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Question 1: Under what circumstances can an Associate which is a local organization registered in a target country receive an exemption from the DUNS number requirement from the Office of Management and Budget?
USDOL Response: All Associates must have a DUNS number (or an exemption from the DUNS number requirement) at the time of application. As stated in the SGA, all requests for exemptions from the DUNS number requirement must be directed to the Office of Management and Budget, Office of Federal Financial Management. USDOL would like to reiterate the requirements stated on page 41 of the SGA:
“Applicants must include their Dun and Bradstreet Number (DUNS) in the organizational unit section of Block 8 of the Standard Form (SF) 424. For Associations, Block 8 of the SF-424 should contain the DUNS number of the Lead Applicant, and a list of the DUNS number(s) of all Associate(s) should be included as an attachment to the SF 424…. Requests for exemption from the DUNS number requirement must be made to the Office of Management and Budget (OMB), Office of Federal Financial Management at 202-395-3993. Unless an Applicant provides evidence of an OMB exemption from the DUNS number requirement, the application must include the Applicant’s unexpired DUNS number on the SF-424. Applications that do not meet these requirements will be considered non-responsive and will be rejected. Any Applicant (including Associates, as applicable) that does not already have a DUNS number is encouraged to begin the process of obtaining their DUNS number as soon as possible to avoid delays that could result in the rejection of an application.”
Question 2: Is there a limit to the annexes that bidders may include with the technical proposal? (May bidders include annexes in addition to those required by the solicitation?)
USDOL Response: While USDOL has not specified a “limit,” per se, to the number of annexes that may be submitted along with the technical proposal, Applicants should note the following guidance on page 43 of the SGA: “Any additional documentation submitted that is not required or specifically requested under this solicitation may not be considered.”
Question 3: The definition of "youth" on page 10 of the solicitation is unclear. Can DOL please specify whether youth are defined to be under the age of 18 years? Or over the age of 18 years?
USDOL Response: In the context of USDOL technical assistance programming, the term “youth” is defined as children under the age of 18 years.
Question 4: If "youth" are defined to be over the age of 18, can DOL please provide clarification on activities that can be implemented with youth over the age of 18 that are in compliance with DOL regulations?
USDOL Response: Please see our response to #3 above.
Question 5: Please confirm that expatriate personnel are eligible to be proposed for the key personnel positions provided they are resident in country.
USDOL Response: Yes, USDOL confirms that expatriate personnel are eligible to be proposed for key personnel positions if they will be resident in the target country.
Question 6: Regarding NICRA: Would the following sentence suffice in lieu of completing the Negotiated Indirect Cost Rate (NICRA) form?
“In lieu of the NICRA, a standard rate of xx percent indirect support costs
(ISC) applies to all grantee operations, as approved by the Executive Board.”
USDOL Response: The SGA states on page 43: “Unless otherwise specified, all documents identified in this section (i.e., section IV.C.; also noted in Appendices A and B to this solicitation) must be included in the application package in order for the application to be considered complete and responsive.” USDOL would like to reiterate that all applicants are required to submit an Indirect Cost Form as part of their Cost Proposal. This requirement is also stated in the Indirect Cost Form instructions: “This form must be completed by all organizations (non-profit, for-profit organizations, international organizations, and State and local organizations, etc.).”
Question 7: Regarding Annex J: Audit: As our Country Offices do not undertake independent financial audits, can we submit the Audited Biennial Accounts of the overall organization?
USDOL Response: Audited Biennial Accounts of the overall organization that are conducted by an external auditor are sufficient.
Questions 8-10: Regarding activities not permitted by USDOL: providing funds to foreign government entities, ministries, officials:
- Can per diem be paid to government officials who attend a workshop/training?
USDOL Response: "Per Diem payments to government officials may be appropriate for attendance at workshops/training, and may be proposed in the application. The allowability of such payments will be determined in accordance with applicable cost principles, as ser forth in OMB Circulars or the Federal Acquisition Regulation.”
- Can funds be transferred to School Directors in support of small projects, such as latrines, fences?
USDOL Response: No funds may be 'transferred' or otherwise given away under the cooperative agreement. Funds may only be used to directly pay for performance by the grantee, or to fund subcontracts awarded by the grantee to providers of goods and services in support of the cooperative agreement. Applicants should refer to page 8 of the SGA, “Applicants are expected to support the provision of healthy learning environments for children and should seek to ensure that goods, services, and schools (including restroom facilities or latrines, and wells), that will be sponsored by and/or associated with the Applicant (including any Associates) and/or subcontractors are safe and pose no threat to the mental or physical well-being of the project’s direct beneficiaries. Applicants may propose other project interventions, such as improvements to school infrastructure (including the construction of latrines and digging of wells) in order to improve the quality of learning environments.”
- If another donor is supporting the same activity e.g. training, can the funds be combined and if yes, should the output indicator reflect the joint funding?
USDOL Response: Please refer to Section III.B. of the SGA on Cost Sharing. If an Applicant proposes to include funds from another non-Federal donor on the SF 424 and SF 424A as “matching funds,” then the Applicant’s Output-Based Budget should reflect both the USDOL and non-USDOL funding sources.
Question 11: If an international organization won the competitive process, would the DOL award agreement honor the organization’s right to receive the exemption from the OMB circulars, CFRs and audit requirements specified in the SGA?
USDOL Response: Unless otherwise determined in consultation with the parties and without prejudice to the privileges and immunities enjoyed by UN agencies under the Convention on Privileges and Immunities of the United Nations and the Convention on the Privileges and Immunities of the Specialized Agencies, all cooperative agreements are subject to the administrative and other standards and provisions outlined in the SGA.
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