I think the subrecipient-or-contractor decision has to be made on the basis
of their actual role on the project. If, as you say, they're just providing
goods or services that are within their normal scope of business, then I'd
lean on the contractor side unless they were actually contributing in some
way to the design or conduct of the research - i.e., guiding development or
implementation rather than just responding to an RFQ and manufacturing to
spec. If that's all they're doing, then they have to be classed as vendors
or contractors.

But that also means they probably wouldn't meet the brief for a research
teaming role. Usually when they use that phrase, they do mean partners who
are actively participating in the design, testing, or implementation of
something. Or at least they're telling the research team what they need and
then cooperating in the design of that new thing. Again, it comes down to
participation in the research.

The cost-share question is a separate issue. It can be contributed by
vendors/contractors (if they see value in the partnership), but it's harder
to get than it is from a subrecipient. But I'd be wary of making someone a
sub just because you want them to contribute to the cost-sharing. It could
lead to a ding at audit about consistent application of the applicable
policy.

Michael Spires, M.A., M.S., CRA
(He/him/his)
Research Development Officer, Sciences
The Research Office
Oakland University
256 Hannah Hall
244 Meadow Brook Road
Rochester, MI 48309-4451
(248) 370-2207
xxxxxx@oakland.edu
Past President, National Organization of Research Development Professionals

Oakland University has taken steps to slow the spread of COVID-19.
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-----Original Message-----
From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> On
Behalf Of Mark Lynam
Sent: Friday, April 24, 2020 12:57
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: [RESADM-L] Determination | Subrecipient or Contractor

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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