What is required when managing subrecipients under a grant?

• A. Subrecipients manage their own compliance without oversight.
• B. Risk assessment, monitoring, ensuring subrecipient compliance with terms, negotiating subaward agreements, and appropriate reporting.
• C. No reporting; invoices only.
• D. Only issue subawards; no monitoring needed.

Answer: (B)

Managing subrecipients under a grant requires active oversight and risk-based monitoring to ensure compliance with award terms and applicable regulations. Start with a formal subaward agreement that defines the scope of work, deliverables, budget and allowable costs, reporting cadence, and the rights to audit or substantiate costs, including the flow-down of federal requirements. Conduct a risk assessment to identify subrecipients that need more intensive oversight based on factors like past performance, internal controls, and the complexity of activities. Then implement ongoing monitoring: review financial and programmatic reports, verify that costs are allowable, reasonable, and allocable, track progress toward milestones, and conduct site visits or desk reviews as needed. Ensure the subrecipient complies with all terms of the award and applicable laws, including audit requirements at the subrecipient level if thresholds are met. Maintain thorough records and report to the awarding agency as required by the grant terms. This approach ensures oversight, accountability, and alignment with the grant’s objectives. Innovation in governance and clear expectations help prevent issues and support successful program outcomes.