ILAB - Frequently Asked Questions (FAQs)

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November 5, 2008 DOL Home > ILAB

FAQs on U.S. Department of Labor (USDOL)
Child Labor Education Initiative Solicitations for Grant Applications (SGAs)

General Information
Q1:	What types of organizations may submit proposals?
A:	SGAs are open to any eligible, qualified organization. An eligible applicant is defined as any commercial, international, educational, or non-profit organization, including faith-based, community-based, or public international organizations. Applications from foreign governments and quasi-governmental agencies will not be considered.

Q2:	What is the funding instrument used to make awards under Child Labor Education Initiative SGAs?
A:	Child Labor Education Initiative funds are awarded through cooperative agreements.

Q3:	How long do SGAs remain open?
A:	The open period for SGAs may vary. SGAs can be open for 30 days or more. The designated open period is established in each SGA.

Q4:	How are grantees selected?
A:	USDOL first screens applications to determine responsiveness to the SGA. Complete applications are then objectively rated by a technical review panel against evaluation criteria indicated in the SGA. Panels then make advisory recommendations to the Grant Officer, who may elect to select a grantee on the basis of initial application submission or may establish a range from which qualified applicants will be selected. The Grant Officer makes final selection determinations based on panel findings and other factors such as cost and the availability of funds. If USDOL does not receive technically acceptable applications in response to a SGA, USDOL reserves the right to terminate the competition and not make any award.

Q5:	What are the criteria used to select grantees?
A:	Technical review panels review applications against established evaluation criteria on the basis of 100 points, with up to five additional points for the inclusion of non-federal leveraged resources. These criteria are outlined in each SGA. Applicants are expected to address four main rating factors: program design/budget-cost effectiveness; organizational capacity; management plan/key personnel/staffing; and leveraging resources.

Q6:	When can applicants expect to find out the results of a cooperative agreement competition?
A:	When possible, decisions will be made within 45 days after the deadline for submission of proposals. Cooperative agreements must be awarded and signed by September 30 of the year in which the SGA is published. The USDOL Grant Officer will notify applicants of competition results through an official letter.

Q7:	What are the goals of the Child Labor Education Initiative?
A:	The overarching goal of USDOL is to work toward the elimination of the worst forms of child labor internationally. All USDOL-funded projects are aimed at achieving this objective. Thus, in addition to providing direct education and training opportunities to children withdrawn from work and those at risk of engaging in exploitive work, the Child Labor Education Initiative has four goals: raise awareness of the importance of education for all children and mobilize a wide array of actors to improve and expand education infrastructures; strengthen formal and transitional education systems that encourage working children and those at risk of working to attend school; strengthen national institutions and policies on education and child labor; and ensure the long-term sustainability of these efforts.

Q8:	What is the duration for Child Labor Education Initiative projects?
A:	The duration of the project(s) funded by each solicitation is up to four (4) years. The start date of program activities will be negotiated upon awarding of the cooperative agreement, but will be no later than September 30 of the year in which the SGA is published.

Q9:	What types of activities qualify as direct education service under the Child Labor Education Initiative?
A:	Projects funded under the Child Labor Education Initiative must provide direct educational services to children as a means to remove them from exploitative child labor and/or prevent them from engaging in the worst forms of child labor. Direct educational services may involve either (a) or (b): a) The provision of at least one of the following educational activities: Non-formal or basic literacy education – This type of educational activity may include transitional, leveling, or literacy classes so that a child may either be mainstreamed into formal education and/or can participate in vocational training activities; Vocational, pre-vocational, or skills training – This type of training is designed to develop a particular, marketable skill (e.g. mechanics, sewing); or b) The provision of goods and/or services (if lack thereof is a barrier to education) that meets the specific needs of the targeted children and results in their enrollment or retention in at least one of the four categories of educational activities listed below. Examples of goods and/or services that may meet the specific gaps/educational needs of targeted children include tutoring, school meals, uniforms, school supplies and materials, books, tuition and transportation vouchers, or other types of support. The four categories of educational activities that qualify for USDOL’s EI are: Non-formal or basic literacy education; Vocational, pre-vocational, or skills training; Formal education – This is defined as the formal school system within the target country; or Mainstreaming – This type of educational activity involves a project transitioning children from non-formal education into the formal education system. Generally, mainstreaming involves the provision of goods and/or services (e.g., school uniforms, registration fees, transportation vouchers and/or tutoring) that may assist in placement testing and enable a child to attend and stay in school.

