Q1:

What types of organizations may submit proposals?

A: 

SGAs are open to any eligible, qualified organization.

Under SGA 07-10, an eligible applicant is defined as any commercial, international, educational, or non-profit organization, including any faith-based, community-based, or public international organizations capable of developing and implementing educational programs that aim to withdraw children from, or prevent children from entering, exploitive child labor in the target country. Applications from foreign governments and entities that are agencies of, or operated by or for, a foreign state or government will not be considered.

Under SGA 07-11, an eligible applicant is defined as any commercial, educational, or nonprofit organization(s), including any faith-based, community-based, or public domestic, foreign or international organization(s) capable of successfully conducting scientifically-valid research is eligible to apply. However, the Grantee (or Lead Grantee, in the case of an Association) is not allowed to charge a fee (profit). Neutral, non-religious criteria that neither favor nor disfavor religion will be employed in the selection of the Cooperative Agreement recipient. Applications from foreign governments and entities that are agencies of, or operated by or for, a foreign state or government will not be considered.

Q2:

What is the funding instrument used to make awards under Child Labor Elimination SGAs?

A: 

Child Labor Elimination funds are awarded through cooperative agreements.  A cooperative agreement is a form of a grant where substantial involvement is anticipated between the donor (USDOL) and the Grantee during the performance of the proposed activities.  The level of monitoring and accountability required by USDOL under a cooperative agreement is less than what is required in a contract, but more than in a regular grant. 

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, responsive 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 which are outlined in each SGA. 

Under SGA 07-10, Applicants are required to address all of the following rating factors in their proposals: project design/budget cost-effectiveness/budget cost-efficiency, sustainability plan, organizational capacity, and key personnel/management plan/staffing. Applications will be evaluated on the basis of 100 points, with up to five additional points that may be awarded for applicants proposing to withdraw or prevent more than 200 children from exploitive child labor through the provision of direct educational services and other project interventions for every $100,000 in project funding awarded, and up to five additional points for “cost sharing,” meaning the inclusion of committed, non-U.S. Government resources that significantly expand the dollar amount, size, and scope of the project.

Under SGA 07-11, Applicants are required to address all of the following rating factors in their proposals: research background and significance, research methodology, key personnel/management plan/staffing, organizational capacity, budget cost-effectiveness, cost-sharing. Applications will be evaluated on the basis of 100 points, with up to five additional points that may be awarded for “cost sharing,” meaning the inclusion of committed, non-U.S. Government resources that significantly expand the dollar amount, size, and scope of the project.

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 Child Labor Elimination projects?

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 Elimination Projects generally seek to:  withdraw or prevent children from involvement in exploitive child labor through the provision of direct educational services; strengthen policies on child labor and education, the capacity of local and national institutions to combat child labor, and formal and transitional education systems that encourage children engaged in or at-risk of engaging in exploitive labor to attend school; raise awareness about exploitative child labor and of the importance of education for all children and mobilize a wide array of actors to improve and expand education infrastructures; support research and the collection of reliable data on child labor; and ensure the long-term sustainability of these efforts.

Q8:

What is the standard duration for Child Labor Elimination projects?

A: 

The standard 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 a Child Labor Elimination project?

A: 

Child Labor Elimination Projects to be funded under SGA 07-10 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.  (Please note that SGA 07-11 focuses on child labor research, and therefore, does not involve the withdrawal or prevention of exploitive child labor through the provision of direct services.)

Direct educational services may involve either (a) or (b):

(a) The provision of at least one of the following educational activities:

    (1) Non-formal or basic literacy education--This type of educational activity may include transitional, levelling, or literacy classes so that a child may either be mainstreamed into formal education and/or can participate in vocational training activities;

    (2) 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 proposed direct beneficiaries and results in their enrollment or 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 incentives. The four categories of educational activities that qualify are:

    (1) Non-formal or basic literacy education;

    (2) Vocational, pre-vocational, or skills training;

    (3) Formal education--This is defined as the formal school system within the target country; or

    (4) 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 that may assist in placement testing and enable a child to attend and stay in school.

Q10:

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.

Q11:

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.

Q12:

Who do I contact for additional information on the Child Labor competitive process for Child Labor Elimination project awards?

A: 

Please contact Ms. Lisa Harvey, U.S. Department of Labor, Procurement Services Center, 200 Constitution Avenue, NW, Room S-4307, Washington, D.C. 20210; telephone (202) 693-4570 (this is not a toll-free-number) or e-mail: harvey.lisa@dol.gov.

Q13:

Does USDOL have a preference for the percentage of the project budget going toward withdrawal and prevention of exploitive child labor through educational and training alternatives; capacity building; awareness raising; mobilization; and administrative costs?

A: 

Applicants are reminded that the largest proportion of budgeted funds must go toward direct services, particularly those that support the withdrawal and prevention of targeted children from exploitative labor, rather than administrative costs.  (See Appendix A of the SGA for the definition of “direct educational service.”)   

Q14:

Does USDOL have examples of documents that should be submitted as part of an application?

