Bringing Clarity to a Clarification in the Circular A-133 Compliance Supplement

June 8, 2011 | By Jerry Ashworth | Post a Comment

Do you ever read something that makes you stop in your tracks and say “Wait, what?” That was my reaction to one sentence in the 1,544 -page 2011 Office of Management and Budget Circular A-133 Compliance Supplement. That one sentence was clear as mud.

Among the changes listed in Appendix 5 of this year’s supplement, the OMB “clarified” that, for American Recovery and Reinvestment Act awards, “a subrecipient is not required to be registered in the Central Contractor Registration at the time of the subaward.” It had been my understanding, and it is explained in numerous passages in the supplement, that all first-tier subawardees receiving Recovery Act funds must be registered in CCR. I was hung up on this for quite a while.

For further explanation, the “Subrecipient Monitoring” section in Part 3 of the supplement states that a pass-through entity is responsible for identifying to first-tier subrecipients of Recovery Act awards the requirement to register in the CCR, including obtaining a DUNS number, and maintain the currency of that information. It now goes on to say, “This requirement pertains to the ability to report pursuant to Section 1512 of ARRA and is not a pre-award eligibility requirement.”

I tend to think a simple rewording of this new clarification is in order to make it easier to understand. Let me give it a shot: A first-tier subawardee is not required to be registered in the CCR prior to receiving a Recovery Act subaward, but once it receives the subaward, it must register in the CCR. How’s that, better?

Are there any portions of the new Circular A-133 Compliance Supplement that you find confusing? Let us know and maybe we can find a way to shed some light on it

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