MDCP Cooperator Tools

Financial Assistance Management Resources for Cooperators

A. Contact

General Questions

• For questions about particular events in your project work, contact your ITA-MDCP team leader.
• For larger questions about policy and process, contact the MDCP team.
• Other contacts specific to financial assistance management are set forth below.

For questions about eRA Commons

• Access eRA, including login and services desk info at www.era.nih.gov.

Drawing down advances or reimbursements from your MDCP award via ASAP

• First, try the ASAP help desk.
• Second recourse is contact the MDCP team.

B. All Other Financial Assistance Management Questions

• ITA does not have primary responsibility for most financial assistance management issues, but we are happy to help if you are having trouble. Contact the MDCP team.

C. General Federal Regulations 

• Standard Terms and Conditions of Department of Commerce Awards 2015-
• 2 C.F.R. Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

Performance Progress Reports (PPRs)

See the description of the three parts of the quarterly reports in the table below. Can’t find the report templates we gave you at orientation? Ask any member of your federal MDCP support team or request them directly from the MDCP Team.

Once completed, email the Excel version of your reports to the MDCP Team, save also as pdf, and submit the pdf in eRA. Due 60 days after March 31, June 30, September 30, and December 31.

Final Performance Report

The final report is due 90 days after the award period ends. There is no prescribed form but please limit it to two pages. There is no need to include the detailed information submitted over the course of the project period. Focus on trends, accomplishments, highlights, how ITA can do better, and what you might do differently. 

Need Help with eRA?

ERA Commons is your portal for submitting reports. The eRA helpdesk at 866-504-9552.

Use of ITA Emblem and CS Logo

Each cooperator must acknowledge its MDCP partnership by using the ITA emblem. ITA encourages each cooperator to also include the Commercial Service (CS) logo in its acknowledgment. Follow the steps below.

1. Get image files

ITA has several different image files you can use. Request them from the MDCP Team.

2. Integrate ITA emblem & CS logo into your graphic

Create a draft of the graphic you intend to use in conjunction with MDCP project activity. Include the ITA emblem and CS logo within these parameters:

a. The ITA emblem and CS logo should be the same size.

b. Use a CS logo image file that includes the circled R symbol denoting registered trademark.

3. Email your draft graphic to your ITA team lead and MDCP director

a. Your team lead and the MDCP director will respond about permission to use the ITA emblem.

b. A CS member of your ITA team will respond about permission to use the CS logo.

Success Agreements

Most MDCP projects include events in which U.S. companies that seek to export participate. When recruiting firms for such events, a cooperator should use a successful agreement. Use the table below as a guide for drafting a successful agreement. Each U.S. company participating in MDCP export development activity should sign a success agreement as a condition of participating in project activity. An example success agreement is included in a mock application. Find it at on the Application Worksheets page, Part B: Budget, Section 3, MDCP App Other Attachments. Contact us at mdcp@trade.gov if you have questions.

Fiscal Year Operating Plan

Each August during the award period, the project team formulates an operating plan based on the work plan submitted in the application. The plan identifies:

• Work items: Events and/or significant ongoing undertakings
• Projected dates
• Team responsibilities, and
• Rough cost estimates for each work item during October through September.

Applicants do not submit fiscal year operating plans in their applications. These are developed only after receipt of an award and designation of the project team. Contact the MDCP Team to request an example operating plan to use as a template. Or ask your ITA-MDCP team lead.

1. By Aug. 10: COOPERATOR provides a ROUGH estimate of the value of major work plan activities  
   • List 3-10 most significant work items planned for the federal fiscal year.

   • Very rough estimate of the total value of the MDCP project budget to be devoted to each item.

     Approximate the portion of the total MDCP project budget (award, cash match, in-kind match, and indirect costs) that will be devoted to each item. These NEED NOT TRACE to cooperator’s detailed project budget. The rough estimate is NOT used by or submitted to the Grants Management Division. ITA needs cooperator’s rough estimate to measure the magnitude of cooperator effort against internal ITA requests for support “admin” funds.

     Cooperators should not overwork this rough estimate. It need NOT reconcile to financial reports. Depending on the size of the project budget, rounding to the nearest $5,000 or $10,000 is probably accurate enough.

