CDC Cooperative Agreement Compliance

The CDC Compliance Framework

CDC cooperative agreement compliance operates on three layers, each adding requirements on top of the one below. Understanding this layered structure is essential for building a compliance system that addresses all applicable requirements without missing obligations that are buried in program-specific documents.

• Layer 1 — Federal Uniform Guidance: 2 CFR 200, implemented by HHS as 45 CFR Part 75. This covers financial management, procurement, cost principles, audit requirements, and administrative procedures that apply to all HHS awards.
• Layer 2 — CDC Standard Terms and Conditions: Agency-wide requirements that apply to every CDC award, including publication clearance, acknowledgment language, lobbying restrictions, intellectual property provisions, and prior approval requirements.
• Layer 3 — Program-Specific Special Conditions: Requirements unique to the specific NOFO and program area, including data system mandates, evaluation requirements, cross-site participation, and performance benchmarks.

Your Notice of Award (NOA) will reference all applicable terms and conditions. Read the NOA carefully upon receipt — it is the legally binding document that defines your compliance obligations for the budget period.

Substantial Involvement Requirements

The defining feature of a cooperative agreement is "substantial federal involvement" in program activities. Each CDC NOFO describes the specific forms that this involvement will take for that program. While the details vary, common forms of substantial involvement include:

• Work plan review and approval: CDC project officers review annual work plans and may require modifications before approval. This is not a rubber-stamp process — POs actively assess whether proposed activities are evidence-based, feasible, and aligned with national program goals.
• Technical assistance: CDC provides ongoing scientific and programmatic guidance, including site visits, webinars, expert consultations, and access to CDC subject matter experts. Recipients are expected to participate in T/TA activities.
• Progress monitoring: Regular check-ins (monthly or quarterly) between the recipient and CDC project officer to review progress, identify barriers, and adjust activities as needed.
• Cross-site coordination: CDC coordinates activities across all recipients of a program, facilitating peer learning, shared protocols, and standardized data collection. Recipients are expected to participate in grantee meetings, learning communities, and collaborative projects.
• Activity redirection: If program objectives are not being met or if public health priorities shift (e.g., an emerging disease outbreak), CDC may redirect activities within the approved scope. This is a unique feature of cooperative agreements that does not exist in standard grants.

Prior Approval Requirements

Certain actions require written prior approval from the CDC Grants Management Specialist (GMS) before they can be implemented. Taking these actions without prior approval is a compliance violation that can result in disallowed costs or adverse award actions. The most common prior approval triggers under 45 CFR Part 75 and CDC standard terms include:

Always submit prior approval requests well in advance of the planned action. CDC processing times for prior approvals range from 2 to 8 weeks depending on the complexity of the request. Do not assume approval — wait for written confirmation before proceeding.

Financial Management Requirements

CDC cooperative agreements are subject to the full financial management requirements of 45 CFR Part 75, Subpart D (which mirrors 2 CFR 200 Subpart D). Your financial management system must be capable of:

• Fund identification: Tracking receipts and expenditures for each federal award separately, identified by CFDA number, award number, and award year
• Cost category tracking: Recording expenses by budget object class category (personnel, fringe, travel, equipment, supplies, contractual, other, indirect) to support SF-425 reporting and rebudgeting monitoring
• Internal controls: Written policies and procedures for authorization, separation of duties, reconciliation, and documentation of transactions. Internal controls must be documented and operational.
• Cash management: Minimizing time between federal fund draw-down and disbursement. CDC funds are drawn through the HHS Payment Management System (PMS), and recipients must draw funds only to meet immediate cash needs, not to maintain advance balances.
• Records retention: Maintaining financial records, supporting documents, and statistical records for 3 years after submission of the final expenditure report (or longer if audit findings are unresolved)

Procurement Standards

Recipients must follow procurement standards consistent with 45 CFR 75.327–75.335 when purchasing goods and services with CDC funds. These standards require:

• Full and open competition: Procurements must be conducted through competitive processes unless a sole-source justification is documented and meets one of the limited exceptions
• Micro-purchase threshold: Purchases under $10,000 (the current federal micro-purchase threshold) may be made without competitive quotes but must be distributed equitably among qualified suppliers
• Small purchase procedures: Purchases between $10,000 and the simplified acquisition threshold ($250,000) require price or rate quotations from an adequate number of qualified sources
• Conflict of interest: Written standards of conduct covering conflicts of interest in procurement. No employee may participate in procurement decisions involving a real or apparent conflict.

