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Do regulatory exceptions, waivers and other forms of COVID-19 related relief for EPA grants to pass-through entities (also known as “prime recipients”) extend to their subrecipients?

Generally, yes.  As provided at 2 CFR 200.331 and EPA’s National Term and Condition for Subawards (PDF), pass-through entities “flow down” requirements that apply to their assistance agreement with EPA through the terms of subawards.  However, there may be situations in which for legal or policy reasons an Authorized EPA Official may limit the “flow down” of regulatory exceptions, waivers or other forms of COVID-19 related relief to the “prime recipient” or certain types of subrecipients. 

Return to Frequent Questions about Grants and Coronavirus (COVID-19).