{"id":"hosp-06-subrecipient-monitoring","version":"2026-10-06","stamp":"Template. Written against the public text of the standard cited; the organization adopts, edits and owns it as its protocol. Every threshold, identity, hold or disclosure decision belongs to the organization. We report the findings against the protocol — counts, dates, states — nothing more. Not legal advice, not a compliance determination, not a consumer report.","title":"Federal grants — subrecipient and contractor verification and monitoring","org":"Hospital research offices, academic medical centers, public-health departments, any pass-through entity","owner_role":"Director, Sponsored Programs / Grants (owner); Principal Investigators (data); Internal Audit (test)","scope":"Every subaward and every contractor paid with federal-award funds, before the covered transaction and at each budget period.","frequency":"Before subaward/contract; at each budget period renewal; monthly roster read while active.","procedure":["Collect the subrecipient's legal name as registered in SAM and its UEI (2 CFR 25 requires it). Without a UEI the subaward cannot be issued; do not substitute a name read for the UEI read.","Before the covered transaction: one dated record of SAM.gov exclusions by UEI (2 CFR 180.300 method (a)); on the same record, the Federal Audit Clearinghouse single-audit status and findings, and the subrecipient's federal award rows from USAspending — side by side, dated, not merged into a judgment.","Risk assessment under 200.332(b): the Grants Director records the factors considered (prior audit findings, new/experienced, system changes) and the monitoring plan. The dated record is one input; the assessment is the Director's.","Monthly while active: the subrecipient and any named contractors stay on the roster read; changed lines route to the Grants Director.","Audit follow-up (200.332(d)(3)): when FAC shows a new audit with findings, record the management decision within the period the regulation sets; keep the FAC read that triggered it.","Keep every record with the award file for the Single Audit sample."],"not_decided":"Subrecipient risk level, monitoring intensity, allowability, and whether a finding is resolved — the pass-through entity decides and documents; the record shows what the files printed.","changes":[["2026-10-06","First issue."]],"standards":[{"standard":"2 CFR 200.332 — requirements for pass-through entities (risk assessment, monitoring, audit follow-up)","url":"https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/subject-group-ECFR031321e29ac5bbd/section-200.332"},{"standard":"2 CFR 200.214 / 180.300 — suspension and debarment verification before a covered transaction","url":"https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/section-200.214"},{"standard":"2 CFR 200.501 — Single Audit threshold; Federal Audit Clearinghouse","url":"https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-F"},{"standard":"Compliance Supplement Part 3 §I and §M — what the auditor tests","url":"https://www.whitehouse.gov/omb/information-for-agencies/circulars/"}],"measures":[{"measure":"Pre-award verification","computed_as":"subawards/contracts with a SAM read dated on or before execution ÷ subawards/contracts","data_source":"award system; receipt created_at","threshold":"set by your protocol; the finding is the number"},{"measure":"UEI completeness","computed_as":"active subrecipients with UEI on file ÷ active subrecipients","data_source":"award system","threshold":"set by your protocol; the finding is the number"},{"measure":"Risk assessment on file","computed_as":"active subawards with a dated 200.332(b) assessment ÷ active subawards","data_source":"grants files","threshold":"set by your protocol; the finding is the number"},{"measure":"Audit follow-up timeliness","computed_as":"FAC findings with a management decision inside the regulatory period ÷ findings","data_source":"FAC reads; decision log","threshold":"set by your protocol; the finding is the number"},{"measure":"Sample readiness","computed_as":"minutes to produce the dated verification for an auditor-sampled transaction","data_source":"HOSP-08 drill","threshold":"set by your protocol; the finding is the number"}],"records":[{"record":"Pre-award SAM/FAC/USAspending record with award file","kept_by":"Grants","retention":"3 years from final expenditure report (2 CFR 200.334) or longer per HOSP-08"},{"record":"Risk assessments and monitoring plans","kept_by":"Grants Director","retention":"same"},{"record":"Management decisions on audit findings","kept_by":"Grants Director","retention":"same"}]}