What it is
A pass-through entity that makes subawards of federal funds has its own compliance duties under 2 CFR 200.332, and subrecipient monitoring is a compliance requirement auditors test in a single audit. This checklist follows that section: verify the subrecipient is not excluded, put the required information in each subaward, evaluate fraud and noncompliance risk, monitor, follow up on audit findings and consider enforcement.
It includes a subaward fact block, the required subaward content, a risk table using the four factors the regulation lists, a monitoring log and the audit follow-up steps including management decisions on findings. Use one copy per subaward and read it with the award terms.
When to use it
- Setting up and monitoring subawards at a nonprofit, university or government pass-through entity.
- Testing subrecipient monitoring in a single audit.
- Preparing for a federal agency review.
What’s inside
- Subaward facts including UEI, FAIN, Assistance Listing and periods
- Pre-award exclusion check and required subaward content
- Risk evaluation table and monitoring log
- Audit follow-up, management decision and closeout steps
Standard cited
This template follows 2 CFR 200.332. It is written in our own words, except for phrases the standard requires the document to contain, with [bracketed placeholders] for client details, amounts in USD and dates as MM/DD/YYYY. Check it against the current standard and your firm’s methodology before use.
Questions
What must a subaward include?
Among other items, the subrecipient’s name and unique entity identifier, the federal award identification number and date, the performance and budget periods, amounts obligated, the project description, the agency and pass-through contact, the Assistance Listing title and number, a research and development flag and the indirect cost rate. The checklist lists them.
Which factors drive risk?
The subrecipient’s prior experience with similar awards, results of previous audits, new personnel or systems, and the extent and results of federal agency monitoring. The pass-through entity sets the monitoring tools to match.
Who issues the management decision?
The pass-through entity issues a management decision for audit findings that pertain only to the federal award it provided to the subrecipient (2 CFR 200.521). Cross-cutting findings may be left to the cognizant or oversight agency in certain cases.
Related templates
- Single Audit Major Program Determination Worksheet
- Management Letter — Internal Control Communication (AU-C 265)
- Audit Planning Memo (AU-C 300)
Last updated 11/05/2026. All free templates.