[lstac] [External] RE: subawarding subawards

Thu Oct 12 09:29:26 PDT 2023

In the past when this was allowed it seemed to occur with our larger academic libraries who wanted to work together on a project.  Generally it involved staff at both organizations working towards the same objective and where the library that the State Library awarded to, as lead, to would then subaward to the other library.

I will say there was at least one instance here back around 2016-17, of yes, its as messy as it sounds, because both academics had federally negotiated indirect cost rates. It got pretty confusing with the IDC alone.  This was when we made it unallowable.

I did float the idea of making the other library a contractor<https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/subject-group-ECFR031321e29ac5bbd/section-200.331>, depending on the nature of the relationship and what is being provided by the other library.  With a contract in place they would have to be determined as a subrecipient or a contractor, in my understanding of 2 CFR 200.

In some respects it does seem like a barrier to applying for certain libraries, which we try to address as best we can. We still want to be thoughtful about the administrative burden, not only for us but for the awardee too.  We were already leaning towards the idea of keeping it unallowable due to our past experiences and concerns, but wanted to see what other SLAAs did and if there were any lessons to be learned.

Catherine M. Prince (she, her, hers)
Please note my email address has changed: catherine.prince at dncr.nc.gov<mailto:catherine.prince at dncr.nc.gov>
Federal Programs Consultant
NC Dept. of Natural and Cultural Resources
919.814.6796 |  catherine.prince at dncr.nc.gov<mailto:catherine.prince at dncr.nc.gov>

109 East Jones Street  | 4640 Mail Service Center
Raleigh, North Carolina 27699-4600

P.S. Library Development now has a newsletter! Check it out and subscribe for the latest NC Library news.
<https://slnclibrarydevelopment.substack.com/>[Logo for State Library of North Carolina (SLNC) with cardinal. Text read SLNC; NC Research. Library Support. Talking Books. statelibrary.ncdcr.gov]<https://statelibrary.ncdcr.gov/>
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.

From: Maura Walsh <mwalsh at njstatelib.org>
Sent: Thursday, October 12, 2023 12:06 PM
To: Tara McCleod <Tara.McCleod at libraries.ok.gov>; Reish, Karren (MDE) <ReishK at michigan.gov>; Prince, Catherine <catherine.prince at dncr.nc.gov>
Subject: [External] RE: subawarding subawards

CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab.

Hi folks,

Sounds like a crazy idea to me. I can't really imagine what a subawardee would need to do this for. Is there any reason they can't do whatever with a contract for services? A contract can be as simple as a letter saying 'I did X in exchange for $X.'

Best,
Maura
Maura Walsh, MLIS (she/her/hers)
Grants Manager and LSTA Coordinator
New Jersey State Library
P: (609) 278-2640 x136
E. mwalsh at njstatelib.org<mailto:mwalsh at njstatelib.org>
W. www.njstatelib.org<https://www.njstatelib.org/>
185 West State Street
P.O. Box 520, Trenton, NJ  08625

[cid:image002.jpg at 01D9FD05.BC3712D0]

From: lstac <lstac-bounces at omls.oregon.gov<mailto:lstac-bounces at omls.oregon.gov>> On Behalf Of Tara McCleod via lstac
Sent: Thursday, October 12, 2023 11:52 AM
To: Reish, Karren (MDE) <ReishK at michigan.gov<mailto:ReishK at michigan.gov>>; Prince, Catherine <catherine.prince at dncr.nc.gov<mailto:catherine.prince at dncr.nc.gov>>; LSTA CoordinatorsList LSTAC <lstac at omls.oregon.gov<mailto:lstac at omls.oregon.gov>>
Subject: Re: [lstac] subawarding subawards

I recently asked this question of our Program Officer and was told it wasn't preferred, which was enough for me to not do it, based on the concerns you mentioned in your email.

[cid:image003.jpg at 01D9FD05.BC3712D0]<https://oklahoma.gov/libraries.html>
Tara McCleod
Federal Programs Officer/Business Manager
PH (405) 522-3317
Oklahoma.Gov/Libraries<https://oklahoma.gov/libraries.html>
DigitalPrairie.OK.Gov<http://digitalprairie.ok.gov/>
 [Connect with ODL's Social Media] <https://oklahoma.gov/libraries/about-odl/connect.html>

From: lstac <lstac-bounces at omls.oregon.gov<mailto:lstac-bounces at omls.oregon.gov>> On Behalf Of Reish, Karren (MDE) via lstac
Sent: Thursday, October 12, 2023 10:50 AM
To: Prince, Catherine <catherine.prince at dncr.nc.gov<mailto:catherine.prince at dncr.nc.gov>>; LSTA CoordinatorsList LSTAC <lstac at omls.oregon.gov<mailto:lstac at omls.oregon.gov>>
Subject: [EXTERNAL] Re: [lstac] subawarding subawards

I understand that they can't regrant like this. I could not find anything in quick check of 2 CFR 200 on it though.

