Subrecipient Pre-Award Risk Assessment Form

Pass-through entities that issue federal subawards should use this form before award execution. It is typically completed by grants, finance, or compliance staff who can verify SAM.gov status, review audit history, and assess internal controls. The form is also useful for supervisors who need a documented basis for monitoring decisions and special conditions.

Complete it before the subaward is issued, renewed, or materially amended if the risk profile may have changed. It is especially important when the subrecipient is new, has limited federal award experience, has prior audit findings, or shows gaps in financial controls. If the organization’s status changes during the award period, the assessment should be updated.

It helps determine whether the subrecipient is eligible to receive the award and what level of monitoring is appropriate. The form supports decisions about special conditions, additional reporting, reimbursement-based payment terms, or denial/deferral of the subaward. It also creates a documented audit trail for why the risk rating was assigned.

The template is structured around the pre-award risk review expectations for subrecipients under 2 CFR 200.332. It prompts reviewers to evaluate financial stability, prior audit results, management systems, and the ability to comply with the terms of the subaward. It does not replace legal review, but it gives you a consistent record of the required assessment.

Common mistakes include leaving the justification too vague, checking SAM.gov without recording the date, and treating every field as required even when the information is not applicable. Another frequent issue is documenting a risk rating without tying it to specific evidence such as audit findings, going-concern concerns, or weak segregation of duties. The form works best when the reviewer records what was reviewed and why it matters.

Yes. You can use conditional logic to show different fields for universities, nonprofits, local governments, or international partners, while keeping the core risk checks the same. For low-risk repeat subrecipients, you may shorten the review; for high-risk or first-time subrecipients, you can add more detail and supporting documentation fields. Keep data minimization in mind and only collect what you will actually use.

Typical supporting documents include recent financial statements, the most recent Single Audit or FAC submission, written financial policies, and any documentation that explains prior findings or sanctions. You may also review SAM.gov registration evidence, organizational charts, and cost allocation materials if they are relevant to the proposed subaward. The template includes a place to record which documents were reviewed so the assessment is auditable.

An ad hoc review often leaves gaps because different reviewers ask different questions and do not document the same evidence. This template standardizes the fields, makes required versus optional items clear, and creates a repeatable audit trail. It also supports progressive disclosure, so reviewers only see the extra fields that apply to the subrecipient’s situation.

Yes. The risk rating and monitoring determination section is designed to feed the post-award monitoring plan. You can use the result to set reporting frequency, desk review cadence, site visits, or special conditions. That makes the assessment useful beyond approval and helps align monitoring with the level of risk.