When establishing partnerships, Head Start and Early Head Start grantees must determine whether the partner functions as a contractor or subrecipient. Subrecipients are subject to monitoring against the compliance requirements of the federal program. Contractors are not. This resource summarizes the determination requirements at 45 CFR § 75.351 and will be helpful to grantees who partner with child care and other entities.
|(1) Provides goods and services within normal business operations.||(1) Determines who is eligible to receive what federal assistance.|
|(2) Provides similar goods or services to many different purchasers.||(2) Has its performance measured in relation to whether objectives of a federal program were met.|
|(3) Normally operates in a competitive environment.||(3) Is responsible for programmatic decision-making.|
|(4) Provides goods or services that are ancillary to the operation of the federal program.||(4) Is responsible for adherence to applicable federal program requirements specified in the federal award.|
|(5) Is not subject to compliance requirements of the federal program as a result of the agreement, though similar requirements may apply for other reasons.||(5) In accordance with its agreement, uses federal funds to carry out a program for a public purpose specified in the authorizing statute, as opposed to providing goods or services for the benefit of the pass-through entity.|
Last Updated: March 6, 2020