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What criteria or factors should a pass-through entity evaluate when conducting a risk assessment on a potential subrecipient?
§ 200§200.331(b)(1-4) provides some factors that pass-throughout entities may review when evaluating a subrecipient's potential risk of noncompliance. These factors should not limit a pass-through entity from evaluating additional factors that are above and beyond those listed in § 200.331.
The Service has developed its own
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risk assessment form for
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evaluating their prime recipients
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. May we use their
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form to evaluate
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our subrecipients?
Pass-through entities who have not specifically developed and implemented their own official risk assessment form are welcome to review the Service's official risk assessment form that it uses for evaluating its prime recipients potential risk of noncompliance. This form may provide a great starting point for pass-through entities as they begin to develop their own a risk assessment forms form that meet their specific requirements. Pass-through entities should be aware that the Service's risk assessment form was developed specifically to satisfy its requirements under § 200.205 Federal awarding agency review of risk posed by applicants. This form was not developed, nor was it ever intended to be used by pass-through entities to meet their risk assessment requirements under § 200.331(b). Pass-through entities who use the Service's risk assessment form do so completely voluntarily and the Service accepts no responsibility or liability should auditors determine that this risk assessment fails to meet the requirements set forth for pass-through entities conducting risk assessments of their subrecipients.
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