Subrecipient Monitoring Site Visit Checklist

Used by pass-through entities to conduct on-site monitoring of subrecipients, reviewing financial management systems, source documentation, programmatic performance, and corrective action status in accordance with 2 CFR Part 200 (Uniform Guidance) subrecipient oversight requirements.

Visit Logistics and Pre-Visit Documentation

• Site visit notification letter issued to subrecipient at least 14 days in advance
  Confirm that written notification was provided to the subrecipient organization no fewer than 14 calendar days before the scheduled visit date.
• Subrecipient award agreement (subaward) on file and reviewed prior to visit
  Confirm the executed subaward agreement, including all terms, conditions, and federal award identification information required by 2 CFR §200.332(a), was reviewed before the site visit.
• Most recent subrecipient progress report and financial report reviewed
  Confirm that the most recently submitted programmatic progress report and financial status report were reviewed as part of pre-visit desk review.
• Subrecipient risk assessment rating (current cycle)
  Record the subrecipient's current risk rating as determined by the pass-through entity's risk assessment process per 2 CFR §200.332(b).
• Prior monitoring findings or audit findings pending resolution
  Indicate whether any unresolved findings from prior monitoring visits, Single Audits, or OIG reviews exist for this subrecipient. If yes, document finding reference numbers in comments.
• Site visit participants and roles documented
  List all pass-through entity staff and subrecipient staff present during the visit, including names and titles.

Financial Management System and Internal Controls

• Subrecipient maintains a financial management system that identifies federal award expenditures separately from other funds
  Verify that federal award expenditures are tracked in a distinct cost center, fund code, or account that prevents commingling with non-federal funds per 2 CFR §200.302(b)(1).
• Chart of accounts or general ledger reviewed and federal award transactions are identifiable
  Inspect the general ledger or chart of accounts to confirm that individual transactions can be traced to the federal award and that account coding is consistent with the approved budget.
• Cash management practices minimize time between drawdown and disbursement (interest earned on federal funds reported if applicable)
  Confirm that federal cash drawdowns are timed to meet immediate disbursement needs per 2 CFR §200.305. If interest exceeds $500 per year, verify it is remitted to the federal agency.
• Written policies and procedures for financial management and internal controls are documented and current
  Review written fiscal policies covering authorization of expenditures, segregation of duties, bank reconciliation, and safeguarding of assets per 2 CFR §200.303.
• Segregation of duties is evident for authorization, recording, and custody of federal funds
  Confirm that no single employee has sole control over all phases of a financial transaction (e.g., the person who approves expenditures does not also reconcile the bank account).
• Bank reconciliations performed monthly and reviewed by a supervisor
  Verify that bank statements are reconciled to the general ledger monthly and that a second authorized individual reviews and approves the reconciliation.
• Federal expenditures reported to date (current award period)
  Enter the total federal expenditures reported by the subrecipient for the current award period as of the visit date.

Source Documentation and Cost Allowability

• Personnel costs supported by time and effort records (timesheets, semi-annual certifications, or equivalent) per 2 CFR §200.430
  Review a sample of payroll records and time distribution documentation. For employees working solely on the federal award, confirm certifications are on file. For split-funded employees, confirm timesheets reflect actual activity.
• Non-personnel direct costs (supplies, travel, contractual) supported by invoices, receipts, or purchase orders
  Select a sample of non-personnel expenditures from the general ledger and verify that each is supported by an original invoice, receipt, or purchase order that matches the recorded amount and is approved by an authorized signatory.
• Costs charged to the award are allowable, allocable, and reasonable per 2 CFR Subpart E cost principles
  Assess whether sampled expenditures conform to the cost principles applicable to the subrecipient's entity type (nonprofit: 2 CFR §200.400–§200.475; governmental: same Subpart E; IHE: same). Flag any unallowable costs (e.g., entertainment, lobbying, unbudgeted items).
• Indirect cost rate applied is consistent with negotiated rate agreement (NICRA) or de minimis rate election
  Verify that the indirect cost rate used matches the current NICRA on file with the cognizant federal agency, or that the 10% de minimis rate is applied correctly per 2 CFR §200.414(f) if no NICRA exists.
• Number of expenditure transactions sampled during this review
  Record the total number of individual expenditure line items reviewed as part of the source documentation sample.
• Number of transactions with documentation deficiencies identified
  Record the count of sampled transactions that lacked adequate supporting documentation or contained unallowable costs. Document specifics in comments.
• Match or cost-share requirements documented and verifiable (if applicable)
  If the subaward includes a matching or cost-sharing requirement, verify that non-federal match is documented, meets the criteria of 2 CFR §200.306, and is tracked separately in the financial system.