A: 

Yes. Please visit http://www.dol.gov/ilab/grants/bkgrd.htm for the following forms and sample materials: Negotiated Indirect Cost Rate (NICRA) Form, Standard Form (SF) 424 and SF 424A, Survey on Ensuring Equal Opportunity for Applicants. logical framework, outputs-based budget, sustainability matrix, and performance monitoring plan (PMP).

Applicants who are applying as an Association should note that they must submit NICRA Forms for each member of the Association, not just the proposed Lead Grantee.

Q15:

What indicators does USDOL use for its Child Labor Elimination projects?

A: 

USDOL common indicators include children withdrawn or prevented from exploitive child labor, capacity raised, retention, and completion.  These common indicators are defined in Appendix A of the SGA.  Project monitoring strategies should be developed to support the collection of reliable data related to these indicators.  Applicants are expected to budget sufficiently to cover costs associated with collecting and reporting on the common indicators, data management, and tracking the working and schooling status of children participating in the program.

Q16:

Should associates be included in the budget as a subcontract line?

A: 

The costs attributed to any and all Associates should be reflected as direct costs of the grantee. Associates are not considered to be subcontractors, and as such, should not be accounted for as a subcontracted cost.

Q17:

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.

Q18:

In the case of an Association, what are the application's audit requirements for the proposed partner(s)?

A: 

Applicants should submit a copy of the most recent single audit report for all proposed U.S.-based non-profit Associates/ partners that are subject to the Single Audit Act. If the proposed Associate(s) or partner(s) is a for-profit or foreign-based organization, a copy of its most current independent financial audit should accompany the application as an attachment.

In order to expedite the screening of applications, and to ensure that the appropriate audits are attached to the proposals, applicants must provide a cover sheet to the audit attachments listing all proposed Associates and subcontractors.

Q19:

Do you require résumés for all project personnel, or only key personnel?

A: 

The applicant must include a résumé and description of the roles and responsibilities of all key personnel proposed in the application.

Q20:

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 project and live in the target country. Key personnel positions must not be combined. In addition, to support the information submitted in the key personnel sections of applications, applicants must submit a letter of agreement for each key personnel candidate, signed by the candidate, which indicates their agreement to serve on the project and their availability to commence work within 30 calendar days of the 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.

Q21:

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 should any key personnel be unable to continue work on the project as planned. A Grantee may nominate substitute key personnel and submit the nominations to USDOL. 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.

Q22:

What activities are not permitted by USDOL?

A: 

Unallowable activities under USDOL cooperative agreements include subgranting; 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.

Q23:

Why are subgrants not permitted by ILAB?

A: 

In general, it is improper for non-governmental entities that receive grant funds from the U.S. Government to subgrant any of these funds where there is not specific congressional authority to do so. ILAB does not have the specific authority in its congressional appropriation to allow subgrants under its child labor elimination cooperative agreements. Subgranting must not to be included in an applicant's budget; however, subcontracting may be included as a budget line item.

Q24:

USDOL permits income generation activity for parents, including skills training, tool-kits, and market feasibility studies; however, ILAB 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 subgrants, ILAB 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.

Q25:

Is the delivery of services through government institutions, such as vocational training authorities, allowable under a Child Labor Elimination project?

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. Projects, however, can help to build the capacity of the government to increase access to education for working children and children at risk of entering work through support for activities such as teacher training, curriculum development, legislative reforms, or national action plans and policy development.

Subcontracts 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 subcontracting to foreign government agencies for the provision of direct services.

Q26:

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 a Child Labor Elimination project. These activities are not considered direct educational services.  However, psychosocial activities would fall within the definition of “other project interventions” in Appendix A of the SGA.

Q27:

Does USDOL support the use of technology in the delivery of services through its Child Labor Elimination projects?

A: 

While USDOL supports the use of innovative technologies, such as radio distance learning strategies, in the implementation of its Child Labor Elimination projects, 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.

Q28:

What is the Dun and Bradstreet Number (DUNS) and how can my organization obtain a DUNS?

A: 

Applicants must include their Dun and Bradstreet Number (DUNS) in the organizational unit section of Block 8 of the SF 424.  For Associations, Block 8 of the SF 424 should contain the DUNS number of the proposed Lead Grantee, and a list of the DUNS number(s) of all proposed members of the Association should be included as an attachment to the SF 424.  DUNS is an acronym which stands for “Data Universal Numbering System,” and a DUNS number is a unique nine-digit number used to identify a business.  Beginning October 1, 2003, all Applicants for Federal grant funding opportunities are required to include a DUNS number with their application per the Office of Management and Budget Notice of Final Policy Issuance, 68 Federal Register 38402 (June 27, 2003).  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.dnb.com/us/. 

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.  Applicants must provide evidence of an OMB exemption from the DUNS number requirement or the actual DUNS number.

If an organization or a member of an Association applying for the award has applied and can show evidence of having submitted an application for a DUNS number prior to the deadline for this SGA, the proposal will be considered as responsive.

