Minimum Pass-Through Monitoring Standards for Federal and Other Sponsor Property

 

Requirements for Pass-Through Entities

A pass-through entity is defined in the Federal Uniform Guidance, 2 CFR 200.74 as a “non-Federal entity that provides a subaward to a subrecipient to carry out part of a Federal program.” The UW acts as a pass-through entity and is therefore required to monitor subrecipients and complete a risk assessment as guided by the 2 CFR 200.331 (b) and 2 CFR 200.331 (d).  UW subrecipients who also act as a pass-through entity are subject to the subrecipient monitoring and risk assessment requirements in the 2 CFR 200.331 as well.

This requirement will initially be addressed via the Office of Sponsored Programs “Subrecipient Entity Certification Form” to be completed by the subrecipient organization and incorporated with other required documents to establish the complete subrecipient agreement.  Thereafter, it will be the responsibility of the Principal Investigator (PI) to ensure subrecipient compliance with the minimum standards noted below. (Note – This could be moved to “Risk Assessment” below if it makes more sense)

Risk Assessment

The 2 CFR 200.331 (b) states, all pass-through entities must “Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring.”  

Subrecipient Monitoring

The 2 CFR 200.331 (d) also states, “All pass-through entities must “Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.”

It is the responsibility of the Principal Investigator of each award to ensure all subrecipients are compliant with the minimum standards as follows:

  • Verification of equipment information to ensure inventory report is up-to date (e.g., Identification numbers, titleholders, physical locations, etc.)
  • Verification equipment is tagged
  • Verification equipment is being utilized as approved
  • Verification equipment is being maintained and is in good working condition
  • Verification usage logs are being maintained as required
  • Verification of insurance on equipment (self-insured or insured through agent)