Subrecipient vs Vendor Determination

Determining whether an external entity is acting as a subrecipient or a vendor is an important classification decision in sponsored research. This determination affects how an agreement is structured, the applicable compliance obligations, monitoring responsibilities, and reporting requirements throughout the lifecycle of a sponsored project.


The classification must be made carefully and consistently, as misclassification can result in compliance risks, delays in agreement execution, and audit issues. The Office of Research Administration (ORA) provides guidance and oversight to support appropriate determinations in alignment with sponsor and institutional requirements.

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  • Understanding the Difference

    The criteria for determining whether an entity is considered a subrecipient or a contractor/consultant is defined in 2 CFR § 200.331 and requires evaluation based on a number of characteristics listed below. Not all characteristics must be present. If unsure, please contact ORA for review and disposition.

    Criteria Subrecipient Vendor / Consultant
    Scope of Work Has performance measured against whether the objectives of the federal program were met. Has responsibility for programmatic decision-making. Uses federal funds to carry out a program for a public purpose specified by statute. Provides goods or services within normal business operations. Provides similar goods or services to many different purchasers. Operates in a competitive environment. Provides goods or services ancillary to the operation of the federal program.
    Terms and Conditions Bound by the terms and conditions contained within the prime award. Not bound by the terms and conditions of the prime award.
    Financials Provides a detailed budget subject to federal cost principles (2 CFR 200 Subpart E). Paid based on hourly, daily, or deliverable rates. May include travel costs if applicable. Typically paid upon milestones or deliverables.
    Facilities & Administrative (F&A) Costs Applies F&A costs consistent with a federally negotiated rate agreement or the 10% de minimis rate under 2 CFR 200.414. F&A rates do not apply. All costs are included in the established rate.
    Salary Limitations Subject to salary limitations contained in the prime award and flowed down. Not subject to salary limitations in the prime award.
    Compliance Requirements Must comply with all applicable compliance requirements contained in the prime award. Not subject to the prime award compliance requirements.
    Intellectual Property Actively engaged in the research. May co-author publications or seek protection for inventions. Not entitled to publication rights or intellectual property.
    Handled By Office of Research Administration (ORA) Purchasing (Academic/Research) or UHealth Supply Chain Services

  • Why the Determination Matters

    Correctly classifying an external entity as a subrecipient or vendor is essential because it drives:

    • The type of agreement issued (e.g., subcontract vs. service agreement)
    • The required contractual terms and flow down provisions
    • Monitoring and oversight responsibilities
    • Financial and technical reporting requirements
    • Compliance with sponsor regulations and university policy

    Incorrect classification can result in noncompliance with sponsor terms, increased audit risk, and delays in project implementation.

  • Role of ORA in the Determination Process

    ORA supports departments and investigators by providing guidance on subrecipient versus vendor determinations. ORA reviews proposed classifications to ensure alignment with:

    • Sponsor requirements and federal regulations
    • University of Miami policies and procedures
    • The project’s scope of work and funding structure

    ORA may request additional information from departments or investigators to clarify the external entity’s role and responsibilities prior to agreement execution.

  • Responsibilities of Departments and Investigators

    Departments and Principal Investigators (PIs) play a key role in supporting accurate determinations by:

    • Clearly defining the scope of work for external collaborators
    • Identifying the level of responsibility and autonomy assigned to the external entity
    • Providing documentation or justification when classification questions arise
    • Working with ORA to resolve classification questions early in the process

    Early coordination helps prevent delays and supports timely agreement review and execution.

  • Supporting Compliance Throughout the Project Lifecycle

    Once a subrecipient or vendor classification is established, it informs ongoing oversight throughout the project lifecycle. For subrecipients, this may include additional monitoring, reporting, and compliance checks. For vendors, standard procurement and payment processes apply.

    For questions regarding subrecipient versus vendor determinations or related agreement considerations, investigators and departments are encouraged to consult ORA early in the planning and submission process.

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