After receiving a DUNS number, Applicants must also register as a vendor with the Central Contractor Registration through the following Web site: http://www.ccr.gov or by phone at 1-888-227-2423.  Central Contractor Registration (CCR) should become active within 24 hours of completion.  For any questions regarding registration, please contact the CCR Assistance Center at 1-888-227-2423.

After registration, 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.

Q29:

May applicants apply online?

A: 

Applicants may 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 Registered” registration steps at http://www.grants.gov/applicants/get_registered.jsp.  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.  It is also recommended that Applicants using www.grants.gov consult the Grants.gov Web site’s Frequently Asked Questions and Applicant User Guide, which are available at http://www.grants.gov/help/faq.jsp, and http://www.grants.gov/assets/UserGuide_Applicant.pdf, respectively.
If submitting electronically through www.grants.gov, Applicants must save the application document as a .doc, .pdf, .txt or .xls file.  Any application received on www.grants.gov after the deadline will be considered as non-responsive and will not be evaluated.

Q30:

Do subcontractors which are foreign organizations need to register to CCR or only the Lead applicant is required to be CCR registered?  The solicitation is not clear on subcontractors/associates regarding the CCR registration but it is very clear that each Associate member should have a DUNS number.   

A: 

Foreign organizations which are “Association” members must have DUNS numbers and be registered with CCR.  Applicants must provide evidence of an OMB exemption from the DUNS number requirement or the actual DUNS number.  If an organization or a member of an Association applying for the award has applied and can show evidence of having submitted an application for a DUNS number prior to the deadline for this SGA, the proposal will be considered as responsive.

Q31:

In the SGA Appendix B Technical Proposal format on p. 32910 appears to be somewhat different from the information to be included that was listed on p. 32895. Specifically, the Appendix lists C. Organizational Capacity and D. Management Plan sections as part of the technical proposal. However, when reading on p. 32895 it seems to suggest that these sections do NOT fall within the 45-page limit, which only seems to apply to the A. Project Design section. Is this correct?

A: 

To clarify, the following sections of the Technical Proposal Format outlined in Appendix B on page 32910 of the Federal register announcement for SGA 07-10 do count toward the 45 page limit:  Section A. Project Design/Budget-Cost Effectiveness (i.-iv.), Section C. Organizational Capacity (i.-iii.), D. Key Personnel/Management Plan/Staffing (i.-iv.), E. Additional Direct Beneficiaries (optional), F. Cost Sharing (optional).

Information that does not count toward the 45 page limit includes the following:

• The two-page abstract summarizing the proposed project and Applicant profile information;
• Table of Contents;
• Section B. Sustainability Plan and Sustainability Matrix (however, the narrative for the Sustainability Plan should not exceed 5 double-spaced pages);
• For Key Personnel—letters of agreement and resumes (please note, applicants are no longer required to submit an SF1420 for key personnel);
• Annex A. The Logical Framework Matrix;
• Annex B. Outputs-Based Budget;
• Project Work Plan;
• Audit attachments; and
• Supporting documentation demonstrating an applicants’ country presence and/or outreach to host government ministries and nongovernmental organizations in the country.

Q32:

Can the Work Plan chart document be included as an Annex? It is not listed in the Appendix B list, and is asked for under Project Strategy on p. 32899, but on p. 32895, it says that the Work Plan should not be part of the 45-page limit.

A: 

Yes, the Work Plan chart document be included as an Annex.

Q33:

Is the Budget-Cost Effectiveness Narrative, which does fall within the 45-page Project Design limit, different from the regular Budget Justification, which should accompany the Outputs-Based Budget in Annex B?

A: 

The Budget Cost Effectiveness Narrative should provide a description and explanation of how the budget and project outputs are linked together within the overall project design to make the most effective and efficient use of project resources.  The Outputs-Based Budget, by contrast, shows this relationship by using a table format to visually link costs to outputs identified in the Logical Framework.  Information provided in each should be consistent, but each provides a slightly different way of looking at the relationship between budget allocations and project outputs.

Q34:

If USDOL received no applications for a given country under SGA 07-10, what is the likely course of action USDOL would take if no applications are received for a country?  If an applicant decides to submit a partial application, is that still a valid option and would a concept paper responding to the USDOL SGA (in the chance no full applications are received) be considered as an alternative?

A: 

In the case that no applications were received for a given country under SGA 07-10, USDOL would consider options such as reallocating some or all of the funds set aside for that country to other countries under the SGA, using the funds for other purposes in line with the relevant appropriations language, or electing not to obligate the funding.  Partial applications that are not fully responsive to the SGA will not be considered.  Applications responding fully to the SGA but requesting only part of the available funding amount would be considered for funding.

Q35:

Does the North Eastern region of Uganda fall under the terms of reference of the solicitation? The solicitation specifies bidders focus on the Northern Uganda region, and we want to confirm that Karamoja is technically considered part of Northern Uganda.

A: 

As indicated in the SGA, "The project should focus direct interventions on withdrawing and preventing war-affected children and youth from exploitive child labor, with particular emphasis on the worst forms of child labor, in northern Uganda, including the Karamoja region."

