In certain circumstances it is difficult to make a distinction between a subrecipient and a vendor. The distinction between a subrecipient and a vendor provides the basis for the decision as to whether ORPA or Corporate Purchasing will issue the agreement. ORPA issues contracts with subrecipients and Corporate Purchasing issues purchase orders to vendors.

• Characteristics of a subrecipient relationship include circumstances where the third party determines who is eligible to receive what financial assistance; has its performance measured against whether the objectives of the program are met; has responsibility for programmatic decision-making; and has responsibility for adherence to applicable compliance responsibilities.
• Alternatively, characteristcs of a vendor relationship include circumstances where the third party provides goods and services within normal business operations; provides similar goods and services to many different purchasers; operaters in a competitive environment; provides goods and services that are ancillary to the operation of the federal program; and is not subject to compliance requirements of the federal program.

Not all of the characteristics need to be or will be present to determine whether the organization is a subrecipient or a vendor, and judgment should be used.