Resources for Implementing Partners

Is USAID approval required for a prime recipient of a USAID assistance award to issue a subaward?

What is a subaward?

An award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a Federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a Federal program award or subaward.

Source 2 CFR 200.92

Remember: a sub award is an assistance instrument, not an acquisition instrument.

During award implementation, USAID only needs to approve NEW sub awards that were not previously identified.

U.S. NGO Subrecipient vs Non-U.S. NGO Subrecipient

Is USAID Approval Required?

U.S. NGO Subrecipient: Yes, USAID AO approval is needed either during the negotiation/award process or through separate approval during the award implementation phase. This does not apply to the purchase of supplies, material, equipment*, or general support services.

Non-U.S. NGO Subrecipient: Yes, USAID AO approval is needed either during the negotiation/award process or through separate approval during the award implementation phase. This does not apply to the acquisition of supplies, material, equipment* or general support services.

What is the source of the approval requirement?

U.S. NGO Subrecipient: 2 CFR 200.308 Revision of budget and program plans.

Non-U.S. NGO Subrecipient: Mandatory Non-U.S. NGO Standard Provision M3. AMENDMENT OF AWARD AND REVISION OF BUDGET.

What standards apply?

U.S. NGO Subrecipient: The recipient must document the rationale for subawarding the given program component and the selection of the subaward organization. The recipient must include all flow-down provisions in the subaward.

Non-U.S. NGO Subrecipient: The recipient must document the rationale for subawarding the given program component and the selection of the subaward organization. The recipient must include all flow-down provisions in the subaward.

*equipment (non-expendable items with a useful life of 1 year or more and a unit cost at purchase of $5k or more) requires approval under the cost principles – not to be confused with subaward/contracting approvals.

USAID does not need to see detailed procurement documentation unless the AO has a reason to believe that the recipient is NOT adhering to the applicable procurement standards or such review is required as part of "specific award conditions."

Where Can I Learn More?

U.S. NGO 2 CFR 200.308 Revision of budget and program plans

Non-U.S. NGO Non-U.S. NGO Mandatory Standard Provision M3. AMENDMENT OF AWARD AND REVISION OF BUDGET (AUGUST 2013)

Developed by USAID/India’s Regional Financial Management Office and Regional Office of Acquisition and Assistance and the Central and South Asia Acquisition and Assistance Innovation Lab in support of Local Capacity Building.