Templates | Pre-Award-Subrecipient vs Contractor Checklist 1

Subrecipient vs Contractor Checklist 1

Pdf Summary

This document is a three-page checklist from the City of North Las Vegas designed to help determine whether an outside entity engaged with a federal award recipient should be classified as a subrecipient or a contractor. <br /><br />The instructions direct users to complete Sections 1 and 2, which outline distinct characteristics of subrecipient and contractor relationships. The classification is based on the greater number of marked characteristics, emphasizing the substance of the relationship over the formal agreement form. Section 3 is for providing written justification for the determination. A copy of the completed form should be kept in the relevant subaward or procurement file.<br /><br />Key definitions from the Uniform Guidance (2 CFR Part 200) explain essential terms:<br /><br />- Recipient: A non-Federal entity receiving a federal award directly, excluding subrecipients.<br />- Non-Federal entity: State/local governments, Indian tribes, institutions of higher education, or nonprofit organizations carrying out federal awards.<br />- Subaward: An award from a pass-through entity to a subrecipient to perform part of a federal program.<br />- Subrecipient: A non-Federal entity receiving a subaward to perform part of a federal program, distinct from beneficiaries.<br />- Contract/Contractor: A legal arrangement wherein a non-Federal entity purchases goods or services for the federal project or program.<br /><br />Section 1 describes subrecipient characteristics such as having discretion to identify eligible beneficiaries, responsibility for programmatic decisions, performing work for a public purpose specified by statute, not earning a profit from the arrangement, and often contributing matching funds.<br /><br />Section 2 describes contractor traits including providing goods/services within normal business operations to multiple customers in a competitive environment, offering ancillary services for the federal program, and potentially earning a profit.<br /><br />The form ends with space for final determination (subrecipient or contractor) and a justification narrative, emphasizing that the nature of the relationship—not just the contract wording—dictates classification. The checklist is to be completed, signed, and reviewed by authorized personnel.

Keywords

subrecipient classification

contractor classification

federal award recipients

Uniform Guidance 2 CFR Part 200

City of North Las Vegas checklist

subaward definitions

non-Federal entity roles

programmatic decision responsibility

matching funds contribution

contractor profit potential