A. Contact
Questions about your MDCP project should always be directed first to your ITA-MDCP team leader. MDCP Director Brad Hess can help as well. Other contacts specific to financial assistance management are set forth below.
- For questions about Grants Online: Email GrantsOnline.HelpDesk@noaa.gov or dial 301-444-2112 or (toll-free) 877-662-2478. Hours of Operation: Monday - Friday (Federal Work Days) 8:00am - 6:00pm Eastern Time
- For ASAP payment questions and all other questions about the financial management of your MDCP award, contact Mr. Lamar.Revis@noaa.gov, 301-628-1308. Ms. Tracy.Jacson@noaa.gov, 301-628-1323, can also help with ASAP questions
B. Financial Assistance Management Resources for Cooperators
1. Explanation of: 425 Quarterly Financial Reporting and ASAP Setup
2. Grants Manual-Department of Commerce
3. Special Award Conditions (COEDIT example) <MISSING>
4. SF-425
5. Roles in Grants Online: Cooperator roles are the 4 that begin "Recip" on right of table
C. General Federal Regulations (awards made prior to 2014.12.26)
1. Standard Terms and Conditions of Department of Commerce Awards
2. 15 CFR 14, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Other Non-Profit, and Commercial Organizations
3. 15 CFR 24, Uniform Administrative Requirements for Grants and Agreements with State and Local Governments
4. OMB Circular A-21, Cost Principles for Educational Institutions
5. OMB Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments
6. OMB Circular A-122, Cost Principles for Non-Profit Organizations
7. OMB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations
D. General Federal Regulations (awards made after 2014.12.25)
On December 26, 2013, OMB published final guidance titled Uniform Administrative Requirements, Cost Principles, and Audit Requirements (OMB Uniform Guidance), which streamlines the language from eight existing OMB circulars, including Cost Principles (OMB Circulars A-21, A-87, A 122) and administrative requirements (OMB Circulars A-102 and A 110), into one consolidated set of guidance applicable to federal assistance awards. The OMB Uniform Guidance supersedes DOC’s uniform administrative requirements set out at 15 C.F.R. parts 14 and 24. In accordance with the Federal Register notice published on December 19, 2014 (79 FR 75871) and the regulation at 2 C.F.R. 1327.101, the DOC adopted the OMB Uniform Guidance, codified at 2 C.F.R. Part 200, effective December 26, 2014, which means that the guidance applies to all new awards and to additional funding to existing awards made on or after December 26, 2014.
1. Frequently asked questions about the new regulations
2. Standard Terms and Conditions of Department of Commerce Awards
3. 2 C.F.R. Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements
4. MDCP authorization to use 10% de minimis indirect cost rate
E. Specific Topics of Interest
1. Documenting purchases in excess of the small purchase threshold
2. Grants Management Division presentation from new cooperator orientation September 10, 2015
3. Pre-Award Notification Requirements
4. Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2CFR 200)
a. Requirements published 2014
b. Requirements published 2014 compared to those published 2013
5. Commerce Department Grants Policy
Disclosure of MDCP project information
With regard to possible disclosure of information related to your MDCP project, not all information receives the same the same treatment. Some of the most frequent distinctions in treatment are set forth below.
1. Details of export sale information provided by companies participating in MDCP projects are protected and are not released publicly.
a. Especially true of part A2 of the quarterly performance progress reports (PPRs).
As a reminder to companies that wish to participate in MDCP project activitys, every organization that proposes an MDCP project should include a proposed success agreement to be signed by each participant company. Included in each such agreement is the following:
"Information provided to the International Trade Administration (ITA) is intended solely for internal use. ITA will protect business confidential information to the full extent permitted by law and Administration policy. U.S. law prohibits U.S. government employees from disclosing trade secrets."
b. Generally not true of part B of the quarterly PPRs.
Ulike part A2, PPR part B is a summary of milestones achieved in conducting project activity and is available below.
2. Information included in MDCP applications is generally public information that can be released to interested members of the public.
As a general matter, members of the public have a right to know how federal funds are being spent. Accordingly, an organization that receives an MDCP award should expect that its application can be viewed by any member of the public that requests to see it. A provision for not disclosing proprietary information exists under Freedom of Information Act (FOIA) exemption 4 as "information such as trade secrets and commercial or financial information obtained by the government from a company on a privileged or confidential basis that, if released, would result in competitive harm to the company, impair the government's ability to obtain like information in the future, or protect the government's interest in compliance with program effectiveness." This provision is designed to cover, among other things, the type of export sale information described in 1. above; however, it is rarely appropriate for the type of information included in MDCP applications.
Any MDCP applicant that does decide to claim information as proprietary must justify the claim and identify what, in particular, should be treated as proprietary. Each page that contains such information must be clearly labeled at the top:
"This page contains proprietary information, identified between brackets [], the release of which would cause competitive harm to (the organization claiming proprietary treatment)."
