20260819 APS QnA.pdf

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U.S.-Africa Strategic Investment Program
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DFOP0019410
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This document is a comprehensive Questions and Answers guide for the Bureau of African Affairs Annual Program Statement (APS) Window 1, Opportunity #DFOP0019410, addressing clarifications to the grant solicitation.

The APS solicits grant and cooperative agreement applications in the $5M–$50M range from legally incorporated U.S. and non-U.S. organizations to implement projects across two focus areas: (1) Critical Minerals exploration, extraction, and processing in sub-Saharan Africa; and (2) Commercial Diplomacy Acceleration addressing business-enabling environments and U.S. market entry in sectors including critical minerals, emerging technologies, energy, infrastructure, digital/telecommunications, and healthcare. Awards are anticipated to be fully funded upon signing with no predetermined country allocations. Organizations may submit up to two Statements of Interest (SOIs) per window as prime applicants. The SOI comprises a 4-page submission: a 1-page cover/critical-details table, a 2-page narrative, and a 1-page summary budget with no annexes permitted. No SAM.gov registration or formal cost share is required at the SOI stage, though projects must demonstrate measurable impact within the 36-month implementation period and mobilization of non-USG resources. Foreign government entities and U.S. government entities are ineligible as applicants, but may serve as beneficiaries or unfunded partners. Construction is generally ineligible except for non-structural modifications and pre-construction activities. Profit or fee is prohibited for prime recipients and subrecipients. The document clarifies evaluation criteria, including that foreign policy goals and U.S. supply chain commitment are assessed under "Quality and Feasibility of Program Idea," while leverage/burden-sharing comprises 20% of the merit score based on cash or in-kind resources supporting projects.

APS questions and answers dated August 19, 2026

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Bureau of African Affairs Annual Program Statement (APS) - Window 1 Questions and Answers

Opportunity #: DFOP0019410

Given the high volume of similar questions received, the Bureau is sharing questions and answers in a summary format. More specific questions can be addressed at the full proposal stage for concepts that advance.

Corresponding clarification edits have been made to the APS in version 3 (v3).

A. Basic Information (Type, Size, Number)

1. Can an applicant propose a specific award type (grant vs. cooperative agreement, cost-reimbursement

vs. fixed amount award)? The applicant may propose an award type, but the Department's grants officer makes the final determination. Cooperative agreements are anticipated.

2. Can I apply through this APS for a contract or subcontract? No — an organization should apply to this

APS only if it wishes to be a direct (“prime”) recipient of a grant or cooperative agreement to design and implement a project.

3. Can I request an amount outside the specified award range? Does requesting less improve my chances? No — SOIs outside the $5M–$50M range are ineligible. Requesting an amount at the lower end of the range neither helps nor hurts selection.

4. Will funds be allocated according to a set formula across countries or windows? No. There are no predetermined allocations; funding depends on availability and project viability. The "10 awards" figure is only an estimate.

5. Will awards be fully funded at signing or will funding be obligated in stages? Awards are anticipated to be fully funded upon signing, subject to funding availability.

6. Is it advantageous to submit a Statement of Interest (SOI) earlier in a window rather than later? No.

SOIs are reviewed only after the relevant window closes, regardless of submission date within that window.

7. FY2026 funds must be obligated by September 30, 2027, while the anticipated program start is no later than October 1, 2027 — what does this mean for applicants in later windows (e.g., Windows 3 and 4)? September 30, 2027 is the deadline for the Department to obligate funding to a prime award — not a deadline for a recipient to expend funds. Awards may be made earlier, or the Department may amend the

APS to remove later windows.

8. Is there a limit to the number of awards a single applicant can receive? No, but funding is limited overall.

9. Can an applicant recommend specific types of Department substantial involvement, a phased approach to a grant, or that consultative co-design be used? An applicant can make recommendations, but these decisions will ultimately be at Department discretion.

