Subrecipient:   A subrecipient holds responsibility for significant programmatic activities under a UNH sponsored program.  When Federal funds are passed to a subrecipient entity, that entity must adhere to all applicable Federal program compliance requirements.  UNH is responsible for monitoring the subrecipient’s performance and compliance.

Vendor:  A vendor provides goods and services to the UNH sponsored program that are not substantially different to those it offers the general public.  A vendor typically is organized as a for-profit and is not subject to Federal program compliance requirements. 

What’s essential?

To comply with the requirements in OMB Circular A-133, UNH must determine whether services provided to further the purposes of an award (grant or contract) should be paid as a vendor agreement or subrecipient of the award. The checklist, Subrecipient and Vendor Determination Checklist for Sponsored Programs, should be used to determine which of these agreements best applies to your sponsored program. 

Why it's important

The nature of the relationship determines whether or not an entity is a subrecipient or a vendor. Neither the dollar amount of the engagement nor the associated overhead is a determining factor.  Careful review of the nature of services to be provided and an appropriate determination as part of the proposal budget review process eliminates post-award problems such as:

• Obtaining sponsor prior approval for unbudgeted subcontracts
• Delays in processing subcontracts
• Meeting audit and compliance requirements with for-profit organizations where a vendor relationship should exist 

Appropriate classification as subrecipient or vendor also is important to the external entity, since significant audit and compliance requirements are attached to a subrecipient. 

How to comply

The checklist is intended to assist in establishing whether an external entity is a subrecipient, which should be engaged by the Sponsored Programs Administration (SPA) office, or a vendor, which should be engaged by USNH Purchasing and Contract Services.  

There may be unusual circumstances or exceptions to the listed characteristics. In determining whether a subrecipient or vendor relationship exists, the substance of the relationship is more important than the form of the agreement. It is not expected that all characteristics of either relationship will be present. Classification can be complex and requires the exercise of informed judgment; SPA and USNH Purchasing Staff are available to assist in the interpretation and determination of how an award should be administered.  Final decisions are at the discretion of the Directors of Purchasing and SPA.