Q10:	Does USDOL give preference to applications that target multiple countries in cases of regional projects, or is it preferable to concentrate funding on fewer countries in order to have a greater impact?
A:	For regional projects, USDOL does not have a preference on the number of countries targeted in a particular application, unless explicitly specified in the SGA.

Q11:	Is it possible that USDOL would fund more than one proposal under a solicitation for a country?
A:	Yes, depending on the number of quality applications received, recommendations made by the technical review panel, and funding available under the solicitation for a particular country.

Q12:	What is the most efficient way to access comprehensive information on global ILO-IPEC programs, including Timebound Programs?
A:	Information on Timebound Programs can be found at: http://www.ilo.org/public/english/standards/ipec/themes/timebound/index.htm. Information on ILO-IPEC sub-regional activities can be found at: http://www.ilo.org/public/english/standards/ipec/child/offices.htm.

Q13:	May applications and attachments be in a language other than English?
A:	Applications will only be accepted in English, and applications that do not conform to this standard will be deemed non-responsive and will not be considered for funding.

Q14:	Who do I contact for additional information on the Child Labor Education Initiative competitive process?
A:	Please contact Ms. Lisa Harvey, U.S. Department of Labor, Procurement Services Center, 200 Constitution Avenue, NW, Room N-5416, Washington, D.C. 20210; telephone (202) 693-4570 (this is not a toll-free-number) or e-mail: harvey.lisa@dol.gov.

Technical Application and Budget Information
Q15:	Does USDOL have a preference for the percentage of activities going toward each Child Labor Education Initiative strategic goal, i.e., does USDOL want more concentration of effort to go toward awareness raising and mobilization of actors versus strengthening policy and institutional capacity?
A:	No. In addition to providing direct education and training opportunities to working children and those at risk of engaging in exploitive work, all four of the Child Labor Education Initiative strategic goals are important. Applicants are reminded that the largest proportion of budgeted funds must go toward direct educational activities for targeted children, rather than administrative costs.

Q16:	SGAs have required grantees to consult with and work with various stakeholders in the country or region, ensure that proposed activities and interventions work within national child labor and education frameworks and priorities, and collaborate with existing projects, particularly those funded by USDOL. What kind of documentation does USDOL expect to verify compliance with this condition?
A:	USDOL expects applicants to consult with the government and other stakeholders to avoid duplication of efforts and to address any gaps in services to the target population. Evidence that these consultations have occurred should be reflected in the project strategy. Within six months after the time of the award, the grantee must deliver the final project design document, based on the application written in response to this solicitation, including the results of additional consultation with stakeholders, partners, and USDOL/ILAB. The final project design document must also include sections that address coordination strategies.

Q17:	Does USDOL have guidelines as to applicants leveraging non-Federal funds or resources to implement the proposed program, e.g., is USDOL requiring a specific percentage of non-Federal resources from applicants?
A:	No. While leveraging is encouraged, the Bureau of International Labor Affairs at USDOL does not have guidelines regarding the leveraging of non-Federal resources, and USDOL does not require that applicants provide a specific percentage of non-Federal resources. However, staff time of proposed key personnel may not be submitted as a leveraged resource. In addition, the project budget submitted with the application must include all necessary and sufficient funds to implement the applicant's proposed project activities and to achieve proposed project goals and objectives without reliance on other contracts, grants, or awards. USDOL will not provide additional funding to cover the costs from other contracts, grants, or awards that fail to materialize.

Q18:	Does USDOL require that the applicant present the cost application as an activity based budget? The Budget/Cost effectiveness section of past SGAs seemed to imply that this type of budget is required.
A:	The budget must be linked to the activities and outputs of the work plan. Applicants are required to submit an output-based budget with their application. An example of an Output-Based Budget is available from the USDOL/ILAB website at http://www.dol.gov/ILAB/grants/output-basedbudget.pdf.

Q19:	Does USDOL have examples of other documents that should be submitted as part of an application?
A:	Yes. Please visit http://www.dol.gov/ilab/grants/bkgrd.htm for examples of a logical framework, performance monitoring plan, outputs-based budget, Standard Form 424A, and a Survey on Ensuring Equal Opportunity for Applicants.

Q20:	Does USDOL envision a high priority of Child Labor Education Initiative resources and time be spent on strengthening local capacity to design, implement, and sustain the initiative supported by a project, or should the emphasis be on rapid action and visible successes?
A:	USDOL cannot advise applicants regarding the allocation of resources for specific strategies since the needs of each project are unique. However, applicants are expected to allocate the largest proportion of resources to direct educational activities aimed at targeted children, rather than administrative costs.