The actual proprietary information must be bracketed. The fact that proprietary treatment is claimed does not mean that the treatment claimed will be granted. If ITA does not agree with the justification, it informs the applicant or MDCP award winner that offered the justifiation. ITA may then take appropriate action, including release of the information if requested.
3. Examples of information that some MDCP applicants might choose not to disclose publicly.
Normally, all or almost all of the information in an MDCP application will be disclosed. Because practically all MDCP applicants are non-profit or state/regional government entities, they do not compete in the the marketplace for customers per se, therefore, they may not suffer "competitive harm" directly in the way that a private business would if certain information were disclosed. Still, disclosure may cause competitive harm in other ways or would impair ITA's ability to obtain like information in the future, or protect ITA's interest in compliance with MDCP effectiveness. Two examples follow:
- Salary and/or benefits and other sensitive personnel information: Such information is typically included in the project budget narrative. It is usually required in order for ITA to access the viability of proposed projects. It would be difficult, if not impossible for ITA to assess applications without such information. Conversely, its disclosure may put the applicant at a competitive disadvantage in personnel matters. Or, if its disclosure discourages MDCP applicants from providing the detail needed by ITA, the agency would no longer have sufficient information to make a thorough assessemt.
- Names of firms pledging to commit to project activity: This information is critical to ITA's evaluation of support among the U.S. industry that the applicant seeks to help to export. The release of such information might not directly affect the competitive position of the non-profit MDCP applicant, but it might affect the competitive position of one or more of the companies named. Its release might also affect the applicant's ability to solicit information from individual companies. A relationship of trust in soliciting sensitive business information is critical to the success of any MDCP project. The reporting of individual export sales is something that ITA witholds from public disclosure. Were ITA to do otherwise, export reporting, and by extension, the success of the program, would be greatly diminished.
4. Performance Reporting
In order to gauge the effectiveness of MDCP projects we must be able to quantify success. Part B of the quarterly performance report is where you can report progress on measures specific to your project. However, it is in Part A that you will report performance on the primary measure of MDCP project success: exports generated by project activity. We are proud that on average, MDCP projects generate $124 in exports for every $1 of MDCP award. We are only able to calculate this statistic because of cooperators that get exporting U.S. companies to report their successes.
A. Strategies for gathering information
- Success agreements.
- Export achievement awards.
- Pre-event USEAC outreach. (See Cooperator Basics line 7.)
B. Clear understanding of how each measure is reported.
- Part A & B: exports and quantified measures
- MDCP tracks funding awarded each year and, after an awards are issued, tracks each cooperator's progress through Part A and Part B of their quarterly reports. Part A, involving exports generated, is the same for all cooperators.
- Part C keep your activity calendar updated. (As of 2010.08.23 Part C is not required due to technical difficulties.)
C. Documenting and sharing success.
- Photos.
- Success stories.
- Reference/attribution to ITA.
Effect of a Federal Government Shut-Down
When Congress shut down the federal government in 2013, the Office of Management and Budget (OMB) issued guidance. (The most relevant portions of this guidance are questions 6-9.) Based on this guidance, and our actual experience from 2013, we offer the following questions and answers, specific to MDCP projects.
1. Does a shut-down mean that we have no claim to our MDCP award funds?
No. Your MDCP award was made as part of a federal appropriation in a fiscal year that precedes the fiscal year of the shut-down in question. MDCP awards, made in one fiscal year, are available through all of the subsequent years that are included in the project period.
2. May we continue MDCP project activity during the shut-down?
Yes, but you will not be able to count on any other federal support that you may have lined up for such activity.
3. Will we be able to claim advances or reimbursements from our MDCP award during the shut-down?
No, do not plan on it. Advances and reimbursements are made through ASAP, a Department of Treasury system. You should expect that this system will NOT be available during a shut-down.
4. After the shut-down, may we claim reimbursement for MDCP project expenses incurred during the shut-down?
Yes.
5. Will federal officials be available to support MDCP project activity?
No, not during the shut-down.
6. May we continue to coordinate with our ITA-MDCP team and other federal officials?
No, not during the shut-down.
7. Will Grants Online or trade.gov/mdcp be available?
Do not count on these or any other federal web-based resource being available during the shut-down.
Each MDCP award is subject to Standard Terms and Conditions (SACs). These are "standard" because they apply generally to all grants and cooperative agreement awards made by the Department of Commerce. They are part of the award package summarized on form CD-450, available to you on Grants Online. SACs are stipulations that do not apply generally to all recipients of Deparment of Commerce financial assistance awards, but which, instead, are applicable to only certain awards, usually those made under a particular program. So, most SACs will be the same for all MDCP award recipients. However, sometimes SACs are specific to a particular award recipient.
SACs often require that the award recipient certify that the SAC has beeen satisfied. Here's how to do this in Grants Online:
Results & Highlights