This is most helpful, Sven.  Thanks.  Brenda

 

 

Brenda,

No, subrecipients are not required to be registered in CCR. They are only required to have a valid DUNS.

From the OMB guidance issuance on implementing 2 CFR 25:

“Although the guidance proposed in February 2010 would have broadened the CCR requirement to first-tier subrecipients, the final guidance being adopted at this time does not require CCR registration for any subrecipients.” (Fed Reg 75(177) pg 55672)

And in response to the comment immediately following regarding the burden of requiring subrecipient CCR registration: “We revised the final guidance so that there is no requirement at this time for any subrecipient to register in the CCR.”

And Appendix A of Part 25

If you are authorized to make subawards under this award, you:

1. Must notify potential subrecipients that no entity ( see definition in paragraph C of this award term) may receive a subaward from you unless the entity has provided its DUNS number to you.

2. May not make a subaward to an entity unless the entity has provided its DUNS number to you.





Kind regards,
Sven

Sven Davisson, CRA
Associate Director, Sponsored Programs

The Jackson Laboratory
600 Main Street, Bar Harbor, ME 04609
V: 207-288-6772   F: 207-288-6053
http://www.jax.org

Leading the search for tomorrow's cures.

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On 3/23/12 11:43 AM, "McKinley, Brenda" <xxxxxx@UTOLEDO.EDU> wrote:

Happy Friday to all!
 
Is Central Contractor Registration (CCR) mandatory for all subrecipients under federal grants and agreements?  While 2CFR 25.110 would lead one to believe that is the case, I find language in other parts of 2 CFR 25 ambiguous.  I am preparing  a subaward agreement from an EPA grant to a corporate entity that indicates it has a DUNS # but is not registered on CCR.   Our grant agreement (prime) indicated that “Unless you are exempted from this requirement under 2 CFR 25.110, you as the recipient must maintain the currency of your information in the CCR…” but does not specify in the clause that this flows down to subrecipients.  Your thoughts?   And thanks so much for them!
 
Brenda  
 
Brenda McKinley, BA, CRA
Associate Director, Research & Sponsored Programs
The University of Toledo
2801 W. Bancroft St.
Toledo, OH  43606-3390
 
Phone:  419-530-2844
Fax:  419-530-2841
xxxxxx@utoledo.edu
 
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