Usually one negotiates a subcontract with an entity where there are
tangible deliverables and/or reports are required.  Consultants rarely make
significant (quantitatively speaking, not qualitatively, which can be
significant) contributions in time and effort (otherwise they would be
cited as personnel or one would negotiate a subcontract to pay a portion of
their salary).  Do you have specific information you can share with us
about this vendor or is this just a generic question?

-- Evelyn

At 09:43 AM 7/21/99 -0700, you wrote:
>...As far as whether a contract is a subcontract or a consultant, I believe
>that if you have a written contract whereby a third party is responsible
>for certain direct costs and is entitled to indirect cost recovery for
>their portion, and as long as you have a contract that meets the NIH
>guidelines and criteria this would be considered a subcontract and not a
>consultant.  See the Guidelines for Establishing and Operating Consortium
>Grants for more details.  Hope this helps.
>
>Candace
>
>>Our indirect cost agreement specifies that we can not charge indirect
>>costs on the portion of major subcontracts in excess of $25,000.  Am
>>looking for a  more specific definition of “major subcontract”.  Have
>>referenced A-133 section 210 and found the information to be vague –
>>what a surprise.
>>Was wondering what others use as criteria for determining whether a
>>vendor is considered a major subcontractor or simply a consultant.
-----------------------------------------------------------------------------
Evelyn J. Ford, Manager, Accounting Operations
Office of Research Support Services
School of Medicine, University of Pennsylvania
356 Anatomy-Chemistry Building
36th Street and Hamilton Walk
Philadelphia PA 19104-6061
voice 215.573.1395   fax 215.573.8802
xxxxxx@mail.med.upenn.edu

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