Subrecipient Watch

Deadlines and rules

The rules come from the Uniform Guidance, 2 CFR Part 200. This is a summary, not legal advice.

RuleWhat it saysWhat we do
§ 200.501An organization that spends $1,000,000 or more in federal awards in its fiscal year needs an audit. The earlier threshold of $750,000 applies to older fiscal years.Use $1,000,000 for fiscal years starting on or after October 1, 2024, and $750,000 before that. The clearinghouse only shows spending for audited years, so we use the last audit as a guide.
§ 200.512The audit is due within 30 days of the auditor's report or nine months after the audit period ends, whichever comes first. The cognizant or oversight agency can extend the nine-month date.Use nine months after the year ends, moved past weekends. We can't see the report date, extensions or federal holidays, which is why we say "usual deadline".
§ 200.521A pass-through entity issues a management decision on findings that affect its subawards, within six months of the clearinghouse accepting the audit.Show six months after the accepted date on every finding matched to your award.
§ 200.332A pass-through entity verifies that subrecipients are audited as required, and follows up on findings related to the subaward.Show who has an audit on file, and each finding, for you to review.
Cross-cutting findings: under § 200.332, you may be able to rely on the subrecipient's cognizant or oversight agency for findings that go beyond your subaward. We flag every finding matched to your award and can't tell which ones this applies to, so that call is yours.

Biennial audits

If the latest audit is marked biennial, the next period is worked out as two years instead of one.

Next: Matching findings →