Public Health Crisis Notice of Funding Opportunity (TP18-1802)

Questions and Answers

Eligibility

Am I eligible for the Crisis NOFO?
Eligible applicants include the 50 states; five U.S. territories; three freely associated Pacific islands; six localities: Chicago, Houston, Los Angeles County, New York City, Philadelphia, and Washington, D.C.; and federally recognized tribal governments that meet the NOFO requirements and serve, through their own public health infrastructures, at least 50,000 people.

Eligible applicants must certify the following are in place:

  • Functional governmental public health department
  • Public health emergency preparedness program/public health emergency management program
  • Demonstrated prior ability to successfully manage HHS federal grant funds
  • Expedited administrative processes
  • Letter of concurrence from the state (for eligible local public health applicants)

How is the Crisis Response NOFO competitive if there are no funds being provided?

It is competitive because virtually all CDC grants and cooperative agreements are intended to have full and open competition. This NOFO is limited to health departments; within that group all applications will be objectively reviewed and scored. But actual funding decisions will be based on the nature of the emergency and the funding that is available. CDC may fund out of rank order depending on the scenario.


The NOFO states it will fund “up to five tribes” that “serve at least 50,000 people.” What exactly does that mean?  Does this mean a tribal population of 50,000?  Or, there are 50,000 members living on a reservation that will be served? And what is meant by “serve”? 

This includes American Indian or Alaska Native federally recognized tribal governments or their bona fide agents that meet requirements listed in Section C.3 of this NOFO for Justification for Less than Maximum Competition. Those that serve, through their own public health (PH) infrastructure, at least 50,000 people (N~5) are eligible. CDC estimates that up to five tribes may be eligible, but any tribe meeting the requirements may apply.

This NOFO is not a capacity-building mechanism; it is not intended to create or establish new public health emergency management programs. It is designed to support the surge needs of existing programs responding to a significant public health emergency. CDC will provide supplemental guidance to pre-approved health departments on the approved but unfunded (ABU) list as to when this NOFO will be activated and for specified activities intended to address the emergency. Applications seeking to create new public health departments or public health emergency management programs will be deemed nonresponsive and will not be considered.

Applicants will need to be capable of activating new or surging current emergency response activities within a two-day period.

Acceptable documentation includes but is not limited to:

  • A letter signed by the director of public health on departmental letterhead attesting to the existing capacity and capability for rapid procurement, hiring, and contracting;
  • A departmental organizational chart; and
  • An incident management structure organizational chart.

What is the criteria for the definition of tribal governments servicing 50,000 people?

CDC would use the tribal government’s criteria, but they would need to have to have an existing health system serving that amount of people. It isn’t tied directly to a tribe’s census.


Page 5 of the NOFO states, “The purpose is to ensure rapid mobilization and response to public health emergencies, focused on threatened or impacted jurisdictions.” Due to the public health impact the evacuation of Puerto Rican Americans will have on our jurisdiction, CDPH will be conducting activities that may include (but are not limited to) coordinating the Healthcare Enterprise at a MARC, inspections at shelters, epi/surveillance at shelters, mobilizing volunteers, etc. These activities all touch upon the many of the PHEP capabilities. Therefore, would an event such as our response to evacuees from Puerto Rico satisfy the requirements of the Public Health Crisis Response application?

No. This is not a fund just to help out for every event, but for really catastrophic or high impact events to public health that reaches the level of a secretarial declaration (or similar) and for which federal funding has been identified. We built a specific scenario to have consistent applications and reviews. If funding were to be available for hurricanes in the future, they could revise their budget and work plan at that time.

General Information (deadlines, how to submit info, etc.)

What is the purpose of the Public Health Crisis NOFO?

The Public Health Crisis NOFO is a novel approach to emergency response that increases the speed at which CDC can award available funds to state, local, tribal, and territorial public health agencies in the event of a public health emergency.


What is considered an emergency?

If there is a Secretarial declaration and the needs exceed what can be covered with existing funding.  This could also include a CDC EOC Activation.  Much will depend on IF CDC has funding to award.


How do I apply for the Crisis NOFO?
The Public Health Crisis NOFO application package is available on Grants.gov. The application deadline is Monday, December 11.

