34. Our university’s research corporation, a 501(c)(3) non-profit, submits and administers grant dollars on behalf of the university. Would the research corporation be eligible to be a CBO on an application submitted under the NOFO?

34. Our university’s research corporation, a 501(c)(3) non-profit, submits and administers grant dollars on behalf of the university. Would the research corporation be eligible to be a CBO on an application submitted under the NOFO?

A nonprofit organization affiliated with a university could qualify as a CBO if they meet the other requirements for a CBO specified in Section III.A of the NOFO. However, if the nonprofit intends to name the university parent as a Statutory Partner or otherwise provide a subaward to the university parent, then EPA’s Financial Assistance Conflict of Interest Policy (https://www.epa.gov/grants/epas-finalfinancial-assistance-conflict-interest-policy) would be implicated due to the potential for personal and organizational conflicts of interest.

Question Category
D. Eligibility and Statutory Partnerships