Subrecipient Monitoring Checklist

Many federal programs authorize entities to subaward (or pass through) federal financial assistance funds to subrecipients. As defined in subpart A of the Office of Management and Budget’s (OMB) uniform guidance, “a pass-through entity means a recipient or subrecipient that provides a subaward to a subrecipient … to carry out part of a federal program.” Pass-through entities include direct or prime recipients of federal funds that provide subawards to subrecipients. A subrecipient that receives funding from a prime recipient, known as the first-tier subrecipient, also could become a pass-through entity if it further subawards those funds to another entity. Pass-through entities also may award contracts. The authority of the pass-through entity to follow the uniform guidance flows through the subaward agreement between the pass-through entity and subrecipient.