Subrecipient Agreement Checklist

How to Use This Checklist

Review every sub-award document against this checklist before the agreement is signed. A sub-award with missing provisions must be corrected before execution - not after the program is underway.

This checklist covers: (1) provisions required under 2 CFR 200.332(a), (2) additional provisions that reduce monitoring risk, and (3) program-specific additions that may be required depending on the federal program.

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Part 1: Required Provisions Under 2 CFR 200.332(a)

These provisions are not optional. Their absence is an audit finding.

Federal Award Identification

• Federal Agency Name The name of the federal agency that made the prime award to your organization. Why required: The subrecipient must be able to trace its federal funding to the source agency. This is required on the SEFA and for any future audit of the subrecipient’s federal expenditures.

• Federal Award Identification Number (FAIN) The unique award identifier assigned to the prime award. Why required: The FAIN ties the sub-award to the prime award in federal tracking systems. Without it, the subrecipient cannot correctly identify the award on its SEFA.

• Federal Award Date The date the prime federal award was made to your organization. Why required: Required element under 2 CFR 200.332(a)(1).

• Federal Assistance Listing (CFDA) Number and Program Name The Assistance Listing number (e.g., 93.576) and the official program name from SAM.gov. Why required: The subrecipient needs this to correctly identify the program on its SEFA. Incorrect or missing Assistance Listing numbers are a common SEFA audit finding.

• Pass-Through Entity’s Award Number The identifier your organization assigns to this sub-award. Why required: This is the “pass-through entity’s identifying number” that must appear on the subrecipient’s SEFA. It allows auditors to trace the sub-award back to your organization’s award records.

• Whether the Award is R&D A statement of whether the federal award is classified as Research and Development. Why required: R&D awards have specific audit and reporting implications. Required disclosure under 2 CFR 200.332(a)(1).

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Period of Performance

• Start Date and End Date The specific beginning and end dates of the subrecipient’s period of performance under this sub-award. Why required: Expenditures outside the period of performance are unallowable. The subrecipient must know the authorized window.

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Approved Budget

• Approved Budget Amount The total sub-award amount and, if applicable, the budget by category. Why required: The subrecipient must track expenditures against an approved budget. Without a documented budget, there is no baseline for budget-to-actual comparison.

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Compliance Requirements

• Statement that the Subrecipient Must Comply with 2 CFR Part 200 A clear statement that the subrecipient is subject to the applicable requirements of 2 CFR Part 200, including cost principles, administrative requirements, and audit requirements. Why required: The pass-through entity is responsible for flowing down applicable federal requirements. A sub-award without this statement does not adequately communicate the subrecipient’s obligations.

• Program-Specific Compliance Requirements Any compliance requirements from the prime award’s notice of award, the OMB Compliance Supplement, or the applicable federal statute that are specific to the program. Why required: General 2 CFR 200 compliance is the baseline; program-specific requirements add to it. If the prime award imposes eligibility criteria, matching requirements, or specific reporting obligations, these must be in the sub-award.

• Allowable Cost Provisions Reference to the applicable cost principles (2 CFR 200 Subpart E) and any award-specific restrictions on allowable costs. Why required: The subrecipient needs to know which cost principles apply to determine what it can charge to the sub-award.

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Reporting Requirements

• Financial Reporting Schedule The frequency (monthly/quarterly/semi-annual), format, and due dates for financial reports from the subrecipient. Why required: Monitoring requires timely financial reports. Without a documented schedule, lateness is not a contract violation and is harder to follow up on.

• Programmatic Reporting Schedule The frequency, format, and due dates for progress and programmatic reports. Why required: Program performance monitoring requires periodic reports. The reporting obligation must be contractual.

• Notification of Significant Issues Requirement for the subrecipient to promptly notify the pass-through entity of any significant problems, delays, legal matters, or anticipated compliance issues. Why required: The pass-through entity cannot monitor what it does not know about. Early notification requirements enable timely response.

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Access and Monitoring

• Access to Records A provision granting the pass-through entity, the federal awarding agency, the Inspector General, and the Government Accountability Office access to all records pertaining to the sub-award for audit or monitoring purposes. Why required: Without this provision, access requests may be contested. 2 CFR 200.332(a)(4) explicitly requires this provision.

• Record Retention Requirement The requirement to retain all records pertaining to the sub-award for the minimum retention period - typically three years from the date the pass-through entity submits its final expenditure report, or longer per program requirements. Why required: Subrecipients must retain records for the same duration as the pass-through entity. Without this contractual requirement, records may be destroyed before the retention period expires.

• Monitoring Authorization Authorization for the pass-through entity to conduct monitoring, including site visits, desk reviews, and financial audits of the sub-award. Why required: Monitoring without explicit contractual authorization may be challenged. This provision establishes the monitoring relationship.

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Audit Requirements

• Single Audit Notification If the subrecipient may expend $1,000,000 or more in federal awards in a fiscal year, a statement that the subrecipient is required to obtain a single audit and submit it to the Federal Audit Clearinghouse. Why required: 2 CFR 200.332(a)(5) requires this notification. The pass-through entity is responsible for ensuring subrecipients are aware of their single audit obligations.

• Requirement to Permit Audit Access If the subrecipient is required to have a single audit, a provision requiring it to permit audit access to records. Why required: Aligns with access to records and ensures the subrecipient understands its audit obligations.

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Other Required Provisions

• Suspension and Debarment Certification Reference to the requirement that the subrecipient is not debarred, suspended, or otherwise excluded from participation in federal programs. Why required: The pass-through entity is responsible for not funding debarred entities. This provision documents that the obligation was communicated.

• Termination Provisions Conditions under which the sub-award may be terminated and the procedures for termination. Why required: Clear termination provisions protect both parties and align with federal award terms.

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