Characteristics of a Vendor vs. Subcontractor
CHARACTERISTICS | SUBRECIPIENT | PURCHASE ORDER | CONSULTANT |
---|---|---|---|
AGREEMENT IS WITH | An entity, usually a university | A business | An Individual with a specialized skill |
RICE ISSUING OFFICE | OSR Issues a subcontract with flow down of terms in prime award; research collaboration detailed in proposal | Procurement issues a PO which includes OMB A-110, Attachment A provisions as needed | OSR issues a Professional Services Agreement (PSA) with OMB A-110 addendum (for PSAs paid from R funds) |
SELLS TO MANY OR A COLLABORATOR | Generally provides a portion of the sponsored award because an intellectual contribution is required (programmatic decision making) | A business | An individual with a specialized skill |
OWNERSHIP OF IP | Shared ownership of intellectual property created during the conduct of the research | No ownership of Intellectual Property | Work made for hire: Rice owns any IP created/explicit terms incorporated to this effect |
PI/PD OR SERVICE PROVIDER/SELLER | Has a Principal Investigator or Project Director | May have a project manager/typically no specified PI | Typically an individual with a specialized skill |
CONTRACTUAL MECHANISM [COST REIMBURSEMENT VS. FIXED PRICE] | Agreement refers to scope of work and references prime award/ level of effort is identified for the key personnel and a line item budget is specified | Agreement refers to project specifications | Agreement includes a very specific statement of work and deliverables |
PUBLICATION | Publication encouraged as part of the collaboration | Publication unlikely | Generally publication is not likely/ Rice PI review is stipulated/ Agreement stipulates work made for hire |
PAYMENT TERMS | Determines how to use the financial support (funding) provided by the subagreement; most typically a cost reimbursement agreement; less often a fixed price agreement. | Financial assistance not provided; entity is paid negotiated amount (fixed price/ fixed fee agreement) | Usually a fixed price agreement |
ACCOUNTABILITY | Is accountable for the use of funds provided | Only accountable if agreement is cost reimbursement | Only accountable if agreement is cost reimbursement |
COMPETITIVE BID OR SOLE SOURCE | In many cases the subrecipient is the sole source of the deliverables/ typically a non-profit entity | Operates in a competitive environment | In many cases the consultant is the sole source capable of performing the required service/ the service is the consultant’s business |
PROGRAMMATIC RESPONSIBILITY | The deliverables provided are central to the award’s purpose | Generally provides goods and services that are ancillary to the operation of the program | The deliverables provided are necessary to conduct the research |
SUBJECT TO INCORPORATION OF TERMS AND CONDITIONS IN PRIME AWARD | Has responsibility to adhere to applicable Federal program compliance requirements [i.e. flow down of prime award terms and conditions] | Is not subject to the compliance requirements of the program such as effort reporting, rebudgeting and allowability rules | Responsibility to adhere to Federal program compliance [i.e. human subjects or animal protocol] may be required |
PERFORMANCE MEASURE | Has its performance measured against whether the objectives of the Federal program are met | Has performance measured against quality of goods or services delivered | Performance is based deliverables |
SUBJECT TO OMB A-113 | Agreement subject to audit and possibly OMB A-133 if the subrecipient spends $500,000 or more in a year in Federal awards | Contract does not have audit clause | No audit clause, depending upon prime award |
EFFORT CERTIFICATION | Subrecipient required to certify that work is completed in accordance with the terms and conditions of the award and Federal rules and regulations | Vendor generally not required to certify effort, although Davis Bacon may apply | Payment based on a schedule of deliverables or hours/days worked |
INVOICE FORMAT | Invoices required to be in Rice’s format | Invoices are in the vendor’s format, not Rice’s format | Invoices are required to contain information on hours/days worked and deliverables and other provisions set forth in the PSA. |
ENTITY IS IDENTIFIED IN PROPOSAL | Generally needed for a subrecipient and the subrecipient is identified in proposal; prior approval is typically required to add a subcontractor if added after the award is issued | Generally vendor is not identified in proposal, although documentation for proposed equipment costing more than $25,000 must be available | Generally the need for the consultant is identified in the proposal |
SPONSOR APPROVAL REQUIRED | Prior approval typically required to add a subrecipient not included in the proposal | Sponsor approval may be required for purchases not identified in award budget if they are more than 10-25% of the total award | Need for consultant typically identified in the proposal; addition of a consultant after the award is made may require sponsor approval if it entails a change in scope |
F&A | Generally, F&A recovery by Rice only on the first $25,000 | Generally, no F&A on equipment, while other purchases are subject to full F&A | Generally, F&A recovery on full amount of professional services |