2. By Aug. 24: FEDERAL TEAM estimates cost of its participation which may include:
   • Travel cost of any federal team member to participate in cooperator project activity
   • Cost of other research, trade press subscriptions, etc. needed to support the project.
3. Federal team does not include cost of Gold Key or other CS products.
   • One exception: Market research report commissioned by CS.
4. ​​​​Federal team maintains principle of mutual benefit  

• The administrative funds that pay for resources for the ITA team to support project activities and undertakings may be used only to pay the cost of resources that benefit both the cooperator’s project and the ITA-led federal team.
• The ITA MDCP team leader submits the plan to the MDCP Director by September 6. The MDCP Director considers the competing needs of all active cooperator projects and recommends an allocation of administrative funds to be used by each ITA MDCP team.    

Specific Award Conditions

Each MDCP award is subject to Standard Terms and Conditions. These are “standard” because they apply generally to all grants and cooperative agreements made by the Department of Commerce. They are part of the award package summarized on form CD-450, available to a cooperator on Grants Online. By contrast, Specific Award Conditions (SACs) are stipulations that are not standard for recipients of Department of Commerce financial assistance awards. SACs may be specific to all MDCP awards but may also be specific to just one particular MDCP award.

SACs often require that the award recipient (cooperator) certify that the SAC has been satisfied. Do this in eRA.

If you need help, see Financial Assistance Management Resources.

Fly America Act Waiver Requests

For travel that is funded by the federal share (your MDCP award) or the non-federal share (match) of the project budget, you must comply with the provisions of the Fly America Act. When this is not possible or practicable, you can request a waiver through eRA. Before you do so, first contact the MDCP Team. Refer to the summary of allowable waiver reasons below. 

“Excessive Cash on Hand” Message from GrantsOnline

Reason 1. for Receiving Message: Award Advance Remainder After 30 Days

As an award recipient, if you receive your MDCP award funds as an advance, you must spend such funds and claim the federal and non-federal share in eRA within 30 days. If you ever have over $5,000 of federal award funds after 30 days, eRA will send you this message to remind you that this is not permitted. This rule prevents recipients of federal financial assistance from earning substantial interest on federal award dollars.

If this accurately describes your situation, contact the MDCP Team to learn what action to take. It will probably include providing a written explanation on line 12 of your quarterly financial report.

Reason 2. for Receiving Message: Slow Draw-Down of Award Funds

Even if you draw down your award funds by reimbursement rather than by advance, you still may receive an “excessive cash on hand” message. eRA automatically checks to see how long it has been since the end of the last quarter that you have requested reimbursement for project activity expenses. If it has been more than several weeks, eRA will generate an “excessive cash on hand” message about your MDCP project should always be directed first to your ITA-MDCP team leader.

In such case, you can address the situation by emailing an explanation to the grants specialist and copying the MDCP director, who acts as the federal program officer. One or a combination of explanations below are likely to suffice for most MDCP projects. “Our draw-down of award funds has been delayed because…”

• The [name of event] listed in our work plan was postponed
• A staffing change temporarily interrupted personnel expense that we planned to charge as we had anticipated in our project budget
• A change in contractor temporarily interrupted contractual expense that we planned to charge as we had anticipated in our project budget
• The ITA-approved MDCP project work plan includes periods of time like the one at issue during which project expenses are too low to warrant a request for reimbursement or advance
• ITA has agreed that it would be better to participate in the [name of recurring event] during the next cycle [year, quarter, etc.] rather than the current cycle

A less timely alternative than the email suggested above will be to include an explanation such as one or more of those listed above on line 12 of your quarterly financial report.

Claim indirect costs as part of your required match 

As an applicant, for every dollar of MDCP financial assistance, you must put up one dollar. But you can claim indirect costs as part of this required match. And you do not need an approved indirect cost rate to do it. Every applicant claims the same 10% of their direct costs. See the table for an example.

How to include indirect costs in an MDCP project budget

First, calculate direct costs. Then apply the indirect cost rate to the total direct costs. Take the amount that results and include it as part of the cash match. See the example below. When you are ready to create an MDCP application for funding, contact the MDCP Team for an electronic spreadsheet to use to create a more detailed indirect cost allocation suitable for including in your application budget.

*Review a more detailed example of match requirements and indirect cost calculations, go to our Application Worksheets page, scroll down, and select Part B: Budget.

