Subrecipient monitoring checklist for nonprofit pass-throughs

If your nonprofit passes federal money on to other organizations, you are a pass-through entity, and the organizations you fund are subrecipients. The federal Uniform Guidance, at 2 CFR 200.332, lists what a pass-through entity has to do about them. Much of it comes down to a steady routine: knowing what each subrecipient owes you, getting it on time, reading it, and following up on what is missing.

This guide turns that section into a working checklist for a grants or compliance coordinator at a United Way, a state coalition or a similar nonprofit. It is organized around the regulation's own steps, in plain language. It is not legal advice and does not tell you whether you are in compliance. Your federal award's terms, your awarding agency's guidance and your auditor govern. Read the current text of 2 CFR 200.332 yourself; this guide follows its paragraph order as published in October 2026.

Before the subaward: set it up so reports can be collected

These steps happen once per subaward. They decide whether monitoring later is easy or a scramble.

• Check the subrecipient is not excluded. The section asks you to verify the organization is not suspended, debarred or otherwise excluded, for example by checking SAM.gov. Save the result with the date.
• Identify it clearly as a subaward. The agreement should say it is a subaward and carry the identifying information the section lists, such as the subrecipient's name and identifier, the federal award number, dates, amounts, a description of the project, the awarding agency and the assistance listing.
• Pass down the requirements. Include the requirements that come with the federal award, plus any of your own, such as the reports you need for your own reporting to the agency.
• Write the reporting schedule into the agreement. Which reports, how often, and when each is due. Monthly or quarterly reimbursement requests and progress reports are common; your federal award may dictate some of them.
• Say what each report must contain. A reimbursement request with expense detail and support; a progress report against the work plan. Specific requirements now save follow-up later.
• Include access and closeout terms. The section requires access to the subrecipient's records for you and auditors, and appropriate closeout terms.
• Settle indirect costs. The section has rules on which indirect cost rate applies. Get this right in the agreement rather than at the first invoice.

Assess risk, then set the level of monitoring

• Evaluate each subrecipient's risk. The section asks you to consider risks of fraud and noncompliance to decide how closely to monitor. It names factors such as the organization's experience with similar awards, the results of past audits, new staff or systems, and whether it receives federal monitoring directly.
• Record the result and what it changes. A higher-risk subrecipient might report monthly with full support; a lower-risk one quarterly with a summary.
• Add specific conditions where warranted. The section allows specific conditions under 2 CFR 200.208, such as more frequent reporting, and asks you to notify the federal agency when you impose them.

During the subaward: the reporting routine

This is the part that repeats every month or quarter, and where most of the work is.

• Keep one list of every report owed, by subrecipient, report and due date.
• Request each report before it is due, with the requirements attached, and remind on a fixed schedule after the due date.
• Review financial and performance reports. The section names this explicitly as part of monitoring. Compare each report with what the agreement requires.
• Check reimbursement requests against support. Expense detail matches the amount requested; costs fall within the budget and the period.
• Follow up in writing on anything missing, with a new date, and keep the follow-up with the report.
• Hold or question payments when reports are outstanding, if your agreement allows it. Decide this deliberately; do not let it happen by accident.
• Keep a log of every request, reminder and follow-up. If an auditor asks how you monitored, the log is your answer.
• Ensure action on significant problems. The section asks you to make sure the subrecipient takes timely and appropriate action on deficiencies you find.

Audits, other tools and closing out

• Verify the subrecipient is audited as required by subpart F of the Uniform Guidance, and get a copy of any single audit report that applies.
• Issue management decisions on audit findings that relate to your subaward, as the section requires.
• Use other monitoring tools when risk calls for them. The section mentions training and technical assistance, site visits and agreed-upon procedures engagements.
• Adjust your own records if audits, site visits or other monitoring show a need.
• Consider enforcement action against noncompliant subrecipients, under 2 CFR 200.339 and your program's rules. This is a decision for you and your counsel, not a checklist item to tick quietly.
• Close out under the agreement's terms: final reports in, final payment reconciled, files retained for the required period.

A monthly report request you can adapt

Subject: [Your organization]: Monthly reimbursement packet due [date] (Subaward [ID])

Hello [first name],

Your monthly reimbursement packet for [month] is due [date]. It should include:

- the reimbursement request form with the amount requested for the month; - expense detail (general ledger or transaction list) for the month; - receipts or invoices for expenses above the threshold in your agreement; - payroll or timesheet support for staff charged to the subaward; - a brief note on activities carried out during the month.

Upload it here: [link]. If you need more time, reply with the date you can meet and why.

Adjust the list to your agreement. The point is that the subrecipient sees exactly what complete means before it sends anything.

Where Report Back fits

Report Back handles the reporting routine in the middle of this checklist. You upload subawards from a spreadsheet, one row per report due, and write what each report type must cover; a monthly reimbursement packet is one of the starting templates. Each subrecipient gets one no-login link listing every report it owes and when. Reminders go before and after each due date, from your organization's name with replies to your inbox, and every request and reminder is logged and can be exported as CSV. Each upload is checked against your requirements, with a drafted follow-up for anything that looks missing, and the overdue list flags grants with a payment coming up.

It does not assess risk, check exclusions, review audits, reconcile budgets or decide anything about compliance. Those stay with you. For report design, see our final grant report template.