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Substantial involvement (sometimes referred to as Substantial Federal Involvement) has at least one of the following characteristics [*1]:

  • Joint collaboration or participation between the awarding agency and recipient partner, volunteer, scientist, technician, or other personnel, in carrying out the scope of work
  • Training of recipient personnel by awarding agency
  • Detailing of federal personnel by awarding agency to work on project effort
  • Review and approval by awarding agency of one stage of work prior to start of next stage
  • Review and approval by awarding agency of modifications or subawards, prior to the award
  • Awarding agency participation in selecting project staff or trainees
  • Directing or redirecting of work by awardin agency because of interrelationships with other projects
  • Ability of awarding agency to immediately halt work because of failure to meet performance specifications
  • Limitation of recipient by awarding agency in respect to designing scope of work, organizational structure, staffing, mode of operations, and other managerial processess
  • Close monitoring or operational involvement by awarding agency

Substantial involvement is not considered to be [*2]:

  • 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 requriements, 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 ActAc t[*3] should be construed as allowing the government to increase its involvement beyond that which is authorized by applicable laws and OMB requirements[*].

 

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[1] 505 DM 2.9 B. (3) (a)

[2] 505 DM 2.9 B. (3) (b)

[3] Federal Grant and Cooperative Act of 1977 (Title 31 U.S.C. §§ 6301-6308.

[4] 505 DM 2.9 B. (5)