Subrecipient Monitoring
Best Practices
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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.
Financial 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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