Karren Reish
Library Grants Coordinator
Library of Michigan
517-241-0021 / www.mi.gov/lsta<https://urldefense.com/v3/__http:/www.mi.gov/lsta__;!!NZFi6Pppv9YRQw!qRwvrHKNlDznon-M516Inz6TXQYLFydSn2l68xEoTjsDhp_mw-7hAxdC3oQY2-vnrbZC32cKzMxkvs7ejKe7RezjwUcIaw$>

From: lstac <lstac-bounces at omls.oregon.gov<mailto:lstac-bounces at omls.oregon.gov>> On Behalf Of Prince, Catherine via lstac
Sent: Thursday, October 12, 2023 11:26 AM
To: LSTA CoordinatorsList LSTAC <lstac at omls.oregon.gov<mailto:lstac at omls.oregon.gov>>
Subject: [lstac] subawarding subawards

CAUTION: This is an External email. Please send suspicious emails to abuse at michigan.gov<mailto:abuse at michigan.gov>

Hi all,

For those who subaward, does anyone allow your subawardee to also subaward? We made subawarding unallowable several years ago, due to the concerns with monitoring and controls that the subawardee would be taking on, in addition to the additional burden for the State Library.

If you do allow for subawarding, do you have any additional procedures or language in your contract/agreement.  Anything to keep in mind?  We are looking at the allowability of subawards for our subawards and just wanted to gauge how other folks handle it.

Thanks in advance!
Catherine

Catherine M. Prince (she, her, hers)
Please note my email address has changed: catherine.prince at dncr.nc.gov<mailto:catherine.prince at dncr.nc.gov>
Federal Programs Consultant
NC Dept. of Natural and Cultural Resources
919.814.6796 |  catherine.prince at dncr.nc.gov<mailto:catherine.prince at dncr.nc.gov>

109 East Jones Street  | 4640 Mail Service Center
Raleigh, North Carolina 27699-4600

P.S. Library Development now has a newsletter! Check it out and subscribe for the latest NC Library news.
<https://urldefense.com/v3/__https:/slnclibrarydevelopment.substack.com/__;!!NZFi6Pppv9YRQw!qRwvrHKNlDznon-M516Inz6TXQYLFydSn2l68xEoTjsDhp_mw-7hAxdC3oQY2-vnrbZC32cKzMxkvs7ejKe7RezZB-3kPw$>[Logo for State Library of North Carolina (SLNC) with cardinal. Text read SLNC; NC Research. Library Support. Talking Books. statelibrary.ncdcr.gov]<https://urldefense.com/v3/__https:/statelibrary.ncdcr.gov/__;!!NZFi6Pppv9YRQw!qRwvrHKNlDznon-M516Inz6TXQYLFydSn2l68xEoTjsDhp_mw-7hAxdC3oQY2-vnrbZC32cKzMxkvs7ejKe7ReyJJ-KD4w$>
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.

________________________________

Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized state official.
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://omls.oregon.gov/pipermail/lstac/attachments/20231012/ebf4151b/attachment-0001.html>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: image001.jpg
Type: image/jpeg
Size: 49715 bytes
Desc: image001.jpg
URL: <https://omls.oregon.gov/pipermail/lstac/attachments/20231012/ebf4151b/attachment-0003.jpg>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: image002.jpg
Type: image/jpeg
Size: 4993 bytes
Desc: image002.jpg
URL: <https://omls.oregon.gov/pipermail/lstac/attachments/20231012/ebf4151b/attachment-0004.jpg>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: image003.jpg
Type: image/jpeg
Size: 5816 bytes
Desc: image003.jpg
URL: <https://omls.oregon.gov/pipermail/lstac/attachments/20231012/ebf4151b/attachment-0005.jpg>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: image004.png
Type: image/png
Size: 4562 bytes
Desc: image004.png
URL: <https://omls.oregon.gov/pipermail/lstac/attachments/20231012/ebf4151b/attachment-0001.png>