McGovern-Dole Q&A Responses 6.4-6.10.pdf

McGovern-Dole FY2026 Notice of Funding Opportunity

Questions and Answers

6/04/26-6/10/26

1. For all standard indicators on the number of people trained (MGD#5, 7, 22, 23 and others), kindly clarify if the annual targets should refer to the actual number trained in each year or the cumulative number of unique individuals trained.

A: Annual targets for all “number of people trained” indicators (such as MGD #5, #7, #22, #23) should reflect the actual number of individuals trained in that specific year, while the life-of-project target should represent the cumulative number of unique individuals trained.

2. Given our NICRA expires prior to the expected award date, we are intending to use the de minimis indirect rate approach as allowed under 2CFR200.414(f) unless USDA would like for us to include NICRA support for a new provisional rate, as the award value would position USDA as our cognizant audit agency. Also note that our current USG funders, as well as our previous cognizant agency (USAID), have not yet reviewed our submission for revision/extension.

Please advise if, given the circumstances, USDA would like for us to submit supporting documentation sufficient for USDA to make a NICRA determination rather than de minimis support?

A: Per the NOFO Section 4.2.g.ii Budget Narrative, if your NICRA expires before the award date, you may elect to use the de minimis indirect cost rate of 15% under 2 CFR 200.414(f), and USDA/FAS allows this option for foreign organizations unless a valid NICRA already exists. The NOFO states that if an applicant includes indirect costs, they must attach their latest NICRA or, if no agreement exists, a description of the basis for the indirect cost calculation. Applicants choosing the de minimis rate must provide a statement of election instead. The NOFO does not require USDA to establish a new NICRA during application review and does not instruct applicants to submit documentation for USDA to determine a provisional rate.

Therefore, given the circumstances described in this question, USDA/FAS would expect the applicant to elect the de minimis rate and provide the required statement, rather than submit NICRA support for a provisional rate. (NOFO p. 31)

3. Section 4.2.f (page 28) Commodity Management, states that applicants should provide “Estimated Arrival to US Port (Month and Year)” for both US-provided and LRP commodities list tables. Can USDA/FAS please confirm that "Estimated Arrival to Destination Country (Month and Year)” should be included for LRP commodities list table?

A: Correct, Section 4.2.f. iv Commodity List of the NOFO requires applicants to list “Estimated Arrival to US Port (Month and Year)” for both U.S.-provided and LRP commodities in the Commodity List table. The NOFO does not require or instruct applicants to provide an estimated arrival date to the destination country for LRP commodities, but applicants may include this column and information for the LRP commodities if the applicant finds it appropriate.

4. USDA provided a response in the 5/28 - 6/3 Q&A posting regarding commodity prices that directed applicants to the AMS International Commodity Procurement Information page for estimates. While this is a helpful resource, the price of commodities used by Applicants https://www.ecfr.gov/current/title-2/section-200.414 significantly impacts their budgets for all other aspects in the proposal design. Not having a universal commodity price list for all Applicants can create unintentional biases depending on which pricing is used. Can USDA please provide all applicants with a common list of commodity prices for the purpose of the proposals? During the award negotiation phase, commodity and transportation prices are typically adjusted by USDA based on most recent market price information, so this should have no impact on submissions. This would help ensure that all applicants are evaluated on an equal basis.

A: USDA’s Agricultural Marketing Service (AMS) does not maintain a single “universal” commodity price list for McGovern-Dole proposal budgeting; instead, USDA directs all applicants to its International Commodity Procurement Reports, which provide quarterly, transaction-level pricing based on actual purchases made through the AMS Procurement Program. To ensure budget transparency and comparability, applicants can extract commodity prices from the latest quarterly report, while also referencing AMS Market News for supplemental market-based prices. Given that this AMS information is available to all applicants, we do not believe that this creates unintentional biases. Section 6 Application Review Information of the NOFO provides clear information on how all applications will be reviewed and this is applied to all applications on an equal basis.

5. We are writing to request direct links to the following standard forms: 1. SF-424 — Signed Application for Federal Assistance, which we understand must include our Unique Entity Identifier (UEI) and bear the authorized signature of the Applicant. 2. SF-424A — Budget Information for Non-Construction Programs, referenced in Appendix F of the NOFO, covering the required budget categorization. Could you please confirm the correct sources or direct links for accessing the current versions of both forms? We want to ensure we are using the USDA/FAS-approved versions and that our submission is fully compliant.

A: The current USDA/FAS-approved versions of both required standard forms—the SF-424 and SF-424A—are available directly from the official Grants.gov Forms Repository.

• The SF-424 (Application for Federal Assistance), can be accessed using the following official link:

https://apply07.grants.gov/apply/forms/readonly/SF424_4_0-V4.0.pdf.

• The SF-424A (Budget Information for Non-Construction Programs), referenced in Appendix F of the FY 2026 McGovern-Dole NOFO for required budget categorization, is available at:

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

6. Given the significant variable in ocean freight rates and transportation costs over recent years, how will USDA evaluate cost realism and cost reasonableness across applications that may utilize differing freight assumptions based on available market data at the time of assumption?

A: Per Section 6.2 Review Criteria of the NOFO, USDA will evaluate applicants on the reasonableness, allowability, and allocability of costs; plus cost-effectiveness and adequacy of the proposed budget, including the applicant’s proposed freight and transportation costs. The NOFO specifically instructs applicants to account for rising commodity and freight rates when developing cost estimates and to provide enough detail for USDA to independently determine that proposed costs are realistic and appropriate for the project. Because USDA also adjusts commodity and freight costs during post-selection award negotiations based on the most current market data, differences in applicants’ https://www.ams.usda.gov/reports/international-commodity-procurement-information https://www.ams.usda.gov/reports/international-commodity-procurement-information https://apply07.grants.gov/apply/forms/readonly/SF424_4_0-V4.0.pdf https://apply07.grants.gov/apply/forms/readonly/SF424A-V1.0.pdf initial freight assumptions will not disadvantage any applicant; instead, USDA evaluates whether assumptions are well-supported, consistent with available market information, and aligned with the cost-effectiveness standards outlined in Section 4.2.g and the Budget Review Criteria.

7. Does an applicant organization need 501(c)(3) status in the U.S. to receive and transfer funds, or are there alternative mechanisms for internationally based nonprofits?

A: An applicant does not need 501(c)(3) status unless it is a U.S.-based nonprofit. Foreign organizations are fully eligible without U.S. tax-exempt status as long as they complete SAM.gov registration, obtain a UEI and NCAGE code, and comply with USDA/FAS terms for foreign organizations. These requirements are detailed in Section 2.1 Eligible Applicants (page 7) and Section 9.3 SAM.gov Registration Instructions (page 46) of the FY 2026 McGovern-Dole NOFO.

8. Our understanding is that there are no eligibility restrictions or US government rules or regulations that would prevent an applicant from proposing an intergovernmental organization such as UNICEF as a subrecipient. Could you please confirm our understanding is correct?

A: Correct. Section 2.1 Eligible Applicants of the NOFO includes intergovernmental organizations, such as UNICEF, among eligible applicants and subrecipients.