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Scenario #2: A state fish and wildlife agency receives a Federal Sport Fish Restoration grant to sample, monitor, and manage 50 public recreational sport fisheries across the state.  Included in the grant, the state agency requests to purchase five new vehicles and two new electrofishing boats from private businesses.  Under this scenario, the state fish and wildlife agency acts as the non-Federal entity.  Both , while both the vehicle dealership and the electrofishing boat manufacturer become contractors, respectively.  A contractor determination would be adequate in this scenario because both entities are (a) providing goods and services within normal business operations; (2) providing similar goods or services to many different purchasers; (3) operating in a competitive environment; (4) providing goods or services that are ancillary to the operation of the Federal program; and (5) not subject to compliance requirements of the Federal program.

 

What additional requirements does the pass-through entity have in regards to its subrecipients?

 

§ 200.331 lists the various requirements that pass-thru entities have in regards to subrecipients.  

Am I required to complete a Risk Assessment on both subrecipients and contractors before issuing the award?

§ 200.331(b) requires all pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for the purposes of determining the appropriate monitoring needed to ensure that Federal funds are used properly.  Pass-through entities are not required to complete a risk assessment on contractors.

What additional requirements does the pass-through entity have in regards to its subrecipients?

§ 200.331 lists the various requirements that pass-thru entities have in regards to subrecipients.  

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Learning Aids

 

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Related Pages

 

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Resources

Service USFWS Risk Assessment Form 

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References

§ 200.22 Contract.

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