The key issue in subcontracting to a company is whether or not the company, by
nature of the services performed, is a subrecipient or a vendor.  We have
prepared a "vendor subcontract" with commercial terms and conditions similar to
the back of our purchase order which distinguishes the vendor subcontractor
from a subrecipient.  We also have a standard subrecipient subcontract which
conforms to A-110 requirements.  This avoids confusion on the part of auditors
who look at subcontracts expecting to find the A-133 audit requirements.  By
definition, a subrecipient must be performing the research effort alongside the
principal investigator in a role equivalent to a co-investigator.  This usually
only occurs when there is a collaboration with another faculty member at
another institution.  Most private company situations are for the performance
of some ancillary service necessary to the research effort (even though they
may be of a large dollar value).

James F. Ball
Associate Director
The Ohio State University Research Foundation