Budgeting: Sub-Contractors

SUBCONTRACTORS

• A contract or Memorandum of Understanding (MOU) is required in order to pay a subcontractor. The contract, generally, will be more specialized and specific than a services agreement.
• Subcontractor invoices against a blanket PO can be approved by the budget authority and grant accounting, and submitted directly to Accounts Payable.

• SOLE-SOURCE CONTRACTING: Typically, the college collects bids from potential contractors /consultants and awards contracts through a competitive bidding process. However, in some instances where grant funds will be used to pay for the contractor services, it may not always be possible to utilize the competitive bidding process (e.g., because the grant program requires that you name the proposed contractor in the application, because there is only one individual / organization who can perform the specified services, etc.).

Different forms are used for contracts of less than $50,000 and for contracts of $50,000 or more. See details about sole-source contracting and get copies of the from ACC’s Purchasing website.

• EXCLUDED PARTIES LIST SYSTEM/DEBARMENT: Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.

If the grant proposal / budget identifies an individual or organization with which ACC will subcontract, it is important to make sure that the individual / organization is not listed on the Excluded Parties List System. It is wise to check the Excluded Parties List System prior to submitting the grant proposal.

Go to https://www.sam.gov and click on “Search Records” button on the right side of the screen. Enter the individual’s or organization’s name and click “search.” Every participant in the grant, from Subrecipient through lower tier participants, must meet the same certification standards.

CFR, Title 2, Subtitle A, Chapter II, §200.213 Suspension and debarment.

CFR, Title 2,Subtitle A, Chapter 1, §180 Guidelines to Agencies on Government wide Debarment and Suspension