Hello;

We have a faculty member applying to the DOE’s EERE Advanced Vehicle Technologies Research FOA.

Here’s the backdrop to the question:  Subrecipient OR Contractor?

1)	The solicitation encourages research teaming arrangements with industry partners.
2)	The solicitation requires cost-sharing.

When applying the template commonly used to determine whether an entity is a subrecipient or contractor, most of the industry partners would be considered contractors (goods and services provided are within normal business operations; provides goods/services to many different purchasers; operates in competitive environment; etc.)

In all things other than the requirement for cost-sharing, these partners would be contractors.  But, because of the cost-sharing requirements, they’re being designated as subrecipients.  As such, there’s the risk assessment, monitoring, de-minimis, and other compliance associated with that designation.

What’s your advice?  What would your designation be?

___________________________
Mark Lynam MBA, CRA, CFRA, CPRA
Sr. Coordinator, Office of Research
Tennessee Technological University
TTU Box 5164 | Cookeville, TN 38505
931.372.3673

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