What EPA-required application requirements would exist for the PGs, keeping in mind the desire to eliminate application barriers?

Full Question:

What EPA-required application requirements would exist for the PGs, keeping in mind the desire to eliminate application barriers? For instance, I assume they would need to obtain a UEI but would not need to complete a full SAM.gov registration, per the EPA General Terms and Conditions effective October 1, 2022 or later (Updated 10.27.2022)? 

Answer:

You are correct. You can devise your own application process to make it as efficient as possible, such as not requiring a UEI at the time of the application but after selection. From the Terms and Conditions: 3. Prior to making subawards, ensure that each subrecipient has a “Unique Entity Identifier (UEI).” The UEI is required by 2 CFR Part 25 and 2 CFR 200.332(a)(1). Subrecipients are not required to complete full System for Award Management (SAM) registration to obtain a UEI. Information regarding obtaining a UEI is available at the SAM Internet site and in EPA’s General Term and Condition “System for Award Management and Universal Identifier Requirements” of the pass-through entity’s agreement with the EPA.