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Saint Paul Public Schools, District 625
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Sub-Recipient Monitoring for Grants

Sub-recipient Monitoring for Grants

Who Completes This Task: Grant Manager


The prime (or direct) recipient of a grant, is the entity that is awarded a grant. A sub-recipient receives a portion of a grant from the prime recipient. The prime recipient must monitor the programmatic and financial activities of the sub-recipient to ensure all applicable regulations are being followed.

Sub-award solicitations should include a summary of how monitoring will be conducted. This ensures all parties understand what will be monitored and the criteria that will be used to evaluate performance.

This procedure applies to all sub-awards issued under federal awards made to SPPS either as a prime recipient or sub-recipient. It does not apply to consultant agreements or the procurement of goods or services from vendors.


  • Sub-recipient receives a portion of a grant to carry out project goals

Steps - Pre-Qualification

  • SPPS assesses the sub-recipient’s financial status and internal controls
  • Terms and conditions of the agreement will be consistent with the level of perceived risk

Steps - Monitoring

When SPPS functions as a pass-through agency for federal awards, it performs stewardship activities and monitoring of sub-recipients.

  1. Advise sub-recipients of requirements imposed on them
    1. Federal laws
    2. Regulations of the flow-down provisions of the prime contract or grant agreement
    3. Any supplemental requirements imposed by SPPS
    4. Any required reporting
  2. SPPS provides all sub-recipients essential basic information
    1. The Catalog of Federal Domestic Assistance (CFDA) title and number
    2. The award name and number
    3. The award year
    4. The type of award
    5. The name of the federal sponsor
  3. Monitor the costs and activities of sub-recipients as appropriate
    1. Confirm funding provided to the sub-recipient is used for purposes authorized in the negotiated agreement
    2. Confirm performance goals articulated in the scope of work are achieved
  4. Upon receipt of an unfavorable audit report from a sub-recipient, SPPS will confirm the sub-recipient has taken appropriate and timely corrective action
    1. If a material weakness or other reportable condition exists, more frequent monitoring will occur, and appropriate actions will be taken
  5. Consider whether sub-recipient audits necessitate adjustment of SPPS’ financial records
  6. Each sub-recipient must allow the funder, SPPS and its auditors access to pertinent records and financial statements
    1. Alternate solutions may be considered, but require the primary funder’s approval
  7. Confirm that sub-recipients are compliant with audit requirements
    1. Identify any weaknesses or reportable conditions that result from audit

Documentation Required

  • Monitoring notes, minutes, financial reviews, progress logs, reports, etc.

Why This Is Important

  • It’s the law (see 2 CFR 200.331, 2 CFR 200 Appendix XI, OMB Circular A-133)
  • SPPS monitors the activities of its sub-recipients in order to ensure:
    • Proper stewardship of federal funds
    • Performance goals (scope of work or specific aims) are achieved
    • Compliance with the terms and conditions during the life of the agreement
  • Responsibility and accountability for contractual sub-recipient relationships
  • Compliance with federal, state, and other legal requirements related to sub-recipient monitoring

Related Topics

Monitoring Contracts