Subrecipient Monitoring Under 2 CFR 200.332

If your organization passes federal award money through to another organization — a subgrant, a subcontract under a grant, a pass-through to a partner agency — you're a pass-through entity, and 2 CFR 200.332 spells out exactly what you owe each subrecipient. This isn't optional paperwork — it's the obligation auditors test against every year, and it's where a large share of Single Audit findings originate.

1. Subrecipient's name (must match the name associated with its unique entity identifier)
2. Subrecipient's unique entity identifier (UEI)
3. Federal Award Identification Number (FAIN)
4. Federal award date
5. Subaward period of performance start and end date
6. Subaward budget period start and end date
7. Amount of federal funds obligated in the subaward
8. Total amount of federal funds obligated to the subrecipient, including the current obligation
9. Total amount of the federal award committed to the subrecipient
10. Federal award project description, as required by FFATA
11. Name of the federal agency, pass-through entity, and awarding official contact information
12. Assistance Listings title and number, with the dollar amount made available under each
13. Identification of whether the federal award is for research and development
14. Indirect cost rate for the federal award, including whether a de minimis rate is used

Before and during the subaward, you must evaluate each subrecipient's risk of noncompliance — including fraud risk — to decide how closely to monitor it. Factors typically considered include the subrecipient's prior experience with federal awards, results of previous audits, whether it has new staff or a new system, and the size and complexity of the award. A subrecipient with a clean audit history and experienced staff warrants lighter monitoring than one that's new, has had findings before, or is managing an unusually large award relative to its size.

Monitoring isn't a one-time check at award setup. § 200.332(e) requires you to monitor the subrecipient's activities throughout the award period, which includes:

• Reviewing financial and performance reports the subrecipient submits
• Following up when a report reveals significant problems, and ensuring the subrecipient takes appropriate corrective action
• Issuing a management decision for audit findings that pertain to the subaward you issued
• Following up to ensure the subrecipient actually resolves audit findings

§ 200.332(g) requires you to verify that a subrecipient meeting the Single Audit threshold ($1,000,000 in federal expenditures in a fiscal year) actually got audited as required under Subpart F, and to follow up when it didn't. This is one of the easier checks to automate: the subrecipient's audit history is public in the Federal Audit Clearinghouse under its EIN.

For fiscal years beginning on or after October 1, 2024, the Single Audit expenditure threshold rose from $750,000 to $1,000,000 (2 CFR 200.501, revised April 2024). A subrecipient whose federal expenditures fall between those two figures no longer triggers a Single Audit at all.

That has a direct consequence for the monitoring obligation above: fewer subrecipients will have a Single Audit for you to verify in the first place. The free, independent assurance a Single Audit used to provide disappears for everyone now under the higher threshold — meaning your own direct monitoring under § 200.332(d)–(e) is doing more of the work it used to share with an auditor.