10. Can the lead applicant be a fiscal sponsor for an implementer? A prime applicant / recipient will be the

Department's interlocutor and holds legal responsibility for award implementation, including monitoring subrecipients / subcontractors. Both the prime and any subrecipients should have substantive roles and clear value-adds explained in the SOI.

11. What types of U.S. business participation are preferred? Will having a U.S. firm as the prime applicant or a subrecipient rate more highly in selection criteria? No one type of U.S. business participation is favored in the selection criteria over others. Depending on the project, U.S. firms may be the prime applicant, subrecipients, subcontractors / suppliers, recipients of services, resource partners, or some other type of participant (or a combination). This is up to the applicant to propose.

12. We note that activities included in this APS are also referenced in a recent Sources Sought Notice.

Does the Department of State anticipate utilizing a contract as an IDIQ vehicle in the future for similar activities, or should applicants expect such activities to continue being implemented through this and other future APS mechanisms? While the APS and Sources Sought notices may address some similar activities, any resulting NOFO or solicitation will have distinct scopes and objectives.

B. Eligibility

8. Who is eligible to apply (individuals, universities, foreign entities, U.S. government entities)? Applicants must be legally incorporated organizations at the time of SOI submission (no individuals). U.S. and non-U.S. universities are eligible. Non-U.S. organizations may apply as prime or be a subrecipient. Foreign government entities / parastatals are not eligible as applicants, subrecipients, or subcontractors but may be beneficiaries or unfunded partners. U.S. government entities cannot apply;

contact the Department directly regarding interagency agreements.

9. How is “U.S. aligned” defined for the eligibility criteria? This has been removed from the eligibility criteria. Instead, as part of the Review Criteria, organizations must demonstrate commitment to or alignment with U.S. supply chain or commercial goals in SOIs.

10. Can a party from outside of the U.S. or Africa be an applicant / subrecipient / consultant? Can some work / expenses (e.g. design work) occur outside of the U.S. or Africa? Yes, but one or more sub-Saharan countries must benefit from the program.

11. Are consortiums encouraged? Neither encouraged nor discouraged. A single legally established prime applicant must hold overall responsibility for award management, including subrecipient monitoring.

12. How many SOIs may an organization submit, and are there restrictions on multiple submissions for the same project? Up to two SOIs per window as a prime applicant (this cap does not restrict subrecipient/subcontractor roles on others' SOIs). Each project must have a single prime and may not be submitted as multiple SOIs (e.g., split into multiple SOIs for each relevant focus area, or organization involved, etc.). It is fine if a single SOI lists both focus areas as relevant.

13. Is construction eligible? New, non-temporary construction involving structural work is generally ineligible. Non-structural modifications, equipment installation, and pre-construction activities

(feasibility studies, environmental/social assessments, design, site prep, permitting support, etc.) can be proposed. See the SF-424A for the definition of construction: SF-424A Instructions v.1, OMB #4040-

0006.

14. What programs are ineligible (e.g., organizational growth, duplicative work)?

• A project is generally considered to go beyond the growth of the applicant if it has public benefits sought by the APS, aligning with the program description in the APS including having mutual benefit to a sub-Saharan African country. Explain whether the project addresses key APS solutions sought, challenges, and indicator(s).

https://apply07.grants.gov/apply/forms/instructions/SF424A-V1.0-Instructions.pdf https://apply07.grants.gov/apply/forms/instructions/SF424A-V1.0-Instructions.pdf

• Applicants should explain in the SOI how their project is distinct, fills an unmet need, or moves an existing project to a new stage; complementary / related projects are welcome.

15. At this stage can the Department share more types of substantial involvement it might have in an award? For example, would the Department review offtake or other commercial agreements, etc.?

No, further examples beyond those in the APS cannot be provided or confirmed at this stage. Substantial involvement for a specific project can be assessed further at the full proposal stage.

16. How is cost share evaluated in the review criteria when it is not required? Non-U.S. government resources will be evaluated, but they need not be cost share (as defined in 2 CFR 200.1 and 2 CFR

200.306), specifically.

