Subrecipient vs Contractor Determination Tool -Updated April 2025 JPMA Fully Signed.pdf

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Attached to
WIC Mobile Food App
Solicitation number
NPSS1 FHLA 2027000084 1
Issued by
Colorado

About this file

This document is a Subrecipient vs Contractor Determination Tool updated in April 2025, developed by the Joint Powers Management Authority (JPMA) in Colorado, for use in evaluating whether entities receiving funds under the WIC Mobile Food App contract should be classified as subrecipients or contractors. The tool provides guidance to the administering agency on applying federal criteria to make this determination, which has significant implications for compliance requirements, reporting obligations, and administrative oversight. The document addresses the distinction between these two classifications as they relate to federal funding flowing through state and local government entities, ensuring proper stewardship of public funds and regulatory adherence.

The determination tool establishes a framework for analyzing factors such as the scope of work, degree of independence, performance monitoring, and compliance requirements to classify entities appropriately. This classification is essential for understanding funding flow, establishing proper contract terms, implementing appropriate oversight mechanisms, and ensuring compliance with applicable federal regulations and grant conditions. The tool serves as a reference document to promote consistency in determinations across the WIC program and related initiatives within Colorado's procurement processes.

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v. 2 July 2019 Determination Tool - Print Page 1 of

SUBRECIPIENT VERSUS CONTRACTOR

DETERMINATION TOOL

(Click here for definitions.)

FILL IN ALL BLUE SECTIONS

QUESTION

(Click anywhere in question boxes 1-9 to see related guidance.)

Project Name: WIC Mobile Food App

Start/End Dates of Project: Start 3/1/2027 End 2/29/2028

Source of Funding (General Fund, State, Private, Federal): Federal

Appropriation/Federal Award Identification Number (FAIN) if available: 273CO701W1003

Funding Agency Name and Subagency Name: USDA - Food and Nutrition Administration

Name of Entity Being Evaluated: JPMA Inc.

Catalog of Federal Domestic Assistance (CFDA) Number (for federal funding ), State Statute or other Funding Authority: 10.557

1. Does the funded entity have responsibility for determining particpant elegibility? No

2. Is the project for direct services? Some examples are: IT services, hotel services, loan repayments, consulting services, hotlines. Yes

3. Is the relationship with the funded entity for this particular project more like a partnership in that they are working with us to achieve an outcome and not simply to provide a good or service? No

4. Does the funded entity have its performance measured against whether the objectives of the program (funding objectives) are met? No

5. Does the funded entity have responsibility for programmatic decision-making? No

6. Is the funded entity using the funds to carry out a program of the organization vs.

providing goods or services for programs at CDPHE? No

7. Does the funded entity provide the goods or services within normal business operations? Yes

8. Does the funded entity operate in a competitive environment where many organizations are performing the same work? Yes

9. Does the funded entity provide goods or services that are ancillary to the operation of the program? Yes

FINAL OVERALL

DETERMINATION

Contractor

Signature Date:

Signature Date:

A PRINTED COPY OF THE DETERMINATION TOOL MUST BE COMPLETED, SIGNED AND INCLUDED IN THE PACKET FOR ALL CONTRACTS, INCLUDED WITH STRAIGHT PAYS FOR SERVICES WHEN A COMMITMENT DOCUMENT DOES NOT EXIST, AND INCLUDED WITH PURCHASE

ORDER SUBMISSIONS IN CORE.

YOUR RESPONSE SUBRECIPIENT OR

CONTRACTOR

DETERMINATION

Contractor

Contractor

Contractor

Contractor

Contractor

Contractor

Contractor

Contractor

Contractor

(Select yes or no from the drop down list.) (Based on your response to each question.)

REFER TO THE GUIDANCE WORKSHEET PRIOR TO MAKING THE FINAL

OVERALL DETERMINATION.

The contractor determination must be analyzed as a whole. If there is any doubt as to the relationship and you are requiring the funded entity to meet programmatic requirements, the relationship must be deemed subrecipient.

(Click here to see guidance.)

(Select subrecipient or contractor from drop down list.)

Printed name and title of Program staff completing form

Printed name of Fiscal Services Manager or delegate

Kathryn Gasowski, Fiscal and Operations Manager

Cyril Padilla - WIC Fiscal Administrator

2026-07-23T12:40:33-0600
Kathryn V. Gasowski
2026-07-23T12:41:47-0600
Cyril Padilla

File details come from the government source that posted it. Updated .