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Subrecipient/Contractor Purchase Orders

Grant-funded research collaborations usually involve issuing a Subaward to the collaborating institution.  Subaward agreements are used to issue grant funds to Subrecipients.  A contractor PO should be used to contract for consulting services.  All grant-funded Subaward agreements must be reviewed by the Sponsored Programs Service (SPS) and the Principal Investigator (PI) before they are sent to Subrecipient for execution.  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.

Subrecipient versus 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 the issuing entity must use judgment in classifying each agreement appropriately.

 

Definitions from Uniform Guidance (2 CFR, PART 200)

Subrecipients – Per §200.93 a subrecipient is a non-Federal entity that receives a subaward from a pass-through entity to carry out part of a Federal program; 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 §200.330):

  • 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
  • In accordance with its agreement, uses the Federal funds to carry out 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 §200.22 a contract means a legal instrument by which a non-Federal entity purchases property or services needed (i.e. like a vendor) to carry out the project or program under a Federal award. In general, the contractor relationship with UConn will include the following characteristics (per §200.330):

  • 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
  • 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.  You can also contact the following individual if you have any questions:

Holly Kasem-Beg
Grants and Contracts Specialist
holly.kasem-beg@uconn.edu
Contractor Agreement requests must be submitted to Procurement Services.  The Hiring of a Consultant form can be found at the following website: https://purchasing.procurement.uconn.edu/procurement_forms/