17. How do you calculate mobilization of non-US Government resources? Do the resources need to be mobilized only because of the funding from the award, directly for the same purpose as the award or broadly spent on the same project? Non-USG resources need not be newly mobilized for a project because of the proposed grant award, though they could be. Explain the total cost of a project and demonstrate that U.S. government resources are not the only resources supporting the project. Resources should be directly related to the project being proposed rather than broad investments in a related sector.

18. How is the limit of 2 SOIs per org per window defined? Each legally incorporated organization with a distinct physical geographic address can submit up to two SOIs per window.

C. Program Description – Focus Area 1, Critical Minerals

1. What is Focus Area 1 (Critical Minerals) intended to cover? Which minerals are eligible? See the

APS for details. All U.S. Geological Survey (USGS), U.S. Department of Energy (DOE), and U.S.

Department of War (DoW)-designated critical or strategic minerals are eligible.

2. For the indicator addressing the value of investments, transactions, and offtake agreements advanced toward financial close, what milestones qualify as “advanced”? The applicant can propose an indicator definition for Department consideration at the full proposal stage or at the SOI stage, page limit permitting. The Department’s priority is accelerating the timeline for these projects to enter production.

3. Are projects that produce intermediate products like critical metals concentrates eligible or is it required that the project ends up delivering refined metals into US supply? Yes, products that produce intermediate products can be proposed.

4. Is the only desired outcome assets that are producing critical material at the end of the implementation period of 36 months or is a well studied asset with a define mineral resource considered a successful outcome as well? Both.

5. If an applicant is awarded funding for an initial critical minerals asset, would this preclude a subsequent application for an adjacent, larger-scale asset in a future funding window? No. However, note that funding is limited and one or more windows may be cancelled.

6. Would the Department consider an access model that provides the host government ownership and administrative control while allowing defined categories of data, etc. to be made available through controlled, tiered, or time phased access? Yes.

C. Program Description – Focus Area 2, Commercial Diplomacy Acceleration

7. What is Focus Area 2 intended to cover? Business-enabling-environment improvements and facilitation of specific deals / U.S. business market entry or expansion.

8. Which sectors are of interest for Focus Area 2 of the APS (Commercial Diplomacy Acceleration)

The following clarification is made to APS Section C.2.

“Sectors of interest include but are not limited to:

• Critical Minerals and Mining (e.g., exploration, extraction, processing and related technologies,

• Emerging Technologies (e.g., artificial intelligence, biotechnology, advanced hardware, and fintech)

• Energy (e.g., power generation, transmission and distribution; oil and gas exploration, production and infrastructure, and energy technologies)

• Infrastructure (e.g., transportation, water, and sanitation))

• Digital, Telecommunications and Cybersecurity (e.g., telecommunications and connectivity, data centers, cloud computing, digital platforms, satellite technology, and cybersecurity technologies)

• Healthcare (e.g., diagnostics, pharmaceuticals, medical devices, healthcare services and technologies)”

9. Can you tell me at this stage whether various types of expenses we’re considering such as purchase commitments or first-loss guarantees are allowable? See the applicable U.S. grant cost principles for your organization (2 CFR 200 Subpart E for not-for-profits, or FAR Part 31 for for-profits). Specific costs can be assessed in more detail if a concept is selected to advance to the full proposal stage.

10. Does the Department prefer projects that deploy commercially proven technologies capable of immediate implementation, or projects that require significant pilot testing or technology validation? Not all proposed technologies must be commercially proven. However, projects must be able to achieve measurable impact within the grant period.

C. Program Description – Applicable to both focus areas

11. Can the Department comment at this stage on whether various other specific activities, sectors, and project ideas would be eligible or preferred? Or whether specific activities can count toward certain key performance indicators (KPIs) in the APS? No. Projects can be proposed if they address priority challenges and solutions sought, and are not described as ineligible in the APS. Propose one or more KPIs you consider relevant to the SOI; further refinement can be done in full proposals.

