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All grants and cooperative agreements |
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A recipient of a Federal financial assistance award must determine the proper role of organizations they partner with to carry out the work under the prime Federal award. Depending on the role established, the partnering organization may be either a subrecipient or contractor. This determination is important in that each award instrument type (subaward or contract) has differing Federal regulations related to administrative practices and documentation, allowability of costs, and other Federal Federal compliance requirements. The incorrect determination by the pass-through entity could result in audit findings, such as the repayment of improper costs, or even affect their future Federal funding opportunities.
Authorities
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2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
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[78 FR 78608, Dec. 26, 2013, as amended at 80 FR 54409, Sept. 10, 2015]
Frequently Asked Questions
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What guidance can you provide in order to help distinguish between a subrecipient or contractor?
§ 200.330(a) provides characteristics which generally support the classification of a non-Federal entity as a subrecipient. Characteristics generally supportive of a contractor are listed in 2 CFR 200.330(b).
What are some of the characteristics indicative of a subrecipient relationship with a non-Federal entity?
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(4) not subject to compliance.
Learning Aids
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Related Pages
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Risk Assessment Requirements for Pass-Through Entities
Resources
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References
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