In this phase you'll put your plans into action. You'll roll out your communications plan, accept submissions and interact with solvers to generate interest and enthusiasm throughout. After your submission deadline, you'll begin to evaluate entries, select winners and verify their eligibility. Successful execution of this phase is critical to maintain credibility of the challenge and your agency.
You've selected winners, but you still have some work to do before you can announce them.
This could be as simple as verifying names, addresses or other contact information. But it also could entail verifying intellectual property and conducting patent searches.
Before you announce winners, check their names against the exclusion records on the System for Award Management website to see if any have been suspended or debarred. If you have international contestants, make sure they aren't citizens of proscribed countries.
If your legal authority doesn't allow for international winners, then you'll need to check that your winners are U.S. citizens or entities.
You can notify your winners in a number of ways, including through a phone call or email. You may decide to notify them as part of an event. This gives you another opportunity to highlight the challenge and bring attention to the problem or issue being addressed.
The "Announce Winners" step in the next phase provides additional considerations.
If you're going step by step through this toolkit, then you already know that not all agencies are covered by the same legal authority. NASA, for example, is governed by both the Space Act and the American Innovation and Competitiveness Act (an update to the original America COMPETES Act).
The latter is the most widely used authority and comes with certain restrictions on who can win a challenge. It requires that a private entity must be incorporated in and maintain a primary place of business in the United States. An individual competing alone or as part of a team must be a citizen or permanent resident of the United States. Some agencies will allow international participants with the understanding that they aren't eligible to receive a cash prize.
Bottom line: You need to understand your legal authority and know how it affects the verification and notification of your challenge winners.
Talk with your legal counsel because verification processes also vary agency to agency. For example, you may only need a passport for verification of citizenship or a license for business verification.
You should make clear during registration the eligibility requirements for your challenge. Still, you need to have a plan for verifying eligible individuals or entities.
And you need to anticipate the time it will take to verify eligibility. It can range from weeks to months depending on the requirements.
Your legal authority can determine some eligibility requirements, but you'll have to decide whether to add any other requirements for your challenge. Additional eligibility requirements require more planning. You'll have to determine when to enforce, how to enforce and who enforces them.
Competitors can be ruled ineligible for a variety of reasons:
- entity location and practice
- patent infringement
- lack of intellectual property ownership or license
- suspension and debarment from award
- unprofessional or unfair treatment of fellow competitors
- actions intending to deter or destroy other challenge entries
The Department of Agriculture has dealt with suspended or debarred competitors by issuing a departmental regulation on prizes that makes these solvers ineligible to receive an award. There are also federal suspension and debarment regulations for nonprocurement transactions (Title 2 CFR Part 180) and procurement transactions (FAR 48 9.4).
Check with your legal counsel for more details on regulations and how to apply them.
You don't have to wait for a specific point in your competition to verify eligibility. It can be done at different stages as long as it's completed before you announce winners.
Some agencies review eligibility prior to judging so they only review entries from those who can win. Other agencies may allow ineligible participants to proceed through judging but not award them any prize money.
Again, just do it before you announce winners.
You also can work through a third-party vendor to verify winners. For this, it needs to be clear whether the responsibility to verify eligibility lies with the federal agency, a partner or a support contractor.