12. Which measurable outcomes will be weighted most heavily during evaluation? Measurable outcomes vary by project; one type is not assigned higher weight than others in the review criteria.

13. Can a single SOI address both Focus Areas, or must one be "primary"? Yes, a single SOI may address both; there is no requirement to designate one as primary.

14. Are the "challenges" and KPIs listed in the APS mandatory or illustrative? A SOI should address at least one priority challenge. Proposals need not address every challenge. Lobito Corridor mentions do not indicate a geographic or project type preference. Applicants should use at least one APS indicator if relevant, or propose an alternative KPI.

15. Can the Department tell us in this Q&A whether other work we do during or after the grant would pose conflicts of interest and what firewalls if any are expected? No. Specific scenarios will need to be assessed with more information if a concept is selected to advance to the full proposal stage.

Disclosures are also welcome at the SOI stage to the extent feasible within the SOI page limit.

16. May a 36-month program support some assessment and pilot work or must all locations be definitively identified at the SOI stage? An applicant can propose to identify or validate some elements of a project during implementation. However, projects must be able to achieve measurable impact within the grant period.

17. How does the Department balance near-term measurable outputs against longer term outputs or investment outcomes that may materialize after the award period? It is understood that some project impacts may materialize after the award period. However, all projects should achieve some measurable impact during the grant period.

18. The APS references "U.S. foreign policy goals" or "U.S. supply chain goals" without listing them explicitly or linking them to a USG public document that would explain them. Please see the public

2025 U.S. National Security Strategy (https://www.whitehouse.gov/wp-content/uploads/2025/12/2025-

National-Security-Strategy.pdf) and Department of State Agency Strategic Plan

(https://www.state.gov/agency-strategic-plan ) for information on U.S. national security and foreign policy goals. Goals of the APS are described in the Program Description.

19. Will the grant funding have any repayment requirements or equivalent equity participation?

Typically no, although it is possible for loans that require repayment to be administered under a prime award.

20. Does the Department have priority countries under this program? Are any countries excluded due to foreign assistance restrictions? Which exact countries are considered part of sub-Saharan

Africa for the APS? See the list of sub-Saharan African countries here:

https://www.state.gov/bureaus-offices/under-secretary-for-political-affairs/bureau-of-african-affairs

No countries on this list are excluded from consideration. Any relevant foreign assistance restrictions will be assessed within the context of a specific SOI.

21. Does this funding proposal seek primarily to support actual investments, or is it also open to organizations that would facilitate investment? Both.

22. Can grant funds be applied as a direct investment into our venture capital fund, or is the program limited to funding specific project activities? Award funds under this APS must be tied to specific project activities and outcomes.

23. Does the Department envisage measures to ease travel between the U.S. and the region — for example visa exemptions or facilitated entry for African business leaders travelling to meet U.S.

investors, alongside a relaxation of U.S. travel guidance for certain jurisdictions? Applicants should not assume such measures for this program.

https://www.whitehouse.gov/wp-content/uploads/2025/12/2025-National-Security-Strategy.pdf https://www.whitehouse.gov/wp-content/uploads/2025/12/2025-National-Security-Strategy.pdf https://www.state.gov/agency-strategic-plan https://www.state.gov/bureaus-offices/under-secretary-for-political-affairs/bureau-of-african-affairs

D. Application Contents and Format

22. What is the total page limit for the SOI, and what does it include? Four pages total: a 1-page cover/critical-details table, a 2-page narrative, and a 1-page summary budget. No annexes, letters of support, or supplemental attachments are permitted at the SOI stage — they will not be reviewed.

23. At the SOI stage, what evidence and documentation do the Department require for elements such as: mineral access and rights, U.S. business participation, valuation of non-USG resources, partner commitments, host government authorizations, projected commercial returns, etc.? Can we include other annexes with our SOI, such as graphs and charts? Do not submit any annexes at the SOI stage. More information will be reviewed at the full proposal stage.

