Nonprofit Subrecipient Monitoring Checklist
A free, print-ready checklist for nonprofits acting as pass-through entities — covering all four stages of subrecipient monitoring required under 2 CFR 200.332.
When a nonprofit passes federal funds to another organization to carry out part of a program, it becomes a pass-through entity with legally defined monitoring obligations under 2 CFR 200.332. The pass-through entity is responsible to the federal awarding agency for ensuring subrecipient compliance — and auditors hold the PTE accountable when subrecipients fail.
This checklist covers all four stages of subrecipient management: pre-award risk assessment, subaward agreement required provisions, ongoing financial and performance monitoring (including site visits for high-risk subrecipients), and subaward closeout. Complete one checklist per subrecipient per grant year and retain it in your grant file.
- Pre-award risk assessment — eight-question scoring matrix with risk level rating
- Subaward agreement requirements — twelve required provisions per 2 CFR 200.332(a)
- Ongoing financial report review — expenditures, invoices, SAM.gov checks
- Performance report review — deliverables, participant numbers, corrective actions
- Subrecipient audit and compliance status monitoring
- Site visit / enhanced desk review checklist for high-risk subrecipients
- Subaward closeout — final reports, equipment disposition, record retention
- Monitoring notes and issues log with sign-off block
One platform built for human services nonprofits — not adapted from generic software.
