Sponsored Programs Finance Administration and Compliance

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A subcontract is required when an institution or organization outside of the University is conducting a defined portion of the programmatic aspects of a sponosred project first awarded to the University. A subrecipient is different than a vendor, and it is important to accurately classify them. OMB Circular A-133 requires determination as to whether an arrangement resulting from a particular award that the awarding entity makes to another organization creates a subrecipient or vendor relationship. Normally, the determination is made in the proposal stage. Below are guidelines when making that determination.

Performance measured against whether the objectives of the program are met
Provides the goods and services within normal business operations
Has responsibility for programmatic decision making
Provides similar goods or services to other customers or clients
Must adhere to applicable program compliance requirements
Operates in a competitive environment
Must use the sponsored program funds to carry out their portion of the programmatic effort of the project
Provides goods and services that are ancillary to the operation of the program.

SPFAC will issue, negotiate and execute all subcontracts. Subcontracts cannot be executed until our office has received and processed the prime award.