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Procedure Library

Sponsored Projects

Determine Subrecipient or Vendor

Purpose

Comply with federal regulations for identifying the role or entities receiving funds from awards made to the University. 

Applicability

Principal Investigators (PIs) and administrators developing a sponsored project budget or managing award funds.

Federal regulations (2 CFR 200.330) require case-by-case determination of whether an entity receiving an agreement to perform project activities has the role of contractor (another word for vendor) or subrecipient. Use these instructions for any project, whether or not it is federally funded.'

Instructions

  1. During the proposal phase or as prospective subrecipients are identified, PIs will need to make an accurate determination. 
    • The proper classification of an entity as a subrecipient or as a contractor during the proposal process is critical to ensure proper accounting for costs and compliance requirements. Misclassification may result in delays of subaward processing, and failure to include or exclude Facilities and Administrative (F&A) costs will lead to significant errors in budget calculations.
  2. Before requesting a subaward, review the role and activities that the entity and its personnel will take on in the award. See the information on determining if you will have a subrecipient, contractor or consultant.
  3. Use reasonable judgment in classifying the entity as a subrecipient. Document the reasons for the determination in cases when the classification might be questioned.
    1. If you determine the entity is a vendor, see Budget for Consultants.
    2. If you determine the entity is a subrecipient, see Include Subrecipient in a Proposal Budget.
  4. Subawards are issued by OSP. PI's and administrators should request a subaward by initiating a request in eAward via the subaward out transaction. See Bridge for detailed instructions.

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Last Updated: 10/1/24