We have an award from U.S. Dept of Commerce’s Economic Development Agency (EDA).  In our proposal, we had listed four subrecipients.  In the award letter and upon further inquiry, EDA has cited 2 CFR 215.43 as requiring that all procurement transactions be subject to a 3-bid minimum. 

However, it seems that 2 CFR 215.2 (ff) specifically defines subawards as NOT a procurement action. 

Any advice for how to have EDA treat subawards in a way that is similar to other federal agencies, i.e., not require a competitive bid process?

Jesse J.K. Szeto

Director

Office of Extramural Support

UW-Extension Building
432 N. Lake Street, Room 104
Madison, WI 53706-1498

E-mail:  xxxxxx@uwex.edu

Phone:  (608) 890-4534