Office of Origin: Finance
Responsibility: Chief Financial Officer
Date Adopted: 11-22-11
Dates Reviewed: 2-24-26
Last Date Board Approved: 2-24-26

Lake Michigan College (the College) will comply with Uniform Grant Guidance (2 CFR Part 200) by classifying all funded partnerships as either subrecipient or contractor based on the substance of the relationship, not the title used in the agreement. 

Funded partnerships are those by which the College will be paid – directly or indirectly – with Federal or State (any) funds.

It is the responsibility of the employee signing a funded partnership contract or agreement to use the characteristics stated in Uniform Grant Guidance 2 CFR §200.331 to determine if the College will be operating as a grant subrecipient or a contractor (vendor). This determination must be made in writing, including documenting the basis for that determination. 

If the classification is not clear, the employee should obtain written clarification from the funding partner as well as use the characteristics in Uniform Grant Guidance 2 CFR §200.331 to evaluate the relationship.

All documentation of determination should be maintained with the original contract or agreement.

REFERENCES: Uniform Grant Guidance 2 CFR §200.331