Resources for Implementing Partners

From whom do you seek approval for a change in key personnel under an assistance award?

1. First things first. Did you identify this role as "key" in your proposed staffing mix?
- No. If the position is not identified as "key," USAID should not be involved in any changes and you should not seek approval.

2. Yes. Is the award a cooperative agreement?
- No. Under grants, the authority to approve key personnel resides with the AO. You need to request written approval from the AO with an explanation for the change.

3. Yes. Is the approval of key personnel in the AOR substantial involvement provisions of the cooperative agreement?
- No. If not explicitly delegated to the AOR in the substantial involvement provisions, it is the responsibility of the AO to approve a change in key personnel. You need to request written approval from the AO with an explanation for the change.

4. Yes. You need to request written approval from the AOR with an explanation for the change.

Key Points to Remember

• In your explanation, the recipient must explain why the change in staff is needed as well as how the proposed new individual is qualified for the role.
• USAID should not be specifying staffing patterns, key personnel or their qualifications in the RFA/APS or award.
• Short of strict requirements that are included in the award (which are really not supposed to be there), USAID should be deferring to the recipient's judgement.
• USAID should not be involved in the recipient's hiring/selection process. When USAID intervenes in the hiring/selection process for staff, the responsibility for performance shifts from the recipient to the USG.

The requirement for approval of key personnel comes from the following regulation:

2 CFR 200.308 Revision of budget and program plans

c) For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for one or more of the following program or budget-related reasons:
(2) Change in a key person specified in the application or Federal award.

Developed by USAID/India’s Regional Financial Management Office and Regional Office of Acquisition and Assistance and the Central and South Asia Acquisition and Assistance Innovation Lab in support of Local Capacity Building.