Subcontracting is when UNI is awarded a grant, contract or cooperative agreement and then subsequently awards a portion of those funds to an eligible subrecipient.
Subrecipient or Vendor
Collaboration with other entities is often an essential component of sponsored projects. It is important to determine what type of relationship is formed when collaborating. PI/PDs need to understand the differences between a subrecipient and a vendor. In general terms, a subrecipient is involved in the programmatic aspects of the sponsored project; they are subject to the same terms and conditions of the prime award and are subject to 2 CFR Part 200 Uniform Guidance audit requirements. A vendor is a dealer, distributor, or merchant, who sells goods and services. A vendor is not involved in the programmatic aspects of the sponsored project and is not subject to 2 CFR Part 200 Uniform Guidance audit requirements.
More information on distinguishing between a vendor and a subrecipient can be found in 2 CFR Subpart D (200.330-200.332).
Most sponsors require their prior approval for UNI to enter into a subrecipient relationship with another entity; therefore PI/PDs must include this information in the proposal to the sponsor. If the proposal is accepted as submitted, the approval is granted. If a subrecipient relationship is created after the project is funded, without prior approval of the sponsor, the PI/PD must contact Office of Research and Sponsored Programs who will request permission from the sponsor to modify the terms and conditions of the agreement.
Once a subrecipient relationship is established, the Office of Research and Sponsored Programs works with the PI/PD and the subrecipient to prepare the contractual paperwork. The instrument used to provide the award to the subrecipient can be called a subcontract, subaward, subgrant or subrecipient agreement. The agreement is between UNI as the primary recipient and the subrecipient. It must include the following:
- Activities to be performed (Scope of Work)
- Time schedule
- Project policies
- Reporting requirements
- Other policies and procedures to be followed
- Funding amount
- Cost principles to be used in determining allowable costs
- CFDA Number, if applicable
Formal modifications are required if there are any changes in the terms and conditions of a fully executed sub agreement. The PI/PD is responsible for monitoring the subrecipient and ascertaining that all fiscal and programmatic responsibilities are fulfilled.
Subrecipients and vendors must have a completed e-Business Supplier Information Form on file with the University.