ACPEN: Sub-Recipient Monitoring 2026: Understanding the Pass-Through Requirements for Managing and Monitoring Your Sub-Awards

Overview

The Uniform Guidance requirements for subrecipient monitoring and management were updated effective October 1, 2024, introducing new expectations for pass through entities overseeing federal awards. This session will provide practical guidance on implementing compliant subaward agreements, performing risk based monitoring, and managing subrecipient financial performance in accordance with 2 CFR SS200.331-200.333. Attendees will also gain insight into indirect cost rate requirements, fixed amount, and subaward agreements to strengthen oversight and prepare for federal agency or Single Audit reviews. Using fixed amount awards to solve an out-of-the-box solution.

Highlights

• Subrecipient vs. contractor determinations under S200.331
• Requirements for pass through entities under S200.332
• Risk based monitoring methodologies
• Indirect cost rate negotiation and de minimis rate application
• The importance of sub-award agreements
• Using fixed amount award to solve an out-of-the-box matter

Prerequisites

None

Designed For

Public accountants performing Single Audits; consultants, grant or subaward recipients as nonprofits, hospitals, institutes of higher education, Federal, state, local and tribal units of government, and commercial entities that have awards; grants administrators, principal investigators, program personnel, legal, accounting and finance personnel.

Objectives

• Distinguish between subrecipient and contractor relationships under 2 CFR S200.331
• Identify required elements of subaward agreements under S200.332
• Apply risk based monitoring techniques to evaluate subrecipient compliance
• Implement procedures for monitoring financial performance
• Evaluate indirect cost rate requirements between pass through entities and subrecipients
• The use of fixed amount awards

Preparation

None