Sneak Preview: USAID Proposes To Rescind PVO Registrations

(The following was excerpted from a recent article in the Federal Grant Development Handbook.) The U.S. Agency for International Development (USAID) recently proposed to rescind its registration requirement for private voluntary organizations (PVOs) that receive foreign assistance funding under a few specific programs. USAID explained that it sought to rescind the rule for these programs because the registration process is not needed for most other USAID programs open to PVOs.

Currently, regulations at 22 C.F.R. Part 203 require PVOs that apply for USAID’s Limited Excess Property Program and Ocean Freight Reimbursement Program, and to other agencies that provide foreign assistance under Section 607(a) of the Foreign Assistance Act (Pub. L. 87-195) to complete and submit to USAID a self-certification form indicating that the organization meets the conditions to register as a PVO. On the form, a PVO must confirm whether it is registered as a U.S.-based organization or an international PVO, and the form must be signed by an authorized representative of the applicant organization.

“Foreign assistance circumstances have evolved since the establishment of the PVO registration process, and a careful review of USAID’s business practices has concluded that there is no longer a need for the current, time-consuming and costly agencywide process,” USAID stated in the Feb. 12 Federal Register proposed rule. “The 22 C.F.R. Part 203 due diligence process for PVO registration is duplicative. In addition, PVOs invest a substantial amount of time and money to obtain and maintain registration.”

USAID anticipates that rescinding the rule could significantly reduce the burden on applicants and could save USAID an estimated $779,000 annually, while allowing the PVO community to save between $2 million to $11.2 million per year.

The regulations at 22 C.F.R. §203(1)(a) state that USAID registers PVOs to: (1) meet statutory and regulatory requirements that a U.S. PVO be registered with USAID as a condition for funding; and (2) provide USAID with information for computing the amount of funding made available to PVOs. USAID said that the registration process is no longer needed because it now examines all potential partner organizations and PVOs through a pre-award assessment in accordance with agency policy (i.e., ADS 303: Grants and Cooperative Agreements to Non-Governmental Organizations) and as required by §200.205 of the uniform guidance.

(The full version of this story has now been made available to all for a limited time here.)

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