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Recipients, Internal Recipients and Subrecipients for SLFRF

State Controller Policy

Effective Date: 01/24/2025

Approved by: Robert Jaros, CPA, MBA, JD, Colorado State Controller

Definitions

  • Recipient means an entity, usually but not limited to a non-Federal entity that receives a Federal award directly from a Federal awarding agency. (2 CFR §200.1 Definitions)  A Recipient also is referred to as a Prime Recipient.  For the State of Colorado SLFRF award, a Recipient is an agency, department, or institution of higher education that received a legislative allocation, or allocation from the Governor’s $370 million allotment.
  • Internal Recipient means an entity that receives an award from a Recipient and the entity is part of the same legal entity as the Recipient.  An agency or department is considered part of the Recipient because they are all part of the same legal entity that received a direct CRF or SLFRF payment from Treasury. (Department of Treasury FAQs Related to Reporting and Recordkeeping).  
  • Subrecipient means an entity, usually but not limited to a non-Federal entity, that receives a subaward from a pass-through entity to carry out part of a Federal award.  A Subrecipient does not include an individual that is a beneficiary of such award. (2 CFR §200.1 Definitions)    

Examples

  • Internal Recipients - All agencies, departments, and institutions of higher education (IHEs) that are part of the primary government that receive an award from a State Agency are considered Internal Recipients.  
  • Subrecipients - Schools and organizations that are not included in the State’s financial reporting entity (primary government) such as local area district colleges (Colorado Mountain College and AIMS), area technical colleges (Emily Griffith Technical College, Pitkin Technical College, and Technical College of the Rockies), and foundations are considered Subrecipients.

Compliance

  • Monitoring
    • A Recipient is responsible to monitor Internal Recipients in the same manner as Subrecipients.
    • Internal Recipients have the responsibility to monitor Subrecipients, same as the responsibility for a Recipient. If an Internal Recipient further awards funds to another Internal Recipient, the awarding Internal Recipient is responsible to monitor the receiving Internal Recipient.
  • SLFRF Interagency Agreement – SLFRF awards from a Recipient to an Internal Recipient shall use the SLFRF Interagency Agreement.  References to “Subrecipient” in the Agreement shall apply to an Internal Recipient.

Reporting

  • Obligations and expenditures that the last Internal Recipient incurs with a SLFRF award must be collected by and reported in the Gravity portal by the Recipient as if they were obligated or expended by the Recipient.
  • A Recipient continues to be responsible for reporting its Subrecipients and direct spending in the Gravity portal.  
  • The Office of the State Controller reports all obligations and expenditures for the State in the Treasury GrantSolutions portal.
  • There is no change in existing reporting requirements due to adding the definition for Internal Recipients.

Other Implications

Indirect Cost Rate –A Recipient is not be required to follow an Indirect Cost Rate negotiated by an Internal Recipient.

 

 State Controller Policies