A key step in subrecipient monitoring under the Uniform Guidance is determining whether an external entity receiving award funds from UMB is a contractor (aka, vendor) or a subrecipient.
The University of Maryland, Baltimore (UMB), as the pass-through entity (prime applicant or awardee), is responsible for deciding whether an arrangement constitutes a subaward or a procurement. The non-federal entity receiving these pass-through funds is classified as a subrecipient or a vendor based on the nature of the agreement and the criteria in 2 CFR §200.330.
The determination is made at the time of proposal and is reviewed and confirmed before the subaward or procurement is initiated. Use the chart below and the Subrecipient or Vendor Checklist to guide the determination.
Contracting with Individuals
UMB usually does not issue subawards to individuals; a consultant agreement is issued by Procurement. For additional guidance on collaborators, review Collaborator Roles.