Q36:

The solicitation states on page 32910 that an example of a Sustainability Plan is available from ILAB's Web site.  When I visited that website, however, I wasn't able to locate the document.  Would you be willing to direct me to the sample sustainability plan?  If it hasn't been posted on the Web site, would it be possible to e-mail me a copy of it?

A: 

As noted in the SGA, a sample Sustainability Plan/Matrix is available from USDOL-ILAB's Web site at  http://www.dol.gov/ilab/grants/bkgrd.htm.
This sample is of the matrix.  Applicants should submit a Sustainability Matrix and a narrative description of the projects Sustainability Plan (the length of the narrative should not exceed 5 double-spaced pages—this does not count toward the 45 page limit).

Q37:

Am I supposed to attach documents like the technical proposal under "Attachments" of the "Mandatory Documents" box? Am I supposed to attach each required section of the technical proposal separately, or can I attache the entire technical proposal in one document.  Again, there does not seem to be any way to attach the optional documents for this solicitation (that is, "cost sharing" and "additional direct beneficiaries") in the "Optional Documents" box. There are no predefined forms or forms where a document can be attached in the "Optional Documents" box.

A: 

Yes.  In the case of attaching your technical proposal separately, you are more than welcome to attach the technical proposal in one document, if it allows you. 

Q38:

While "Additional Direct Beneficiaries" and "Cost Sharing" are listed as optional documents in “Appendix B Technical Proposal Format” of the solicitation, they are not listed as optional documents in the Grant Application Package. If Applicants have these optional documents how are we supposed to submit them online?

A: 

In order to post these forms to Grants.Gov, you will need to save them to your computer.  Once you have saved them to your computer, you must hit the attachment button in Grants.Gov where you mandatory form are displayed and pull the document over, which would then allow you to post your attachments to Grants.Gov.   

Q39:

Is it better for an organization to apply by itself or as part of Association?  Does the reputation and capacity of an Association partner strengthen an application?

A: 

As noted in the SGA 07-10,
"The U.S. Department of Labor (USDOL), Bureau of International Labor Affairs (ILAB), [will award funds] by Cooperative Agreement to one or more qualifying organizations and/or Associations..."

The SGA notes with respect to eligibility that,
"Any commercial, international, educational, or non-profit organization(s), including any faith-based, community-based, or public international organization(s) capable of successfully developing and implementing educational programs that aim to withdraw children from, or prevent children from entering, exploitive child labor in the target country is eligible to apply... If it is deemed the most effective and efficient strategy for achieving the goals outlined in the Scope of Work, USDOL may award one or more Cooperative Agreements to an Association, which is a partnership of more than one organization(s).”

As this suggests, applicants are responsible for determining the most effective way to apply—whether as an independent organization or as an Association.

The SGA does notes that organizational capacity is one of the SGA's application evaluation criteria, worth 25 points.  As stated in the SGA,
"Under this criterion, Applicants must present the qualifications of the organization(s) implementing the project. The evaluation criteria in this category are as follows:

i. International and U.S. Government Grant Experience
    Applicants must have international experience implementing basic, transitional, non-formal, or vocational education programs that aim to withdraw or prevent children from exploitive labor and address issues of educational access, quality, and policy reform for vulnerable children, preferably in the country of interest...
Note to All Applicants: In judging organizational capacity, USDOL will take into account not only information provided by an
Applicant, but also information from USDOL and others regarding past performance of organizations implementing USDOL-funded child labor and EI projects, or activities for USDOL and others. Past performance will be rated by such factors as the timeliness of
deliverables and the responsiveness of the organization and its staff to USDOL or grantor communications regarding deliverables and Cooperative Agreement or contractual requirements. In addition, 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 with similarly qualified staff, and the timeliness of replacing key personnel, will also be taken into consideration when rating past performance. Lack of past experience with USDOL projects, Cooperative Agreements, grants, or contracts is not a bar to eligibility or selection under this solicitation.”

Please note that for SGA 07-11, USDOL intends to make only one cooperative agreement award.  As stated in SGA 07-11,
“The U.S. Department of Labor, Bureau of International Labor Affairs, will award up to USD 3.5 million through a Cooperative Agreement to a qualifying organization or Association to carry out research on children working in the carpet industry in India, Nepal, and Pakistan.”

Q40:

Could a proposal include only secondary education or adolescents and youth only, instead of all children, i.e. certain target beneficiary age groups instead of the entire category of children?

A: 

The only age range specified as required for all countries in the SGA is that direct beneficiaries must be under the age of 18 years.  Unless a more specific age restriction/priority age focus is stated in a country-specific scope of work, applicants are only be required to adhere to the requirement to target direct beneficiaries under the age of 18 years.  The SGA does state, however, that "applicants will be rated based on the quality and relevance of their proposed strategies."

Q41:

Does the DOL award numerous cooperative agreements or typically one large one for each country, and then expect the prime cooperative agreement recipient to subcontract to others?