24. Do partners/subrecipients need to be fully identified and committed at the SOI stage? No. Partner roles may be tentative, though SOIs with more named / confirmed partners may score more favorably.

25. What is the basis for calculating the "Total Federal Share Requested" percentage in the cover table? The percentage should be calculated against the total of the Federal Share (USG resources) plus any estimated non-Federal Share (non-USG resources such as cost share or leverage).

26. Should the SOI budget reflect the U.S. government share only, or total project cost? If the budget table is not conducive to explaining non-U.S. government resources, explain them in a note or elsewhere in the SOI.

27. How do you calculate mobilization of non-US Government resources? Do the resources need to be mobilized only because of the funding from the award, directly for the same purpose as the award or broadly spent on the same project? Non-USG resources need not be directly managed by the applicant or newly mobilized for a project due to the grant, though they could be. Explain the total cost of a project and demonstrate that U.S. government resources are not the only resources supporting the project. Resources should be directly related to the project being proposed rather than broad investments in a related sector.

28. How should indirect costs be handled without a Negotiated Indirect Cost Rate Agreement

(NICRA)? Not-for-profits without a NICRA may elect the de minimis rate (currently up to 15%) under

2 CFR 200.414. For-profit entities should use established overhead / general & administrative (G&A) rates, or allocate all costs to direct cost categories if no such rate exists.

29. Does the Department have a preferred percentage allocation between technical assistance, personnel, sub-awards, transaction support and programme management? No.

30. Given the one-page limit on the cover table, may applicants summarize project stages/spend plan there and provide more detail in the narrative? Yes, applicants may summarize stage-level information in the cover table and elaborate further in the two-page narrative.

31. How does the Department define "stages" for purposes of the required spend plan? Applicants should propose stages that are logical for their SOI — these can be annual periods or based on programmatic phases/milestones.

32. What is meant by "partners" in the Table Listing of Critical Details? "Partners" includes but is not limited to subrecipients — applicants should list any type of partner considered important to the project

(e.g., private-sector partners), to the extent feasible within space limits.

33. At the SOI stage, should applicants name specific U.S. commercial partners, or is it sufficient to describe categories of intended partners? Applicants should list specific proposed partners where possible, indicating whether their participation is confirmed.

34. Are applicants required to provide quantitative targets for performance indicators at the SOI stage? Yes, provide tentative targets. They can be refined in a full proposal.

35. What font size is acceptable for tables, charts, and figures in the SOI, given page limits? 10-point

Times New Roman is acceptable for tables/figures, except for the Table Listing of Critical Details, which must use 12-point font.

E. Submission Requirements and Deadlines

26. Is it advantageous to submit a Statement of Interest earlier in a window rather than later? No.

SOIs are reviewed only after the relevant window closes, regardless of submission date within that window.

27. Are UEI/SAM.gov registrations required at the SOI stage? No. Full SAM.gov registration is required of the prime applicant before award; UEIs are required for subrecipients before grants officer approval (not for subcontractors or unfunded partners).

28. Where can I get help and forms for applying? See the APS and this Q&A for full information, by searching for “DFOP0019410,” on www.grants.gov. There are no application forms at the SOI stage.

29. Can an unsuccessful SOI be resubmitted in a later window? No — the same or a highly similar concept cannot be resubmitted; applicants should propose materially different concepts.

30. The Grants.gov listing identifies May 27, 2027 as the opportunity closing date, while the

Annual Program Statement lists May 31, 2027 as the Window 4 application deadline. Which date controls? This has been corrected to May 31. However, note that future windows are not guaranteed.

APS Section E 5.v, Prohibition of Unmanned Aircraft System (UAS)

31. Would the UAS restrictions apply to my organization or the specific activities we are proposing? See UAS detailed guidance here: https://www.state.gov/wp-content/uploads/2026/05/UAS-NOFO-Guidance-current.pdf.

