Alpha Covenant Holdings · Government Forms Register · https://alphacovenantholdings.com/forms/two-cfr-200-332
Subrecipient risk assessment and monitoring (pass-through entity's own file; no numbered form)
| # | Step | Who | When | Record | Citation |
|---|---|---|---|---|---|
| 1 | Decide, case by case, whether the party is a subrecipient or a contractor. | pass-through entity | before the agreement | determination memo | 2 CFR 200.331 |
| 2 | Write the required terms into the subaward, including the federal award identification and the 2 CFR 180 flow-down. | pass-through entity | at subaward | subaward agreement | 2 CFR 200.332(a); 2 CFR 180.330 |
| 3 ● | Verify that a subrecipient expected to expend $1,000,000 or more in federal awards in its fiscal year ($750,000 for fiscal years beginning before 1 Oct 2024) had the required audit, and that it was filed. | pass-through entity | each subrecipient fiscal year, within 9 months of its year end | the dated FAC read: whether an SF-SAC is on file, the FY end, the finding references | 2 CFR 200.332(f); 2 CFR 200.501(a); 2 CFR 200.512(a) |
| 4 | Issue a management decision on audit findings that pertain to the subaward within six months of FAC acceptance. | pass-through entity | within 6 months | management decision letter | 2 CFR 200.332(e); 2 CFR 200.521 |
| 5 ● | Report each first-tier subaward of $30,000 or more, with the subrecipient's UEI, by the end of the month following the month of obligation. | prime recipient | monthly | the USAspending subaward rows as published under the prime's UEI | 2 CFR 170 Appendix A; FAR 52.204-10(d) for contracts |
● a dated receipt is the record at this step.
| # | Step | Record | Where |
|---|---|---|---|
| F1 | At each ● step, pull the dated receipt under the party's exact name or UEI and file its receipt id with the transaction record. | receipt id (r_…) on the procurement, subaward or payment record | https://alphacovenantholdings.com/screening |
| F2 | Anchor your own document for the step — the signed check, the certification, the memo — by its SHA-256 beside the receipt. The document stays with you; only its hash is logged. | anchor id (a_…) in the same log as the receipt | https://alphacovenantholdings.com/r/{receipt_id} → Anchor |
| F3 | Note the retention line the file sits under and, once the trigger date is known, the date the period runs to. | the rule's own words and date (FAR 4.703/4.705 or 2 CFR 200.334) | https://alphacovenantholdings.com/api/retention/rules |
| F4 | At period end, keep the signed file statement for the organization: every receipt and anchor, the sources read and which did not answer, the log head they chain to. | one signed page per UEI; its hash and signature verify without Alpha Covenant | https://alphacovenantholdings.com/file/{uei} |
How the dated records are kept, not what they prove. A receipt shows what the official file printed on the read date; an anchor shows a document existed in that exact form on that date; the file statement lists what the file holds. None of them states that a step was done correctly or that the organization is eligible or compliant.
The steps as the regulation and the auditor's program state them, each with its citation. Nothing here is advice or a determination; the agency's text controls. A dated receipt is the record at the marked steps — it shows what the official file printed on the read date, not that the step was done correctly.
Not legal advice, not a compliance determination, not a statement that any filer's certification is true or false. Form numbers and line numbers are as published on the date noted and may be renumbered by their agencies; the official page controls. Audit findings quoted are the auditor's words as filed at the Federal Audit Clearinghouse, cited by report id; they describe a documentation gap, not a conclusion about any party.