By
tony on Thursday, April 10, 2003 -
12:24 pm: When issuing a
federal grant to an Association or Society can the award address
be other than the national HQ for these entities? Like a
regional chapter, etc...
By
Don Assistance on Thursday, April
10, 2003 - 11:29 pm:
Yes, it can. Who submitted the
grant proposal, the regional chapter or the national HQ?
By
Tony on Friday, April 11, 2003 -
10:56 am:
I don't know who submitted the
proposal but 99% certain it was the Chapter. So the answer is
yes?
I am arguing the answer can only be yes if the entity is
consistent in how they are awarded Grants from the Federal
Government just like any accounting and accountable function in
Federal government contracts, consistency, by reasonable and
accepted practices. Would that not also be true?
By
Don Assistance on Friday, April 11,
2003 - 03:16 pm:
I don't see any reason why you
couldn't award it to a chapter of a national organization, as
long as the Chapter meets the definition of a "recipient" in OMB
Circular A-110:
"Recipient means an organization receiving financial assistance
directly from Federal awarding agencies to carry out a project
or program. The term includes public and private institutions of
higher education, public and private hospitals, and other
quasi-public and private non-profit organizations such as, but
not limited to, community action agencies, research institutes,
educational associations, and health centers. The term may
include commercial organizations, foreign or international
organizations (such as agencies of the United Nations) which are
recipients, subrecipients, or contractors or subcontractors of
recipients or subrecipients at the discretion of the Federal
awarding agency. The term does not include government-owned
contractor-operated facilities or research centers providing
continued support for mission-oriented, large-scale programs
that are government-owned or controlled, or are designated as
federally-funded research and development centers."
It would be analogous to awarding to a subsidiary of a larger
parent company. Regarding your point about consistency, if the
chapter has submitted grant proposals in its name in the past,
and those grants have been awarded to the national HQ, then it
would be prudent to inquire about the current change. Provided
their answer was reasonable, there's no hard and fast rule
preventing you to award to the chapter. However, one thing to
keep in mind, if this is a DoD Grant, the chapter would have to
have a unique CAGE code or they'll have difficulties receiving
payments. |