What it is
Recipients of federal awards carry the compliance burden that auditors later test. This checklist is for the recipient: financial management and internal control, allowable costs and indirect rates, cash management, procurement, property, subawards and subrecipient monitoring, reporting and closeout, and audit.
It reflects the 2024 revision of 2 CFR 200, which has a government-wide effective date of October 1, 2024 and includes the 15 percent de minimis indirect rate and the single audit threshold of $1,000,000. Agencies could apply the revision to new awards at different times, from as early as June 21, 2024 to as late as October 1, 2025, so older awards may still be under the previous version. Each award can add terms, so read the notice of award.
When to use it
- At the start of a federal award.
- Before the single audit, as a readiness check.
- When a nonprofit takes its first federal pass-through award.
What’s inside
- Financial management and internal control
- Cost principles and indirect cost method
- Cash management and procurement
- Property, subawards and monitoring
- Reporting, closeout, records and audit
Standard cited
This template follows 2 CFR 200. 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 is the de minimis indirect rate?
A recipient without a federally negotiated indirect cost rate may elect up to 15 percent of modified total direct costs under 2 CFR 200.414(f), as revised in 2024. It was 10 percent before.
Is a contractor a subrecipient?
It depends on the substance of the relationship. Use the criteria in 2 CFR 200.331, such as who determines eligibility, who carries out the program and who is responsible for compliance, and document the conclusion.
How long must award records be kept?
Generally three years from submission of the final financial report, with longer periods in some cases (2 CFR 200.334), including while litigation, a claim or an audit is open and for property records after disposition. Read the award terms for any extension.
Related templates
- Nonprofit Organization Audit Checklist (ASC 958)
- Single Audit Checklist: Compliance Requirements by Type (2 CFR 200, Subpart F)
- Segregation of Duties Conflict Matrix
Last updated 11/05/2026. All free templates.