Publication and Acknowledgment Requirements

CDC has specific and strictly enforced requirements regarding publications, presentations, and public communications produced with cooperative agreement funding. These requirements reflect CDC's role as a scientific agency and its need to ensure accuracy of health communications.

CDC Clearance for Publications

Any publication, presentation, report, or communication produced with CDC cooperative agreement funding that references CDC or uses CDC data must undergo CDC clearance before release. This includes journal articles, conference presentations, press releases, educational materials, and website content. The clearance process involves review by your CDC project officer and potentially by CDC communications staff.

Plan for clearance timelines of 30 to 90 days depending on the nature of the publication and CDC's review workload. Submit materials for clearance well in advance of publication deadlines or conference dates. Failing to obtain CDC clearance before publication is a compliance violation — one of the most common mistakes described in the Common Mistakes guide.

Acknowledgment Language

All publications and materials funded by a CDC cooperative agreement must include a standard acknowledgment statement and disclaimer. The specific language is included in your award terms and typically follows this format:

"This [publication/report/presentation] was supported by the Centers for Disease Control and Prevention of the U.S. Department of Health and Human Services (HHS) as part of a financial assistance award totaling $[amount] with 100 percent funded by CDC/HHS. The contents are those of the author(s) and do not necessarily represent the official views of, nor an endorsement by, CDC/HHS or the U.S. Government."

Sub-Recipient Monitoring

If you issue sub-awards with CDC cooperative agreement funds, you are responsible for monitoring sub-recipient compliance with federal requirements. Under 45 CFR 75.352, your monitoring obligations include:

• Sub-award documentation: Each sub-award must include the CFDA number, award name, award number, federal amount, and all applicable compliance requirements flowed down from your CDC award
• Risk assessment: Evaluate each sub-recipient's risk of non-compliance before making the sub-award and periodically thereafter. Consider prior experience, audit history, financial stability, and management capacity.
• Ongoing monitoring: Review financial and programmatic reports, conduct site visits as appropriate, and verify that expenditures are allowable and properly documented
• Single Audit follow-up: Verify that sub-recipients expending $750,000 or more in federal awards annually obtain the required Single Audit and follow up on any findings related to your sub-award

Data Sharing and Intellectual Property

CDC cooperative agreements frequently involve collection, analysis, and sharing of public health data. The data sharing provisions in your award terms address several key areas:

• Data access: CDC may require access to data collected under the cooperative agreement for national surveillance, program evaluation, or public health response purposes. Your award terms will specify the data sharing requirements and mechanisms.
• Privacy protections: All data sharing must comply with applicable privacy requirements, including HIPAA for health information, the Privacy Act for individually identifiable information maintained in systems of records, and any program-specific data use agreements.
• Intellectual property: Works produced under CDC cooperative agreements are subject to 45 CFR 75.322. The federal government has a royalty-free, nonexclusive, and irrevocable right to reproduce, publish, or otherwise use works produced under the award.
• Data management plans: Some CDC programs require recipients to develop and maintain data management plans that address data collection, storage, security, sharing, and long-term preservation.

Compliance Calendar

Building a compliance calendar is one of the most effective tools for avoiding missed deadlines and compliance violations. Key dates to track for each CDC cooperative agreement include:

• Annual continuation application due date (typically 90–120 days before budget period start)
• Annual performance report due date
• SF-425 quarterly and/or annual due dates (30 days after each reporting period)
• Interim progress report due dates (semi-annual or quarterly, per NOFO)
• Program-specific data submissions (varies by program)
• SAM.gov registration renewal date
• Single Audit completion deadline (9 months after fiscal year end)
• Indirect cost rate agreement renewal date