I’d just note for this discussion that for reporting purposes for systems like FFATA and FAPIIS, you as the prime should consider requiring your subrecipients to register in CCR. With the subs DUNS number entered, some of the fields in FFATA and FAPIIS may/should be pre-populated for you as the prime. It may not be required by the Feds but you may want to require it. With the ARRA reporting, ARRA picked up the FFATA requirements and extended them to first tier subs. Just a thought.

Carol J. Blum

Director, Research Compliance and Administration

Council on Governmental Relations

1200 New York Ave., NW, Suite 750

Washington DC 20005

202.289.6655, ext. 117/202.289.6698/fax

xxxxxx@cogr.edu

website: www.cogr.edu

From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Ricky Ray
Sent: Friday, March 23, 2012 3:57 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] CCR registration of subrecipients (2 CFR 25)

Kurt,

Yes, first-tier subs were required to be registered in CCR for ARRA reporting purposes. The requirement stems from page 54 of the second promulgation of guidance from OMB, M-09-15:

"Ensure that there is an award term or condition requiring first tier sub-awardees to begin planning activities, including obtaining a DUNS number (or updating the existing DUNS record), and registering with the Central Contractor Registration (CCR). Prime recipients and Federal agencies must establish mechanisms to meet Recovery Act data collection requirements. Agencies should work with prime recipients to ensure that DUNS and CCR requirements for first tier sub-awardees are met no later than the first time Recovery Act data requirements are due."

Ricky Ray

On Fri, Mar 23, 2012 at 3:06 PM, McKinley, Brenda <xxxxxx@utoledo.edu> wrote:

Thanks!

From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Gray, Madison
Sent: Friday, March 23, 2012 12:19 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] CCR registration of subrecipients (2 CFR 25)

Brenda:

CCR is not mandatory for a first-tier subawardee. See clips from EPA material below please.

http://www.epa.gov/ogd/training/Previous%20Webinars%20Page%20-%206.16.10%20%26%20forward/webinar_questions_final.pdf

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.

CONFIDENTIALITY NOTICE: This e-mail and any attachments are confidential and may also be privileged. If you are not the named recipient, please notify the sender immediately and delete the contents of this message without disclosing the contents to anyone, using them for any purpose, or storing or copying the information on any medium. A transcript of this email is available free of charge. Any information, of any nature, provided in this e-mail, unrelated to Vanderbilt University, is the sole opinion of the sender and does not reflect the view, endorsement by, or position of Vanderbilt University.

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

xxxxxx@utoledo.edu

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