Federal grants — subrecipient and contractor verification and monitoring
Template version 2026-10-06 — adopted by: ____________________  effective: __________  owner: Director, Sponsored Programs / Grants (owner); Principal Investigators (data); Internal Audit (test)

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.

STANDARDS SERVED
- 2 CFR 200.332 — requirements for pass-through entities (risk assessment, monitoring, audit follow-up) — https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/subject-group-ECFR031321e29ac5bbd/section-200.332
- 2 CFR 200.214 / 180.300 — suspension and debarment verification before a covered transaction — https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/section-200.214
- 2 CFR 200.501 — Single Audit threshold; Federal Audit Clearinghouse — https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-F
- Compliance Supplement Part 3 §I and §M — what the auditor tests — https://www.whitehouse.gov/omb/information-for-agencies/circulars/

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
1. 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.
2. 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.
3. 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.
4. Monthly while active: the subrecipient and any named contractors stay on the roster read; changed lines route to the Grants Director.
5. 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.
6. Keep every record with the award file for the Single Audit sample.

MEASURES (findings reported monthly; the threshold for each is your protocol's)
- Pre-award verification: subawards/contracts with a SAM read dated on or before execution ÷ subawards/contracts. Data: award system; receipt created_at. Threshold: your protocol: ________
- UEI completeness: active subrecipients with UEI on file ÷ active subrecipients. Data: award system. Threshold: your protocol: ________
- Risk assessment on file: active subawards with a dated 200.332(b) assessment ÷ active subawards. Data: grants files. Threshold: your protocol: ________
- Audit follow-up timeliness: FAC findings with a management decision inside the regulatory period ÷ findings. Data: FAC reads; decision log. Threshold: your protocol: ________
- Sample readiness: minutes to produce the dated verification for an auditor-sampled transaction. Data: HOSP-08 drill. Threshold: your protocol: ________

RECORDS
- 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
- Risk assessments and monitoring plans — kept by Grants Director — retention same
- Management decisions on audit findings — kept by Grants Director — retention same

WHAT THIS PROCEDURE DOES NOT DECIDE
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.

CHANGE LOG (add a line for every change; keep superseded versions)
- 2026-10-06: First issue.
- ________: adopted/edited by ____________________

Source template: https://alphacovenantholdings.com/api/public-record/sop-templates/hosp-06-subrecipient-monitoring/html · Duty Sheets: https://alphacovenantholdings.com/api/public-record/duty-sheets · Our own procedures: https://alphacovenantholdings.com/api/trust/sops