A: 

As stated in the SGA 07-10, "The U.S. Department of Labor, Bureau of International Labor Affairs, will award up to USD 46.494 million through 10 or more Cooperative Agreements to one or more qualifying organizations and/or Associations to combat exploitive child labor in the following 10 countries."  As this suggests, USDOL may award one or more cooperative agreements for each country noted in the SGA.  Grantees may award subcontracts to carry out work under cooperative agreements awarded through this SGA.

Please note that for SGA 07-11, USDOL intends to make only one cooperative agreement award.  As stated in SGA 07-11,
“The U.S. Department of Labor, Bureau of International Labor Affairs, will award up to USD 3.5 million through a Cooperative Agreement to a qualifying organization or Association to carry out research on children working in the carpet industry in India, Nepal, and Pakistan.”

Q42:

If an implementing partner is a local NGO who does not have a Duns and Bradstreet number and is not currently registered with the US government, can this partner agency be part of an Association if we are the lead agency?

A: 

Local NGOs may apply for a DUNS number.  Please see the relevant information on applying for a DUNS number or an OMB exemption on pages 32894-32895.  Foreign organizations which are “Association” members must have DUNS numbers and be registered with CCR.  Applicants must provide evidence of an OMB exemption from the DUNS number requirement or the actual DUNS number.  If an organization or a member of an Association applying for the award has applied and can show evidence of having submitted an application for a DUNS number prior to the deadline for this SGA, the proposal will be considered as responsive.

Q43:

What is the difference between a sub-grant and subcontracting?  The guidelines say we cannot sub-grant, but we can subcontract.

A: 

Under cooperative agreements made based on SGA 07-10 or SGA 07-11, Grantees may sub-contract, but Grantees may not sub-grant.  Please see the table provided in Appendix C in SGA 07-10 or Appendix B in SGA 07-11 for further guidance on “Definitions and Usual Characteristics of Subgrants VS. Subcontracts.”

Q44:

Do we need to provide information about grants for projects from all donors (including non-US) that are relevant to the above solicitation?

A: 

The SGA states that "The application must include information on the Applicant’s previous and current grants, Cooperative Agreements, or contracts with USDOL and other Federal agencies that are relevant to this solicitation."

The SGA does not require applicants to provide information from non-USG donors, however, this information may be included if an Applicant feels this is relevant to their proposal.

Q45:

On page 32901 under C. Organizations Capacity, does "the organisation for which the work was done" means the donor who provided the grant?

A: 

This refers to the USG agency for which work was done under the Cooperative Agreement, grant or contract.

Q46:

On page 32901 under C. Organizations Capacity, does the reference to “professional effort involved in the project” means the level of staffing allocated to deliver the project?

A: 

Yes, this is meant to refer to the level of staffing allocated for performance of the project.

Q47:

On page 32903, it states that all key personnel must each complete a SF 1420, which needs to be included with the proposal for submission.  This form is a requirement under the Federal Acquisition Requirements (FAR), which are the regulations governing USG contracts.  Since this RFA is for assistance funding, and therefore not bound by FAR, do applicants need to provide the SF 1420 for key personnel with their proposal?

A: 

This requirement for submission of SF1420 has been removed.  Applicants are not required to submit this form, but must submit information on salary history for key personnel covering their last 10 years of employment and for the various positions held during that period.     

Q48:

In reference to Appendix A on page 32907:  Please clarify the distinction between Associates and subcontractors, which are mentioned separately in the solicitation, as well as the Department of Labor’s expectations for each type of partnership in terms of application requirements.  

A: 

As stated in the SGA, “An Association is a partnership of one or more than one organization that becomes a Grantee of USDOL. An Association is comprised of two or more organizations that do not constitute a single legal entity but join in applying for an award under this solicitation. Each member of the Association must be individually eligible for the award, and must sign, and agree to be bound jointly and severally by the Cooperative Agreement.”

The Grantee may also utilize subcontracts to implement activities under this cooperative agreement; however, such subcontractors would not be considered a Grantee of USDOL.  Such a subcontractor would not sign the Cooperative Agreement or otherwise agree to be bound jointly or severally by it.

For Associations, the SGA states that:

“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. Copies of such agreements will not count toward the page limit. If any entity identified in the application as an Associate does not sign the Cooperative Agreement, the Lead Grantee must provide, within 60 days of award, either a written subcontract agreement with such entity, acceptable to USDOL, or an explanation as to why that entity will not be participating in the Cooperative Agreement. USDOL reserves the right to re-evaluate the award of the Cooperative Agreement in light of any such change in an entity's status and may terminate the award if USDOL deems it appropriate.”

The SGA does not include any requirements for specific information on subcontracts, but notes that such information may be included.  The SGA notes, for example, that information on “subcontractors (if applicable)” may be included in the two page abstract. 

