Can past performance/environmental results include work where a grantee was not the direct recipient of the funds?
No. While subgrants are not relevant to past performance, an applicant could explain how the substantive work under a subgrant relates to programmatic capability. The applicant must be the direct recipient of the federal funding for the work to qualify under the past performance/environmental results criterion. Work they may have done as a subgrantee to another recipient under a federal grant does not qualify since their relationship is with the recipient not the federal agency. As the clause indicates, you should provide past performance information for assistance agreements that you had with EPA or other federal agencies and this does not include subgrants that you may have received from a non-federal entity under a federal grant.