Procurement and Contractor Oversight

• Written procurement policy exists and includes competition thresholds, conflict of interest, and debarment/suspension checks
  Review the subrecipient's procurement policy for required elements: small purchase thresholds, sealed bid/competitive proposal procedures, sole-source justification criteria, and prohibition on doing business with debarred parties (SAM.gov check per 2 CFR §200.213).
• Contracts or purchase orders reviewed reflect competitive procurement or documented sole-source justification
  For a sample of contracts charged to the award, verify that procurement files contain evidence of competition (e.g., bid tabulations, RFP/RFQ documentation) or a written sole-source justification approved by an authorized official.
• Subrecipient verified contractors/vendors are not on the SAM.gov Exclusions list prior to award
  Confirm that SAM.gov exclusion checks were performed and documented for contractors receiving $25,000 or more per 2 CFR §200.213 and 2 CFR Part 180.
• Contractor performance is monitored and documented (deliverables, invoices reviewed against scope of work)
  Verify that the subrecipient has a process for reviewing contractor invoices against deliverables and that evidence of performance monitoring (e.g., progress reports, acceptance memos) is on file.

Programmatic Performance and Reporting

• Performance measures and targets defined in the subaward are documented and tracked
  Confirm that the subrecipient has a system for tracking performance indicators, output measures, and outcome targets specified in the award agreement or approved work plan.
• Progress reports submitted on schedule and contain required performance data
  Review submission dates of the most recent progress reports against required reporting deadlines in the subaward. Verify that reports include quantitative performance data, narrative on activities, and explanation of any variances.
• Current performance against targets — overall assessment
  Based on review of progress reports and programmatic records, assess the subrecipient's overall progress toward meeting award objectives.
• Program files and participant/client records are maintained and accessible for review
  Verify that programmatic records (e.g., participant eligibility files, service logs, case notes) are organized, complete, and available for inspection. Confirm records are retained per the schedule required by 2 CFR §200.334.
• Subrecipient has reported any significant developments, scope changes, or budget modifications to the pass-through entity
  Confirm that the subrecipient has notified the pass-through entity of any problems, delays, adverse conditions, or budget/scope changes requiring prior approval per 2 CFR §200.308 and subaward terms.
• Budget modifications requiring prior approval were submitted and approved before implementation
  If any budget reallocations exceeding 10% of the total award or changes in scope occurred, verify that prior written approval was obtained from the pass-through entity (and federal agency if required) before the change was made.

Federal Award Compliance and Special Conditions

• Subrecipient has an active registration in SAM.gov (or equivalent system) if required by the prime award
  Confirm SAM.gov registration status and expiration date if the subrecipient is required to maintain registration as a condition of the subaward.
• Civil rights compliance assurances on file (Title VI, Section 504, ADA, as applicable)
  Verify that the subrecipient has signed applicable civil rights assurances and has policies prohibiting discrimination in program delivery per Title VI of the Civil Rights Act, Section 504 of the Rehabilitation Act, and the ADA.
• Lobbying certification (SF-LLL or equivalent) on file if award exceeds $100,000
  For awards exceeding $100,000, confirm that the subrecipient has submitted a completed lobbying disclosure certification per 31 U.S.C. §1352 and 2 CFR Part 418.
• All special conditions attached to the subaward have been reviewed with subrecipient and are being met
  Review any special conditions imposed on the subaward (e.g., restricted drawdown, required training, additional reporting) and confirm the subrecipient is in compliance with each condition.

Corrective Actions and Prior Findings Resolution

• Open findings from prior monitoring visits are documented in a corrective action plan (CAP) with responsible parties and due dates
  Confirm that each unresolved finding has a written corrective action plan identifying the root cause, corrective steps, responsible staff member, and target completion date.
• Single Audit findings (if applicable) have been addressed and evidence of corrective action is on file
  If the subrecipient had findings in their most recent Single Audit (required when federal expenditures exceed $750,000 per 2 CFR §200.501), verify that corrective actions have been implemented and documented.
• Number of open corrective action items as of visit date
  Record the total count of corrective action items that remain open (not yet fully resolved) as of the site visit date.

Site Visit Findings, Summary, and Sign-Off

• Overall monitoring determination
  Select the overall compliance determination for this monitoring visit based on findings identified across all sections.
• Summary of findings and deficiencies identified during this visit
  Provide a narrative summary of all findings, deficiencies, and areas of non-conformance identified during the site visit. Reference the applicable regulatory citation for each finding (e.g., '2 CFR §200.430 — time and effort records incomplete for 3 of 5 sampled employees').
• Required corrective actions and deadlines communicated to subrecipient during exit conference
  Confirm that findings and required corrective actions were verbally communicated to subrecipient management during the exit conference, and that a written monitoring report will be issued within 30 days.
• Follow-up monitoring visit or desk review required?
  Indicate whether a follow-up monitoring activity (on-site or desk review) is required to verify corrective action implementation. If yes, document the planned timeframe in comments.
• Supporting documentation and evidence collected during visit (photos, copies of records)
  Attach photographs or scanned copies of key documents reviewed during the visit (e.g., general ledger excerpts, time records, procurement files) to support monitoring findings.
• Pass-through entity monitor signature
  Authorized pass-through entity monitoring staff member signature certifying that this checklist accurately reflects the findings of the site visit.
• Subrecipient authorized representative signature (acknowledgment of findings)
  Subrecipient authorized organizational representative signature acknowledging receipt of verbal findings communicated during the exit conference. Signature does not constitute agreement with findings.