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WSFR completes a risk assessment annually on each of our prime recipients (state fish and wildlife agencies). Pass-through entities should complete a risk assessment on of their subrecipients prior to issuing an agreement to pass Federal funds. For multi-year agreements with the same subrecipient, according to their established and documented policies and procedures.
§ 200.331(b) requires pass-through entities may choose to complete one risk assessment that will cover the entire duration of the award. Pass-through entities are strongly encouraged to develop written policies and procedures outlining their processes for risk assessments. to conduct an assessment of risk of their subrecipients, but does not specify that such assessments must be done prior to issuing the subaward or the subsequent disbursement of funds to the subrecipient. COFAR addressed this question in its FAQs (updated July 2017). Their response is: "No. While section § 200.331(b) requires risk assessments of subrecipients, there is no requirement for pass-through entities to perform these assessments before making subawards. Under the Uniform Guidance, the purpose of these risk assessments is for pass-through entities to determine appropriate subrecipient monitoring. Pass-through entities may use judgement regarding the most appropriate timing for these assessments. Regardless of the timing chosen, the pass-through entity should document its procedures for assessing risk. § 200.331(b)(1-4) includes factors that a pass-through entity may consider when assessing subrecipient risk. While § 200.205 imposes requirements for a Federal awarding agency to review the risk posed by applicants prior to making a Federal award, there are no corresponding requirements for a pass-through entity; however, it is a best practice for pass-through entities to evaluate risk prior to making a subaward."
Where should I keep the results of our subrecipient risk assessment?
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The Service's role in overseeing implementation of the risk assessment is to ensure that its prime recipients follow the requirements of 2 CFR 200 when they are issued Financial Assistance. Our OIG auditors may, during their reviews, test whether prime recipients are following the requirements of 2 CFR 200.331 when it has been determined that they are subawarding Federal funds to subrecipients. If prime recipients are found to not comply with the requirements of 2 CFR 200, then the Service may impose additional conditions on prime recipients as outlined in 2 CFR 200.338 in order to meet our Federal stewardship responsibilities.
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Learning Aids
USFWS_PrimeRecipient_Risk Assessment Form (Excel)
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Related Pages
Subrecipient vs Contractor Determination
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