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Chapters:

3.14 Subrecipient Management and Monitoring

Best Practices

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Subrecipient Pre-Award and Monitoring Procedures
Remedies for Subrecipient Noncompliance

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

Subrecipient Pre-Award and Monitoring Procedures

  • Develop a request for applications (proposals) that clearly defines the work to be accomplished in furtherance of the Federal award purpose(s).
  • Require subrecipients to include in their applications a time-phased milestone plan of action based on clearly-stated accomplishments defined in the proposal.
  • 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, and
  • Actual cost incurred compared to each budget line item with variances explained.

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Remedies for Subrecipient Noncompliance

If a subrecipient fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the pass-through entity may impose additional conditions. However, if it is determined that noncompliance cannot be remedied by imposing additional conditions, the pass-through entity may take one or more of the following actions:

  • 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.
  • Document transactions, agency guidance, performance evaluations, etc., in writing.
  • Keep documentation on hand.
  • Document, document, document! If it isn’t documented, it doesn’t exist!

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