Sponsored Program 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.
Below are helpful questions to determine whether a third party entity is a subrecipient. If the answers are "yes" the relationship is probably a subrecipient relationship.
- Is there an identified investigator at the third party entity? If yes, is he or she a co-investigator on the primary award?
- Is the third party free to decide how to carry out the activities requested of it?
- Will there be potentially patentable or copyrightable technology created or reduced to practice from the activities of the third party? If yes, does the third party have rights to or the right to file for protection of its technology?
- Are publications anticipated from the third party? Will individuals at the third party entity be co-authors on articles?
A key question to answer to determine whether the third party is a vendor is bulleted below.
- Is the activity to be performed a series of repetitive tests or activities requiring little or no discretionary judgment on behalf of the third party?
If the answer is "yes" the relationship is most likely a vendor relationship.
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.
For more information, see Section II, Definitions, of the Subagreement Manual.
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