Examples
Worked examples
- Is an instance
A research office reviews each subrecipient invoice for allowability and matches to the approved budget before payment.
- Is an instance
A risk assessment flags a new subrecipient as high-risk; the prime requires monthly rather than quarterly reporting.
Counter-examples
Looks similar, but isn't
- Not an instance
Routine quality assurance on a purchased reagent is not subrecipient monitoring.
- Not an instance
An internal departmental progress review is not subrecipient monitoring.
Editorial commentary
Required by 2 CFR 200.332, subrecipient monitoring includes initial risk assessment at award time, financial monitoring (invoice review, expenditure documentation), programmatic monitoring (progress reports, deliverables), and audit follow-up (review of subrecipient’s Single Audit findings, if applicable). The prime is ultimately responsible to the sponsor for subrecipient performance. Risk-based monitoring approaches concentrate oversight effort on higher-risk subrecipients.
Vantage point: the oversight activity, not the relationship itself
Subrecipient monitoring is the activity a prime award holder performs downward once a subaward exists — distinct from “prime award,” which names the funder-facing relationship, and distinct from Horizon Europe’s coordinator/partner roles, which describe co-equal beneficiaries jointly party to a single EU Grant Agreement rather than a prime/subrecipient hierarchy (Horizon Europe consortia can still involve subcontractors or third parties that functionally resemble subrecipients, but the terminology and flow-down mechanics differ).
The MTDC subaward threshold: general rule and NIH exception
Under 2 CFR 200.1’s definition of Modified Total Direct Cost, indirect costs apply only to the first $50,000 of each subaward — raised from $25,000 in OMB’s April 2024 Uniform Guidance revision, for awards issued on or after 1 October 2024; costs beyond that are excluded from the base entirely. See MTDC for the full definition. This figure is quoted from a WebSearch snippet of the current eCFR text rather than an independently re-fetched primary page (a direct ecfr.gov fetch redirected to an access-gate this session); treat as REPORTED/eCFR-adjacent tier. NIH is a documented exception: Notice NOT-OD-26-072 (20 April 2026) reverted NIH awards specifically back to the $25,000 subaward threshold, alongside the parallel 10 percent de minimis reversion described on cost reimbursement, citing the same FY2026 appropriations-rider rationale (45 CFR Part 75 parity). Both the general and NIH-specific figures are secondary-sourced — attributed to COGR, Harvard OSP, and Princeton ORPA summaries rather than a direct grants.nih.gov fetch, which 403s to automated requests.
Separately, a prime may issue a subaward on a fixed-amount rather than cost-reimbursement basis, with prior federal-agency approval, up to $500,000 (2 CFR 200.333, raised from $250,000 in the same April 2024 revision) — see fixed-price grant.
References
- US Office of Management and Budget Uniform Guidance 2 CFR 200.332; NCURA subrecipient monitoring guidance.
Also known as
Subrecipient oversight · Subaward monitoring
Machine-readable encodings
Use in your systems
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