Monthly Webinar | Subrecipient Monitoring: Managing Risk in the Real World-Video Recording

Video Transcription

Video Summary

The NGMA webinar, moderated by Adam Bruning with legal experts Laquell Little and Scott Sheffler from FTLF, focused on federal subrecipient relationships and pass-through entities under the Uniform Guidance (2 CFR Part 200). Key topics included distinguishing subrecipient versus contractor roles, selecting and structuring subawards, risk assessment, monitoring, and closeout procedures.<br /><br />Subrecipient relationships involve a non-federal entity performing a portion of a federal award with programmatic decision-making, eligibility determinations, and adherence to federal requirements, effectively acting as a mini-prime grantee. In contrast, contractor relationships entail purchasing goods or services for the pass-through entity’s benefit, usually under procurement rules with competition requirements. Because real-world scenarios can be ambiguous, organizations must apply professional judgment case-by-case, document their decisions, and then comply with the applicable regulations.<br /><br />Prior approval from federal awarding agencies is often required before making subawards, especially when there are changes in project scope or key personnel. Pass-through entities must evaluate subrecipient risk considering past performance, audit results, financial stability, and federal oversight. Based on this risk assessment, they structure agreements with clear terms on funding purpose, reporting, payment (typically cost reimbursement, no profit), and the federal flow-down requirements, including recognizing approved indirect cost rates.<br /><br />Effective administration involves monitoring performance, audit follow-up, and providing training or technical assistance to subrecipients. Closeout requires timely reconciliation of records, property management, and maintaining rights to recover disallowed costs post-performance.<br /><br />The session also covered fixed amount subawards, requiring prior agency approval and established unit pricing, beneficial for clear, measurable deliverables under $150,000. Throughout, the presenters emphasized compliance with federal and agency-specific regulations, thorough documentation, and proactive risk mitigation to ensure proper management of subrecipient relationships and federal funds.

Keywords

NGMA webinar

Uniform Guidance

2 CFR Part 200

subrecipient relationships

pass-through entities

federal awards

risk assessment

subaward structuring

monitoring and closeout

fixed amount subawards