Definition
Collaboration between the awarding agency and cooperator in the management of a project, as outlined in terms of the cooperative agreement. Substantial involvement is considered a relative concept, rather than absolute, and in general refers to the specific responsibilities of both parties in meeting the objectives of a cooperative agreement.
Department Policy
Substantial involvement (sometimes referred to as Substantial Federal Involvement) has at least one of the following characteristics:
- 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:
- 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
