[wiaattorneys] Sub recipient vs. Vendor

  • From: "Pomerantz, Jane C. (GC-LI)" <jpomerantz@xxxxxxxxxxx>
  • To: <wiaattorneys@xxxxxxxxxxxxx>
  • Date: Fri, 23 Sep 2005 10:33:56 -0400

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

Does your Department monitor eligible providers for accessibility?


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.

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