All applicants must provide certification from their public health director (or equivalent)  that the applicant has an existing capacity, capability, and infrastructure to provide the 10 essential public health services (https://www.cdc.gov/nphpsp/essentialservices.html)  and that within that public health infrastructure there currently exists an established public health emergency management program that meets the requirements outlined in CDC’s 15 Public Health Preparedness Capabilities: National Standards for State and Local Planning (https://www.cdc.gov/cpr/readiness/00_docs/DSLR_capabilities_July.pdf).

In addition, applicants must submit: (1) an organizational chart that represents their emergency preparedness program or Incident Command System (ICS), and (2) a crisis response plan/concept of operations that includes a provision outlining expedited business processes, including but not limited to, rapidly hiring surge staff, contracting, procuring, and travel procedures.


Are applications only required to be submitted on grants.gov?

Yes.


Will the notice of award number be the same as the current preparedness cooperative agreement number?

No. It will be a separate award number.


Does a one-year cycle imply that this will be an annual application?

It is open/continuous so if we needed to put it out again, we may open it up and receive new applications. We could potentially have 16 months of activities covered. Once the emergency has been mitigated, we would then move awardees to other mechanisms within CDC.


Does the award period begin when Part A is awarded?

Yes.


If we go a full year with no events (December – December) will we need a new application?

Yes.


Can an application be written around ongoing hurricane activities?

No. Please respond as asked to the infectious disease scenario.


Are applications due on December 11 at 11:59 p.m. Eastern Time?

Yes, but applicants are encouraged to submit a few days early to avoid IT system glitches or other issues.


What happens if a jurisdiction does not meet the deadline on December 11? Would the application be rejected and not reviewed?

Yes; absent an approved extension by OGS, the application would not be reviewed in this round.


Once all the information is provided in the application, will a jurisdiction need to provide this same information again once an event occurs? We understand that it will help expedite the funds, however, it has never taken that long to get the funds in the past. We are concerned whether it’s worth the work it takes to complete the application if we will just have to do it all over again when an event occurs. So why not wait until the event happens?

In the past it has taken several months to get money out to states; even an application period is usually 60 days. With this mechanism, OGS thinks they can get money to recipients in 10 days or less. At that point we will know more about the actual emergency, so we will ask you to review/revise work plans and budgets to match the new reality. There won’t be any new application; think of it more as a redirection.


The NOFO document referred to a team that would need to work with CDC to support the Part B dollars. Who is this team?

CDC would work with the recipient to determine the activities that need to take place and establish performance measures for them. We don’t anticipate sending people to work alongside you. First-time recipients might have to work with CDC’s Office of Grants Services.


I am writing to inquire about the comparisons between the ELC grant and the NOFO. Should the scenarios and budgets be the same or similar as those for the ELC grant? The intent sounds really similar, and I wanted to just get a little more clarification on how similar the program aspects for these two grants should be.

They can be as similar as needed. Our working assumption is that if an emergency happens and funding comes down, it would more likely come through this NOFO. Unfunded projects in ELC might be used if there is no – or insufficient – funding dedicated to this crisis NOFO. But we’d be careful not to fund the same activities in both.


We have a question regarding the recovery section of the narrative (p. 7): ‘Implementation and execution of actual recovery operations and activities are not covered by this NOFO. The activities under this NOFO are intended for work activities related to an impending or occurring public health emergency. CDC will provide additional supplemental guidance as appropriate at the time this NOFO is to be implemented.’

This section is referring to the difference between response and recovery efforts. So activities covered by this NOFO will be those related to responding to a public health crisis at hand (or imminent), not recovering from a public health crisis. Of course, the line between response and recovery can be difficult to determine, so supplemental guidance based on the incident will be issued when the NOFO is funded for that specific incident. You may include steps to plan for the recovery.


Page 22 outlines Limited Source Competitions, if a local health department is NOT outlined in a bullet point, does this mean that if we have an idea it should be: 1) presented to our state or partner LHD listed? or 2) if we as a LHD receive PHEP funds from the state and are a governmental agency (a LHD not listed under Local health Departments bullet), we can assert that we are a “bona fide agent” of a state?

Option 1 is correct for LHDs not listed. You should work with your state or partner health department listed. A “bona fide fiscal agent” is a legal arrangement with the state. Being a subawardee or partner with the state is not the same thing. Also, bear in mind that this NOFO does not replace the PHEP funding, which is for public health emergency preparedness. This NOFO focuses on the actual response, for which PHEP funding may not normally be used.