ITA policy on MDCP project indirect costs 

The indirect cost rate is the ratio, expressed as a percentage, of an organization’s total indirect costs (numerator) to its direct cost base (denominator). ITA has an agency approved 10 percent indirect cost rate for MDCP awards. This rate is the same percent as the de minimis rate discussed in 2 C.F.R. §200.414. The 10 percent rate is used by all MDCP award recipients even if they have a negotiated indirect cost rate with the Department of Commerce or any other cognizant agency. Indirect costs constitute part of the cash match. Indirect costs are included in the budget by multiplying the 10 percent indirect cost rate by the total direct costs of the project. 

Match (non-federal share): Cash v in-kind

Each MDCP award dollar (federal share) must be matched on a 1-to-1 basis. (Note: For MDCP awards made from 1993 through 2022, the match requirement was 2-to-1. This means that cooperators that received their award in 2022 or before will continue to use the 2-to-1 match. The example below is for a 1:1 match.)

The applicant must put up a match equal to or greater than the federal award amount.  the first dollar of the match. Of this match, an amount equal to at least half of the federal award amount must be cash. The balance of the match may include additional cash or in-kind contribution by the applicant. It may also include contributions by other organizations. All contributions for entities other than the award recipient are considered to be in-kind. 

See the table below for an example.

*Review a more detailed example of match requirements and indirect cost calculations, go to our Mock Application (example) scroll down, and select Project Budget.

Need a source of cash match? Claim program income if there is value added.

Program income expended on project activity may be counted as cash match if it represents value added by the cooperator for project activity. For example, a cooperator could claim as program income fees paid to it by the prospective exporter for technical seminar participation if these fees are paid in recognition of the value added by the cooperator’s project. In this example, the value could be evident in the technical-seminar participation package that the cooperator creates. This might include organizing pre-seminar training, finding optimal hotel accommodations, securing group airfare, meeting with seminar organizers beforehand, and organizing a reception. Such a cooperator package helps determine project success.

Buy-in by participating U.S. firms

When companies seeking to export pay fees for such a package to the cooperator, they are doing more than getting themselves to a technical seminar; they are agreeing that the project itself has value. Because the cooperator’s package adds value and furthers project goals, the cooperator could charge fees, use the fees to pay for the project package, and claim the fees paid as cash match. Payment by a prospective exporter to a cooperator may only be claimed as program income and cash match if the payment is for a project participation package created by or facilitated by the cooperator.

Cannot count expenses incurred by participating firms

If it is a prospective exporter participating in your project that makes the arrangements, then the cooperator has not added value that the exporter is paying for and the cooperator cannot claim any program income.

Example

This can be illustrated in the example of a prospective exporter that attends a technical seminar as part of a cooperator’s project. If the prospective exporter negotiates amounts for its own arrangements with vendors, pays the total amount to the cooperator, then has the cooperator pay the amount to the vendors, the cooperator has not added value that the exporter is paying for. Except for the final payment to vendors, it is the prospective exporter, not the cooperator that has made all of the arrangements. The prospective exporter’s payment to the cooperator is not in recognition of any value that the cooperator had added with its project. Accordingly, it could not be claimed as program income. When structuring participation packages designed to elicit program income an applicant may include expenses that a prospective exporter might otherwise arrange and pay by itself. Common examples include hotel accommodations and exhibition hall booth rental. By grouping such expenses together, negotiating more favorable group rates, and adding additional activities that a prospective exporter is unlikely to arrange on its own, the cooperator adds value. The prospective exporter’s payment to the cooperator for the full amount of the participation package recognizes this value. Accordingly, it is program income to be counted as cash match.

Example in the table above

The example explained in the paragraph above is detailed and instructive. But the table above includes a more simple example of “cash match if value added” identified as note [e]. 

Per Diem Rates

When formulating an MDCP project budget you need to estimate travel costs. For the airfare portion, just query a reputable travel site, ensuring that you are using U.S. flag carriers. For the per diem rates, you can use your organization’s pre-existing travel policy or you can use the federal GSA rate for domestic travel. For international travel, use the State Department rates. 

Bid Threshold

For contractual expenses you include in your budget, no bids are required for anything less than the $10,000 micro-purchase threshold. For contracts valued at $10,000 to $250,000, you are required to have at least three bids. You do not necessarily have to choose the lowest bid. Ensure that the bidder you choose fulfills your statement of work. You are not required to include your bids in your MDCP project budget or supporting information. Just keep good records in case of an audit.

