• I. General
  Information
• II. Preaward
  Requirements
• III. Postaward
  Requirements
• IV. Organization
  Structure
• 
  V. Appendices

Chapters:

• 3.1 Payments
  • Using the Grant Payment Request System
  • Payment Transaction Timeline
  • Understanding the Withholding of Funds
  • Draw Only What is Needed
  • Managing Interest Earned
  • Understanding the Cash Management Improvement Act
    of 1990
  • How to Manage Interest Income
• 3.2 Availability of Funds
  • Availability of Funds
  • Obligation of Funds
  • Expenditure of Funds
  • Criteria for Award Extension
  • Project Extension Guidance
• 3.3 Matching or Cost Sharing Requirements
  • Match Requirements
  • Types of Match
  • Source and Type of Funds
  • Timing of Matching Contributions
  • Records for Match
  • Waiver of Match
• 3.4 Program Income
  • Introduction
  • Accounting Processes for Program Income
  • Examples of Program Income
  • Procedures for Recovery of Costs Incurred
• 3.5 Adjustments to Awards
  • Grant Adjustment Notice
  • Prior Approval of Certain Costs
  • Reprogramming of Funds
• 3.6 Costs Requiring Prior Approval
  • Introduction
  • Responsibility for Prior Approval
  • Procedures for Requesting Prior Approval
  • Listing of Costs Requiring Prior Approval
• 3.7 Property Standards
  • General Principles for Property Acquisition and Management
  • Screening and Property Management Systems
  • Equipment Ownership, Use, Management, and Disposition
  • Equipment and Supplies Acquired With Grant Program Funds
  • Federal Equipment
  • Replacement of Equipment
  • Supplies
  • Real Property Acquired With Federal Funds
  • Retention of Property Records
  • Intangible Property
  • Copyrights
  • Data Produced Under A Federal Award
  • Patents, Patent Rights, and Inventions
• 3.8 Procurement under Awards of Federal Assistance
  • Procurement Standards—
    General Guidance
  • OJP Construction Requirements
• 3.9 Allowable Costs
  • Introduction
  • Compensation for Personal Services
  • Conferences and Workshops
  • Travel
  • Project Site
  • Printing
  • Publication
  • Duplication
  • Other Allowable Costs
• 3.10 Conference Approval, Planning, and Reporting
  • Introduction
  • Policy Overview
  • Definitions
  • No Prior Approval Required
  • Prior Approval Required
  • Event Planning Guidance
  • Conference Cost Categories
  • Post Event Reporting
  • FAQs
  • Resources
• 3.11 Indirect Costs
  • Introduction
  • Federal Indirect Cost Rate—Negotiated Agreements
  • Establishment of Indirect Cost Rates
  • Indirect Cost Distribution Bases
  • Cost Allocation Plans—Central Support Services
  • Lobbying Costs and the Indirect Cost Pool
  • No Approved Plan
  • Approval of Indirect Cost Rates for Subrecipients
• 3.12 OJP's Confidential Funds
  • Introduction
  • Approval Authorities
  • Confidential Funds Certification
  • Written Procedures
  • Informant Files
  • Regional Information Sharing Systems (RISS) Program
  • Accounting and Control Procedures
• 3.13 Unallowable Costs
  • Introduction
  • Unallowable Cost Categories
• 3.14 Subrecipient Management and Monitoring
  • Introduction
  • Subrecipient Monitoring
  • Best Practices
• 3.15 Reporting Requirements
  • Introduction
  • SF-425 Federal Financial Reports
  • Progress/Program Reports
  • Government Performance and Results Act
  • Reports Required under the Federal Funding Accountability and Transparency Act
• 3.16 Retention and Access Requirements for
  Records
  • Retention of Records
• 3.17 Remedies for Noncompliance
  • Introduction
  • Termination
  • Hearings and Appeals
  • Effects of Suspension and Termination
• 3.18 Closeout
  • Introduction
  • First Step
  • Closeout of Discretionary/
    Categorical and Block/Formula Awards
  • Refund of Federal Grant Monies and/or Program Income
  • Failure to Remit Funds Owed
• 3.19 Audit Requirements
  • Audit Threshold
  • Audit Objectives
  • Audit Reporting Requirements
  • Audit Submission Requirements
  • Submission of Audit Reports
  • Audit Report Confirmation Requests
  • Due Dates for Audit Reports
  • Audit Compliance
  • Resolution of Audit Reports
  • Top 10 Audit Findings (Fiscal Year 2014)
  • Audit of Subrecipients
  • Technical Assistance
  • Full-Scope Auditing
  • Commercial (For-Profit) Organizations
  • Failure to Comply
  • Office of Inspector General Regional Offices
• 3.20 Grant Fraud, Waste,
  and Abuse
  • Introduction
  • Detection of Grant Fraud
  • Penalties of Grant Fraud
  • Fraud Indicators
  • Common Grant Fraud Schemes
  • Ways to Reduce the Risk of Fraud
• 3.21 Payment Programs
  • Introduction
  • Bulletproof Vest Partnership
  • State Criminal Alien Assistance Program
  • Northern Border Prosecution Initiative and Southwest Border Prosecution Initiative

3.14 Subrecipient Management and Monitoring

Best Practices

Jump to Section:
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.

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