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The requirement placed on Federal financial assistance award recipients to determine relationships with third-party entities they work with on those awards is an important one: failure of the pass-through entity to establish the correct award instrument with the third party as either a subaward or a contract could mean subsequent audit findings that require repayment of improper costs (in the case of a subaward treated as a contract), or unnecessary audits that cost both time and money to the
and its partner in the relationship (in the case of a contract treated as a subaward). Federal award recipients should consult 2 CFR 200 for guidance on making the correct determination.
Authorities
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2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
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