Brenda:
CCR is not mandatory for a first-tier subawardee. See clips from EPA material below please.
Questions and Answers from December 2010
EPA Grants Award Process Webinars
Q1. Are all subawardees or vendors receiving $25k or more from a prime recipient required to register with
the CCR.
A1. Subawardees are only required to have a DUNS number and are not required to register with CCR. If
they do choose to register with CCR, their information regarding the top five compensated executives
are loaded into FSRS, making the reporting requirement a bit easier for prime recipients. Also, if that
subawardee ever wants to apply for funding as a prime recipient, it will need to register with the CCR.
For this reason, EPA encourages registering with the CCR even if you are a subreceipient.
Also, this EPA Guidance Memo applicable to EPA grants might be helpful to read:
http://www.epa.gov/ogd/forms/ffata_memo_final_10_22_10.pdf
b. CCR/DUNS Numbers
OMB has published a standard award term at 2 C.F.R. Subtitle A, Chapter I, Part 25 that
requires:
Prime recipients to maintain a current registration in the CCR; and
Prime recipients and first-tier subrecipients to have DUNS numbers.
GMOs must include the standard award term in all new awards, as defined in Section 6, made on
or after October 1, 2010, except for awards to individuals (i.e., where the recipient receives the
award as a natural person unrelated to any business or non-profit organization they may own or
operate in their name). There are other exceptions to the Part 25 CCR/DUNS number
requirements, including certain situations involving foreign entities or protected information (for
more information on these exceptions, see 2 C.F.R § 25.110 or contact Frank Roth, Office of
Grants and Debarment (OGD) or Jim Drummond, Office of General Counsel (OGC)).
TGIF!
With kind regards, Madison
Madison Gray, J.D.*, C.R.A., C.C.R.P.
Senior Assistant Director
Office of Contract & Research Administration (OCRA)
Vanderbilt University
email: xxxxxx@vanderbilt.edu
phone: 615-343-1374
*Not legal counsel for Vanderbilt University. The Office of the General Counsel is the only authorized legal counsel for Vanderbilt University.
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From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of McKinley, Brenda
Sent: Friday, March 23, 2012 10:43 AM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] CCR registration of subrecipients (2 CFR 25)
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
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