Work Plan Strategies and Activities

Can Component A include lab activity?

It could, if you are able to surge in the first 90-120 days. If you have additional needs not listed for an event, CDC could make adjustments.


Could you clarify what you are looking for regarding duplication of efforts?

We are looking at speed and scale. The scenarios we envision are not for routine public health emergencies, but for real “bad” days when resources have been exhausted.


What if there is an emergency that affects one part of the state and then spreads? Would you want to see that tiering?

You should build a budget based on your jurisdiction (the entire state) and past experiences. Once funding is received the state would determine the best allocation of those funds.


Can you explain what activities are not covered by this NOFO?

This is for response only, not capacity building, or long term issues. We do allow for planning for recovery during the response, but not actual recovery activities.


What vector control activities are allowed?

Vector services such as those included in some current ELC awards; it may also include vector surveillance activities.


This application is requiring a complex work plan. What level of detail are you looking for?

In the work plan, include high level, strategic activities that are responsive to the scenario and give reviewers an understanding that there is an existing public health infrastructure.


Could additional domains like biosurveillance or information management be included in the application in addition to the two domains in Component A?

Yes, if the activities would done in the first 90 days, it would be acceptable.


At what point do we consider an activity a response activity (the 90-day mark) rather than preparations?

This mechanism is not for capacity building or development of the preparedness plan. However, the ability to use funds retroactively would be determined at the time of funding availability.


Are we supposed to include subcontracts for existing local county health departments?

If appropriate, yes, but you need to track how funds received from this mechanism are being used.


The NOFO guidance includes the strategy: Strengthen Jurisdictional Recovery. If this is funding only for response, how should we address this strategy?

It allows for the planning for recovery activities stemming from the emergency, however actually implementing or executing recovery activities is not covered.

Budget

Guidance regarding the level of budget detail expected/desired, especially for the personnel budget category, would be useful. Previous Q&As state that applicants should use the SF-424A, but the NOFO also requires a budget narrative, which would contain significantly more detail that the SF-424A (which only contains the budget category totals). It would be helpful to understand what level of detail is expected in that budget narrative. Are templates available?

Applicants should use the SF Form 424-A budget template provided in Grants.gov. The budget justification should include the same level of detail that you as an applicant would include as if this NOFO were to award funding.  For example, for the personnel justification your budget should include the position, the name (or TBD if not known), the salary, percentage of effort and the position description. CDC needs sufficient information to determine the allowability of budgeted costs. The standard OGS justification template is available in the Grants.gov toolbox. CDC has also posted an optional work plan template that may be used to support and develop the work plan and associated budget.


Is there a budget template?

Applicants should use the SF Form 424-A budget template provided in Grants.gov. A budget justification template will also be available at the Grants.gov site.


Is there a $5 million cap, and should we make a total budget for Components A and B for it?

We expect the average award to be 5 million dollars. Applicants should build their budget on past experiences. There is an award ceiling of 5 million dollars, but that may be revised to include a floor instead. The system required entering a dollar amount, however the text says no ceiling and we reserve the right to state a ceiling in the supplemental guidance.


Can you please advise on how to budget between Component A and B for items we need funding for within the first 120 days, but would require funding throughout the 12-month period?; For example, if we need to hire staff, do we budget for the full annual salary in Component A- or just for 120 days in Component A and the remainder in Component B?; Other examples of items we would need within the first 120 days, but would require funding throughout the 12-month period are: Temp workers through contract with staffing agency, Courier service for lab specimens

CDC needs enough information to determine what costs will be included in a Part A award versus Part B. If you hire staff, you should allocate the costs proportionally, because they will be incurred in different periods. Other costs should be based on when something is purchased. If you want to buy 100 ‘things’ but will only use half in the first 120 days, that’s fine because the costs are incurred at one time. The only accounting rule really relates to not buying more than a year’s worth.


Can we budget for hiring contractors to evaluate our emergency response, i.e. conduct hot washes, administer surveys and develop After Action Report/Improvement Plan?

Yes, budgeting for these items is acceptable.


