Question: I am concerned that submitting a proposal that includes a for-profit team member (i.e. contractor) that was not selected via a competitive process may disqualify our proposal. Can you advise me on this issue and any precedents you are aware of?
Response: Please see the guidelines section where these statements are made "Applicants must compete contracts for services and products, including consultant contracts, and conduct cost and price analyses to the extent required by the procurement provisions of the regulations at 40 CFR Parts 30 or 31, as appropriate. ...Applicants are not required to identify subawardees/subgrantees and/or contractors (including consultants) in their proposal/application. However, if they do, the fact that an applicant selected for award has named a specific subawardee/subgrantee, contractor, or consultant in the proposal/application EPA selects for funding does not relieve [emphasis added] the applicant of its obligations to comply with subaward/subgrant and/or competitive procurement requirements as appropriate. Please note that applicants may not [emphasis added] award sole source contracts to consulting, engineering, or other firms assisting applicants with the proposal solely based on the firm’s role in preparing the proposal/application."
Please become familiar with the federal regulations concerning open competition of procurements under federal grants. Procurement of professional services in a non-competitive manner would be a potentially ineligible grant cost. If you participate in a grant writing workshop or get a copy of the presentation, you will learn that EPA recommends applicants do not raise cost eligibility "red flags" in their proposals. Red flags cause lower rankings. Lower ranked proposals are not selected for funding.
While applicant's planned procurement procedures are not a "Threshold Criteria" (basic grant eligibility issue), discussions in proposals about applicant's procurement plans can impact the ranking review and ultimate selection for funding.
Source: EPA Region 6 Brownfield Program
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