In-Kind Match: Fair Market Value

When you claim in-kind contribution as part of your required match, ensure that the amount claimed is fair market value. Consider the example of a member of your board who is the CEO of a company and earns $500,000 a year in that capacity. This translates, roughly, to $250 an hour. As part of your MDCP project, this CEO/board member will serve on a panel of experts about how companies in your industry can better compete abroad. If you were to hire a consultant on international business competitiveness, you would pay the market rate of $100 per hour. So, for the CEO/board member’s preparation and presentation time for service on the panel, you would claim $100 per hour, not $250 per hour.

Do you need to amend your project budget? 

Most changes to an MDCP project budget are agreed and approved by the cooperator discussing such changes with the ITA-led federal support team. However, when cumulative transfers between the 8 standard OMB budget categories exceed 10% of the total project budget, you will need to submit a revised budget for approval. The best way to do this is to use the same linked spreadsheets that you used to generate the budget you submitted in your MDCP application. Most applicants use the MDCP budget worksheet Excel file as the basis for their budget worksheets.

Steps for amending a budget that exceeds the 10% threshold

1. Draft a short description of the changes between your originally-approved budget and your revised budget.

2. Show the changes on a worksheet.

3. Summarize the changes on a new form 424A. Note that the mock application generates a 424A that includes columns for “Previous Fed” and “Prev/ Non-Fed”. These columns are where you can record your original budget as presented on the 424A you included in your application.

4. Attach the worksheets & 424A on Grants Online. See below an example of what section 6 of you Form 424A should look like.

Example 1: In a $900,000 total project budget, re-allocating $45,000 from travel to contractual expenses does not trigger need for an amendment request because it is less than 10% of the total.

Example 2, shown above: Continuing on Example 1, later in the same year the same cooperator wants to move $50,000 from other to contractual. This would trigger the need for an amendment request because the cumulative of cross-category re-allocations exceed 10%: $45,000 + $50,000 = $95,000, which exceeds $90,000, 10% of the total budget.

Example 3: In a $900,000 total project budget (fed & non-fed shares together), spending $91,000 on travel to an expo in Hamburg instead of $90,000 for an expo in Munich exceeds 10% of the total budget but does not trigger a need for an amendment because the change remains within one budget category, travel, in this example.

Most cooperators find that they need more time to complete their MDCP project work plan. You can extend up to five years following September 30 of the year you received your MDCP award. Most extensions are requested in chunks of one year at time. 

If your budget going forward does not differ substantially from our original budget, you should not need a new budget for the extended period. Just state you propose to continue with the same budget you have been using. Do be clear that you are requesting a “no-cost” extension.

How to extend:

1. Draft a short one-paragraph explanation. Email it to the MDCP Team. We’ll take a look at it prior to your submitting via eRA Commons.

2. Log on to eRA Commons and submit your request.

3. Once your authorized rep approves the extension request, it goes to the federal program officer (MDCP Director), who recommends final action by the grants officer.

Public Release of Winning Applications & the Freedom of Information Act (FOIA)

ITA may make available publicly “winning” applications. This generally happens in response to requests from entities that wish to see examples of winning applications. Such requests are almost always made informally but may come pursuant to a FOIA request. Whether in response to an informal request or a FOIA request, ITA’s policy with regard to public disclosure of applicant information is the same.

If your application contains information or data that you want to withhold from public disclosure:

a. Bracket [information] to be withheld from public disclosure. Above each affected page or paragraph include header: “LIMITED USE: BUSINESS IDENTIFIABLE INFORMATION (BII) surrounded by brackets [] includes trade secrets, commercial, or financial information.”; and

b. Explain why the information should not be disclosed and mark each affected page to assist ITA in making disclosure determinations.

Based on your bracketing, marking, and explanation, ITA will protect the confidentiality of the content of your application to the maximum extent permitted by law.

If you receive an MDCP award and have claimed BII treatment for any of your application content, you will redact such content to create a public version that we can release upon request.

Based on prior experience, some, but not all MDCP applicants consider the following to be BII:

• Salary and benefits information that identifies specific people.
• The identity of specific companies that indicate their interest in participating in MDCP project activities in the event the application is selected to receive an MDCP financial award.

See frequently asked questions about how a lapse in federal funding affects MDCP project work.