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Substantial Involvement occurs when the Recipient and the Service FWS 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 be unavailable to the Recipient.

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Substantial involvement (sometimes referred to as Substantial Federal Involvement) has at least one of the following characteristics: [14]

• 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 awarding 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 processes
• Close monitoring or operational involvement by awarding agency

Substantial involvement is not considered to be: [25]

• 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

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References

[1] 505 DM 2.9 B(3)(a)Office of Management and Budget Implementation of Federal Grant and Cooperative Agreement Act of 1977 (Pub. L 95-224). 

[2] 505 DM 2.9 B(3)(bibid, G.(2)

[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)ibid, C. 2.

[4] 505 DM 2.9 B(3)(a)

[5] ibid., (b)

[5] SERVICE PERSONNEL: See the FAPO webpage on InsideFWS FASO-Policy Branch InsideFWS webpage for current version of NOA template.

[6] FAPO, "Issuing a New Financial Assistance Award Guidance", Step 3 B., pg. 910.

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