is it a grant or a contract?  Either way, the first thing I would do is call the program official at the federal agency.

Marisa
________________________________________
From: Research Administration List [xxxxxx@lists.healthresearch.org] On Behalf Of Szeto, Jesse [xxxxxx@UWEX.EDU]
Sent: Friday, July 26, 2013 4:32 PM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] EDA requires a competitive bid process for subagreements?

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<mailto:xxxxxx@uwex.edu>
Phone:  (608) 890-4534

====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.healthresearch.org (click on the "LISTSERV" link in the upper right corner)

A link directly to helpful tips: http://tinyurl.com/resadm-l-help ======================================================================
This message and any attachments are confidential and intended solely
for the use of the individual or entity to which they are addressed.  If
you are not the intended recipient, you are prohibited from printing,
copying, forwarding, saving, or otherwise using or relying upon them in
any manner.  Please notify the sender immediately if you have received
this message by mistake and delete it from your system.

======================================================================
 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.healthresearch.org (click on the
 "LISTSERV" link in the upper right corner)

 A link directly to helpful tips:  http://tinyurl.com/resadm-l-help
======================================================================