:
- Salaries and Allowances Must be proposed consistent with 2 CFR 200.430 Compensation - Personal Services. The applicant's budget must include position title, salary rate, level of effort, and salary escalation factors for each position. Allowances, when proposed, must be broken down by specific type and by position. Applicants must explain all assumptions in the Budget Narrative. The Budget Narrative must demonstrate that the proposed compensation is reasonable for the services rendered and consistent with what is paid for similar work in other activities of the applicant. Applicants must provide their established written policies on personnel compensation. If the applicant's written policies do not address a specific element of compensation that is being proposed, the Budget Narrative must describe the rationale used and supporting market research.
- Fringe Benefits (if applicable) If the applicant has a fringe benefit rate approved by an agency of the U.S. Government, the applicant must use such rate and provide evidence of its approval. If an applicant does not have a fringe benefit rate approved, the applicant must propose a rate and explain how the applicant determined the rate. In this case, the Budget Narrative must include a detailed breakdown comprised of all items of fringe benefits (e.g., superannuation, gratuity, etc.) and the costs of each, expressed in U.S. dollars and as a percentage of salaries.
- Travel and Transportation Provide details to explain the purpose of the trips, the number of trips, the origin and destination, the number of individuals traveling, and the duration of the trips. Per Diem and associated travel costs must be based on the applicant's normal travel policies. When appropriate please provide supporting documentation as an attachment, such as company travel policy, and explain assumptions in the Budget Narrative.
- Procurement or Rental of Goods (Equipment & Supplies), Services, and Real Property Must include information on estimated types of equipment, models, supplies and the cost per unit and quantity. The Budget Narrative must include the purpose of the equipment and supplies and the basis for the estimates. The Budget Narrative must support the necessity of any rental costs and reasonableness in light of such factors as: rental costs of comparable property, if any; market conditions in the area; alternatives available; and the type, life expectancy, condition, and value of the property leased.
- Subawards Specify the budget for the portion of the program to be passed through to any subrecipients. See 2 CFR 200.330 for assistance in determining whether the sub-tier entity is a subrecipient or contractor. The subrecipient budgets must align with the same requirements as the applicant's budget, including those related to fringe and indirect costs.
- Construction If applicable
- Other Direct Costs This may include other costs not elsewhere specified, such as report preparation costs, passports and visas fees, medical exams and inoculations, as well as any other miscellaneous costs which directly benefit the program proposed by the applicant. The applicant should indicate the subject, venue and duration of any proposed conferences and seminars, and their relationship to the objectives of the program, along with estimates of costs. Otherwise, the narrative should be minimal.
- Indirect Costs Applicants must indicate whether they are proposing indirect costs or will charge all costs directly. In order to better understand indirect costs please see Subpart E of 2 CFR 200.414. The application must identify which approach they are requesting and provide the applicable supporting information. Below are the most commonly used Indirect Cost Rate methods:
Method 1 - Direct Charge Only
Eligibility: Any applicant
Initial Application Requirements: See above on direct costs
Method 2 - Negotiated Indirect Cost Rate Agreement (NICRA)
Eligibility: Any applicant with a NICRA issued by a USG Agency must use that NICRA
Initial Application Requirements: If the applicant has a current NICRA, submit your approved NICRA and the associated disclosed practices. If your NICRA was issued by an Agency other than USAID, provide the contact information for the approving Agency. Additionally, at the Agency's discretion, a provisional rate may be set forth in the award subject to audit and finalization. See USAID's Indirect Cost Rate Guide for Non Profit Organizations for further guidance.
Method 3 - De minimis rate of 10% of modified total direct costs (MTDC)
Eligibility: Any applicant that has never received a NICRA
Initial Application Requirements: Costs must be consistently charged as either indirect or direct costs, but may not be double charged or inconsistently charged as both. If chosen, this methodology once elected must be used consistently for all Federal awards until such time as a non-Federal entity chooses to negotiate an indirect rate, which the non-Federal entity may apply to do at any time. The applicant must describe which cost elements it charges indirectly vs. directly. See 2 CFR 200.414(f) for further information.
Method 4 - Indirect Costs Charged As A Fixed Amount
Eligibility: Non U.S. non-profit organizations without a NICRA may request, but approval is at the discretion of the AO
Initial Application Requirements: Provide the proposed fixed amount and a worksheet that includes the following:
- Total costs incurred by the organization for the previous fiscal year and estimates for the current year. Guidance to AO: If the indirect costs are expected to be minimal or easily attributed to performance of a USAID agreement, the AO should delete this first bullet.
- Indirect costs (common costs that benefit the day-to-day operations of the organization, including categories such as salaries and expenses of executive officers, personnel administration, and accounting, or that benefit and are identifiable to more than one program or activity, such as depreciation, rental costs, operations and maintenance of facilities, and telephone expenses) for the previous fiscal year and estimates for the current year
- Proposed method for prorating the indirect costs equitably and consistently across all programs and activities of using a base that measures the benefits of that particular cost to each program or activity to which the cost applies.
If the applicant does not have an approved NICRA and does not elect to utilize the 10% de minimis rate, the Agreement Officer will provide further instructions and may request additional supporting information, including financial statements and audits, should the application.
Questions: 5 . Would USAID consider an extension of the submission deadline to 14 December 2020?
USAID Response: Consider submission deadline extended to December 14, 2020.
