Direct comparison
Subaward vs. Subcontract: What's the Difference?
Subaward and subcontract aren't synonyms: the right term depends on whether the prime award is a grant (2 CFR 200) or a federal contract (FAR Part 44).
Side-by-side comparison
| Dimension | Subaward | Subcontract |
|---|---|---|
| Governing regulation | 2 CFR 200 (Uniform Guidance) -- Section 200.1 definitions, Sections 200.331-200.333 subrecipient monitoring | FAR Part 44 (48 CFR Part 44) -- FAR 44.101 definitions, flow-down clause FAR 52.244-2 |
| Type of prime award it flows from | A grant or cooperative agreement (federal financial assistance) | A federal procurement contract (the prime award itself is a contract) |
| Downstream entity is called | Subrecipient | Subcontractor |
| What the downstream entity does | Carries out part of the project's programmatic goals and objectives (2 CFR 200.1) | Furnishes supplies or services needed to perform the prime contract (FAR 44.101) |
| Does the other regime's term even appear in this regulation? | No -- "subcontract" does not appear anywhere in 2 CFR Part 200 | No -- "subaward" does not appear anywhere in the FAR |
| Classification test used | Substance-over-form multi-factor test at 2 CFR 200.331 (subrecipient vs. contractor) | FAR flow-down analysis; consent-to-subcontract thresholds at FAR 44.201-44.204 |
| Pass-through / prime obligations | Pass-through entity must risk-assess and monitor the subrecipient under 2 CFR 200.332-200.333 | Prime contractor must flow down required FAR clauses and, above certain thresholds, get contracting officer consent (FAR 44.201-44.203) |
| Federal reporting | FFATA subaward reporting via SAM.gov for subawards of $30,000 or more | Subcontracting plan/reporting under FAR 52.219-9 for applicable large contracts; no FFATA subaward filing |
| Typical example in research | An NIH R01 or NSF cooperative agreement passing part of the work to a partner university | An SBIR/STTR Phase II contract or DOD R&D contract where the prime issues work to a supplier |
| Common misuse | Frequently mislabeled a "subcontract" in institutional policy and everyday PI conversation | Rarely mislabeled a "subaward" -- the FAR-contract context is usually unambiguous |
Common questions
FAQ
Is a subaward the same as a subcontract?+
No. Which term applies depends on the type of prime award, not on the relationship alone. If the prime award is a grant or cooperative agreement governed by 2 CFR 200 (Uniform Guidance), the instrument used to pass part of the work to another organization is a subaward, and that organization is a subrecipient. If the prime award is itself a federal procurement contract governed by the FAR, the instrument is a subcontract, and the organization is a subcontractor. The two regulatory regimes essentially never overlap on this specific term.
Why do people call subawards "subcontracts"?+
Mostly habit and imprecise institutional language -- "subcontracting out" work is common English usage, and some university offices are even named "Subcontracts Office" for historical reasons. But under 2 CFR 200, the word "subcontract" doesn't exist. Using it for an NIH or NSF subaward can cause confusion about which compliance regime applies: subrecipient monitoring under 2 CFR 200.331-200.333, not FAR consent-to-subcontract rules.
How do I know whether I need a subaward agreement or a subcontract?+
Start with what kind of instrument your own organization received. If your institution's prime award is a grant or cooperative agreement, any downstream instrument passing part of the substantive work to another organization is a subaward, governed by 2 CFR 200.331's subrecipient-vs-contractor test. If your institution's prime award is itself a federal contract -- for example, an SBIR Phase II contract or an R&D procurement contract -- any downstream instrument is a subcontract, governed by FAR Part 44.
Is a subrecipient the same as a subcontractor?+
No -- these track the same subaward/subcontract distinction. A subrecipient receives a subaward under a grant or cooperative agreement and contributes to the project's programmatic goals. A subcontractor receives a subcontract under a federal procurement contract and furnishes supplies or services. This is a different question from classifying an entity's role under a single grant (subrecipient vs. contractor vs. vendor using the 2 CFR 200.331 test) -- see CASRAI's companion comparison for that question specifically.
Going deeper
