Subcontract Versus Purchase Order

Questions? Contact SCM Response Team

Overview

Information about subcontracts and purchase orders.

Subrecipient Versus Contractor Determination

Sometimes there is confusion between whether a transaction should be considered a subaward (subrecipient) or a purchase of services (purchase order/contractor).

Federal Uniform Guidance emphasizes the responsibility of the prime awardee in the identification of a subrecipient vs. a contractor in the Code of Federal Regulations §200.330 – Subrecipient and Contractor Determinations. For each award, on individual basis, UCSF must determine which type of agreement – subaward or procurement contract – is appropriate for the planned award expenditure and be able to show that determinations are made consistently from award to award.

 

When does subcontract or purchase order apply?

CriteriaSubcontractPurchase Order
The Principal Investigator (PI) is primarily responsible for determining whether a transaction is a subaward under his/her grant/contract/cooperative agreement, or a purchase of services. However, the Research Services Coordinator helping to develop the proposal should also be reviewing all third-party involvement to determine if it is categorized appropriately as a Contractor (i.e., Consultant, Independent Contractor and service contracts) that should be handled as a procurement or a subrecipient that would be issued a collaborative research subaward through the Research Management Service (RMS) Subcontracts Team.
  • Transfers programmatic effort (e.g., programmatic decision-making) to a third party
  • Has a PI
  • Provides for collaboration with UCSF on work related to the award
  • Includes flow down of award terms and conditions required by the prime agreement
  • UCSF must monitor the entity to ensure ongoing compliance with terms and conditions
  • Does not have a PI
  • Does not have a collaborative element
  • Does not include flow-through requirements from the prime award
  • The supplier supplies similar goods and services to many different purchasers

Things I Need to Know or Do

UCSF's decision must be made at the time of proposal. The primary responsibility for this decision falls to the Principal Investigator. However, research administrators should review all third-party involvement to ensure the appropriate categorization as either a procurement or collaborative subaward.

It is important to remember that both subawards and procurement contracts have a defined scope of work, a detailed budget and are formal agreements between the Regents of the University of California and a legal third-party entity.

BearBuy Form to Use

  • If a purchase of services, use the BearBuy Professional Services/Independent Consulting Form
  • If a subaward, consult UCSF’s Office of Sponsored Research (OSR) on next steps.

Other Useful References

 

Things I need to know or do

UCSF's decision must be made at the time of proposal. The primary responsibility for this decision falls to the Principal Investigator. However, research administrators should review all third-party involvement to ensure the appropriate categorization as either a procurement or collaborative subaward.

It is important to remember that both subawards and procurement contracts have a defined scope of work, a detailed budget and are formal agreements between the Regents of the University of California and a legal third-party entity.

 

BearBuy Form to Use

  • If a purchase of services, use the BearBuy Professional Services/Independent Consulting Form
  • If a subaward, consult UCSF’s Office of Sponsored Research (OSR) on next steps.

Contacts

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