Gina GiacomoD20DCF by broverya77

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									                         SAPT – BLOCK GRANT
   FINANCIAL ASSISTANCE (SUBGRANT) TO PUBLIC OR NON-PROFIT ENTITY

SAPT (CFDA 93.959) Compliance Requirement for Activities Allowed or
Unallowed:

Grants funds may not be used to provide financial assistance (i.e., a subgrant) to any
entity other than a public or non-profit entity. A State is not precluded from entering
into a contract for services, since payments under such a contract are not financial
assistance to the contractor (42 USC 300x-31(a); 45 CFR section 96.135(a)(5)).

The OMB Circular No. A-133 Audit of States, Local Governments, and Non-Profit
Organizations provides guidance in determining whether payments constitute a
Federal award (financial assistance) or a payment for goods and services. In Section,
___.210 Subrecipient and vendor determinations, paragraphs (b) and (c) are the core
to in determining what constitutes a Federal award (financial assistance) or a payment
for goods and services.

(b) Federal award. Characteristics indicative of Federal award (financial assistance)
received by a subrecipient (sub-contractor) are when the organization (provider):

   (1) Determines who is eligible to receive what Federal financial assistance;
   (determines eligibility of clients)

   (2) Has its performance measured against whether the objectives of the Federal
   program are met; (performance measures in the sub-contract, enters data in DCF
   data system for accountability)

   (3) Has responsibility for programmatic decision making;

   (4) Has responsibility for adherence to applicable Federal program compliance
   requirements:

   (5) Uses the Federal funds to carry out a program of the program compliance as
    compared to providing goods or services for the program. (program compliance=
    a subcontract for SAMH units of service)

(c) Payment for goods and services. Characteristics indicative of a payment for
goods and services received by a vender (sub-contractor –can be for profit) are when
the organization (provider):

   (1) Provides the goods and services within normal business operations
   (2) Provides similar goods or services to many different purchasers;
   (3)Operates in a competitive environment;
   (4)Provides goods and services that are ancillary to the operation of the program;
   (5) Is not subject to compliance requirements of the federal program.
In Conclusion: Once DCF has contracted SAPT Block Grant Funds to a non-for-profit
provider and the non-for profit provider is asking for approval to sub-contract the SAPT
Block Grant Funds. You would need to determine if paragraph (b) or (c) above apply
to the sub-contract.

For assistance in making the determination please refer to OMB Circular No. A-133,
Section, ___.210 Subrecipient and vendor determinations, paragraphs (d) (e) and (f).

If you need assistance please contact Gina Giacomo 850-413-7244 or SC293-7244

								
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