Training on a humanitarian project

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1. Everyone in the room is receiving assistance

A workshop looks like the least controversial thing a humanitarian program can fund. It is in fact one of the most tightly governed, because of a single definitional point about who counts as a recipient.

The rule is stated without exceptions for observers or guests. "Except for the instructors and administrative personnel providing the training event, all persons attending the OHDACA-funded training event are recipients of OHDACA-funded assistance and must be eligible for such assistance, even if they fund their own travel expenses" (SAMM C12.3.6).

Paying for a seat therefore does not create eligibility. Anyone sitting in the room is being assisted, and the eligibility rules follow them in.

The same logic reclassifies events people might not think of as training at all. "An HA project that consists of an OHDACA-funded conference, seminar or workshop will provide training to partner personnel" (SAMM C12.3.6). What the appropriation covers generally is described in what OHDACA funds.

2. The exchange that is not allowed

One familiar format is ruled out by name. "A subject matter expert exchange with partner personnel is not authorized as such exchanges do not provide partner training or effectively build partner capacity" (SAMM C12.3.6).

The reasoning matters more than the prohibition. The money buys capacity in the partner, so an activity where expertise flows both ways and nobody is formally taught does not qualify. An event has to be designed to leave something behind.

Screening applies before any of it happens. Human rights vetting of security force individuals and units receiving training or equipment must be complete first (SAMM C12.3.6), the process described in screening international military students.

3. Where the training may take place

Location is constrained, and not for cost reasons. Training is conducted in the assisted partner’s own territory or another regional location, "outside the United States and its territories" (SAMM C12.3.6.2).

Bringing people to America is an exception requiring a request to the division chief, and the request has to review other regional options and justify why the United States is more appropriate (SAMM C12.3.6.2). Medical screening, insurance and student travel procedures then apply as they would for any international student.

Mine action training carries its own physical constraint. "HMA training must take place a safe distance from any explosive hazard" (SAMM C12.3.6.2). Related work is covered in mine action and excess property.

One route is closed entirely. "OHDACA funds may not be used to send partner participant(s) to a DoD school for formal training" (SAMM C12.3.6.3). Where a partner needs a formal course, the command is told to look at grant financing or the international education program instead, which is covered in planning training from the embassy.

4. Training several countries at once

Regional events are common and have a defined structure. "Multi-lateral HA training events are conducted in one of the attending partners and will be submitted as Umbrella projects with a subproject for each of the benefiting partners" (SAMM C12.3.6.4).

Each subproject carries its own coordination. Embassy office and chief of mission agreement from every participating country is required and recorded in that country’s subproject (SAMM C12.3.6.4). One event, one location, and as many approval chains as there are countries in the room.

International organizations sit outside the model. "OHDACA projects do not provide training or HA to an IO" (SAMM C12.3.6.5). A multi-lateral event may still train people from several governments who happen also to represent such an organization (SAMM C12.3.6.5). The distinction is who is being built up, not who is in the room.

5. Non-governmental and private participants

The starting position is a prohibition. "OHDACA funds are not used to provide assistance to or build the capacity of an NGO or private sector individuals or organizations" (SAMM C12.3.6.6).

Two roles remain open. The first is teaching: "An NGO or private sector individual may participate in an OHDACA training project, such as a disaster preparedness workshop, as a presenter/instructor if their expertise is necessary" (SAMM C12.3.6.6) to the purpose of the event, and their travel and subsistence can be a project cost.

The second is operating. Such organizations or individuals may run a facility or equipment provided to the partner government, where that government relies on them to deliver the humanitarian service to civilians (SAMM C12.3.6.6). The asset belongs to the partner; the operator may be private.

Attendance is otherwise limited to officials. "all persons attending an OHDACA-funded training event, other than the instructors and coordinators, must be an employee of a partner government" (SAMM C12.3.6.8), absent a written exception. "In rare circumstances, a CCMD may request DSCA (IOPS/GEX/HDD) approval to provide training to a limited number of NGO or private entity personnel who self-fund their own travel expenses" (SAMM C12.3.6.8), on a showing that their attendance serves the department.

6. Running an event with a partner organization

Where an outside body co-hosts, an agreement is compulsory. "CCMDs must conclude a written co-sponsorship agreement between DoD and the co-sponsoring NGO of an OHDACA training event" (SAMM C12.3.6.7), so that responsibilities are clear and the ethics rules are satisfied.

Not any organization qualifies. "The proposed co-sponsor must be a recognized scientific, technical, educational, or professional organization" (SAMM C12.3.6.7).

The draft agreement goes into the project file before approval, and the concluded version is signed by the general counsel or a designated ethics official (SAMM C12.3.6.7). An event with an outside partner therefore needs a legal instrument as well as a plan.

7. Money that runs out mid-course

Training has to finish inside the life of the appropriation, with two exceptions. "The period of performance of training engagements shall not extend beyond the period of funds availability, unless all project funds, including funds for instructor and student travel, have been obligated or the contracting officer considers the service to be non-severable" (SAMM C12.3.6.1).

Both exceptions are worth knowing. Obligating everything, travel included, buys time. So does a contracting officer judgment that the course is a single undivisible undertaking.

One category of event gets a specific description. "Disaster management training events generally entail training and/or exercises for national and local-level authorities in disaster preparation, response, mitigation, and emergency operations planning and management" (SAMM C12.3.6.9), with commands told to consult the state department locally to avoid duplicating other efforts. Relief operations themselves are covered in donated relief supplies and disaster response.

8. What a supplier can take from this

The attendance rule shapes who can be in a room, and it catches people who assume that paying their own way puts them outside the program. It does not. Everyone other than instructors and coordinators is a recipient, and a private participant needs a written exception.

Instructing is the open door. Where specialist expertise is necessary to the purpose of an event, an outside presenter can be funded, and an outside organization can operate a facility the program has provided to the partner. Both are real roles for a provider, and both are narrower than general participation.

On timing, the funding period governs the course, not the other way round. Where dates are tight, whether the work counts as a single undertaking is the question that decides whether it can run on.

Key terms

Recipient of assistance	Anyone attending a funded event other than instructors and administrative staff, self-funded or not.
Umbrella project	A multi-country training event held in one partner, with a subproject and separate coordination for each participant.
Co-sponsorship agreement	The written instrument required before an outside organization may co-host an event.
Non-severable training	A course treated as one undertaking, which may run beyond the funding period.

Every statement above links to the document behind it. The full source list for this piece is on the sources page.

This page describes public United States government programs for general information. It is not legal, regulatory or procurement advice, and it does not address the facts of any particular case.

How Sentfore supports this

Training delivered in country brings people and equipment that need support once they arrive. Sentfore supports defense programs at the delivery end, providing secure transport, protective security, accommodation and life support. Requirements can be sent through the contact page.