Institutional Research Effectiveness & Assessment

Subcontracting & Subrecipient Monitoring

In accordance with sponsor requirements, as well as federal and state regulations—most notably, 2 CFR 200—a pass-through entity must make case-by-case determinations for each agreement it makes for the disbursement of Federal program funds to a subrecipient entity. This case-by-case determination requires that the pass-through entity evaluate each subrecipient's risk of noncompliance with Federal and State statutes, regulations, and the terms and conditions of the subaward (for purposes of determining the appropriate subrecipient monitoring needed). Based on the pass-through entity’s assessment of risk, additional requirements may be imposed on the subrecipient as a term and condition of the subaward so as to ensure that the pass-through entity can meet it own obligations to the awarding agency.

Additionally, sponsor guidelines, federal and state regulations, and best practices dictate that the pass-through entity monitor the activities of the subrecipient—as necessary—to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.  

Role of Institutional Research Effectiveness and Assessment (IREA) 

The Subaward team serves as subject matter experts in drafting subagreements and ensuring that subrecipients are monitored in accordance with the level of risk assigned to the entity and the individual project.