Can we budget for hiring staff/contractors to assist in collection of Performance Measures? Our Office of Emergency Preparedness and Response has a dedicated Evaluation Unit, which collects and submits annual HPP-PHEP Performance Measures; however, these staff would be mobilized to serve in their dedicated ICS roles for an emergency response. It would very difficult for existing staff to collect real-time data for Crisis Response Performance Measures, particularly the Outcome measures.

Yes, budgeting for these items is acceptable.


If a program does not have duplication of effort, is anything required to be uploaded?

Yes, a negative reply is required: applicants submitting this information should address the items outlined under Duplication of Efforts on page 26 of the NOFO:

Duplication of Efforts-Applicants are responsible for reporting if this application will result in programmatic, budgetary, or commitment overlap with another application or award (i.e. grant, cooperative agreement, or contract) submitted to another funding source in the same fiscal year. Programmatic overlap occurs when (1) substantially the same project is proposed in more than one application or is submitted to two or more funding sources for review and funding consideration or (2) a specific objective and the project design for accomplishing the objective are the same or closely related in two or more applications or awards, regardless of the funding source. Budgetary overlap occurs when duplicate or equivalent budgetary items (e.g., equipment, salaries) are requested in an application but already are provided by another source. Commitment overlap occurs when an individual’s time commitment exceeds 100 percent, whether or not salary support is requested in the application. Overlap, whether programmatic, budgetary, or commitment of an individual’s effort greater than 100 percent, is not permitted. Any overlap will be resolved by the CDC with the applicant and the PD/PI prior to award. Report Submission: The applicant must upload the report in Grants.gov under “Other Attachment Forms.” The document should be labeled: “Report on Programmatic, Budgetary, and Commitment Overlap.”

Application Package Details (attachments, clarification of documents, etc.)

The top of the Crisis NOFO application requires the identification of the grant manager. In the past we have used PHEP Director, Principal Investigator (PI), and Business Manager. Who do they mean by grant manager? Is that a staff member in our office that works with the PHEP Director?

Since each jurisdiction is submitting one combined application (including possible PHEP needs, ELC needs, etc.), they should identify the administrator or manager that they want to be the POC. This could be the PHEP director, but would probably best be the business manager who will manage the grant.


Page 28 references that the work plan is included in the project narrative document, but on page 30 we are told to name the work plan and attach it to grants.gov separately. Is the work plan included in the project narrative or is it a separate document?

The work plan is part of the project narrative.  As a reminder, and unless specified in the “H. Other Information” section, the project narrative is a maximum of 20 pages, single-spaced, 12-point font, 1-inch margins, with all pages numbered. This includes the work plan.


Page 45 lists the acceptable attachments that can be uploaded to grants.gov, and states that applicants may not attach documents other than those listed. However, the list does not include all of the documents referenced in the NOFO, such as the Administrative Requirement Capability Letter (Director’s Letter), Org Charts, Indirect Cost Rate; additionally, we would normally attach a signed version of the SF-424. Are we able to attach items not included on this list but referenced in the NOFO?

Please attach all supplemental documents, such as the org chart, SHO letter or indirect cost rate agreement, in the appendices.


Is the Crisis Response Plan/Concept of Operations part of another document (such as the Administrative Requirement Capability Letter (Director’s Letter) or Project Narrative) or is it a stand-alone document that should be attached to grants.gov?

This plan is a separate, stand-alone document that should be attached in the appendices.


Is this mandatory – page 16 of 50 indicates “acceptable documentation” letter signed by the Director of Public Health attesting to the existing capacity and capability for rapid procurement, hiring, and contracting

Yes, this letter is mandatory


Do we actually have to submit 2 work plans when we submit the application? Some interpret the instructions to say submit a Component A work plan with the application and then a Component B work plan at the time of the crisis.

You may submit 1 work plan with two components.


Can you provide clarification in Item I where it says, “For international NOFOs” – are the items listed under that on p. 45 and p. 46 required with this application?

This is template language, however, this is not an international NOFO. The following documents required for the application package include, but are not necessarily limited to:

  • Project Abstract
  • Project Narrative (includes Background, Approach, Applicant Evaluation and Performance Measurement Plan, Organizational Capacity of Applicants to Implement the Approach, and Work Plan (which outlines Components A and B)
  • CDC Assurances and Certifications
  • Report on Programmatic, Budgetary and Commitment Overlap (All applicants are required to indicate if there will be programmatic, budgetary, or commitment overlap: see Question 11 regarding questions about negative responses)
  • Table of Contents for Entire Submission
  • SF424
  • SF424A
  • Budget Narrative
  • Funding Preference Deliverables
  • Letter signed by the Director of Public Health on departmental letterhead attesting to the existing capacity and capability for rapid procurement, hiring, and contracting
  • Existing incident management structure for the department’s public health emergency management
  • Organizational chart reflecting public health department’s make up and placement of the emergency management program

Can you confirm that the work plan template problem statements are limited to 500 words as the instructions state and not 500 characters?

