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Definition
Collaboration between the awarding agency and recipient in the management of a project, as outlined in terms of the cooperative agreement. Substantial Substantial Involvement occurs when the recipient Recipient and the Service participate together in the management and/or performance of the activity/project during post-award. This collaboration is programmatic in nature and may provide benefits (e.g. technical expertise, use of specialized equipment, labor) that would otherwise would be unavailable to the recipient.be unavailable to the Recipient.
According to OMB Implementation Guidance to Federal agencies that issue Cooperative Agreements[1], the language of the Substantial Involvement statement should be properly detailed to avoid ambiguity of responsibilities of each party (Federal Awarding Agency and the Recipient) in the agreement, with the interest of protecting the Federal government from liability.
"Statement of Federal involvement. Each cooperative agreement should include an explicit statement of the nature, character, and extent of anticipated Federal involvement. These statements must be developed with care to avoid unnecessarily increasing Federal liability under the assistance instrument." [2]
Substantial involvement is NOT the same as the Service's standard financial assistance management normal Federal stewardship responsibilities, nor is it to be used solely as a means of exercising greater control over the recipient. OMB policy encourages Federal agencies to limit use of Substantial involvement as much as possible, consistent with its Program requirements.
"OMB policy on substantial involvement. Agencies should limit Federal involvement in assisted activities to the minimum consistent with program requirements. Nothing in this Act should be construed as authorizing agencies to increase their involvement beyond that authorized by other statutes." [3]
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Department Policy
Substantial involvement (sometimes referred to as Substantial Federal Involvement) has at least one of the following characteristics: [1]
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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 requirements, 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]top
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Service Policy
From the Notice of Award template:
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“Substantial involvement on the part of the Service is anticipated for the successful completion of the activities to be funded. In particular, the Service will be/expects to be responsible for the following: [list the specific project-related activities to be performed by Service staff].”[6]
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Frequently Asked Questions
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Learning Aids
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Related Pages
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Resources
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References
[1] 505 DM 2.9 B(3)(a)
[2] 505 DM 2.9 B(3)(b)
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