Determine Subrecipient or Vendor

Research, Sponsored Projects   |   Approved October 9, 2015

Purpose

Comply with federal regulations for identifying the role of entities receiving funds from awards made to the University of Maryland Baltimore (UMB).

Applicability

Investigators 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.

For more information, see the Sponsored Programs Administration website on Collaborations and Subrecipients.

Instructions

1. Before requesting a subaward, review the role and activities that the entity and its personnel will take on in the award.
   1. Characteristics of a subrecipient include:
      • Usually cooperates with the UMB principal investigator in developing the proposal
      • Is usually responsible for the design of the supported activities, and subrecipient investigators are likely to author or co-author publications resulting from the work
      • Has responsibility for programmatic decision-making. Performs specified activities (scope of work), but has latitude to make decisions regarding how it carries out the project
      • Has its performance measured in relation to whether objectives of a Federal program were met
   2. Characteristics of a vendor include:
      • Meets only the requirements of the procurement contract
      • Provides the goods or services within its normal business operations
      • Provides similar goods or services to many different purchasers
      • Often involves performance of repetitive tests or activities requiring little or no discretionary judgment on the part of the provider
      • Organization competes with other organizations to provide a similar good or service
      • May provide goods or services ancillary to the project such as staff development or travel services
      • Is not subject to the compliance requirements of the project
2. Use reasonable judgment in classifying the entity as a subrecipient. Document the reasons for the determination in cases when the classification might be questioned.
3. Subawards are issued by Sponsored Programs Administration. See procedure, Request a New Subaward.
4. Procurements from a vendor are managed by Procurement Services.