One of the (many) things I found very confusing when I started working in the world of federal grant management is the way the terms subrecipient, subawardee, contractor, subcontractor, and vendor are bandied about, seemingly interchangeably.
It didn’t matter if I was talking with my colleagues or federal agency personnel; there always seemed to be lots of confusion around these terms.
And I knew making the distinction was important because there were very different grant compliance and monitoring requirements, depending on which group they were classified with.
One of the main responsibilities when you have subawards, has to do with monitoring subrecipients.
Subrecipient Monitoring
Federal award recipients have a primary responsibility to ensure subrecipients comply with applicable federal grant management requirements. You may hear this referred to as “subrecipient monitoring” or “subaward monitoring.” Let’s look at it this way: The recipient is the legal entity to which a federal award is made. Therefore, the recipient is responsible to the awarding agency for how the funds are used and for compliance with all applicable federal regulations. The subrecipient is the legal entity to which a subaward is made. Therefore, the subrecipient is responsible to the recipient for how the funds are used and for compliance with all applicable federal regulations. When it comes to subaward monitoring, the recipient steps in the shoes of the awarding agency in monitoring subrecipients. The monitoring responsibilities of the pass-through entity start prior to awarding funds with a risk assessment of the potential subrecipient and then continue throughout the period of the award.Subrecipient Monitoring Documentation
The recipient must be able to demonstrate to the federal agency that subrecipients are being monitored for compliance. This process of documentation starts with the risk assessment done by the pass-through entity to ensure a sufficient monitoring plan is in place and continues throughout the subaward period with adequate documentation to support compliance with 2 CFR Part 200.Key Concepts
- The recipient must determine the proper classifications of subawards from procurement contracts.
- The recipient has primary responsibility for monitoring their subrecipient(s).
- The recipient must be able to prove that they are conducting monitoring activities.