Subrecipient Monitoring Checklist
TLDR
Pass-through entities are responsible for what their subrecipients do with federal funds. The monitoring obligation is not a check-in — it is a documented system of pre-award assessment, compliance terms, ongoing review, and audit verification. This checklist covers every required step under 2 CFR 200.332, organized for the organization doing the monitoring.
Before You Start: Confirm Subrecipient Classification
The monitoring requirements in this checklist apply to subrecipients — not contractors. Before issuing any payment to a downstream organization, determine which category applies using the 2 CFR 200.331 five-factor test.
Subrecipient indicators (all five factor into the classification):
- The entity determines who is eligible for the federal assistance
- The entity’s performance is measured against federal program objectives
- The entity has responsibility for programmatic decision-making
- The entity is responsible for federal program compliance requirements
- The entity uses the funds to carry out its own program, not provide goods/services
Contractor indicators:
- Provides goods or services in normal business operations
- Provides similar goods or services to many purchasers
- Operates in a competitive market environment
- Is not subject to federal program compliance requirements
Document the classification determination in writing before the sub-award is issued.
Part 1: Pre-Award Risk Assessment
Required under 2 CFR 200.332(b). Must be completed before the sub-award is made.
Financial Stability
- Reviewed the subrecipient’s most recent financial statements (audited if available)
- Assessed the organization’s financial stability: adequate liquid reserves, no significant debt concerns, no indication of financial distress
- Documented the financial stability assessment in the risk file
Prior Audit History
- Searched fac.gov for the subrecipient’s single audit history (if applicable)
- If single audits exist, reviewed findings from the most recent two years
- Assessed whether prior findings are relevant to the programs under the proposed sub-award
- Documented the audit history review with the date searched and findings noted
Experience with Federal Awards
- Assessed the subrecipient’s prior experience administering federal awards of similar type and size
- For first-time federal grantees or organizations new to the specific program: noted as higher risk on the experience factor
- Prior performance with your organization (if applicable) factored into the assessment
Financial Management Systems
- Assessed whether the subrecipient’s accounting system can track federal funds separately from other revenue
- For higher-risk organizations: reviewed the subrecipient’s financial policies and procedures
- Noted whether the subrecipient has experience with the relevant compliance requirements (e.g., 2 CFR 200 cost principles, specific program requirements)
Key Personnel Qualifications
- Assessed the qualifications of individuals who will manage the sub-award (program and financial staff)
- Noted any staff vacancies in key positions that create risk
Overall Risk Rating
- Assigned an overall risk rating (low / medium / high) based on the factor-by-factor assessment
- Documented the rationale for the rating
- Determined the monitoring approach based on the risk rating (see Part 3)
- Completed and filed the pre-award risk assessment before issuing the sub-award
Subrecipient Monitoring Checklist
A complete subrecipient monitoring checklist covering pre-award risk assessment, agreement requirements, ongoing monitoring, and documentation — organized for the pass-through entity. Delivered by email.
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