Q21:	What are the Child Labor Education Initiative Common Indicators?
A:	Child Labor Education Initiative common indicators include withdrawn/prevented, retention, and completion. Further guidance on common indicators is provided to grantees after award, thus applicants should focus their program management and performance assessment responses toward the development of their project's monitoring strategy in support of the delivery of direct education and training opportunities to children withdrawn from work and those at risk of engaging in exploitive work, and the four goals of the Child Labor Education Initiative. However, applicants are expected to budget for costs associated with collecting and reporting on the common indicators, data management, tracking the working status of children participating in the program, and assessing the impact of other educational services/interventions, such as teacher training and awareness raising.

Personnel/Staff/Partner Information
Q22:	Can applicants partner with one or more organizations in response to SGAs?
A:	Yes. Applicants are strongly encouraged to work with other qualified organizations including those already undertaking projects in the countries of interest, particularly local non-governmental organizations (NGOs), including faith-based and community-based organizations. Such associations may take the form of partnerships, joint ventures, or other contractual agreement. Applicants that are associations of organizations, but are not a single corporate entity must identify a lead organization as a point of contact with DOL. Each member of the association must be individually eligible for award. All members of an association, however, must sign and agree to be bound jointly and severally by the grant or cooperative agreement. In addition, associations must submit, as an attachment to the application, an Association agreement reflecting an appropriate partnership, joint venture or other contractual agreement and outlining the deliverables, activities, and corresponding timeline for which each Associate will be responsible, recognizing, however, that all members of the alliance are ultimately responsible for the entire project. Copies of such agreements will not count toward the page limit.

Q23:	What is the audit requirement for the lead or prime organization submitting an application?
A:	If the applicant is a U.S. based, non-profit organization, the applicant's most recent single audit, as submitted to the Federal Audit Clearinghouse, must accompany the application as an attachment. In addition, the single audit provided with the application must comply with the report submission timeframes established in OMB Circular A-133. If the applicant is not in compliance with the requirements for completing their single audit, the application will be considered non-responsive and will not be considered for funding. If the applicant is a for-profit or foreign based organization, a copy of its most current independent financial audit must accompany the application as an attachment. If the audit submitted by the applicant reflects any adverse opinions, the application will not be further considered by the technical review panel and will not be considered for funding.

Q24:	In the case of a partnership, what are the application's audit requirements for the proposed partner(s)?
A:	Applicants should also submit a copy of the most recent single audit report for all proposed U.S. based, non-profit partners and sub-contractors that are subject to the Single Audit Act. If the proposed partner(s) is a for-profit or foreign based organization, a copy of its most current independent financial audit must accompany the application as an attachment. In order to expedite the Procurement screening of applications, and to ensure that the appropriate audits are attached to the proposals, the applicant must provide a cover sheet to the audit attachments listing all proposed partners and sub-contractors. Applicants may wish to review the audits of prospective organizations before deciding whether they want to partner with or sub-contract to them under a Child Labor Education Initiative cooperative agreement.

Q25:	Do you require resumes for all project personnel, or only key personnel?
A:	The applicant must include a resume and description of the roles and responsibilities of all key and professional personnel proposed in the application.

Q26:	What commitment of time does USDOL require of an applicant's key personnel?
A:	All key personnel must work full-time, and allocate 100 percent of that time to the grant project and be present within the target country(ies). Accordingly, key personnel positions may not be combined. In addition, to support the information submitted in the key personnel sections of grant applications, applicants must submit letters of agreement, each signed by proposed key personnel candidates, that indicates their availability and willingness to commence work on the project within 30 days of cooperative agreement award. Applicants must submit these letters as an attachment to the application, which will not count toward the page limit. If key personnel letters of agreement are not submitted as part of the application, the application will be considered non-responsive and will be rejected.

Q27:	Can applicants request a change in key personnel after a cooperative agreement has been awarded?
A:	After a cooperative agreement has been awarded and throughout the life of the project, Grantees agree to inform USDOL whenever it appears impossible for any key personnel to continue work on the project as planned. A Grantee may nominate substitute key personnel and submit the nominations to USDOL. A Grantee may also propose reducing the hours of key personnel. However, a Grantee must obtain prior approval from USDOL for all such changes to key personnel. If USDOL is unable to approve the key personnel change, USDOL reserves the right to terminate the cooperative agreement or disallow costs. Please note: the performance of the organization's key personnel on existing projects with USDOL or other entities, whether the organization has a history of replacing key personnel, and the quality and timeliness of such key personnel replacements, will be taken into consideration by USDOL when rating past performance.

