{"id":4057,"date":"2021-06-30T08:00:19","date_gmt":"2021-06-30T14:00:19","guid":{"rendered":"https:\/\/www.research.colostate.edu\/osp\/?p=4057"},"modified":"2021-06-30T08:00:19","modified_gmt":"2021-06-30T14:00:19","slug":"subaward-administration-at-csu-making-a-determination","status":"publish","type":"post","link":"https:\/\/www.research.colostate.edu\/osp\/2021\/06\/30\/subaward-administration-at-csu-making-a-determination\/","title":{"rendered":"Subaward Administration at CSU \u2013 Making a Determination"},"content":{"rendered":"

\"CSU\t\t\t\t\t\t\t\t\t\t\t\t\t\t<\/p>\n

When developing a proposal with institutions and organizations outside of the University, CSU has an obligation to make a case-by-base determination if the outside entity is functioning as a subrecipient (awardee) or a vendor\/contractor (procurement) (2 CFR \u00a7 200.330).<\/p>\n

According to Uniform Guidance, an organization is considered a subrecipient of a federal award when it:<\/p>\n

    \n
  1. Determines who is eligible to receive what financial assistance;<\/li>\n
  2. Has its performance measured against whether the objectives of the federal program are\u00a0met;<\/li>\n
  3. Has responsibility for programmatic decision-making;<\/li>\n
  4. Has responsibility for adherence to applicable federal program compliance\u00a0responsibilities; and<\/li>\n
  5. Uses the federal funds to carry out a program of the organization as compared to\u00a0providing goods and services for a program of the pass-through entity.<\/li>\n<\/ol>\n

    According to Uniform Guidance, an organization is considered a contractor (vendor) when it:<\/p>\n

      \n
    1. Provides goods and services within normal business operations;<\/li>\n
    2. Provides similar goods and services to many different purchasers;<\/li>\n
    3. Operates in a competitive environment;<\/li>\n
    4. Provides goods or services that are ancillary to the operation of the Federal program; and<\/li>\n
    5. Is not subject to compliance requirements of the Federal program.<\/li>\n<\/ol>\n\n\n\n\n\n\n
      \n

      SUBRECIPIENT<\/strong><\/p>\n<\/td>\n

      		\n

      VENDOR\/CONTRACTOR<\/strong><\/p>\n<\/td>\n<\/tr>\n

      \n

      Performs a substantive portion of the programmatic effort<\/p>\n<\/td>\n

      		\n

      Provides similar goods and services within normal business operations to different purchasers<\/p>\n<\/td>\n<\/tr>\n

      \n

      Responsible for programmatic decision making<\/p>\n<\/td>\n

      		\n

      No programmatic decision making<\/p>\n<\/td>\n<\/tr>\n

      \n

      Work performed by the subrecipient\u2019s personnel at their facilities<\/p>\n<\/td>\n

      		\n

      Provides own tools and training<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

      Making a status determination is not always straightforward because not all of the characteristics listed above will exist in every case. For example, let\u2019s say that an entity will be providing project evaluation services such as collecting data on outcome measures and providing an analysis to CSU. Is this entity acting as a subrecipient or a vendor or contractor? In order to make an accurate determination, we need to know more information. Questions to ask might include:<\/p>\n