In making the determination of 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 of the characteristics will be present and sound judgment should be used in determining
whether an entity is a subrecipient or a vendor.
SUBRECIPIENT RELATIONSHIP
A subrecipient relationship exists when a third party:
➢ performs a substantive portion of the programmatic work, which is defined as project
activities that are a primary purpose of the prime award;
➢ has responsibility for programmatic decision making;
➢ uses the funds provided to carry out a program of the subrecipient as opposed to
providing goods or services for a program of the Prime institution;
➢ is responsible for helping the Prime institution meet the requirements of its prime award;
➢ has its performance measured against whether the objectives of the prime award are met;
or
➢ has responsibility for adherence to applicable program compliance requirements.
VENDOR RELATIONSHIP
A vendor relationship exists when a third party:
➢ provides professional services or highly technical advice, such as a consultant;
➢ provides goods or services as a part of its normal business operations;
➢ provides similar goods or services to many different purchasers;
➢ operates in a competitive environment;
➢ is responsible only for meeting the requirements of the contractual services contract
between the Prime institution and the vendor;
➢ provides goods or services that are ancillary to the operation of the program; or
➢ is not subject to compliance requirements of the program.
CHECKLIST – Use the checklist on the next page to assist in making this determination.
Questions may also be directed to OSP at 328-9540.
EAST CAROLINA UNIVERSITY
CHECKLIST FOR DETERMINATION OF VENDOR/SUBRECIPIENT
ECU PRINCIPAL INVESTIGATOR:
SPONSORING AGENCY:
CONTRACT/GRANT FUND #:
NAME OF SUBRECIPIENT ORGANIZATION:
RELATIONSHIP DETERMINED:
[
] VENDOR [ ] SUBRECIPIENT
YES
NO
VENDOR
Does the organization operate in a competitive environment?
Does the organization provide goods and services within normal
business operations to different purchasers?
Does the organization provide goods or services that are ancillary
to the operation of the program?
Are services being performed routine services that could be
performed for the general public or general research/scientific
community rather than unique to the project?
Is the contribution made to the project one of services performed
rather than independent research?
Is the organization free from programmatic compliance
requirements?
SUBRECIPIENT
Is the organization using funds to carry out a program of the
organization rather than providing goods and services to ECU’s
program?
Is the organization free to decide how to carry out the activities of
the program?
Is work being performed unique to the project and designed
specifically to enhance the scientific research goals and outcomes
of the program?
Does organization have distinct deliverables to deliver to the
research goals of the project?
Will organization contribute deliverables with little direct
supervision from ECUD’s PI?
Is there an identified investigator at the organization?
Does the organization have publishing rights and responsibilities?
Will the organization have rights to resulting patentable or
copyrightable technology?
Does the organization make measurable, significant, scientific
contributions to the final report or product?
Is the organization required to adhere to applicable program
compliance requirements?