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Subrecipient vs. Vendor Determination Checklist
Federal Program Name
CODA Number
Name of Contractor (Vendor) or Grantee (Subrecipient)
Active Contract Numbers (if any)
Please complete the following
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How to fill out subrecipient versus vendor determination

How to fill out subrecipient versus vendor determination:
01
Identify the purpose of the agreement: Determine the specific reason for entering into a subrecipient versus vendor relationship. If the agreement is mainly to carry out a portion of a federally funded program or project, it is likely a subrecipient relationship. However, if the agreement is primarily for the procurement of goods or services, it is considered a vendor relationship.
02
Gather relevant documentation: Collect all necessary documents, such as the agreement or contract, budget details, scope of work, and any other supporting materials. These documents will help in making an accurate determination.
03
Review the nature of the requirements: Analyze the tasks and responsibilities outlined in the agreement. If the recipient has significant programmatic decision-making authority and carries out the project alongside the donor, it suggests a subrecipient relationship. On the other hand, if the recipient is simply providing goods or services as specified by the donor, it indicates a vendor relationship.
04
Assess the financial involvement: Examine the financial aspect of the agreement. A subrecipient is typically awarded a portion of the funds and assumes a certain level of financial risk. They may have their own budget and can incur cost overruns. In contrast, a vendor is paid for specific goods or services according to predetermined terms and does not assume financial risks or manage their own budget.
05
Consider monitoring and oversight: Evaluate the level of oversight and monitoring required for the agreement. Subrecipients often receive a higher level of monitoring and technical assistance compared to vendors. If ongoing programmatic and compliance monitoring is necessary, it indicates a subrecipient relationship.
06
Consult regulatory guidelines or grant requirements: Check any applicable regulatory guidelines or grant requirements that provide specific criteria for determining subrecipient versus vendor relationships. These guidelines can offer additional clarity on the distinction between the two.
Who needs subrecipient versus vendor determination?
Organizations or individuals involved in federally funded programs or projects where funds are being distributed to perform specific tasks or provide services may need to determine whether they are acting as a subrecipient or vendor. This determination helps clarify roles, responsibilities, and compliance requirements, ensuring proper financial management and accountability within the funding agreement. Both the entity providing the funds (the donor) and the entity receiving the funds (the recipient) need to understand whether the relationship falls under subrecipient or vendor guidelines.
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What is subrecipient versus vendor determination?
Subrecipient versus vendor determination is the process of determining whether an entity receiving funds is a subrecipient (provides services as a partner) or a vendor (provides goods or services for the program).
Who is required to file subrecipient versus vendor determination?
The entity providing the funds or grants is required to file the subrecipient versus vendor determination.
How to fill out subrecipient versus vendor determination?
To fill out the subrecipient versus vendor determination, the entity must gather information about the nature of the relationship with the recipient, the purpose of the funds, and the expected outcomes.
What is the purpose of subrecipient versus vendor determination?
The purpose of subrecipient versus vendor determination is to accurately classify recipients of funds to ensure proper oversight, reporting, and compliance with regulations.
What information must be reported on subrecipient versus vendor determination?
The information reported on the subrecipient versus vendor determination includes the name of the recipient, the amount of funds received, the purpose of the funds, and the nature of the relationship.
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