The SGA further states:

“Subgranting may not be included in the budget as a line item or in the text of the application. However, subcontracting may be included as a budget line item. Subcontracts must be awarded in accordance with 29 CFR 95.40-48 and are subject to audit, in accordance with the requirements of 29 CFR 95.26(d). Subcontracts awarded after the Cooperative Agreement is signed, and not proposed in the application, must be awarded through a formal competitive bidding process, unless prior written approval is obtained from USDOL. The determination of whether a Grantee's relationship with a subrecipient would constitute a subgrant or subcontract is determined primarily with reference to an agreement's general purpose, programmatic functions, and responsibilities given to the subrecipient. These three elements should be closely examined, together with the usual characteristics (terms and performance standards, scope of work, etc.). In case of doubt, consultations are expected to be held between USDOL and the Grantee with a view to ensuring proper determination of the particular agreement. As a reference tool in determining whether an agreement is a subgrant or a subcontract, see Appendix D. The table in Appendix D is for reference only and does not create any legally binding obligation.”

Q49:

Please clarify whether the requirement for Applicants and their Associates to submit their DUNS number (or evidence of an OMB exemption) and to register as a vendor with the Central Contractor Registration also applies to subcontractors?

A: 

This requirement applies only to the Lead Grantees and other members of an Association, as described in the SGA.

Q50:

The Application and Submission Information on page 32895 states:

The cost proposal must contain information on the Applicant's indirect costs, using the form provided on ILAB's Web site at http://www.dol.gov/ilab/grants/bkgrd.htm. Applicants should note all instructions outlined on this form and include one of the following supporting documents, as applicable, in their application: (1) A current, approved Cost Allocation Plan (CAP); (2) a current Negotiated Indirect Cost Rate Agreement (NICRA); or (3) a Certificate of Direct Costs. In the case of Associations, each member of the Association must submit a copy of the aforementioned documents.

Please provide details on how to obtain a Cost Allocation Plan (CAP) or a Certificate of Direct Costs for organizations without a Negotiated Indirect Cost Rate Agreement (NICRA)? In addition, could you please clarify whether foreign-based organizations must submit a copy of one of the three previously mentioned documents (CAP, Certificate of Direct Costs, or NICRA)?

A: 

Applicants may contact the Division of Cost Determination, 200 Constitution Ave, N.W., S-1510 Washington, D.C. 20210, (P) 202-693-4100 (F) 202-693-4099.  Foreign-based organizations must submit a copy of one of the three previously mentioned documents (CAP, Certificate of Direct Costs, or NICRA).

Q51:

The Background section of Combating the Worst Forms of Child Labor in Cambodia on page 32875 identifies several provinces and rural districts with a high prevalence of child labor, obstacles to schooling and risk of dropping out, and risk of being trafficked. Would the Department of Labor be receptive to the suggestion of other areas for interventions identified as having a high prevalence of child labor through needs assessments conducted during the application preparation process, or would it prefer that applicants focus their interventions on the areas named in the solicitation?

A: 

As stated in the SGA in the country-specific scope of work for Cambodia, “At a minimum, Applicants should propose four provinces for project interventions and provide a clear justification for choices.”

Q52:

In some countries, internal transportation is heavily dependent on air travel.  Can you provide guidance on the USG regulations regarding which air carriers are allowed to be used with DOL funds?  Do these restrictions apply equally to the transport of goods as to the travel of personnel?

A: 

As stated in the Federal Acquisition Regulations (FAR), 47.402, “Federal employees and their dependents, consultants, contractors, grantees, and others must use U.S.-flag air carriers for U.S. Government-financed international air travel and transportation of their personal effects or property, if available (Section 5 of the International Air Transportation Fair Competitive Practices Act of 1974 (49 U.S.C. 40118) (Fly America Act)).”  Section 47.403-1 goes on to say, “Availability and unavailability of U.S.-flag air carrier service. (a) If a U.S.-flag air carrier cannot provide the international air transportation needed or if the use of U.S.-flag air carrier service would not accomplish an agency’s mission, foreign-flag air carrier service may be deemed necessary.”  Please see FAR Subpart 47.4—Air Transportation by U.S.-Flag Carriers, for further guidance.

Q53:

Are there any restriction or limits put on expenses related to internal travel?

A: 

Maximum rates of per diem allowances for travel in foreign areas are established by the Secretary of State and apply to all U.S. Government employees and contractors.  USDOL requires its grantees to adhere to these rates as well.  For regulations pertaining to these rates, see the Federal Travel Regulations, Chapter 301-7, as established by the General Services Administration and implementing regulations established by Federal Agencies, (Foreign Affairs Manual - See 6 FAM 150).

Q54:

In the case that an application proposes a specific sub-contractor in the application, what documentation should be submitted?

A: 

The SGA does not include any requirements for specific information on subcontracts, but notes that such information may be included.  The SGA notes, for example, that information on “subcontractors (if applicable)” may be included in the two page abstract.  The SGA further states:

“Subgranting may not be included in the budget as a line item or in the text of the application. However, subcontracting may be included as a budget line item. Subcontracts must be awarded in accordance with 29 CFR 95.40-48 and are subject to audit, in accordance with the requirements of 29 CFR 95.26(d). Subcontracts awarded after the Cooperative Agreement is signed, and not proposed in the application, must be awarded through a formal competitive bidding process, unless prior written approval is obtained from USDOL. The determination of whether a Grantee's relationship with a subrecipient would constitute a subgrant or subcontract is determined primarily with reference to an agreement's general purpose, programmatic functions, and responsibilities given to the subrecipient. These three elements should be closely examined, together with the usual characteristics (terms and performance standards, scope of work, etc.). In case of doubt, consultations are expected to be held between USDOL and the Grantee with a view to ensuring proper determination of the particular agreement. As a reference tool in determining whether an agreement is a subgrant or a subcontract, see Appendix D. The table in Appendix D is for reference only and does not create any legally binding obligation.”

