Principal Investigator: ____________________ University Proposal Number: ___________________
Checklist to Determine Subrecipient or Contractor Classification
NOTE: Contractors/vendors may not provide cost share on projects.
OBJECTIVE: Generally, the determination of the relationship with an entity is verified through the institutional
review of the proposal narrative, budget justification, and other related proposal documents, as well as through
discussions with key personnel prior to proposal submission. When the relationship remains unclear, this form
may provide assistance in making an accurate determination.
§200.93 Subrecipient means 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.
§200.23 Contractor means an entity that receives a contract as defined in §200.22 Contract.
§200.22 Contract means a legal instrument by which a non-Federal entity purchases property or services needed to
carry out the project or program under a Federal award.
INSTRUCTIONS: Complete sections one and two of the checklist by marking all characteristics that apply to the
outside entity. The section with the greatest number of marked characteristics indicates the likely type of
relationship the entity will have with the University. On occasion there may be exceptions to the type of
relationship indicated by the completed checklist. In these situations, the substance of the relationship should be
given greater consideration than the form of agreement between the University and the outside entity. Section 3
should be used to provide documentation on the use of judgment in determining the proper relationship
NAME OF OUTSIDE ENTITY (subrecipient or contractor): ______________________________________________
Description: A subaward is for the purpose of carrying out a portion of a Federal award and creates a Federal
assistance relationship with the subrecipient. Characteristics which support the classification of the non-Federal
entity as a subrecipient include when the contractor:
1. Determines who is eligible to receive what Federal assistance;
2. Has its performance measured in relation to whether objectives of a Federal program
were met;
3. Has responsibility for programmatic decision making;
4. 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;
5. Is responsible for adherence to applicable Federal program requirements specified in the Federal
Description: A contract is for the purpose of obtaining goods and services for the non-Federal entity's own use and
creates a procurement relationship with the contractor. Characteristics indicative of a procurement relationship
between the non-Federal entity and a contractor are when the non-Federal entity receiving the Federal funds:
1. Provides the goods and services within normal business operations;
2. Provides similar goods or services to many different purchasers;
3. Normally operates in a competitive environment;
4. Provides goods or services that are ancillary to the operation of the Federal program;
5. Is not subject to compliance requirements of the Federal program as a result of the agreement, though
similar requirements may apply for other reasons.
SECTION 3 - USE OF JUDGMENT (use only when the determination cannot clearly be made using the above
Description: In determining whether an agreement between a pass-through entity and another non-Federal entity
casts the latter 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 above may not be present in all cases, and the pass-through entity
must use judgment in classifying each agreement as a subaward or a procurement contract.
Explanation of Use of Judgment Determination:
Prepared by: _________________________________________ Date: __________________________________