Treasury, Subrecipient Monitoring and Management
Summary
Training slides from Treasury's Office of Capital Access on subrecipient monitoring and management. They cover how 2 CFR Part 200 requirements flow down to subawards under 2 CFR § 200.101(b)(2), the post-award requirements of Subpart D (§200.300 – §200.346), such as financial management, internal controls, procurement standards and award closeout, and the pass-through entity requirements of 2 CFR §§ 200.331 through 200.333. The deck explains how a pass-through entity decides whether an arrangement is a contract or a subaward, and lists monitoring tools. One slide refers to a pass-through entity carrying out the objectives of its HAF award.
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“Treasury, Subrecipient Monitoring and Management.”
Original at home.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/treasury-subrecipient-monitoring-and-management-01999e800d/
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U. S. DEPARTMENT OF THE TREASURY
Subrecipient Monitoring and
Management
Office of Capital Access
1
Objectives
• Gain a high-level understanding of:
• Subrecipient Monitoring and Management
• Flow of 2 CFR Part 200 requirements to
subrecipients
• Subrecipient and contractor determination
• Pass-through entity requirements
• Monitoring tools
2
Applicability: Flow of 2 CFR Part 200 Requirements
Source: 2 CFR § 200.101(b)(2) Applicability
• Terms and Conditions of Federal awards flow down to
subawards to subrecipients unless otherwise indicated
• Pass-through entities must comply with requirements
described in 2 CFR §§ 200.331 through 200.333
• This means that recipients must comply with terms and
conditions of the Award/Grant Agreement when executed by
the recipient
3
Award Management – Federal Business Lifecycle
Program Administration
Program Oversight
Award Recipient Oversight
Post-Award Pre-Award
Management Management
Award Management
Source: Federal Integrated Business Framework for Grants Management
4
Performance and Financial Monitoring and Reporting
Subpart D – Post Federal Award Requirements
Subpart Key Concepts / Requirements
Subpart D Federal awarding agency management of financial assistance awards
Post Federal Award • Clear performance goals, indicators, targets
Requirements • Treatment and remedies for recipient noncompliance
• Closeout and Termination of awards
(§200.300 – §200.346)
Recipient management of awards
• Documented, consistent financial management and internal control
policies and procedures, and effective financial systems
• Property standards and vesting for real property, equipment, supplies,
and intangible property purchased with award funds
• Procurement standards including competition requirements,
procurement methods, contracting with small and minority
businesses, and contract provisions
• Subrecipient monitoring and management
• Award Closeout
Both
• Effective internal controls
• Payment requirements
• Revisions to budgets and program plans
• Financial and program performance reporting for the awards
• Record Retention and Access requirements
6
Subpart D – Key Concepts/Requirements In Depth
National Policy Performance Financial Internal Controls
Requirements Measurement Management
(§200.300) (§200.301) (§200.302) (§200.303)
Recipients must • Federal agencies • Recipient financial • Recipients must
comply with all must measure management establish and
requirements of the recipient systems must maintain effective
award including performance to identify awards internal controls for
federal laws and show achievement received and managing awards
regulations, of program goals expended based on • Recipients must
including, but not and objectives information in the evaluate and
limited to, those • Federal agencies programs’ monitor
related to: should provide Assistance Listings compliance
• Civil Rights clear performance • Recipients must with statutes,
• Prohibiting goals, indicators, have written regulations, and
discrimination targets, and procedures for award agreements
• Environmental baseline data financial • Recipients must
protections • Recipients must management take prompt action
• Whistleblower track and report requirements such when instances of
protections progress against as determining cost noncompliance are
• Lobbying performance allowability and identified
measures ensuring internal
controls
7
Subpart D – Subrecipient and Contractor
Determinations
A pass-through entity has discretion to decide what type of transaction it will enter
into with other entities to assist it in carrying out the objectives of its HAF award. In
accordance with 2 CFR 200.331, a pass-through entity may determine whether it will
be a contract or subaward.
.
Subrecipients Contractor
(1) Determines who is eligible to receive what (1) Provides the goods and services within
Federal assistance; normal business operations;
(2) Has its performance measured in relation to (2) Provides similar goods or services to many
whether objectives of a Federal program were different purchasers;
met; (3) Normally operates in a competitive
(3) Has responsibility for programmatic environment;
decision-making; (4) Provides goods or services that are ancillary
(4) Is responsible for adherence to applicable to the operation of the Federal program; and
Federal program requirements specified in the (5) Is not subject to compliance requirements of
Federal award; and the Federal program as a result of the
(5) In accordance with its agreement, uses the agreement, though similar requirements may
Federal funds to carry out a program for a public apply for other reasons.
purpose specified in authorizing statute, as
opposed to providing goods or services for the
benefit of the pass-through entity.
