WE are dealing with the issue of whether eligible service providers are vendors or sub recipients for purposes of accessibility. So far what I have found is that under 29 CFR Part 99-audits of states, local gov'ts and non-profits it would appear that they would be vendors. But, and I think it's a big one, under 29 CFR Part 37 the regs are clear that they would be sub recipients. The regulation in Part 37 defines recipient much more broadly than is the case for the financial and administrative requirements of our grant programs or the definition of recipient in the WIA regulation. Also the definitions of recipient under WIA and Part 37 are different. Has anyone dealt with this? Can an entity be a vendor under one reg and a sub recipient under another? Does your Department monitor eligible providers for accessibility? JP Jane C. Pomerantz Deputy Chief Counsel Department of Labor & Industry Phone: 717-787-4186 Fax: 717-787-1303 Wisdom is knowing the right road to take. Integrity is taking it.