Doug,
The distinction between subcontractor (or subawardee, more generally) and vendor is driven by the nature of the work involved. If the relationship is one where the recipient provides a defined function available on a fee-for-service basis to anyone who comes calling, then a vendor relationship is probably appropriate. If the recipient is involved in the project more actively - designing, carrying out the work, determining methods of the work or of analyzing the results, writing reports and publications - then a subaward relationship is likely appropriate.

If the relationship is a subaward, then that is based on having a ‘project lead’ for that component of the research - a ‘subaward PI’ who would be responsible for overseeing the activity associated with the subaward and communicating the local work back to the overall project PI, which requires dedicated effort. If the work is ‘fee-for-service’ and the relationship is as a vendor, then you would not be charging indirect costs, would not have a PI per se, and your relationship to the prime is a procurement function rather than an intellectual arrangement.

If you run a Google search for "subaward vs. vendor", you’ll find many results from institutions with guidance on making this determination.

Roger

Roger Wood, ASSOCIATE VP, PRODUCT MANAGEMENT
xxxxxx@infoedglobal.com | +1.518.713.4200   ext  150


On Oct 14, 2016, at 6:13 PM, dougm (Doug Mounce) <xxxxxx@CRAB.ORG> wrote:

Does a subcontract have to have a designated PI?  We have R-type proposals overlapping with U-type awards, so I have an investigator who could qualify, but I don’t like committing 1% just to have a PI.
 
If there is no PI, would the classification as a vendor or subcontractor be an internal categorization or is there an NIH policy that establishes that distinction in the absence of an investigator?  If we are only managing the data, for example, and not exactly doing the research then should we self-classify as a vendor in any case?  thanks!
 
Doug Mounce, Grants & Contracts Manager, 206-839-1787
 


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