8
Subpart D – Post Federal Award Requirements
Subpart Key Concepts / Requirements
Requirements for All pass-through entities must:
pass-through entities • Ensure that every subaward is clearly identified to the
(§200.332) subrecipient as a subaward;
• All requirements imposed by the pass-through entity onto the
subrecipient so that the Federal award is used in accordance
with Federal statutes, regulations and the terms and conditions
of the Federal award;
• Any additional requirements that the pass-through entity
imposes on the subrecipient in order for the pass-through entity
to meet its own responsibility to the Federal awarding agency
including identification of any required financial and
performance reports;
• A requirement that the subrecipient permit the pass-through
entity and auditors to have access to the subrecipient's records
and financial statements as necessary
• Appropriate terms and conditions concerning closeout of the
subaward.
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Subpart D – Post Federal Award Requirements
Subpart Key Concepts / Requirements
Requirements for All pass-through entities must:
pass-through entities • Evaluate each subrecipient's risk of noncompliance with Federal
(§200.332) statutes, regulations, and the terms and conditions of the
subaward for purposes of determining the appropriate
subrecipient monitoring which may include consideration of
such factors as:
(1) The subrecipient's prior experience with the same or similar
subawards;
(2) The results of previous audits including whether or not the
subrecipient receives a Single Audit in accordance with Subpart
F, and the extent to which the same or similar subaward has
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 Federal awarding agency monitoring
• Consider imposing specific subaward conditions upon a
subrecipient if appropriate
10
Subpart D – Post Federal Award Requirements
Subpart Key Concepts / Requirements
Requirements for All pass-through entities must:
pass-through entities • Monitor the activities of the subrecipient as necessary to ensure
(§200.332) that the subaward is used for authorized purposes, in compliance
with Federal statutes, regulations, and the terms and conditions of
the subaward; and that subaward performance goals are achieved.
Pass-through entity monitoring of the subrecipient must include:
(1) Reviewing financial and performance reports required by the pass-
through entity.
(2) Following-up and ensuring that the subrecipient takes timely and
appropriate action on all deficiencies pertaining to the Federal
award provided to the subrecipient from the pass-through entity
detected through audits, on-site reviews, and written confirmation
from the subrecipient
(3) Issuing a management decision for applicable audit findings
pertaining only to the Federal award provided to the subrecipient
from the pass-through entity as required by § 200.521.
(4) The pass-through entity is responsible for resolving audit findings
specifically related to the subaward and not responsible for
resolving crosscutting findings.
11
Subpart D – Post Federal Award Requirements
Subpart Key Concepts / Requirements
Risk posed by • Depending upon the pass-through entity's assessment of risk posed by
subrecipients the subrecipient, monitoring tools may be useful for the pass-through
(§200.332) entity to ensure proper accountability and compliance with program
requirements and achievement of performance goals:
(1) Providing subrecipients with training and technical assistance on
program-related matters; and
(2) Performing on-site reviews of the subrecipient's program operations;
(3) Arranging for agreed-upon-procedures engagements as described in
§ 200.425.
• Verify that every subrecipient is audited as required by Subpart F when it
is expected that the subrecipient's Federal awards expended during the
respective fiscal year equaled or exceeded the threshold set forth in
§ 200.501.
• Consider whether the results of the subrecipient's audits, on-site
reviews, or other monitoring indicate conditions that necessitate
adjustments to the pass-through entity's own records.
• Consider taking enforcement action against noncompliant subrecipients
as described in § 200.339 of this part and in program regulations.
12
Subpart D – Key Concepts/Requirements
Subpart Key Concepts / Requirements
Financial Reporting Financial reporting information must be collected with the
(§200.328) frequency required by the terms and conditions of the Federal
award, but no less frequently than annually nor more frequently
than quarterly.
Monitoring and The recipient is responsible for oversight of the operations of the
Reporting Program Federal award supported activities. The recipient must monitor its
Performance activities under Federal awards to assure compliance with
(§200.329(a)) applicable Federal requirements and performance expectations are
being achieved. Monitoring by the recipient must cover each
program, function or activity.
Reporting Program The recipient must relate financial data and accomplishments to
Performance performance goals and objectives of the Federal award.
(§200.329(b))
Final Reports for The final financial and performance reports submitted by the
Closeout recipient and/or pass-through entity are due no later than 120
(§200.344(a)) calendar days after the period of performance end date. A
subrecipient must submit all final financial and performance
reports to the pass-through entity, no later than 90 calendar days
after the period of performance end date.
13
Concept Review
Subrecipient monitoring and management
• Monitor the activities of the subrecipient as necessary to ensure that the subaward is used
for authorized purposes
• Review financial and performance reports required by the pass-through entity.
Flow of 2 CFR Part 200 requirements subrecipients
• Terms and Conditions of Federal awards flow down to subawards to subrecipients unless
otherwise indicated
• Recipients must comply with terms and conditions of the Award/Grant Agreement when
executed by the recipient
Subrecipient and contractor determination
• A pass-through entity has discretion to decide what type of transaction it will enter into with
other entities to assist it in carrying out the objectives of its HAF award. In accordance with
2 CFR 200.331, a pass-through entity may determine whether it will be a contract or
subaward. Ensures stakeholders share an understanding of roles and requirements relative
to contractors and subrecipients, as applicable.
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