Any reference to a “character” limit in the application should be replaced with “word”. The template should not cut you off (even beyond 500 words) so guidance is to write what you need to respond to the prompt.  However, character limits in attachments (such as the work plan) still apply.

Regarding the page limit for the Crisis Response application package: The page limitation on grants.gov is driven by the Activity Code (AC), in this particular case U90 is the AC for this NOFO. There is no limit set for the number of pages that will be accepted; On page 27 of the NOFO, the project abstract requires a maximum of one page; project narrative requires a maximum of 20 pages to include (background, approach, applicant evaluation and performance measurement plan, organizational capacity of applicants to implement the approach, and work plan); Please see paragraph below from the NOFO: (Unless specified in the “H. Other Information” section, maximum of 20 pages, single-spaced, 12 point font, 1-inch margins, number all pages. This includes the work plan. Content beyond the specified page number will not be reviewed.); The work plan must be included in the 20 pages, this may be why the NOFO indicates only 500 characters, to support each component; The optional section has space to hold well over 2,500 Word document pages and will convert to PDF).

Domain-Specific Questions

For our BP1 PHEP application, the cooperative agreement utilized the following domains, with the capabilities rolling up under them: Domain 1: Community Resilience, Domain 2: Incident Management; Domain 3: Information Management; Domain 4: Countermeasures and Mitigation; Domain 5: Surge Management; Domain 6: Biosurveillance (PHEP only); The Domains in the NOFO work plan template don’t match these – there is one that is completely different, “Strengthen Jurisdictional Recovery” and all are different domain numbers; for instance Biosurveillance in the NOFO is Domain 3 and was Domain 6 in the cooperative agreement. Can you let me know if these are intentional changes? I’m not quite sure what to do with the new domain, Strengthen Jurisdictional Recovery, and what PHEP capabilities roll up into it.

Correct, there are some differences. This NOFO (when funded) will be for public health emergency response efforts while the PHEP cooperative agreement is for preparedness. The difference in domains reflects differences in anticipated jurisdictional activities for responding to rather than preparing for a public health emergency.


Is there a cross walk to indicate how the capabilities roll up under the domains?

No, there is no crosswalk. The PHEP/HPP cooperative agreement and any cooperative agreement that would come from this NOFO are separate and not directly related. Capabilities may be similar as many preparedness priorities and response activities influence each other, but not all capabilities or activities will be the same.

Further, because this is an agency-wide mechanism (not limited to PHEP or ELC, for instance) there is not an exact match with how you may have addressed domains in previous PHEP applications.


What should be included in the domain “Strengthen Surge Management”? Specifically, what kind of examples would fall under the category of “prevent/mitigate injuries and fatalities” on page 9?  We originally thought this could include first responders, but that seems to be listed in Countermeasures (page 8).

For the “prevent/mitigate injuries and fatalities” category, guidance is to focus on the same type of activities that were included the Zika supplemental application.


The example work plan template for Domain 6 lists activities like a tiered hospital/healthcare approach and coordinating with EMS for PUI response. Will this type of activity be allowable under this crisis grant?

As for Domain 6 activities, consider what you would do to support the interface between public health and healthcare, similar to what was done during Ebola (i.e., coordinating with EMS).

Review Process

How are recipients selected?

Review of applications will done on a competitive basis, with applications undergoing a three-phase objective review process. A CDC review panel will evaluate the applications and establish a corresponding “approved but unfunded” (ABU) list of eligible health departments with pre-existing emergency management programs that submit timely applications.


Is this a competitive process?

Yes. Applications will be reviewed and scored. There will be three reviews, and the feedback from these will be compiled and sent in a summary statement to the applicant, similar to past FOAs. However, to be clear, during a specific funded emergency, applications may be funded out of rank order in order to meet the needs of affected jurisdictions.

