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Subrecipient Award Checklist Resource Tool

Background

When allocating federal funds, the first step is determining if the entity receiving the funds is a subrecipient or a contractor.  Please refer to the Subrecipient vs. Contractor Determination tool. If it is determined that the entity is a subrecipient, please use the checklist below as a guide to ensure the grant agreement contains all of the required elements per state fiscal rules and 2 CFR 200 requirements.  
The approved OSC Grant Agreement Templates must be used to officially award the grant. This agreement contains the required elements necessary to fully protect the state. These templates can be found on the OSC Website under the State Purchasing and Contracts page (see Central Contracts Unit, Templates & Tools subpage).

Data and Terms for Subaward

Please Note: All items listed below with an asterisk (*) are required per the denoted Uniform Guidance within 2 CFR 200.332. In addition, pass-through entities must verify that the subrecipient is not excluded or disqualified in accordance with 2 CFR 180.300.

Data - Basic Information

  • Name, Address, and Contact Information of Grantor/Pass-Through Entity* (2 CFR 200.332(b)(1)(xi))
  • Name, Address, and Contact Information of Grantee/Subrecipient* (2 CFR 200.332(b)(1)(i))
  • Grantee/Subrecipient’s Unique Entity Identifier* (2 CFR 200.332(b)(1)(ii)) - This can be found on SAM.gov. The name associated with ID must match name listed above
  • Project Name/Description * (2 CFR 200.332(b)(1)(x))
  • Subaward Period/Performance Start and End Dates* (2 CFR 200.332(b)(1)(v))
  • Total Amount of Subaward* (2 CFR 200.332(b)(1)(vii))
  • Amount Being Obligated with this Action* (2 CFR 200.332(b)(1)(viii)) This would be necessary if the obligated amount is different than total subaward—such as if only obligating an amount for one year or one project at a time
  • Total amount of the Federal Award committed to the subrecipient by the pass-through entity* (2 CFR 200.322(b)(1)(ix))
  • Budget Period Start and End Dates* (2 CFR 200.332(b)(1(vi)))  If the budget period is different from the award period (in the case that only one year or project is being obligated at this time)
  • Include the indirect cost rate* (2 CFR 200.332(b)(1)(xiv)):  If the subrecipient does not have a federal negotiated indirect rate, the de minimis rate may be used in accordance with 2 CFR 200.414.
  • Federal Award Identification Number (FAIN)* – List number on your entity’s federal award (2 CFR 200.332(b)(1)(iii))
  • Federal Award Date* – List date on your entity’s federal award * (2 CFR 200.332(b)(1)(iv))
  • Name of Federal Awarding Agency* – (2 CFR 200.332(b)(1)(xi))
  • Assistance Listings title and number which must identify the dollar amount available with each Federal award and the Assistance Listings Number (also known as CFDA numbers) at the time of disbursement* - List number from your entity's federal award (2 CFR 200.332(b)(1)(xii))
  • Identification of whether the award is Research and Development* – Yes or No as applicable  (2 CFR 200.332(b)(1)(xiii))
     

Scope of Work, Budget, Terms and Conditions

  • Services to be Provided/Scope of Work* (2 CFR 200.332(b)(2))
  • Grant Budget (line-item budget or narrative)
  • An approved indirect cost rate is required.* (2 CFR 200.332(b)(4))
  • Deliverables/Reporting/Due Dates* (2 CFR 200.332(b)(3)):  Financial and performance reporting and other deliverables and their respective due dates. Align these dates so that you, as the pass-through entity, have the information needed before filing reports due to the US Treasury or awarding agencies
  • Payment Terms:  Will payments be in advance or on a reimbursement basis? How many payments/installments? Are payment(s) triggered by completion of a task or at the end of a time period?
  • Unearned Grant Funds:  All unearned federal grant funds on hand at the end of the grant period shall be returned (to your agency as the pass-through entity).
  • Record Retention and Access* (2 CFR 200.332(b)(5)):  Subrecipient must permit pass-through entities and auditors to have access to records as necessary to meet federal requirements (such as for audits and closeout of the grant).
  • Audit Requirements per 2 CFR Part 200, Subpart F(501)(b)(c) & (d): Non-federal entities that expend $1,000,000 or more in Federal awards must have a single or program-specific audit conducted for that fiscal year.
  • Evaluate each subrecipients fraud risk and risk of noncompliance* (2 CFR 200.332(c)) and if deemed appropriate, implement specific conditions in the subaward per 2 CFR 200.208(c).
  • Monitor subrecipients activities as necessary to ensure that they comply with Federal statutes, regulations, and the terms and conditions of the subaward* (2 CFR 200.332(e))
  • Publications:  Any publications produced with funds from this award must display the following language provided in the grant agreement template.
  • Subrecipient agrees to comply with any additional federal requirements associated with the funds
  • Termination Clause(s)
  • Legal Clauses as needed
  • Signatures (with dates) of Grantor and Grantee (pass-through entity and subrecipient)