Funding Restrictions: Allowable and Unallowable Costs
Q28:	What activities are not permitted by USDOL?
A:	Unallowable activities under USDOL cooperative agreements include sub-granting; providing direct cash transfers to communities, parents, or children; providing micro-credits, revolving funds, or loan guarantees; fund-raising or lobbying of the U.S. Government; providing gifts or other monetary incentives to program partners or participants; providing funds to foreign government entities, ministries, officials, or political parties; providing resources or support to individuals and organizations associated with terrorism; and providing resources for the promotion of prostitution and related activities. Other unallowable costs are specified in OMB Circular A-122.

Q29:	Why are sub-grants not permitted by USDOL?
A:	In general, it is improper for non-governmental entities that receive grant funds from the U.S. Government to sub-grant any of these funds where there is not specific congressional authority to do so. USDOL does not have the specific authority in its congressional appropriation to allow sub-grants under its cooperative agreements. Sub-granting must not to be included in an applicant's budget; however, sub-contracting may be included as a budget line item.

Q30:	USDOL permits income generation activity for parents, including skills training, tool-kits, and market feasibility studies; however, in past SGAs, USDOL has specifically prohibited micro-credit, revolving funds and/or loan guarantees as a mechanism of delivering income generation activity. Why are income generation activities permissible, but common mechanisms of delivering such assistance prohibited?
A:	As is the case with sub-grants, USDOL does not have the specific authority in its congressional appropriation that would allow for a grant recipient to provide micro-credits or revolving funds. In addition, USDOL reserves the right to negotiate the exact nature, form, or scope of any alternative income-generating activities after award of the cooperative agreement.

Q31:	Is the delivery of services through government institutions, such as vocational training authorities, allowable under the Child Labor Education Initiative?
A:	USDOL-funded projects are not intended to support activities that supplant the functions of the host government, such as teacher's salaries, and operating expenses, government agencies' personnel costs, or travel. Instead, the project should build the capacity of the government to increase access to education for working children and children at risk of entering work through the support of sustainable activities including teacher training, curriculum development, legislative reforms, or national action plans and policy development. In addition, grantees may not provide any USDOL-awarded funds to foreign government entities, ministries, officials, or political parties. However, sub-contracts with foreign government agencies may be awarded to provide direct services or undertake project activities, subject to applicable laws and only after a competitive procurement process has been conducted and no other entity in the country is able to provide these services. Grantees must receive prior USDOL approval before sub-contracting to foreign government agencies for the provision of direct services.

Q32:	Does USDOL allow applicants to support psychosocial activities in addressing the needs of children removed from the worst forms of child labor?
A:	Psychosocial activities are an allowable cost under the Child Labor Education Initiative. However, these activities are not considered direct educational services.

