Federal Grant Reporting Requirements: A Compliance Reference

The Foundation: 2 CFR Part 200

Every federal grant to a nonprofit is governed by 2 CFR Part 200, the Uniform Guidance. Published by the Office of Management and Budget (OMB), it establishes the rules for financial management, allowable costs, procurement, reporting, and audit requirements that all federal awarding agencies must enforce.

The Uniform Guidance was first enacted in December 2014, consolidating eight prior OMB circulars (including A-110 and A-133). It was substantially revised in 2024. If your organization receives federal funding, your finance staff need to know this document.

Agency-specific requirements layer on top of the Uniform Guidance. HHS, HUD, DOJ, USDA, and other agencies publish program regulations and award terms that add requirements beyond the baseline 2 CFR 200 rules.

Required Financial Reporting: The SF-425

The SF-425 (Federal Financial Report) is the standard form for financial reporting on federal grants. It captures cumulative expenditures by budget period, unliquidated obligations, and program income.

SF-425 reports are typically due 30 days after each calendar quarter ends:

Q1 (January-March): due April 30
Q2 (April-June): due July 30
Q3 (July-September): due October 30
Q4 (October-December): due January 30

The final SF-425 is due 90 days after the grant period ends.

Recipients submit SF-425s through the awarding agency’s grants management system, not through Grants.gov (which handles applications, not post-award reporting). Submission portals vary by agency: HHS uses the Payment Management System and GrantSolutions, HUD uses IDIS or DRGR depending on program, DOJ uses JustGrants, and so on. Each system requires separate credentials and has its own interface.

Agency-Specific Reporting Systems

Grants.gov is the federal portal for grant applications. Post-award management, reporting, and fund drawdowns happen in separate agency systems.

Key systems by agency:

HHS: The Payment Management System (PMS) is used for fund drawdowns on many HHS grants. Organizations request funds through PMS and the system maintains a running accounting of cash received versus expenditures. Some HHS grants also require reporting in GrantSolutions.

HUD: Community Development Block Grant (CDBG) and HOME programs use IDIS (Integrated Disbursement and Information System) for activity setup, fund drawdowns, and performance reporting. Disaster Recovery grants use DRGR (Disaster Recovery Grant Reporting).

DOJ: Office of Justice Programs grants use JustGrants for post-award management and reporting.

USDA: Rural Development programs use multiple systems; specific requirements are in each award agreement.

Managing multiple federal awards means maintaining active credentials in several portals and knowing which reporting deadlines belong to which system.

Programmatic Reporting

Programmatic (performance) reports describe what the grant-funded program accomplished: activities completed, outputs produced, and outcomes achieved. Frequency varies by agency and program: many require semi-annual or annual reports, submitted through the agency’s grants management system.

Some programs require performance reporting through dedicated federal data systems in addition to narrative reports. AmeriCorps grantees report into the Volunteer Generation Fund reporting system. HUD Continuum of Care grantees report into HMIS (Homeless Management Information System). These program-specific requirements are specified in the Notice of Funding Opportunity and the award agreement.

Time and Effort Reporting

Personnel costs are often the largest budget line on federal grants and receive significant audit scrutiny. Under 2 CFR 200.430, salaries charged to federal awards must be supported by records reflecting actual time worked on grant-funded activities.

Acceptable documentation includes personnel activity reports, time and attendance records, or other records that capture how an employee’s time was distributed across funding sources. Records must be maintained for all employees whose salaries are charged to federal awards, including employees who split time between grant-funded and non-grant activities.

Reconstructed time records (filled in after the fact from memory) are a compliance risk. Auditors look for contemporaneous documentation.

Single Audit Requirements

Organizations that expend $750,000 or more in total federal awards in a fiscal year must have a Single Audit, per 2 CFR 200.501. The threshold applies to the total across all federal awards, not per-grant.

The Single Audit has two components: an audit of the organization’s financial statements and an audit of compliance with requirements applicable to each major federal program. The independent auditor issues a Schedule of Expenditures of Federal Awards (SEFA) and, if compliance findings exist, a schedule of audit findings.

The completed Single Audit package must be submitted to the Federal Audit Clearinghouse within 9 months of the fiscal year end. Late submissions are a compliance finding.

Organizations approaching the $750,000 threshold should track federal expenditures carefully. Crossing the threshold mid-year triggers the Single Audit requirement for the entire fiscal year.

Record Retention

The baseline record retention requirement under 2 CFR 200.334 is 3 years from the date the final expenditure report is submitted for the award. For grants with no final financial report, the 3-year clock starts from the date the final payment is received.

Exceptions that require longer retention:

Real property and equipment records: 3 years after final disposition
Records subject to litigation, claims, audits, or investigations: retain until resolved
Some programs specify longer retention in their award terms

Records that must be retained include financial records, supporting documentation (invoices, receipts, payroll records), grant agreements, sub-award records, and programmatic documentation.

