To determine whether NC State should issue an entity a subaward to a “subrecipient” or a procurement contract to a “contractor”, follow the governing regulation Uniform Guidance 2CFR 200, Section 200.330 Subrecipient and Contractor determinations. In order to remain consistent, NC State has adopted this guidance to determine the status of a subrecipient versus a contractor for all sponsored projects, no matter the funding type (federal, state, or industry funding).

Under the Uniform Guidance, Section 200.330 (a), characteristics that support a classification of subrecipient include:

Other indications that an organization should be deemed a subrecipient include when:

A contract is used for obtaining goods and services for NC State’s own use and creates a procurement relationship with the contractor.

The characteristics of a “contractor” under the Uniform Guidance, Section 200.330 (b), include:

  1. Provides goods and services within normal business operations;
  2. Provides similar goods and services to many different purchasers;
  3. Operates in a competitive environment;
  4. Provides goods or services that are ancillary (secondary) to the operation of the program; and
  5. Is not subject to compliance requirements of the Federal program.

The Uniform Guidance, Section 200.330 (c), instructs us to use judgement in making a determination.

For additional information on subaward collaborations and vendors/consultant services, go to Consultants and Subawards.