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Subrecipient Monitoring Tool For Pass-Through Entities

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The Association of Government Accountants (AGA) Intergovernmental Partnership members developed a guide to provide a consistent approach for pass-through entities to monitor a grant subrecipient’s compliance with federal administrative requirements. It is designed for use in monitoring the administration of grant dollars provided by federal awarding agencies.

The Subrecipient Monitoring and Self-Assessment Guide is intended for use with the Intergovernmental Partnership’s Risk Assessment Tool, both of which are available on AGA’s websiteWhile this guide is designed for use by pass-through entities, it can also be instructive for federal awarding agencies in monitoring non-federal entities or non-federal entities that want to conduct a self-assessment.

How the Guide Works

The guide consists of a series of questions in key areas of risk. Each user can customize the set of provided questions to meet specific needs and some sections, such as procurement, can be eliminated if the section is irrelevant to a specific entity. There is no absolute rule for interpreting the collective answers to the questions included within this guide. Users of the guide are asked to answer questions with a “YES” or “NO” response. Occasionally, “Not Applicable” (N/A) may also be an appropriate response.

Throughout this guide, a “YES” response is desired, indicating the subrecipient has appropriate policies, procedures or controls in place. However, no specific number of “YES” answers indicates a subrecipient is deemed in compliance with all federal award requirements. Rather, “NO” answers help pass-through entities, or entities conducting self-assessments, determine areas in which compliance may be an issue and may require additional attention.

The guide is a great tool for pass-through entities to incorporate into their full lifecycle grant management process. Get the guide now. For more information on subreceipient monitoring best practice watch the video below.

Subrecipient Monitoring Video

This panel was moderated by Rhea Hubbard, Policy Analyst, OMB. Speakers include Merril Oliver, former Director, Governor’s Grants Office, State of Maryland, Carol A. Kraus CPA, Director, Grant Accountability and Transparency Unit, State of Illinois, Kim Moreland, Associate Vice Chancellor for Research and Sponsored Programs, University of Wisconsin – Madison.

Free Resource: 2 CFR 200 Training Videos

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