Federal grants — subrecipient and contractor verification and monitoring

Template version 2026-10-06 · for: 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) · adopted by organization effective date . Editable .txt · JSON

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

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.

Findings reported — computed from your own records; the threshold is your protocol's

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

Records

Record	Kept by	Retention
Pre-award SAM/FAC/USAspending record with award file	Grants	3 years from final expenditure report (2 CFR 200.334) or longer per HOSP-08
Risk assessments and monitoring plans	Grants Director	same
Management decisions on audit findings	Grants Director	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

Date	Change
2026-10-06	First issue.
date	adopted / edited by name

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