Subcontract Versus Purchase Order

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.

Version Date: May 2018 

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