32. What UAS information must be included at the SOI stage, as opposed to the full-proposal stage? This information described in the UAS detailed guidance is required at the full proposal stage only.

APS Section E.5.vi Promoting Human Flourishing in Foreign Assistance (PHFFA)

33.

• How do the PHFFA requirements apply to my organization?

• How do they apply to our proposed subrecipients, contractors, unfunded partners, and our proposed activities?

https://www.state.gov/wp-content/uploads/2026/05/UAS-NOFO-Guidance-current.pdf https://www.state.gov/wp-content/uploads/2026/05/UAS-NOFO-Guidance-current.pdf

• Do they apply to any of our non-USG funded work?

• What monitoring responsibility will we have?

• Can related compliance and training costs be charged to the grant? Could this be charged as direct costs or indirect costs?

The most important way to learn about what the policy requires is to read the PHFFA standard provisions in the three published U.S. Federal Register rules. Each entity type is subject to distinct requirements. In some cases, the policy applies to non-U.S. government funded activities. Please find PHFFA FAQs (including Tables 1 and

2 on applicability and restricted activities) and the related U.S. Federal Register Rules here:

https://www.state.gov/federal-assistance-policies-appeals

34. Are applicants expected to address PHFFA compliance at the SOI stage, or only at full proposal or award stage? Indicate on the cover page whether your organization can accept the PHFFA award requirements.

F. Application Review Information

31. Is profit or fee allowed under a Department grant / cooperative agreement? No — profit/fee is not allowable for prime recipients or subrecipients of any type (including on fixed amount awards). In other words, fee or profit cannot be included in costs in the grant budget. This does not apply to (sub) contractors engaged by the recipient. See also below references to program income and 2 CFR 200.1 and 2 CFR 200.307 on program income.

32. Is cost share required, and how does it relate to the "Leverage" scoring criterion? Formal cost share is not required and is not separately evaluated. However, 20% of the merit score is based on

"Leverage, Burden Sharing, and Partnerships" — defined as cash or in-kind resources that support or sustain the project (not limited to formal cost share).

33. How will concepts spanning multiple countries or overlapping sectors/opportunities be evaluated relative to single-country or non-overlapping concepts? Neither is preferred; each SOI is scored individually against the review criteria, not against competing SOIs.

34. How are foreign policy goals, Department priority needs, and the de-risking/U.S. business participation preferences applied in review, since none appear among the four weighted criteria? — as a threshold gate, as an adjustment to the weighted score, or as a separate recommendation to the selecting official? The Review Criteria have been revised to clarify that these elements are considered under the criterion Quality and Feasibility of Program Idea.

35. How is Organizational Capacity and Experience evaluated, and can subrecipient / staff experience count? Organizational Capacity and Past Experience includes experience of subrecipients. Staff experience can contribute to the extent it is included in a SOI. Experience must be relevant; it need not be U.S. government award experience specifically.

36. If an SOI is selected for co-design or full proposal development, may the lead applicant or intended prime recipient change, with Department concurrence, prior to submission of the full application? With justification and Department concurrence it may be possible at the full proposal stage https://www.state.gov/federal-assistance-policies-appeals for an organization originally proposed as a subrecipient to instead be the prime applicant or vice versa if the subrecipient has needed the expertise in its stated field, demonstrated success with projects of a similar nature, and relevant country level expertise.

37. How can applicants demonstrate commitment to US supply chain and commercial goals? Is any specific documentation needed? No documentation beyond the 4-page SOI is needed at the SOI stage.

Applicants can demonstrate this through submitting a concept that is responsive to the APS.

38. What determines whether an SOI is routed to consultative program design versus directly to a full application? SOIs are recommended for consultative program design if the Bureau assesses that further

Department–applicant collaboration could help refine the concept before submission of a full proposal.

39. Are costs associated with participating in consultative program design allowable as pre-award costs? No. These are considered proposal costs (see 2 CFR 200.460 for nonprofits; FAR 31.205-18 for for-profits) and are not allowable as pre-award costs. Virtual meetings can be considered where in-person participation is cost-prohibitive.

