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What is the purpose of having to complete a Risk Assessment risk assessment on our subrecipients?
The purpose for pass-through entities having to complete a risk assessment on each of their subrecipients is to better help ensure that the Federal award is spent properly and that the subrecipient complies with all applicable Federal statutes, regulations, and terms/conditions. This is the same reasoning why each Federal awarding agency must also complete a risk assessment on each of their prime recipients prior to issuing a Federal award. The risk assessment also provides the framework by which the pass-through entity can help to mitigate for any potential risk associated with each subrecipient.
Am I required to complete a Risk Assessment risk assessment on both subrecipients and contractors before issuing a subaward?
§ 200.331(b) requires all pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for the purposes of determining the appropriate monitoring needed to ensure that Federal funds are used properly. Pass-through entities are not required to complete a risk assessment on contractors.
The Uniform Guidance 2 CFR 200.331(b) states that pass-through entities are required to evaluate each subrecipient's risk of noncompliance to ensure that Federal funds are used properly. My organization uses only "contracts" as the legal instrument to enter into agreements with both subrecipients and contractors. Therefore we consider all of our relationships as contractors. Is this acceptable?
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Where should I keep the results of our subrecipient Risk Assessmentrisk assessment?
It is a best management practice to keep the results of each subrecipient Risk Assessment risk assessment in either your agencies official subrecipient award file or a centralized subject-matter reference file. In either the case, the results of the Risk Assessment risk assessment should be easily obtainable by your program/fiscal staff and auditors if they request it.
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Yes there are differences in the requiremementsrequirements. § 200.205 requires that Federal awarding agencies, for competitive grants and cooperative agreements, must have in place a framework for evaluating the risk posed by applicants before they receive Federal awards. In evaluating such risk, the Federal awarding agency may use a risk-based approach and may consider any items such as the following: (1) Financial stability; (2) Quality of management systems and ability to meet the management standards prescribed in 2 CFR 200; (3) History of performance; (4) Reports and findings from audits performed under Subpart F - Audit Requirements of this part or the reports and findings of any other available audits; and (5) The applicant's ability to effectively implement statutory, regulatory, or other requirements imposed on non-Federal entities.
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§ 200.331 Requirements for pass-through entities.
§ 200.521 Management decision.