Q33:	Does USDOL support the use of technology in the delivery of services through its Child Labor Education Initiative?
A:	While USDOL supports the use of innovative technologies, such as radio distance learning strategies, in the implementation of its Child Labor Education Initiative, applicants who propose to use these technologies in awareness raising, or in the delivery of direct educational services, must be able to demonstrate that this strategy is likely to have a measurable, positive impact on the project's ability to achieve its enrollment, retention, and completion targets.
Q34:	What is the Dun and Bradstreet Number (DUNS) and how can my organization obtain a DUNS?
A:	Beginning October 1, 2003, all applicants for Federal grant funding opportunities are required to include a DUNS number with their application. See OMB Notice of Final Policy Issuance, 68 Federal Register 38402 (June 27, 2003). Applicants' DUNS number is to be entered into Block 8 of SF-424. The DUNS number is a nine-digit identification number that uniquely identifies business entities. There is no charge for obtaining a DUNS number. To obtain a DUNS number call 1-866-705-5711 or access the following web site: http://www.dunandbradstreet.com. Requests for exemption from the DUNS number requirement must be made to the Office of Management and Budget. If no DUNS number is provided then the grant application will be considered non-responsive. After receiving a DUNS number, all grant applications must also register as a vendor with the Central Contractor Registration through the following website: http:www.ccr.gov or by phone at 1-888-227-2423. CCR registration should become active within 24 hours of completion. If grant applicants have questions regarding registration, please contact the CCR Assistance Center at 1-888-227-2423. After registration, grant applicants will receive a confirmation number. Grantee listed Point of Contact will receive a Trader Partnership Identification Number (TPIN) via mail. The TPIN is, and should remain, a confidential password.
Q35:	May applicants apply online?
A:	Applicants may also apply online at www.grants.gov. Applicants submitting proposals online are requested to refrain from mailing a hard copy application as well. It is strongly recommended that applicants using www.grants.gov immediately initiate and complete the "Get Started" registration steps at www.grants.gov/GetStarted. These steps may take multiple days to complete, and this time should be factored into plans for electronic submission in order to avoid facing unexpected delays that could result in the rejection of an application. If submitting electronically through www.grants.gov, the applicants must save application document as a .doc, .pdf, .txt or .xls file. Any application received on grants.gov after the deadline will be considered as non-responsive and will not be evaluated.
Specific Questions Addressing SGA 06-06
General
Q36:	Must leveraged non-USG resources identified in the application be fully committed at the time the application is submitted to USDOL or can they be committed post-submission?
A:	Applicants are cautioned against relying on uncommitted leveraged resources in either award applications or in project budgets. As outlined in the SGA (71 Fed. Reg. 30192, Section V(1)(F) Leveraging Resources), an applicant must list the source(s) of funds, the nature, and possible activities anticipated with these resources under this Cooperative Agreement and any partnerships, linkages or coordination of activities, cooperative funding, etc., in order to be eligible for the additional points. However, USDOL reserves the right to contact donor organizations during the best and final offer negotiations to verify resources reported in an application, and to deduct points earned by an applicant for having leveraged resources should it be determined that an organization(s) is not fully committed to obligating these resources to the proposed project. Further, the SGA states that the project budget that is submitted with the application must include all necessary and sufficient funds without reliance on other contracts, grants, or awards, to implement the applicant's proposed project activities and to achieve proposed project goals and objectives under this solicitation. If anticipated funding from another contract, grant, or award fails to materialize, USDOL will not provide additional funding to cover these costs (see page 30189 Section V (1) (A) (iv) Budget-Cost Effectiveness).
Q37:	The SGA requires collaboration with ILO-IPEC. Would it be a conflict of interest if an organization were to collaborate with ILO-IPEC in the preparation phase if ILO-IPEC is also submitting an application?
A:	While the ILO would be deemed an "eligible applicant," as defined within the SGA, this determination does not limit the ability of other organizations from submitting applications. The SGA states that "applicants are strongly encouraged to collaborate with existing projects" and specifically notes national collaboration in Egypt with several organizations, including ILO-IPEC. Therefore, potential applicants would be encouraged to collaborate with relevant organizations in the country. In preparing an application, an organization might initiate discussions with these relevant organizations to facilitate future valuable collaborations in the case where an award is secured. It is not foreseen that such initial discussions would either constitute a conflict-of-interest or hinder the preparation of a competitive application. It is permissible and not viewed as a conflict of interest for the ILO to submit its own application, while at the same time being either a co-applicant with another entity on a separate application, or being a proposed subcontractor on another entity’s application.
Q38:	Associates will be included in the budget as a subcontract line item, correct?
A:	The costs attributed to any and all Associates should be reflected as direct costs of the grantee. Associates are not subcontractors, and cannot be accounted for as a subcontracted cost.
Q39:	In addition to Associate subcontracts, can an organization issue subcontracts to organizations that are not considered part of an "Association" such as a local NGO?
A:	Associates are not subcontractors; they are co-grantees. Subcontracts may be awarded to any responsible entity, including NGOs, but applicants are cautioned that subcontracts are properly used to obtain goods and services in support of the work of the cooperative agreement. They may not be used to sub-grant portions of the work under the cooperative agreement.
