9.2 - ‘Step Back’ Phase

Pass-through entities should begin to develop a monitoring program long before they sign agreements with subrecipients. Step back, start fresh and organize the process. Make Subrecipient/Contractor Determinations One of the biggest issues in the area of subrecipient monitoring is determining whether an organization is a subrecipient or a contractor (§200.331). Pass-through entities, therefore, should make sure they select the appropriate agreement. Subrecipients receive subaward agreements. Contractors receive contract or acquisitions agreements. Under the prior circulars, the term “vendor” was frequently used along with “contractor.” Under the uniform guidance, the term… Read More