Pass Through Accounting Procedures - Table 1
Definitions and Characteristics to Consider in the Determination of Subrecipient or Vendor Relationships
These definitions and characteristics are taken from OMB Circular No. A-133, revised June 24, 1997, because the most
occurrences of subrecipient arrangements will occur in the administration of federal grant funds. There may be some
rare occasions where a subrecipient relationship will exist outside of federal funds, and the subrecipient coding should be
used in those instances also.
SUBRECIPIENT:
A non-federal entity that expends federal awards received from a pass-through entity to carry out a
federal program, but does not include an individual that is a beneficiary of such a program. A subrecipient may also be a
recipient of other federal awards directly from a federal awarding agency. A subrecipient:
- Determines who is eligible to receive federal financial assistance.
- Has its performance measured against whether the objectives of the federal program are met.
- Assumes Has responsibility for programmatic decision making.
- Assumes Has responsibility for adherence to applicable federal program compliance requirements.
- Uses the federal funds to carry out a program of the organization as compared to providing goods or services for a program of the pass through entity.
VENDOR:
A dealer, distributor, merchant, or other seller providing goods or services that are required for the conduct of a federal
program. These goods or services may be for an organization's own use or for the use of beneficiaries of the federal program.
A vendor:
- Provides the goods and services within normal business operations.
- Provides similar goods or services to other purchasers.
- Operates in a competitive environment. (This may not be the case in when one state agency purchases goods or services from another.)
- Provides goods or services that are ancillary to the operation of the federal program.
- Is not subject to compliance requirements of the federal program.
NON-SUBRECIPIENT/NON-VENDOR:
These are usually casual transactions between two agencies usually for convenience purposes, that do not fit the definitions
above. For example, DPB allows the Cabinet Secretary's staff to use DPB copy machines for large copy jobs. DPB charges the
Cabinet Secretary five cents per copy made. DPB records the charge as an expenditure refund recovery or credit, as
appropriate, depending on whether the year has closed. An expenditure credit would be booked against the machine rental and/or
copy supplies depending on whether the year has closed.
