Authority/Reference(s) Uniform Grant Guidance (UGG) ; UGMS Part IV
Revision Date October 15, 2018


DFPS must comply with the Federal Uniform Grant Guidance (UGG) and the State Uniform Grant Management Standards (UGMS) to categorize entities as either subrecipient, recipient or vendor (contractor).

Subrecipient, Recipient, or Vendor (Contractor) Determination

The appropriate determination must be made during the procurement planning phase or when federal or state guidelines change. The determination process involves various stakeholders that may include: contract staff and leadership, program staff, federal funds coordinator, and legal services; with the final determination from the COS director or designee.

When a relationship is determined to be a subrecipient/recipient, DFPS Finance confirms if the service will be federally funded (subrecipient) or state-funded (recipient).

In situations where the determination of an entity's category is unclear, contract staff, in conjunction with appropriate stakeholders, must study the substance of the relationship between DFPS and the entity.

Multi-Use Determination Form 438

To guide the determination of the contracting relationship, DFPS staff are required to complete Form 438, Multi-Use Determination. Once the Form 438 is completed and submitted to COS, the COS Director, in collaboration with appropriate stakeholders, will study the substance of the relationship and document the final determination.

In addition to determining the contractor relationship, Form 438 is also used to document critical information that supports business processes related to a procurement and resulting contracts, including assisting with: 

  • Information technology components;
  • Categorizing administrative services vs. client services; and
  • Utilizing IMPACT for payments.