Making this distinction properly is very important for organizations receiving federal awards. Subrecipients are subject to audit under A-133, while payments to a vendor for goods and services are not. The dollar amount of a transaction is not a determining factor. It is important to be aware that it is the nature of the relationship that determines whether or not an organization is a subrecipient or a vendor. To help your organization make this distinction, consider the following:
Characteristics of a Subrecipient
They determine who is eligible to receive assistance
Their performance is measured against meeting the objectives of the program
They have programmatic decision-making responsibility
They are responsible for applicable program compliance requirements
They use the funds to carry out a program of the organization as opposed to providing the services for a program of the awarding entity
Characteristics of a Vendor
They provide the service as part of their normal business operations
They provide a similar service to many different purchasers
They operate in a competitive environment
Their program compliance requirements do not pertain to the service provided
It is important to understand that determining whether your organization is a vendor or a subrecipient takes judgment. The answer is not always black and white, and there is not a single factor that will dictate whether one or the other relationship exists. However, keep in mind that if your organization transfers federal funds to another organization that is deemed a “subrecipient,” your organization is responsible for oversight of the recipient’s use of the funds. If the recipient is deemed a “vendor,” you have no formal oversight responsibilities.
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The Schneider Downs Our Thoughts On blog exists to create a dialogue on issues that are important to organizations and individuals. While we enjoy sharing our ideas and insights, we’re especially interested in what you may have to say. If you have a question or a comment about this article – or any article from the Our Thoughts On blog – we hope you’ll share it with us. After all, a dialogue is an exchange of ideas, and we’d like to hear from you. Email us at [email protected].
Material discussed is meant for informational purposes only, and it is not to be construed as investment, tax, or legal advice. Please note that individual situations can vary. Therefore, this information should be relied upon when coordinated with individual professional advice.