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Contractors vs. Subrecipients

How to distinguish subrecipients from contractors

Review and save this quick guide for tips to determine subrecipients from contractors, or use the subrecipient vs. contractor determination form.

The Uniform Guidance, 2 CFR Part 200.330 sets forth the criteria to determine whether a collaborator is a subrecipient or a vendor/contractor.

Subrecipients will fit many of these factors:

• The entity will be engaged to perform substantive, programmatic work (e.g. an important or significant portion of the research program or project.)
• The entity is granted some element of programmatic control and discretion over how the work is carried out.
• The entity’s personnel are identified as having a key role in JHU’s proposal.
• The entity participates in designing and/or conducting the work.
• The entity may seek to publish or co-author the results.
• The entity may provide cost-sharing and may sub out some of its work.
• May require prior sponsor approval
• Cannot charge a profit fee
• Non-profits can include appropriate F & A costs
• Terms and condition from the prime award are flowed down
• Subject to Uniform Guidance audit requirements
• University collects its F&A on the 1st $25,000 of a subaward
• Subawards are handled through JHURA

Contractors will fit many of these factors:

• The entity is providing specified services in support of or ancillary to the research program/project
• The entity is not directly responsible for determining research or project results.
• The entity has not significantly participated in the design of the work itself.
• The entity provides these goods and services in its normal business operations and markets its services to a range of customers; creates procurement relationship.
• The entity has little or no independent decision-making in the design and conduct of the work being completed
• The entity would not be author or co-author, but may receive attribution.
• The entity will perform work that involves the performance of routine or repetitive tests or activities. Normally operates in a competitive environment.
• Typically does not require sponsor approval.
• For-profits can charge a fee.
• Generally, terms and conditions of the prime award are not flowed down to a vendor (except for a few federal regulations (e.g. debarment, fraud, etc.). However, the contract is subject to procurement regulations.
• Not subject to Uniform Guidance audit requirements.
• University collects its F&A on the entire amount of contract.
• Contractor agreements are handled through Purchasing.


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