I believe the first tier sub still exempt from registering in the CCR (for FFATA) if the dollar value of the sub is less than $25k, or have they changed that recently?

BARBARA KOURY KORZYK

Subcontracts Manager

Office of Grant & Research Development

Washington State University

Phone: (509) 335-7248

Fax: (509) 335-1676

From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Ricky Ray
Sent: Thursday, July 21, 2011 8:41 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] is this a big deal?

Some background can be found in the Federal Register, Vol. 75, No. 177, Pgs. 55663-55664 and 55671-55673, published on September 14, 2010. Relevant excerpts included below:

"As it (FFATA guidance) was proposed in 2008, the new part 33 (now part 170) would have required direct recipients of Federal agency awards and, with some exceptions, subrecipients at all lower tiers (if their subawards were subject to Transparency Act reporting requirements) to have DUNS numbers and register in the CCR. Since the publication of the June 2008 proposal, OMB proposed a new part 25 to 2 CFR on February 18, 2010 [75 FR 7316]. The proposed part 25 superseded the DUNS number and CCR elements of the June 2008 notice and limited the DUNS number requirement to applicants, recipients, and first-tier subrecipients only. The preamble of the February 2010 Federal Register document also contained responses to the public comments on the DUNS and CCR requirements proposed in June 2008. Part 25 is being finalized in another document in this section of today’s Federal Register. Therefore, the DUNS and CCR requirements will not be addressed further in this document."

"SUMMARY: OMB is issuing guidance to Federal agencies concerning two requirements for financial assistance applicants and recipients, and one requirement for first-tier subrecipients. An agency under the guidance must require applicants other than individuals, with some specific exceptions, to have Dun and Bradstreet Data Universal Numbering System (DUNS) numbers and maintain current registrations in the Central Contractor Registration (CCR) database. An agency must require applicants and recipients of grants and cooperative agreements to comply with the DUNS number and CCR requirements by October 1, 2010 and require applicants and recipients of all other financial assistance types to comply by October 1, 2011. The guidance provides standard wording for a new award term that each agency must include in its financial assistance awards to require recipients to maintain current CCR registrations, which requires that they also have DUNS numbers. The guidance also specifies that each recipient may make subawards only to entities that have DUNS numbers."

On Thu, Jul 21, 2011 at 6:45 AM, Theresa Defino <xxxxxx@aol.com> wrote:

Yes, but this instant rejection is a new thing.

-----Original Message-----
From: Sharon Smith <xxxxxx@MTSU.EDU>
To: xxxxxx@lists.healthresearch.org

Sent: Thu, Jul 21, 2011 9:43 am
Subject: Re: [RESADM-L] is this a big deal?

CCR registration has been around for a long time. Applicants must be registered in CCR in-order to submit grant applications. Some funders require that subs also are registered and have a DUNS#.

Sharon D. Smith, M.S., CRA

Research Development Specialist

MTSU Office of Research Services

(615) 898-5894 (Office)

(615) 898-5028 (Fax)

"Destiny is not a matter of chance, it is a matter of choice; it is not a thing to be waited for, it is a thing to be achieved." ~ William Jennings Bryan

From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Theresa Defino
Sent: Thursday, July 21, 2011 8:33 AM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] is this a big deal?

How long have grantees been required to get a CCR, and what about subs? Was this a new requirement under FFATA? Is this action a big deal? Or is everyone registered and current who needs to be? I read somewhere there had been a backlog.

Friday, July 15, 2011

Grants.gov to actively reject submissions from organizations with expired CCR registration.

Please be advised that on August 9th, 2011, Grants.gov will implement a real-time registration confirmation with the Central Contractor Registration (CCR) system. (Per 2 CFR Part 25, all applicants must have current CCR status at the time of application and throughout the duration of any Federal award.)

Central Contractor Registration will now be checked at the time of every Grants.gov application submission. If your CCR registration is expired and you attempt to submit an application, you will receive a rejection email indicating that your CCR account is expired. Your organization will be required to go to CCR and renew the registration.

Applicants should verify their CCR status and renew registration if needed. You can check your CCR status at http://www.ccr.gov.

Kind regards,

Theresa Defino

Editor

Report on Research Compliance

301-738-3721

xxxxxx@aol.com

Sample issue, 2/11: http://www.aiseducation.com/samplerrc.pdf

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