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Can a State agency be a sub-recipient or vendor of another State agency in relation to Section 1512 reporting?

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Can a State agency be a sub-recipient or vendor of another State agency in relation to Section 1512 reporting?

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A. The general rule is no. If the State distributes funding to entities that are not State agencies, these funds would be reported as sub-recipients or vendors. Under this approach, movement of money between State agencies would not be separately reported into FederalReporting.gov. As the State awards monies to non-State entities, either as a sub-recipient or vendor, the additional reporting requirements would become applicable and direct recipients to visit the Federal agency websites for more information. However, several Federal agencies have identified exceptions to this general rule. Those Federal agencies have published additional guidance on these exceptions on their respective websites. OMB will compile a list of exceptions and publish this list to assist recipient reporting.

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