APSU ORSP classifies your collaborator as a subrecipient or a contractor on a case by case basis using these guidelines. A federal awarding agency may require recipients to comply with additional guidance
to support these determinations provided such guidance does not conflict with any
other provisions or policies.
Subrecipients. A subaward is for the purpose of carrying out a portion of an award and creates an assistance relationship with the subrecipient. Characteristics which support APSU's determination as a subrecipient include:
Subrecipient performance measured in relation to whether objectives of the prime agreement
were met;
Subrecipient has responsibility for programmatic decision-making;
Subrecipient is responsible for adherence to applicable Federal program requirements
specified in the Federal award; and
Subrecipient 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.
Contractors. A contract is for the purpose of obtaining goods and services for APSU's own use
and creates a procurement relationship with the contractor. Characteristics indicative
of a procurement relationship between APSU and a contractor are when the contractor:
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.
If you meet the definition of a subrecipient, above, ORSP needs the following:
Contact information for your collaborators ORSP office
If you do not meet the subrecipient definition, please see the consulting policy for faculty
At proposal time, if the person meets the definition of a subrecipient, above, ORSP
needs the following:
Budget
Build sub's budget into the subcontract line item of YOUR budget
Provide a Scope of Work
Provide us the contact information for your collaborator's ORSP office
ORSP generates an intent to enter a subrecipient agreement.
ORSP generates and routes the subrecipient agreement or signatures and legal review.
ORSP works with collaborator's ORSP to finalized the agreement.
Closes with purchasing department.
PI MONITORS EXPENDITURES
If they meet the definition of a contractor above, build their costs into the consulting
line item. After the award, see APSU purchasing policies. If you already have an award
and you are ready to pay the person who meets the contractor definition, then work
with APSU purchasing.