Financial Monitoring of Subrecipients: What Makes Sense Now?

Webinar • Thursday, March 14, 2019 • 2:00-3:30 p.m. ET

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$249.00 Financial Monitoring of Subrecipients: What Makes Sense Now? (03.14.19) (CD Only)
Webinar Details

Prerequisites: Some knowledge of federal grant management and audit requirements is helpful

Recommended Field of Study: Specialized Knowledge and Applications

Program Knowledge Level: Basic

Advanced Preparation: None

The federal government has made a big deal about the responsibility of primary grant recipients and other “pass-through entities” to monitor their subrecipients. Countless grant statutes impose program designs that require extensive subgranting. And, even where subawards are not required, grant applications are often constructed by consortia and other arrangements in which one organization takes the lead in requesting the direct grant and its “partners” receive subawards.

Given the amount of funds involved, it is logical that federal requirements say that pass-through entities must “monitor the activities of the subrecipient as necessary to ensure that the subaward is used in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that subaward performance goals are achieved” (2 CFR 200.331(d)).

Compliance monitoring and performance monitoring are required and relatively understandable. However, how financial monitoring exactly fits into those categories is never fully explained.

This has led pass-through entities to undertake a patchwork of resource-intensive activities often in the name of “internal control.” Some financial monitoring arguably duplicates what is supposed to happen in single. And, the phrase “micro-management” sometimes describes reviews in which back-up documentation for every transaction charged to the subaward is submitted to the pass-through entity or scrutinized onsite.

In the face of this policy and practice ambiguity, what should pass-through entities sensibly do and what should subrecipients expect? This webinar will answer these and related other questions. The session will cover:

  • The actual requirements imposed on and monitoring prerogatives of pass-through entities
  • How federal policies on documentation, reporting, records retention and single audit really can fit together logically
  • How concepts like “reasonable assurance,” “risk management” and “differential accountability” can be implemented in subaward oversight
  • How a pass-through entity can organize its subrecipient “universe” based on due diligence
  • When desk reviews, site visits or agreed-upon procedures audits are warranted
  • How findings that result from financial monitoring should be handled
  • How pass-through entities and subrecipients can comfortably step away from overly burdensome approaches

Join Bob Lloyd, principal of Federal Fund Management Advisor™, for this informative and practical look at a high-profile federal grants management activity that currently generates more than its share of frustration.


  • From prime recipient organizations and other pass-through entities:
  • Finance directors
  • Grant and contract managers
  • Sponsored projects administrators
  • Internal auditors
  • Monitoring specialists
  • Subaward managers
  • From subrecipient organizations:
  • Finance directors
  • Subaward administrators
  • Program managers
  • External auditors

Hand-out Materials:

Attendees will receive presentation slides as well as access to background materials.

Allowable Charges

The costs of webinars sponsored by Federal Fund Management Advisor™ are allowable charges to your federal grants and subgrants. The cost principles issued by OMB under its uniform guidance (and applicable to all types of awardees) state, “The cost of training and education for employee development is allowable” (2 CFR 200.472).

Attend this Live Webinar and Earn up to 1.5 CPE Credits

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  • Know the nuances of requirements for subrecipient assessment and monitoring
  • Understand contract clauses in agreements for procurement under grants
  • Apply the general tests of allowability
  • Understand special issues confronting pass-through entities contracting with foreign organizations
  • Know which clauses flow down when crafting a subaward
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