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In making this determination, the substance of the relationship is more important than the form of the agreement. Contractors are notified of the purchase requirements and submit a sealed bid to a specified location by a specified date and time. This document is intended to help a recipient of federal funds make a judgment as to whether each agreement it makes, for the disbursement of federal program funds, casts the entity receiving the funds in the role of a subrecipient or a contractor.

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Before entering a contract using federal grant funds, consult your legal counsel and the federal agency administering the awarded funds The ifb defines the quantity, timeframes, product requirements, specifications, and pertinent attachments of the good or service being purchased This checklist is intended to provide talking points for your conversation with your legal counsel to ensure that your agreement is compliant with federal rules.

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The following are examples of sensitive expenditures

If these types of expenses are invoiced, ensure that the subcontract explicitly approved these expenses as allowable per the prime award: Below are essential legal and programmatic areas to prioritize, drawn from industry best practices and regulatory frameworks. Before issuing an agreement to a third party in support of a grant, a recipient must determine whether the third party should be considered a “subrecipient” or a “contractor.” Items purchased with any funds awarded in a subrecipient agreement must adhere to all south carolina state procurement and disbursement regulations in addition to any applicable funding guidelines and requirements.

It is important that the correct agreement determination is made early in the process of preparing a grant application, as overhead treatment and monitoring requirements for these types of agreements vary and will impact the grant budget and, in some cases, the grant narrative.