Office of Research and Project Administration
SPONSORED PROGRAMS COMPLIANCE
How is a Subrecipient Different from a Vendor?
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 order 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, characteristics 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; operates 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.
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