New Federal guidelines require completion of new form

Screenshot of online form. Text: Miami University. Please provide the following information: Subrecipient/contractor name. Project title. Prime sponsor (i.e., name of funding agency). Miami Principal Investigator. SUBRECIPIENT - All of the characteristics listed might not be present in all cases. In determining whether an entity should be classified as a subrecipient or a contractor, the substance of the relationship is most important. Please check all that apply: Scope of work represents an intellectually significant portion of the overall programmatic effort and is measured against the objectives of the Federal program. There is an identified Principal Investigator for the subrecipient who has responsibility for making programmatic decisions. Proposed work could result in the development of intellectual property. Is expected to author or co-author publications on the results of its work.

The new Uniform Administrative Requirements for Federal Awards (commonly referred to as Uniform Guidance) mandates that recipients of Federal funds document their process of classifying third parties included in grant proposals as either subrecipients or contractors. In order to meet this requirement, OARS and Grants & Contracts have developed an online form that must be completed, saved as a PDF, and attached to your eSPA proposal record for all proposals that include funds going to a third party.

A separate form is required for each entity to be included in your proposal budget. Although this requirement is for funds from Federal sources, consistency principles dictate that we apply this same scrutiny to all proposals, whether the sponsor is Federal or non-Federal. Nothing is new in the criteria for determining whether a third party is classified as a subrecipient or a contractor — the only thing new is the requirement to document our process for making the determination.

A link to the online form can be found in the Proposal Preparation Resources section of the OARS website, as well as on the Budget and Subcontract pages in eSPA. If you have any questions about this new form, please contact your OARS representative. Use of this form will begin immediately.


Photo of contractor by Amanda Bicknell, from the FEMA Photo Library, via Wikimedia Commons, used under public domain.

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