Direct comparison
Prime Recipient vs. Subrecipient
Prime recipient holds the direct federal award and monitors subrecipients; subrecipient performs part of the scope and reports upward, not to the agency.
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How do Prime Recipient, Subrecipient compare side by side?
The table below compares Prime Recipient, Subrecipient across 9 procurement-relevant dimensions, from relationship to federal agency through can also be a pass-through entity.
Side-by-side comparison
| Dimension | Prime Recipient | Subrecipient |
|---|---|---|
| Relationship to federal agency | Direct award holder; sole point of accountability to the agency | No direct relationship; reports through the pass-through entity |
| Governing determination | Determines (as pass-through entity) whether a downstream party is a subrecipient or contractor, per 2 CFR 200.331 | Is the party being determined to be a subrecipient (not a contractor) under that same test |
| Core obligation | Risk assessment, flow-down of terms, and ongoing subrecipient monitoring (2 CFR 200.332) | Compliance with flowed-down terms; performs a defined portion of the substantive scope of work |
| Reporting direction | Reports to the federal awarding agency | Reports to the pass-through entity, not the federal agency |
| Closeout deadline | 120 calendar days after period of performance ends (awards issued on/after Oct 1, 2024) | 90 calendar days, reporting to the pass-through entity |
| FFATA/SAM.gov subaward reporting | Responsible for reporting subaward actions of $30,000+ | Not the reporting party |
| Single Audit exposure | Subject to Single Audit on its own federal expenditure, incl. amounts passed through | Separately subject to Single Audit on its own federal expenditure, if threshold met |
| Indirect cost rate | Must honor a subrecipient's existing negotiated rate; cannot force the de minimis rate | May use its own negotiated rate, or elect the de minimis rate of up to 15% of MTDC if it has no current negotiated rate (2 CFR 200.414(f)) |
| Can also be a pass-through entity | Always is one, with respect to its own subawards | Only if it issues a further subaward to a lower tier |
Common questions
Common questions about Prime Recipient vs Subrecipient
Can the same organization be a prime recipient on one award and a subrecipient on another?
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Yes. The roles are defined per-award, not as a permanent institutional status.
Is a subrecipient the same as a pass-through entity?
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Not usually, but it can become one with respect to any further subaward it issues to a lower tier, while remaining a subrecipient relative to the prime above it.
Does the subrecipient ever report directly to the federal awarding agency?
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Generally no — financial and performance reporting flows to the pass-through entity above it, which incorporates it into the prime recipient's own reporting.
Who decides whether a downstream relationship is a subaward (subrecipient) or a contract (contractor)?
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The pass-through entity makes that determination, using the case-by-case characteristics test at 2 CFR 200.331 — see Subrecipient vs. Contractor vs. Vendor for the full test. Prime recipient vs. subrecipient, by contrast, describes the two sides of a relationship that has already been determined to be a subaward.
Going deeper
