Subrecipient Monitoring Site Visit Checklist

Confirm that written notification was provided to the subrecipient organization no fewer than 14 calendar days before the scheduled visit date.

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.

Confirm that the most recently submitted programmatic progress report and financial status report were reviewed as part of pre-visit desk review.

Record the subrecipient’s current risk rating as determined by the pass-through entity’s risk assessment process per 2 CFR §200.332(b).

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.

List all pass-through entity staff and subrecipient staff present during the visit, including names and titles.

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).

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.

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.

Review written fiscal policies covering authorization of expenditures, segregation of duties, bank reconciliation, and safeguarding of assets per 2 CFR §200.303.

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).

Verify that bank statements are reconciled to the general ledger monthly and that a second authorized individual reviews and approves the reconciliation.

Enter the total federal expenditures reported by the subrecipient for the current award period as of the visit date.

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.

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.

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).

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.

Record the total number of individual expenditure line items reviewed as part of the source documentation sample.

Record the count of sampled transactions that lacked adequate supporting documentation or contained unallowable costs. Document specifics in comments.

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.

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).

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.

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.

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.

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.

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.

Based on review of progress reports and programmatic records, assess the subrecipient’s overall progress toward meeting award objectives.

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.

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.

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.

Confirm SAM.gov registration status and expiration date if the subrecipient is required to maintain registration as a condition of the subaward.

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.

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.

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.

Confirm that each unresolved finding has a written corrective action plan identifying the root cause, corrective steps, responsible staff member, and target completion date.

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.

Record the total count of corrective action items that remain open (not yet fully resolved) as of the site visit date.

Select the overall compliance determination for this monitoring visit based on findings identified across all sections.

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’).

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.

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.

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.

Authorized pass-through entity monitoring staff member signature certifying that this checklist accurately reflects the findings of the site visit.

Subrecipient authorized organizational representative signature acknowledging receipt of verbal findings communicated during the exit conference. Signature does not constitute agreement with findings.