Government forms register · OMB (2 CFR 200)
2 CFR 200.332
Subrecipient risk assessment and monitoring (pass-through entity's own file; no numbered form)
Alpha Covenant Holdings, Government Forms Register: 2 CFR 200.332 — Subrecipient risk assessment and monitoring (pass-through entity's own file; no numbered form) (OMB (2 CFR 200)); citation 2 CFR 200.332(b), (d), (f); 2 CFR 200.501; read 2026-10-08. https://alphacovenantholdings.com/forms/two-cfr-200-332
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Subrecipient monitoring and single-audit follow-through (2 CFR 200.332, 200.501) — the steps as written
● a dated receipt is the record at this step · printable
| # | 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 |
How the auditor tests it
- Determine whether the pass-through entity verified that subrecipients expending at or above the threshold met the audit requirement, and whether it issued management decisions and followed up. — OMB Compliance Supplement, Part 3, Section M — Subrecipient Monitoring
- Finding written when the audit was not obtained: 'did not obtain the required audit report for the program subrecipient or perform any additional monitoring procedures' (County of Dauphin 2019-001, FAC 2019-12-CENSUS-0000166825). — the auditor's words as filed at fac.gov
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.
Upstream — the rule as printed
2 CFR 200.332 — § 200.332 Requirements for pass-through entities. · as of 2026-10-20 · last amended 2024-10-01
A pass-through entity must: (a) Verify that the subrecipient is not excluded or disqualified in accordance with § 180.300. Verification methods are provided in § 180.300, which include confirming in SAM.gov that a potential subrecipient is not suspended, debarred, or otherwise excluded from receiving Federal funds. (b) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information provided below. A pass-through entity must provide the best available information when some of the information below is unavailable. A pass-through entity must provide the unavailable information when it is obtained. Required information includes: (1) Federal award identification. (i) Subrecipient's name (must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated in the subaward; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity, including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414). (2) All requirements of the subaward, including requirements imposed by Federal statutes, regulations, and the terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient for the pass-through entity to meet its responsibilities under the Federal award. This includes information and certifications (see § 200.415) required for submitting financial and performance reports that the pass-through entity must provide to the Federal agency; (4) Indirect cost rate: (i) An approved indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, a pass-through entity must determine the appropriate rate in collaboration with the subrecipient. The indirect cost rate may be either: (A) An indirect cost rate negotiated between the pass-through entity and the subrecipient. These rates may be based on a prior negotiated rate between a different pass-through entity and the subrecipient, in which case the pass-through entity is not required to collect information justifying the rate but may elect to do so; or (B) The de minimis indirect cost rate. (ii) The pass-through entity must not require the use of the de minimis indirect cost rate if the subrecipient has an approved indirect cost rate negotiated with the Federal Government. Subrecipients may elect to use the cost allocation method to account for indirect costs in accordance with § 200.405(d). (5) A requirement that the subrecipient permit the pass-through entity and auditors to access the subrecipient's records and financial statements for the pass-through entity to fulfill its monitoring requirements; and (6) Appropriate terms and conditions concerning the closeout of the subaward. (c) Evaluate each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient's risk, a pass-through entity should consider the following: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency). (d) If appropriate, consider implementing specific conditions in a subaward as described in § 200.208 and notify the Federal agency of the specific conditions. (e) Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation. (3) Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) Resolve […] full text at the eCFR link
Amended: 2016-11-28, 2020-11-12, 2021-02-22, 2024-10-01 · SHA-256 of the XML as served: a88c0e1b8aeceba7db63641b439ca96734f268cea91b7a994743bd8c4d94fad3 · eCFR
The eCFR is an editorial compilation maintained by the Office of the Federal Register and GPO; it is updated daily and is not the official legal edition (the annual Code of Federal Regulations is). Text printed here is as the eCFR served it on the read date.
2 CFR 200.501 — § 200.501 Audit requirements. · as of 2026-10-20 · last amended 2024-10-01
(a) Audit required. A non-Federal entity that expends $1,000,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part. (b) Single audit. A non-Federal entity that expends $1,000,000 or more in Federal awards during the non-Federal entity's fiscal year must have a single audit conducted in accordance with § 200.514 except when it elects to have a program-specific audit conducted in accordance with paragraph (c) or (d) of this section. (c) Program-specific audit election (in general). A non-Federal entity may elect to have a program-specific audit conducted in accordance with § 200.507 if the following conditions are met: (1) The non-Federal entity expends Federal awards under only one Federal program (excluding research and development); and (2) The Federal program's statutes or regulations, or terms and conditions of the Federal award, do not require a financial statement audit of the non-Federal entity. (d) Program-specific audit election for research and development. A non-Federal entity may elect to have a program-specific audit for research and development conducted in accordance with § 200.507, but only if all of the following conditions are met: (1) The non-Federal entity expends Federal awards only from the same Federal agency, or the same Federal agency and the same pass-through entity; and (2) The Federal agency, or pass-through entity in the case of a subrecipient, approves a program-specific audit in advance. (e) Exemption when Federal awards expended are less than $1,000,000. A non-Federal entity that expends less than $1,000,000 in Federal awards during its fiscal year is exempt from Federal audit requirements for that year, except as noted in § 200.503. However, in all instances, the records of the non-Federal entity must be available for review or audit by appropriate officials of the Federal agency, pass-through entity, and the Government Accountability Office (GAO). (f) Federally Funded Research and Development Centers (FFRDC). Management of an auditee that owns or operates a FFRDC may elect to treat the FFRDC as a separate entity for purposes of this part. (g) Subrecipients and contractors. An auditee may simultaneously be a recipient, a subrecipient, and a contractor. Unless a program is exempt by Federal statute, Federal awards expended as a recipient or a subrecipient are subject to audit under this part. Payments received for goods or services provided as a contractor under a Federal award (see § 200.331) are not subject to audit under this part. (h) Compliance responsibility for contractors. In most cases, the auditee's compliance responsibility for contractors is to ensure that the procurement, receipt, and payment for goods and services comply with Federal statutes, regulations, and the terms and conditions of a Federal award. Federal award compliance requirements normally do not flow down to contractors. However, for procurement transactions in which the contractor is made responsible for meeting program requirements, the auditee must ensure those requirements are met, including by clearly stating the contractor's responsibilities within the contract and reviewing the contractor's records to determine compliance. Also, when these procurement transactions relate to a major program, the scope of the audit must include a determination of whether these transactions comply with Federal statutes, regulations, and the terms and conditions of a Federal award. See also § 200.318(b). (i) For-profit subrecipient. This subpart does not apply to for-profit organizations. As necessary, the pass-through entity is responsible for establishing requirements to ensure compliance by for-profit subrecipients. The subaward with a for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient's compliance responsibility. Methods to ensure compliance for Federal awards made to for-profit subrecipients may include pre-award audits, monitoring throughout the performance of the subaward, and post-award audits (see § 200.332).
Amended: 2016-11-28, 2020-08-13, 2020-11-12, 2024-10-01 · SHA-256 of the XML as served: c08fc79471486e988e6a4285bf05d2d9315ac81eea2e693c66174817ea306613 · eCFR
The eCFR is an editorial compilation maintained by the Office of the Federal Register and GPO; it is updated daily and is not the official legal edition (the annual Code of Federal Regulations is). Text printed here is as the eCFR served it on the read date.
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