Federal Subrecipient Risk Assessment Worksheet (2 CFR 200.332)

This worksheet is used to document the pre-award risk review required before issuing a federal subaward. It helps you evaluate the subrecipient’s financial capacity, audit history, internal controls, program experience, and any recent organizational changes. The output is a risk rating plus the monitoring actions you will apply if the subaward is approved.

It is usually completed by grants management, compliance, finance, or program staff who are responsible for subaward due diligence. In many organizations, the reviewer gathers input from accounting, program leads, and procurement or legal staff before routing it for approval. The approver should be someone with authority to sign off on the subaward decision and monitoring plan.

Use it before every new subaward and again when a material change affects risk, such as a new audit finding, leadership turnover, or a major scope change. It is also useful when renewing or extending a subaward if the original assessment is no longer current. If your monitoring plan changes, the worksheet should be updated to match.

No. This worksheet records that those checks were completed and captures the results, but it does not replace the underlying verification steps. You still need to confirm SAM.gov registration and exclusion status, review available financial statements or audits, and retain supporting documentation. The worksheet is the audit trail for those actions.

Common mistakes include leaving required fields blank, treating every subrecipient the same, and writing vague risk notes that do not explain the rating. Another frequent issue is failing to connect the risk rating to specific monitoring actions. The worksheet works best when the reviewer ties each concern to a concrete control, such as more frequent invoice review or additional reporting.

2 CFR 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance and to consider factors such as prior experience, audit results, and personnel or systems changes. This template organizes those factors into a repeatable review with documented approval. It also helps you show why a particular monitoring approach was selected.

Yes. You can add program-specific questions, scoring rules, or conditional logic for high-risk awards, new entities, or foreign subrecipients. Many teams also add fields for required attachments, such as financial statements, audit reports, or SAM.gov screenshots. Keep the form focused on information you will actually use so it stays aligned with data minimization.

After submission, the reviewer should confirm the evidence, finalize the risk rating, and assign monitoring actions before the subaward is executed. If the risk is elevated, the form should trigger additional review or approval rather than automatic release. The final record should be retained with the subaward file as part of the audit trail.