Coordination with Other Programs or Agencies

Much of this will cross into the medical system; is this being coordinated with HHS/ASPR?

CDC has communicated with ASPR and has built this mechanism specifically for public health emergencies.

Funding

How quickly will I receive funding? What is the decrease from before?

The Public Health Crisis NOFO will enable approved but unfunded (ABU) applicants to quickly receive available preparedness and response funds within the first 10-15 days of an emergency. ABU applicants may be selected for initial response activities only or may be awarded additional crisis-specific funding depending on the public health emergency and the associated needs and jurisdictional impacts.

We cannot control when CDC will get any funds that could be awarded. However, we hope to award funds within 10-14 days.


Where would the money come from?

The money could be from supplemental funds appropriated by Congress, moved from elsewhere within HHS, or the HHS Secretary’s emergency fund (if funded).


If there is a regional event, how would funds be distributed?

CDC will use an algorithm which would be largely based on population and demonstration of need.  It would also be situation dependent (e.g. final round of Zika funding that went to most impacted jurisdictions).

**Note:  CDC’s intent is NOT to redistribute funds from existing programs to the crisis NOFO.


Can this funding be used for biological, chemical, radiological and natural disasters (hurricane, earthquake, flooding, etc.)? These awards are for any emergencies that exceed capacity and for which funding has become available. It could include all hazards.


What if supplemental funding for hurricanes becomes available before this process is finished?
The NOFO will be amended identifying the specific requirement; CDC programs and OGS will complete an accelerated objective review and award schedule. But since there won’t be an ABU on file, it will still have to go through the normal (albeit expedited) review and approval process.


Once we have the ABUs and funding becomes available for an emergency, what is the process for adding funding? How long will it take?

An NOA will be issued for Part A funding based on the funds available as quickly as possible. No additional information would be submitted for that portion. Speed of processing will depend on the funding available, the scope of the emergency, the breadth of the funding authorization, and other factors. It could be anywhere from 10-14 days. Part B will require a revised budget and work plan and is intended to be issued as quickly as possible, but before Part A funding is exhausted.


Can staff from other areas of the health department for whom preparedness activities are not in scope be assigned to these grant funds for emergency response activities for the time period of response (first 120 days and/or 120 + days)?

Yes.


Are you also expecting local jurisdictions within each state to have a mechanism to receive funds? Is this just a state activity?

This is not just a state activity. For example, if Cincinnati has an issue, then Ohio would submit the response on behalf of the city. This is very similar to when applying to Zika or Ebola in that you should account for distribution to local jurisdictions.


Are you not concerned about locals receiving itemized dollars for Components A and B?

CDC will look at the primary awardee. If there are questions, we will work with you to address them. Remember, this mechanism is only for response activities.


Is funding only for emerging infectious diseases?

This is just the application example, but the mechanism can be used for natural disaster, radiological or nuclear event, or any other kind of public health emergency.  Applicants should write to Part A to cover all common needs as this funding will be quicker.

However, depending on the event, Component A could be waived and funding directed straight to Component B.


What if multiple emergencies happen at the same time?

This mechanism, should funding be available, could be used for multiple emergencies.


What if hundreds of thousands of staff are activated. Could funding be used to pay for their overtime?

This would be on a case by case basis, but it could be an allowable expense. However, as overtime is a contingency expense, applicants should not include it in their initial budget.


If the Epidemiology and Laboratory Capacity (ELC) program wanted to fund specific lab issues, could they avail themselves of this mechanism?

Yes, and they are active partners in this.


Are we restricted to our usual partners or could we fund untraditional partners?

This would depend on the specifics of the event.


The mechanism also mentions countermeasures. Are there going to be restrictions on the purchase of pharmaceuticals or what we can do for vector control?

CDC doesn’t see anything that would be out of consideration right now, but it would be on a case-by-case basis.


If the need exists to tap into other federally funded staff, could this mechanism fund their overtime?

Budgets cannot include overtime, because it is considered contingency planning. However, it can include planning scenarios for overtime. Specific approvals for overtime would be considered on a case-by-case basis.


If much of existing staff is funded through PHEP, will we be able to fund this?

You need to account for in your crisis NOFO budget the staff you would pay for using this mechanism. You cannot pay for the same work in two programs, but you can move staff costs from the PHEP cooperative agreement to this award if appropriate.