Page History
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- Government approval of recipient plans prior to award
- Normal exercise of Federal stewardship responsibilities during the project period (e.g. site visits, performance or financial reporting, review of objective accomplishment and adherence to terms and conditions of award)
- Unanticipated Government involvement to correct deficiencies in project or financial performance from the terms of the assistance instrument
- Preaward compliance requirements (e.g. civil rights, environmental projections, provisions for the handicapped, etc)
- Government review of performance after completion of assisted activity
- General administrative requriementsrequirements, such as included in OMB Circulars A-21, A-87, A-102, A-110, A-133), and applicable implementing regulations
Substantial involvement in cooperative agreements will be limited to the minimum required consistent with program requirements. Nothing in the Act [3] should be construed as allowing the government to increase its involvement beyond that which is authorized by applicable laws and OMB requirements.[4]
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Service Policy
Expected substantial involvement on Service cooperative agreements will be in the following format:
From the Notice of Award template:
If the award is for a cooperative agreement, include a detailed and project-specific description of the substantial activities to be carried out by Service staff under the award (“The Service will…” and “the Recipient will…” statements). Substantial involvement does NOT include: awarding funds, assigning a project officer, reviewing and approving standard financial and performance reports, processing payments, monitoring to ensure project is completed on time, or performing any other routine administrative and monitoring activities. These responsibilities are inherent to every financial assistance award and do NOT justify issuing a cooperative agreement! Do not include these types of activities in
the “The Service will…” substantial involvement statement.[5]
Funding opportunities for expected cooperative agreement awards must include in the Synopsis description the following:
“Substantial "Substantial involvement on the part of the USFWS Service is anticipated for the successful completion of the activities to be funded. In particular, the USFWS Service will be/expects to be responsible for the following: [insert a description of list the specific project-related activities /responsibilities to be performed by USFWS Service staff."
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].”[6]
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[1] 505 DM 2.9 B. (3) (a)
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[3] Federal Grant and Cooperative Agreement Act of 1977, as incorporated in 31 USC § 6301-6308 (cited online at http://www.law.cornell.edu/uscode/text/31/subtitle-V/chapter-63)
[4] 505 DM 2.9 B. (5)
[5] SERVICE PERSONNEL: See the FAPO webpage on InsideFWS for current version of NOA template.
[6] FAPO, "Issuing a New Financial Assistance Award Guidance", #5 C.
Step 3 B., pg. 9.
