As the primary recipient, ultimate responsibility for any federal funds rests solely with Drake University. The federal government holds the recipient, not the subrecipient, responsible for compliance.

Subawards are described in the grant application and funded in the approved awards. Otherwise, prior approval from the granting agency must be obtained before issuing a subrecipient award.

A subcontract or subaward is an agreement that is written under the authority of, and consistent with, the terms and conditions of a prime award and authorizes a portion of the research or substantive effort to be performed by another organization, which is a separate legal entity. The involvement of the subcontractor organization is that of actually performing a portion of the programmatic activity as opposed to simply providing a routine service to the prime award recipient.

The following sections outline the identifying characteristics of subcontracts and monitoring:

  • Subcontract vs. Vendor
  • Subaward Monitoring

Subcontract vs. Vendor

One or more of the following factors indicate a subcontract:

The other organization which,

  • Has responsibility for programmatic decision-making
  • Contributes to the scholarly/scientific conduct of the project as described in the statement of work for the prime award
  • Uses the funding to carry out its own program, as compared to providing goods or services for a Drake program
  • Provides matching funds or cost sharing
  • Requires considerable discretionary judgment and the unique expertise of the other organization in the conduct of the work
  • Measures performance against the objectives of the prime award
  • Considers its investigator as a co-author of publications resulting from the work performed under the prime award
  • Has responsibility for adherence to applicable federal program compliance

One or more of the following factors indicate a vendor:

The other organization which,

  • Provides goods and services within normal business operations
  • Provides similar goods and services to many different purchasers
  • Operates in a competitive environment
  • Provides goods and services that are ancillary to the operation of the federal program
  • Is not subject to compliance requirements of the federal program

Learn more: Consultants/Contractors

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