Vendor or Subrecipient

A key step in subrecipient monitoring under the Uniform Guidance is determining whether an external entity receiving award funds from UMB is a contractor (aka, vendor) or a subrecipient.

The University of Maryland, Baltimore (UMB), as the pass-through entity (prime applicant or awardee), is responsible for deciding whether an arrangement constitutes a subaward or a procurement. The non-federal entity receiving these pass-through funds is classified as a subrecipient or a vendor based on the nature of the agreement and the criteria in 2 CFR §200.330. 

The determination is made at the time of proposal and is reviewed and confirmed before the subaward or procurement is initiated. Use the chart below and the Subrecipient or Vendor Checklist to guide the determination.

Contracting with Individuals

UMB usually does not issue subawards to individuals; a consultant agreement is issued by Procurement. For additional guidance on collaborators, review Collaborator Roles.


  • Performs specified activities, but quantity, quality, and other characteristics of end-products or deliverables are not specified in advance; or no end-product or deliverable is required except reports describing the supported activities.
  • Performs “substantive project work” defined as “a significant portion of the activities for which support was awarded.”
  • Provides unique services or products.
  • Has responsibility for programmatic decision-making.
  • Usually cooperates with the UMB principal investigator in developing the proposal for submission to the sponsor.
  • Is usually responsible for design or development of the supported activities.
  • Investigators from the organization are likely to be co-authors on articles resulting from the project.
  • Is likely to be paid on a cost-reimbursement basis (based on actual project costs incurred).
  • Subrecipient agreements are issued by Sponsored Programs Administration.



  • Meets only the requirements of the procurement contract.
  • End-products or deliverables are specified in advance with regard to quantity, quality, or other characteristics.
  • Provides the goods or services within its normal business operations.
  • Provides similar goods or services to many different purchasers.
  • Operates in a competitive environment.
  • Involves performance of routine services or repetitive tests or activities requiring little or no discretionary judgment on the part of the provider.
  • Is not subject to compliance requirements of the sponsored program.
  • Is likely to be paid on a fixed-price basis for products or services delivered.
  • Purchase orders are issued by Procurement Services.