Q55:

Are for-profit, non-lead Associates allowed to charge a fee on the portion of the grant that they will undertake?

A: 

Neither Lead Associates nor non-lead Associates are allowed to charge a fee on the portion of the grant that they will undertake (see OMB Cost principles A-122).

Q56:

If the Lead Grantee's NICRA rate establishes that it can be applied to all components of a grant, can the NICRA be applied, without modification, on Associate awards in the same manner it would to a subcontractor (e.g. components led by an Associate of the lead grantee)?

A: 

Each Associate must use its own established NICRA.

Q57:

While the solicitation invites applicants to specifically address the needs of Internally Displaced Persons (IDPs) in Colombia, could a proposal focus exclusively on IDPs (and their hosting communities), or would you rather advise us to include a larger range of beneficiaries?

A: 

As stated in the SGA, page 32878, subsection iii. Scope of Work, second column, “Since many Colombian children are affected or displaced by conflict, the project should pay special attention to their needs.”  The SGA, however, does not limit the focus to this group or restrict an Applicant from making this their primary focus. 

Unless a more specific age restriction/priority age focus is stated in a country-specific scope of work, applicants are only be required to adhere to the requirement to target direct beneficiaries under the age of 18 years.  The SGA does state, however, that "applicants will be rated based on the quality and relevance of their proposed strategies."

Q58:

Would the DOL award numerous cooperative agreements for a country, or one large one instead? And if an applicant were to focus exclusively on a specific target group (and their hosting communities), should it propose a smaller-scale proposal and budget?

A: 

As noted in the SGA, "The U.S. Department of Labor (USDOL), Bureau of International Labor Affairs (ILAB), [will award funds] by Cooperative Agreement to one or more qualifying organizations and/or Associations..."

In terms of the scope of the proposal and the amount of funding requested, Applications responding fully to the SGA but requesting only part of the available funding amount would be considered for funding.  As the SGA states, "applicants will be rated based on the quality and relevance of their proposed strategies."

Q59:

If religious study is mandatory in a proposed country, should a grantee address in their applications how they will ensure that USDOL funds and matching funds do not go towards paying for the proportion of school fees and tuition that fund religious classes?

A: 

Yes, this issue should be taken into account in an Applicant’s proposal(s) to the SGA.

Q60:

The program announcement for SGA 07-11 indicates, on page 34288, that the Principal Investigator (PI) must allocate 100 per cent of their time to the project. In our experience with large projects of this type, the PI needs to spend a significant proportion of their time on such a project.  However, given that PIs are senior staff, a PI may usually be requires to allocate at least a small proportion of their time - say 25-30% - to institutional strategic development activities such as preparation of mid term plans, mentoring and performance evaluation of junior staff, participation in publication or other committees, and providing intellectual leadership to other initiatives as needed.  Usual practice for an organization, therefore, may be to co-finance the percentage of time allocated by the PI to institutional activities, while project funds are used solely for the PIs contribution to the project.  Can an Applicant propose such an arrangement as part of its staffing plan on this project?

A: 

As mentioned on p. 34288 of SGA 07-11, “All key personnel must allocate 100 percent of their time to the project.”  However, additional personnel who may contribute positively to the project can be included in the application.  For example, the referenced senior staff member may be included in the application in addition to the PI. Any participation in institutional strategic development activities should be charged through indirect costs.

Q61:

For SGA 07-11, the program announcement indicates, on page 34287, that the child labor research specialist, is one of the key personnel. Is it possible for us to hire this person under a sub-contract? And if we form an "association" for the purposes of responding to this funding opportunity, can this specialist come from an organization that is not the lead grantee?

A: 

As mentioned on p. 34288, “Key personnel must be employed by the Grantee, not a subcontractor.  In the case of an Association, the PI/PD must be employed by the Lead Grantee.  In cases of Associations where Applicants propose that other key personnel would not all be employed by the Lead Grantee, a clear indication of the following must be provided in the application:  the rationale for dividing key personnel among the members; the lines of authority among key personnel and other staff; the process of supervision and evaluation of personnel who are not members of the same organization; the process by which all parties would come to agreement on key implementation issues; and mechanisms of conflict resolution should the need arise.” 

Q62:

Please confirm if the DOL prefers a hard-copy or electronic-copy submission.

A: 

USDOL will accept both hard copy and electronic-copies of submissions.  The form of an Applicant’s submission of its applications (whether in hard copy or an electronic format) will not be a factor considered in assessment of any proposals.  Applicants, however, are asked to submit a proposal in only one of the two formats, not in both.

