Understand the distinctions between subrecipients and contractors as defined by Sections 331 and 333 of Subrecipient Monitoring and Management. Learn the responsibilities pass-through entities assume when managing federal grant funds and sub-awarding to other entities.
Key Insights
- Section 331 outlines key characteristics distinguishing subrecipients from contractors to guide proper instrument selection during grant fund distribution.
- Pass-through entities are organizations authorized by a federal agency to sub-award funds to other recipients, thereby assuming specific compliance obligations.
- Pass-through entities must fulfill monitoring and certain pre-award responsibilities that align with federal agency standards when managing subrecipients.
This lesson is a preview from our Grants Management Certificate Program. Enroll in a course for detailed lessons, live instructor support, and project-based training.
If you are a pass-through entity or if you are a subrecipient, a contractor, or vendor of federal grant funding, then this section, Subrecipient Monitoring and Management Sections 331 and 333, is critical for your understanding and interpretation. It lays out and distinguishes the difference between a subrecipient and a contractor in Section 331. OMB lists characteristics, those that are unique to contractors and those that are unique to subrecipients, to help you make a distinction and determination on the correct instrument to select when you are sub-awarding or procuring goods and services from a federal grant.
Additionally, this section goes over the pass-through entity's responsibilities. Now remember, the pass-through entity is created when a federal agency has authorized a funder the ability to sub-award. That funder becomes what's called a pass-through entity because the funds are flowing through them to the subrecipient.
And as such, once a recipient of funds becomes a pass-through entity, in many cases, they are required to have the same monitoring requirements and some pre-award requirements as federal agencies also are obligated to perform.