CGA Post-Award Administration & Grant Closeout 2 — Questions and Answers
Question 1: According to 2 CFR 200.332(a), which of the following must a pass-through entity include in every subaward agreement?
- The subrecipient's marketing and outreach plan
- The Federal Award Identification Number (FAIN) and applicable program requirements (Correct answer)
- A copy of the subrecipient's board meeting minutes
- The subrecipient's 5-year strategic plan
Correct answer: The Federal Award Identification Number (FAIN) and applicable program requirements
Per 2 CFR 200.332(a), subaward agreements must include the Federal Award Identification Number, applicable laws and regulations, and reporting and performance requirements.
Question 2: What is the key characteristic that distinguishes a subrecipient from a contractor (vendor) in federal grant administration per 2 CFR 200.1?
- Subrecipients provide commercial goods while contractors provide program services
- Contractors receive federal funds directly from the awarding agency
- A subrecipient carries out a portion of the federal program while a contractor provides goods or services for the recipient's own use (Correct answer)
- There is no meaningful legal or administrative distinction between the two
Correct answer: A subrecipient carries out a portion of the federal program while a contractor provides goods or services for the recipient's own use
A subrecipient carries out a portion of a federal award's program objectives and bears programmatic responsibility, while a contractor provides commercial products or services that support the recipient's operations.
Question 3: Before issuing a subaward, a pass-through entity must verify that the potential subrecipient is not suspended or debarred by checking:
- The federal awarding agency's internal do-not-fund list
- The IRS tax-exempt database (Publication 78)
- The System for Award Management (SAM.gov) exclusions (Correct answer)
- The state procurement vendor list
Correct answer: The System for Award Management (SAM.gov) exclusions
Per 2 CFR 200.332(b), pass-through entities must verify subrecipients are not suspended or debarred by checking the exclusions section of SAM.gov before issuing a subaward.
Question 4: If a subrecipient expends $750,000 or more in federal awards during its fiscal year, it is subject to:
- Quarterly audits by the pass-through entity
- A program-specific review by the federal awarding agency
- An annual Single Audit conducted by an independent auditor (Correct answer)
- Monthly financial reporting directly to the federal awarding agency
Correct answer: An annual Single Audit conducted by an independent auditor
Per 2 CFR 200.501, non-federal entities that expend $750,000 or more in federal awards in a fiscal year must have a Single Audit (or program-specific audit) conducted by an independent auditor.
Question 5: Which of the following BEST describes a 'high-risk' subrecipient designation in federal grant administration?
- A subrecipient that has received more than $1 million in total federal funding
- A subrecipient requiring enhanced monitoring due to prior findings, weak controls, or poor compliance history (Correct answer)
- A subrecipient located in a different state than the pass-through entity
- Any for-profit organization receiving federal subaward funds
Correct answer: A subrecipient requiring enhanced monitoring due to prior findings, weak controls, or poor compliance history
A high-risk designation is applied to subrecipients with prior audit findings, weak internal controls, or a history of non-compliance, requiring enhanced monitoring measures from the pass-through entity.
Question 6: What is the primary purpose of a subrecipient monitoring plan developed by a pass-through entity?
- To document the subrecipient's hiring and HR processes
- To outline how the pass-through entity will ensure subrecipient compliance with federal requirements (Correct answer)
- To provide the subrecipient with a template for future grant applications
- To satisfy only the pass-through entity's internal audit requirements
Correct answer: To outline how the pass-through entity will ensure subrecipient compliance with federal requirements
A subrecipient monitoring plan documents the pass-through entity's systematic approach to overseeing subrecipient activities and ensuring compliance with all applicable federal award requirements.
Question 7: When a pass-through entity identifies a non-compliance finding during subrecipient monitoring, it is required to:
- Terminate the subaward immediately without notice
- Withhold all future payments until the subrecipient submits a new application
- Issue a management decision and ensure the subrecipient takes timely corrective action (Correct answer)
- Report the finding directly to the Inspector General without informing the subrecipient
Correct answer: Issue a management decision and ensure the subrecipient takes timely corrective action
Per 2 CFR 200.332(d), pass-through entities must issue management decisions for audit findings pertaining to subawards and ensure that subrecipients take timely and appropriate corrective action.
CGA Post-Award Administration & Grant Closeout 2
According to 2 CFR 200.332(a), which of the following must a pass-through entity include in every subaward agreement?