Many grant-funded research collaborations involve issuing a subrecipient agreement (subaward or subcontract, depending upon UConn’s prime funding agreement) to collaborating institutions to provide a portion of the UConn grant award (which serves as “pass-through entity,” or PTE) to the collaborator/subrecipient. Contractor Purchase Orders, by contrast, are used to contract for consulting services. All grant-funded Subaward agreements are drafted by Sponsored Program Services (SPS) and provided to the Principal Investigator (PI) for review before they are sent to the subrecipient entity for signature. All grant-funded Contractor agreements for consulting services must be reviewed by Procurement Services and the PI before they are sent to the Contractor for execution.

The pass-through entity (PTE) is responsible for making case-by-case determinations to determine whether the entity receiving Federal funds is a subrecipient or a contractor. In determining whether an agreement between the issuing entity and another non-Federal entity is classified as a subrecipient or a contractor, the substance of the relationship is more important than the form of the agreement. All of the characteristics listed below may not be present in all cases, and UConn must use judgment in classifying each agreement appropriately.

Definitions from Uniform Guidance (2 CFR, PART 200)

Subrecipients – Per §200.1 a subrecipient is an entity that receives a subaward from a pass-through entity to carry out part of a Federal award; but does not include an individual that is a beneficiary of such program. A subrecipient may also be a recipient of other Federal awards directly from a Federal awarding agency. In general, a subrecipient relationship with UConn will include the following characteristics (per §200.331):

• Has its performance measured in relation to whether objectives of a Federal program were met;
• Has responsibility for programmatic decision making;
• Is responsible for adherence to applicable Federal program requirements specified in the Federal award; and
• Implements a program for a public purpose specified in authorizing statute, as opposed to providing goods or services for the benefit of the pass-through entity.

Contractor – Per §200.1, a contract means a legal instrument by which a non-Federal entity conducts procurement transactions under a Federal award. In general, a contractor relationship with UConn will include the following entity characteristics (per §200.331):

• Provides the goods and services within normal business operations;
• Provides similar goods or services to many different purchasers;
• Normally operates in a competitive environment;
• Provides goods or services that are ancillary to the operation of the Federal program; and
• Is not subject to compliance requirements of the Federal program as a result of the agreement, though similar requirements may apply for other reasons.

Assistance

Subaward agreement requests must be submitted to subawards@uconn.edu.

Contractor Agreement requests must be submitted to Procurement Services via the Hiring of a Consultant form