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Subrecipient Monitoring

Best Practices

Jump to Section:
Subrecipient Pre-Award and Monitoring Procedures
Subrecipient Legal Agreement/Contract
Award Agreement Penalties & Sanctions

Listed below are best practices that pass-through organizations may consider in developing policies and procedures around subrecipient monitoring.

Subrecipient Pre-Award and Monitoring Procedures

  • Develop Request for Application with detailed Statement of Work (SOW).
  • Require the subrecipient to provide a time-phased milestone plan of action based on accomplishments defined in their SOW.
  • Integrate budget line items into the performance plan.
  • Require performance/progress reports and supporting documentation with monthly invoices. Performance reports should discuss:
  • Milestones achieved/to be achieved
  • Any significant problem, issues, or concerns
  • Timely accomplishments and delays
  • Actual cost incurred compared to each budget line item with variances explained.

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Subrecipient Legal Agreement/Contract

  • Award information: CFDA title, agreement number, amount of award, award name, name of Federal agency
  • Requirements imposed by law or regulation, special conditions
  • Approved budget line items
  • Agreement conditions:
  • Period of performance;
  • Level of authorized funding from budget;
  • Cost, billing, and payment (cost reimbursable);
  • Records and audits;
  • Key personnel;
  • Subcontracting and assignment consent;
  • Termination and disputes;
  • Subrecipient invoice format:
  • Monthly and cumulative columns
  • Incurred cost should be the same as the budget line items from SF 424a as rows
  • Line item expenses should have an internal crosswalk to natural accounts
  • Show total authorized funding
  • Show backlog: authorized funding less costs to date.
  • Financial Reporting—Frequency (at a minimum, quarterly, and at the end of the award).

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Award Agreement Penalties & Sanctions

  • Withholding of disbursements or further awards
  • Disallowance of cost
  • Suspension/termination of award
  • Suspension/Debarment
  • Civil lawsuit, or
  • Criminal prosecution.

information iconFinancial Management Tip

To proactively monitor subrecipients:

  • Read award/contract documents carefully.
  • Ask for explanation and clarity; don’t assume.
  • Request a deviation or exception if needed as issues arise.
  • Document transactions, agency guidance, performance evaluations, etc., in writing.
  • Keep documentation at hand.
  • Document, document, document! If it isn’t documented, it doesn’t exist!

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