Q63:

Please confirm if there are any source/origin restrictions on the use of grant funds for the purchase of commodities, vehicles, and or services (i.e. airfare).  There are no restrictions cited in the misc. prohibitions.  

A: 

Grantees are required to adhere to Circular A-122.

Q64:

In the SGA there are references to various supporting documents that do not count towards the page limit, i.e. resumes, letters of association, and USAID 1420 form. Please confirm the order of submission preferred for these Attachments.  We understand they would begin as Annex C, etc.      

A: 

USDOL has no preference for the order of submission of these Attachments.  Please note that USAID 1420 forms are no longer required.

Q65:

Please confirm that only the narrative for the proposal should be double-spaced, specifically that the resumes, work plan, logical framework, etc. are not held to this restriction.     

A: 

Yes this is correct.

Q66:

On page 32903 there is a reference to the need to chart all key tasks. This is generally contained in a work plan. Please confirm if this discussion should be included as an annex, therefore, is not counted towards the 45 page limit.

A: 

This information may be included as an annex and/or within the workplan and will not be counted toward the 45 page limit.

Q67: 

Please provide general guidance on the application of different NICRA rates among the Lead and Associate Grantees.  For example, can each apply their organization’s NICRA rates? Or can a composite rate be applied? Or is it dependent on the associate agreement? Does the DOL have any specific prohibitions or restrictions regarding the budget when there is a lead grantee and associate grantee(s)?

A:

Each Associate must use its own established NICRA.

Q68: 

This question is in reference to the SGA stipulation that, “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 time line for which each Associate will be responsible”.

Can DOL provide additional clarity as to the format and content for the Association agreement as the proposal document itself will highlight the deliverables, activities and corresponding time line for which each Associate will be responsible? Does DOL consider teaming agreements generally signed by the collaborating agencies as meeting the requirement of the Associate agreement?

A:

At this time, DOL does not have and does not require any standard format for documenting/establishing such an Association agreement.  The agreement must, however, designate a Lead Grantee.  The agreement should also demonstrate that all Associates have agreed to apply together for this award and would be prepared to sign a Cooperative Agreement with the Department of Labor, binding each member of the Association jointly and severally.  It is also important to note, as stated in the SGA,

"If any entity identified in the application as an Associate does not sign the Cooperative Agreement, the Lead Grantee must provide, within 60 days of award, either a written subcontract agreement with such entity, acceptable to USDOL, or an explanation as to why that entity will not be participating in the Cooperative Agreement. USDOL reserves the right to re-evaluate the award of the Cooperative Agreement in light of any such change in an entity’s status and may terminate the award if USDOL deems it appropriate."

Q69:

How does DOL judge according to the criteria provided whether the prospective associates are independently eligible to enter into a Cooperative Agreement, or if in fact they would be considered a sub-contractual relationship?  For example, Local NGO X will be substantially involved in the project’s implementation over the life of the project, but does not have enough organizational capacity at this time (in terms of Finance, Administration, etc.) to be individually eligible for the award.  How would this situation be assessed according to DOL’s criteria?  Would the Cooperative Agreement be open to revision at a later time when the Local NGO has reached an appropriate level of capacity and could take on the full responsibilities that an Associate would be expected to fulfill?

A:

Once an organization is proposed as a member of an Association, the Association as a whole will be considered and assessed as a single applicant/potential grantee for the purposes of the competition.  After an Association is awarded a cooperative agreement by DOL, DOL considers the entire Association as the grantee.  As noted in the SGA, "Each Associate is ultimately responsible for overall project performance, regardless of any assignment of specific tasks, but Associates may agree, among themselves only, to apportion the liability for such performance."  Therefore, once an Association is formed, DOL would not consider the relationship between Association members as sub-contracting or sub-granting.

Q70:

When a new education program for an older age group is initiated and enrolls a child who was a direct beneficiary from a previous DOL funded activity, can that child be counted as a direct beneficiary for the new program?  An example would be new children enrolled in a current project who could be enrolled in a complementary educational service when the new project starts.

A:

A child counted as a direct beneficiary by a grantee in a previous project may not be counted as a direct beneficiary again for a project funded under this cooperative agreement.  A grantee may propose, however, to offer services to such children (under the age of 18 years) to help ensure that they remain out of exploitive labor, but may not report those children to USDOL for GPRA purposes.

Q71:

Please clarify how children who transition between one age group to another can be counted.  For example, if a child was withdrawn in one age group and then enrolls in a separate educational program when he or she is in another age group, can the child then be counted as a direct beneficiary in the second age group?  If not, how can this direct assistance be reflected in the statistics?

A:

A child (under the age of 18) may be counted as a direct beneficiary only once by a grantee.  In terms of common indicators, this could be considered persistence.

• ILAB Mission Statement
• Leadership
• Organization
• Key Personnel

• OCFT
• OIR
• OTLA

• Executive Order 13126
• Food, Conservation, and Energy Act of 2008 ("Farm Bill")
• Trafficking Victims Protection Reauthorization Act (TVPRA)