PantherExpress

Services Agreements

Office of Research vs. Purchasing Services

bullet Review the overview below or go directly to the this checklist to determine which office to approach for assistance.

Background

Under federal grants there are different administrative and audit requirements for subrecipients (financial assistance) and suppliers (procurement actions). Because of these differences, University agreements must be funneled to and administered by either the Office of Research or the Purchasing Services Department. Determining which of these two offices should handle the agreements is sometimes difficult.

Office of Research or Purchasing Services Department

Along with several other duties, the Office of Research is authorized to enter into agreements with subrecipients, for example, other institutions of higher education. In contrast, the Purchasing Services Department is able to manage the procurement process with suppliers. The following information should help clarify the terms “subrecipient” and “supplier” and thus provide direction regarding which office handles each type of agreement.

Subrecipient or Supplier

The United States Code of Federal Regulations, Title 2, Subtitle A, Chapter II, Part 200 (the “Uniform Guidance”) attempts to distinguish between subrecipients and suppliers (also known as "contractors"), thus §_200.330(c) states:

“(c) Use of judgment in making determination. In determining whether an agreement between a pass-through entity and another non-federal entity casts the latter as a subrecipient or a contractor, the substance of the relationship is more important than the form of the agreement.”

and

“…the pass-through entity must use judgment in classifying each agreement as a subaward or a procurement contract.”

See the chart below for further clarification:

Office of Research versus Purchasing Services Department
Differences Between Subrecipients and Suppliers

Office of Research – manages agreements with subrecipients

 

Purchasing Services – manages agreements with suppliers (contractors)

Uniform Guidance §_200.330(a) states that:

A subaward is for the purpose of carrying out a portion of a federal award and creates a federal assistance relationship with the subrecipient. 

Characteristics that support the classification of the non-federal entity as a subrecipient include whom the non-federal entity:

Uniform Guidance §_200.330(b) states that:

A contract is for the purpose of obtaining goods and services for the non-federal entity’s own use and creates a procurement relationship with the contractor.

Characteristics indicative of a procurement relationship between the non-federal entity and a contractor are when the contractor:

 

Determines who is eligible to receive which type of federal assistance.

Provides goods and services within normal business operations.

Has its performance measured in relation to whether the objectives of the federal program are met.

Provides similar goods and services to many different purchasers.

Has responsibility for programmatic decision making.

Normally operates in a competitive environment.

Is responsible for adherence to applicable federal program requirements specified in the federal award.

Provides goods or services that are ancillary to the operation of the federal program.

Uses the federal funds to carry out a program of the organization as compared to providing goods and services for a program of the pass-through entity.

Is not subject to compliance requirements of the federal program.

Checklist to Determine Which Office to Approach for Assistance - Office of Research or Purchasing Services

Office of Research is a central department charged with administrative responsibility for all University research and related activities involving extramural sponsorship. The areas supported by Office of Research staff include information services, project and proposal development assistance, and grants and contracts administration for pre-award and selected post-award tasks. All proposals submitted by University personnel must be transmitted to and reviewed by Office of Research staff to assure adherence to internal and external policies and procedures. The Office of Research is responsible for assuring that proposals submitted for external funding and awards made to the University meet sponsor and University requirements.

Purchasing Services’ mission is to obtain the overall best value for purchases of goods and services University-wide; provide efficient, effective purchasing processes; assist departments in complying with federal, state and local laws; implement a system of sound internal controls, and monitor compliance; provide opportunities for Diverse Business Enterprises (DBE’s), and; provide excellent customer service to the University community. Purchasing Services analyzes departmental spending patterns to identify opportunities or savings and assists departments with specialized or complex purchases.

Questions

  • Do the requested services significantly contribute to the development of the science?

  • Are the requested services part of a collaborative research project with another institution of higher education?

  • Is a substantive portion of the research being transferred to the potential contractor?

  • Does the Notice of Award or award document providing funding have “flow down” provisions that must be applied to subcontracted goods or services?

  • Will the contractor conduct research involving human subjects or animals under this agreement?

  • Will the contractor conduct research involving rDNA or ionizing radiation under this agreement?

  • Will University materials or data be given to contractor for contractor to use for conduct of research under this agreement?

If you answered yes to any of the questions above then you must contact the Office of Research at 412-624-7400 or the Grant or Contract Officer assigned to your department.

Please note that it is possible that after Office of Research review, agreements may then be referred to Purchasing Services for processing.

 

If you answered no to all of the questions above thenyou must contact Purchasing Services for all other purchases of goods, equipment and services, such as:

  • consulting services with companies or individuals
  • programming services
  • information management
  • website development
  • lab testing
  • computers
  • microscopes
  • major equipment
  • equipment loans
  • office and laboratory supplies

Consult Purchasing Guides for instructions on purchasing goods, services, and event-related reservations.


 


Copyright © | Financial Information Systems | Revised: 27-Apr-2017