Q40:	Are Associates (other than the Lead) required to sign the cooperative agreement? The SGA states that "if any entity identified in the application as an Associate does not sign the Cooperative Agreement...." If an NGO is the lead and was awarded the Cooperative Agreement, then that NGO would provide the Associates with subcontracting agreements prepared by the NGO. The Associates would not sign the cooperative agreement; that would be signed only by USDOL and the NGO. Please confirm whether this understanding is correct or not.
A:	As stated above, "If two or more applicants, who do not constitute a single legal entity (hereinafter referred to as "Associations"), join in applying for an award, each member of the Association (hereinafter referred to as "Associate") must be individually eligible for award." The SGA further states that, "All Associates must sign, and agree to be bound jointly and severally by, the awarded Cooperative Agreement, and all must designate one Associate as the 'Lead.' Any such Association must submit to USDOL, as an attachment to the application, an Association agreement, reflecting an appropriate joint venture, partnership, or other contractual agreement and outlining the deliverables, activities, and corresponding timeline for which each Associate will be responsible." (See also #39)
Q41:	Are Associates required to be exclusive to this Association? For example, if an organization wanted to include a local NGO as part of its Association, would it also be eligible to be an Associate with another Association? Could it also be a subcontractor to another Association/Lead?
A:	The SGA does not prohibit an organization from applying as an Associate in one application and as an Associate, or being noted as a sub-contractor, in a second application.
Q42:	If an organization were able to incorporate a program that already exists into the curriculum and ensure that it reached at least the minimum number of children suggested in the SGA, would that qualify as a valid project strategy?
A:	The SGA sets the minimum number of direct beneficiaries to be served at 8,600 per USD 5 million. Direct beneficiaries are children who, as a result of a USDOL-funded project, are: Withdrawn or prevented from entering exploitative child labor, and Are provided with a direct educational service (as defined below) that results in their enrollment in at least one of the four categories of educational activities. (Please see page 30177 in the SGA for the four categories.). In order to count a child/adolescent as a direct beneficiary, the applicant must: Assess the specific needs of each child targeted by the project in order for the child to (a) be withdrawn from or prevented from entering exploitative labor and (b) be enrolled in an educational activity; Develop and implement an appropriate strategy for the child that provides a direct educational service that supports his/her enrollment in at least one of the educational activities defined in the SGA; and Monitor and report to USDOL on the work (e.g., is the child working in an exploitative labor situation?) and education status (e.g., is the child still attending an educational or training program?) of each child beneficiary.
Egypt
Q43:	The SGA states that there should be a program balance between prevention and withdrawal, but the Country Specific Scope of Work for Egypt suggests that the interventions should focus primarily on withdrawing children from exploitative labor. These are two different sets of guidelines. Can USDOL clarify which is the preferred approach: a balance between the withdrawal and prevention of direct target beneficiaries from exploitative child labor, or a focus on withdrawal over prevention?
A:	The Department of Labor requires each of its agencies to submit cost efficiency measures. For this reason, the SGA requires applicants to target a minimum number of children/adolescents for withdrawal and/or prevention. However, while applicants might be tempted to design a strategy focusing on prevention as a more cost-effective intervention than withdrawal, applicants are reminded that withdrawal is the priority for USDOL and the main focus of ILO Convention No. 182. Within this guideline, applicants may determine the specific number of children withdrawn and prevented in each project. In addition, USDOL suggests that applicants propose strategies that can demonstrate effective, cost-efficient and sustainable interventions for both withdrawing and preventing children from involvement in exploitative work.
Q44:	Are applicants required to provide coverage in each of the 12 governorates listed in the SGA? (See page 30181, Section I 5 A iii. (4)) If an applicant identified the most vulnerable governorates (fewer than 12) and focused its activities there, justifying the selection, and providing services to the minimum number of direct beneficiaries, would USDOL consider this responsive to the SGA?
A:	The SGA does not require intervention in all 12 governorates.
Q45:	The SGA identifies 15 governorates where child labor activities are already being implemented and therefore implies that interventions in those areas are unnecessary. Based on our knowledge of the country and our experience in these areas, we have observed that some of the governorates have activities on paper, but do not have operational child labor programs on the ground. Would USDOL consider it responsive if we proposed activities in some of these 15 governorates, as long as it was justified and met the minimum number of direct beneficiaries?
A:	The SGA does not limit project activities to the 12 governorates identified. A proposed strategy operating within other governorates would be considered. Please see page 30181, Section I 5 A iii. (4) of the SGA, which states, "In addition to complementing the upstream policy and awareness activities of the NCCM and ILO-IPEC in the 15 governorates in which child labor elimination programs are already underway, this project should focus direct action efforts primarily in the 12 governorates without ongoing activities…,".
Q46:	Does the age range specified in the SGA for Peru only include up to the 15th year or are children between 15 and 16 included in the primary focus?
A:	Children between the ages of 15 and 16 can be included.
Peru
Q47:	In Peru, most children in the 11-15 age range who engage in child labor begin to do so before reaching age 11, so prevention activities for 11-15 year olds should also include children under 11 years. Would including those children in prevention activities be acceptable to USDOL?
A:	The primary focus of this solicitation is children ages 11-15. Applicants should propose strategies that balance withdrawal and prevention. If an applicant has solid evidence that significant numbers of children under 11 years are working in a proposed area of intervention, USDOL would certainly consider such a prevention strategy as a supplement to the primary focus of ages 11-15.