Sub-Recipient Monitoring 2026: Understanding the Pass-Through Requirements for Managing and Monitoring Your Sub-Awards

Overview

The Uniform Guidance requirements for subrecipient monitoring and management were updated effective October 1, 2024, introducing new expectations for pass through entities overseeing federal awards. This session will provide practical guidance on implementing compliant subaward agreements, performing risk based monitoring, and managing subrecipient financial performance in accordance with 2 CFR SS200.331-200.333. Attendees will also gain insight into indirect cost rate requirements, fixed amount, and subaward agreements to strengthen oversight and prepare for federal agency or Single Audit reviews. Using fixed amount awards to solve an out-of-the-box solution.

Objectives

Distinguish between subrecipient and contractor relationships under 2 CFR S200.331
Identify required elements of subaward agreements under S200.332
Apply risk based monitoring techniques to evaluate subrecipient compliance
Implement procedures for monitoring financial performance
Evaluate indirect cost rate requirements between pass through entities and subrecipients
The use of fixed amount awards

Highlights

Subrecipient vs. contractor determinations under S200.331
Requirements for pass through entities under S200.332
Risk based monitoring methodologies
Indirect cost rate negotiation and de minimis rate application
The importance of sub-award agreements
Using fixed amount award to solve an out-of-the-box matter

Designed For

Public accountants performing Single Audits; consultants, grant or subaward recipients as nonprofits, hospitals, institutes of higher education, Federal, state, local and tribal units of government, and commercial entities that have awards; grants adminis

Prerequisites

None

Preparation

None

Notice

Your webinar can be accessed via https://ctcpas.acpen.com/. If you do not have an ACPEN account, please sign up for an account using the email address you have on file with CTCPA.

Fees

Credits

Specialized Credits

Level

Code

Vendor

Fields of Study

Leader(s):

Paul Calabrese, GRF CPAs & Advisors

Leader Bios

Paul Calabrese, GRF CPAs & Advisors

Paul H. Calabrese Principal, Outsourced Accounting & Advisory Services GRF CPAs and Advisors

As a Principal in the firm’s Outsourced Accounting & Advisory Services group, Mr. Calabrese brings a successful track record of working with both government contractors and nonprofit organizations. His remarkable career includes positions with the Air Force Audit Agency, Defense Contract Audit Agency (DCAA), and three government contractors, in addition to 25+ years in public accounting. Mr. Calabrese’s extensive experience with the Cost Accounting Standards (CAS) and CAS disclosure statements, Federal Acquisition Regulation Cost Principals (FAR), and the Uniform Guidance for federal grants, positions him as a sought-after resource and consultant for all facets of federal government contract and grant cost accounting.

Mr. Calabrese has prepared over 40 incurred cost submissions for DOD and USAID. He has also provided indirect rate development, advance agreements, forward pricing reviews, fixed price, T&M and CPFF/CPAF/CPIF cost proposals, defective pricing, billing systems, contract close-outs, compensation, contract brief preparation, voucher reviews, provisional billing rates, SF 1408 audits and prep, and preparation and reviews of DOD business systems for Accounting, Estimating, and Contractor Purchasing System Reviews. His experience also includes interfacing with DCAA and USAID with respect to audit resolution of questioned cost and findings. Paul has worked with law firms and litigation support on contract Request for Equitable Adjustments, Termination for Convenience, and Delay Claims on the Quantum portion of the Settlement Proposal.

Mr. Calabrese has hands-on experience with the Uniform Guidance for Federal grants recipients including nonprofits, universities, hospitals, and state/local/tribal units of governments. His background and skill set includes grant cost accounting, sub-recipient monitoring, preparation of over 100 indirect rates/NICRA for several Federal agencies, development of policies and procedures, medical management systems invoicing to state Medicaid agencies, and development of a toolkit for unit cost rates for Ryan White HIV AIDS HRSA awards. He has also developed grant and financial statement dashboards and performed outsourced CFO duties, annual budgets, cash flow projections, grant draws, and budget monitoring.

Mr. Calabrese is a prolific speaker on Uniform Guidance topics, making frequent presentations at seminars and conferences for GWSCPA, MACPA, IMA, NGMA as well as video webinars for BPN-ACPEN and webinars for GRF. Topics include indirect cost and rates per the UG, indirect rate development, pre- and post-award standards, overview of the 56 cost principals, time reporting, developing unit cost rates R/W, sub-recipient monitoring, building a nonprofit annual budget, procurement standards, annual budgeting and dashboards, grant budgets and monitoring, and Government Shutdown/Anti-Deficiency Act.

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