FFATA Reporting

The Federal Funding Accountability and Transparency Act (FFATA) requires prime award recipients to report information on subawards of $30,000 or more and executive compensation into USASpending.gov through the FSRS (FFATA Subaward Reporting System). Reports are due by the end of the month following the month the subaward was made.

Organizations that pass federal funds through to sub-recipients are prime recipients subject to FFATA, regardless of their overall federal expenditure level.

Staying Compliant Across Multiple Awards

Most federal compliance failures come from tracking gaps, not intentional misuse. Missing an SF-425 deadline because it was in an Outlook calendar that did not sync is a compliance finding. A time record filled in two months after the fact is a compliance finding.

Grant management software that centralizes reporting calendars, deadline alerts, restricted fund ledgers, and supporting documentation by grant record reduces these risks. GrantPipe’s Growth tier ($49/month) handles unlimited grant lifecycles with restricted fund tracking and compliance documentation, without requiring a consultant to configure. For organizations managing multiple federal awards, having all grant records, deadlines, and financial data in one place is the baseline for maintaining compliance.

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Uniform Guidance (2 CFR 200): The OMB's consolidated administrative rules for federal grants and cooperative agreements with states, local governments, tribes, and nonprofits. Effective December 2014, last revised 2024.

Single Audit: An annual independent audit required under 2 CFR 200.501 for organizations expending $750,000 or more in federal awards in a fiscal year. Covers both financial statements and federal award compliance.

SF-425: Standard Form 425, the Federal Financial Report used to report expenditures and obligations on federal grants. Required quarterly and at grant closeout.

Indirect Cost Rate: The percentage applied to direct costs to recover an organization's administrative overhead on federal grants. Must be either negotiated with a federal cognizant agency or use the 10% de minimis rate available under 2 CFR 200.414.

Direct Cost: Costs that can be specifically identified with a federal award, such as salaries of grant-funded staff, supplies purchased for grant activities, or travel directly related to grant work.

FFATA: Federal Funding Accountability and Transparency Act. Requires prime award recipients to report information on subawards above $30,000 and executive compensation into USASpending.gov.

“The organizations that get into compliance trouble usually are not misusing funds. They are missing deadlines or failing to maintain the time records that support personnel costs charged to federal awards. Both are fixable with the right systems.”

Angel Campa , Founder at GrantPipe

What reports are required for federal grants?

Federal grants subject to 2 CFR Part 200 typically require: quarterly SF-425 Federal Financial Reports due 30 days after each quarter ends, annual or semi-annual programmatic performance reports per agency requirements, a final SF-425 due 90 days after the grant period ends, and a final performance report. Some agencies add program-specific reporting through their own portals.

What is the SF-425 and when is it due?

The SF-425 is the Federal Financial Report showing cumulative expenditures against the approved budget. It is typically due 30 days after each calendar quarter ends (April 30, July 30, October 30, January 30). The final SF-425 is due 90 days after the grant period ends.

What triggers a Single Audit?

Expending $750,000 or more in total federal awards in a single fiscal year triggers the Single Audit requirement under 2 CFR 200.501. The threshold applies to the cumulative total across all federal sources, not per-award. Organizations just below the threshold should track federal expenditures carefully because crossing it mid-year creates an audit obligation for that entire fiscal year.

Frequently Asked Questions

What is the Uniform Guidance?

The Uniform Guidance is the federal Office of Management and Budget's (OMB) consolidated set of rules governing grants and cooperative agreements with non-federal entities. Published at 2 CFR Part 200, it covers allowable costs, procurement, financial management, reporting, and audit requirements. All federal awarding agencies must follow it.

When is a Single Audit required?

A Single Audit is required for any non-federal entity that expends $750,000 or more in federal awards during its fiscal year, per 2 CFR 200.501. The audit must be completed by a licensed independent auditor and submitted to the Federal Audit Clearinghouse within 9 months of the fiscal year end.

What is the SF-425 form?

The SF-425 (Federal Financial Report) is the standard form used to report financial status on federal grants. It shows cumulative expenditures, unliquidated obligations, and program income. It is typically due 30 days after each quarter and 90 days after the grant period ends.

How long must nonprofits retain federal grant records?

The baseline under 2 CFR 200.334 is 3 years from the date the final expenditure report is submitted. Records for real property and equipment must be retained for 3 years after final disposition. Some programs specify longer retention periods in their award terms.

What is time and effort reporting?

Time and effort reporting is the documentation requirement that personnel costs charged to federal grants be supported by records reflecting the actual time worked on grant-funded activities. Per 2 CFR 200.430, these records must be maintained for all employees whose salaries are charged to federal awards.

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