Section F.2 Indirect Costs (tie-breaking mechanism)

40. In a tie-breaking scenario, how will an applicant with a NICRA be compared to an organization that claims the de minimis rate in 2 CFR 200.414 or to a for-profit with its own established non-

NICRA rates? How will it apply if one organization allocates all costs directly? Can an organization claim less than its official rates? When two different types of rates are in the tie-breaking scenario, the lower rate prevails. If one organization allocates all costs directly, the tie-breaking scenario is not applicable. An organization can claim lower than its official rates if doing so is otherwise in accordance with applicable cost principles. For this APS, the Department would apply the tie-breaking scenario (if applicable) at the full proposal stage rather than the SOI stage.

APS Section G – Award Notices

41. Are the payment methods in the APS relevant to subs or just primes? Prime recipients.

Subrecipients or subcontractors would receive payment from the prime, not from the Department.

42. Is a non-disclosure mechanism available for more detailed technical submissions at the full-proposal stage? Reviewers for SOIs and full proposals sign non disclosure agreements.

APS Section H - Post-Award Requirements and Administration

43. If a for profit entity were to participate solely as a contractor, would the audit, monitoring, and compliance requirements under 2 CFR Part 200 applicable to recipients and subrecipients still apply? If a for profit entity participates as a contractor / vendor to a prime recipient of a grant or cooperative agreement, only those requirements in 2 CFR 200 that apply to contractors would apply to

it. For example, see 2 CFR 200.501(h) Audit Requirements - Compliance responsibility for contractors;

and 2 CFR 200 Appendix 2 - Contract Provisions for Non-Federal Entity Contracts Under Federal

Awards.

44. Would 2 CFR 200 program income rules apply to revenue directly generated by award-funded activities or infrastructure during or after the period of performance? Can the applicant propose the program income method (e.g. adding it back to the grant to increase the project budget). The 2

CFR 200 program income rules generally apply during the award period, unless the Department and

Recipient negotiate and include continuing responsibilities in the award terms.

45. Are there source, origin, or nationality restrictions on procurements beyond any requirements in 2

CFR 200? No.

46. What property, title, data-rights, and disposition requirements apply to equipment, data, and intellectual property developed or purchased under an award? Property standards in 2 CFR

200.310–200.316 apply to awards issued under this APS, including the intangible property standards at 2

CFR 200.315 (governing data, data rights, and IP) and equipment title/disposition rules at 2 CFR

200.313. Property right questions can be assessed in more detail for concepts that advance.

47. What are the Department's expectations for public accessibility versus proprietary protection of data generated under an award? Property standards in 2 CFR 200.315 apply. Applicants should propose what data (if any) would be made publicly available versus retained, along with plans for sustaining any grant-funded systems using non-USG resources after the award ends. This can be proposed at the full proposal stage.

48. Does the Department's Single Audit threshold ($750,000 in federal expenditures per fiscal year) apply per subrecipient, or only in aggregate at the prime recipient level?

See the current Department of State Standard Term and Conditions for federal assistance awards for details on the audit threshold—currently $1,000,000 in Department funds in a single fiscal year—that is applied to prime recipients and flowed down to subrecipients.

https://www.state.gov/wp-content/uploads/2026/02/Final-FY26-Standard-Terms-and-Conditions-for-Federal-

Awards-FINAL-HRC1259439-Accessible-2.6.pdf

49. If an application is approved, is the recipient required to maintain a U.S. bank account to receive the award funds? No.

https://www.state.gov/wp-content/uploads/2026/02/Final-FY26-Standard-Terms-and-Conditions-for-Federal-Awards-FINAL-HRC1259439-Accessible-2.6.pdf https://www.state.gov/wp-content/uploads/2026/02/Final-FY26-Standard-Terms-and-Conditions-for-Federal-Awards-FINAL-HRC1259439-Accessible-2.6.pdf

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