What does the risk level indicate about the sub-recipient?

When material risk is identified in a sub-recipient’s organization or project, 2 CFR 200.331 requires pass-through entities to implement risk management tools to ensure proper accountability, compliance with program requirements, and achievement of performance goals.  Examples of available risk management tools include:

  • Providing sub-recipients with training and technical assistance on program related matters.
  • More frequent monitoring of programmatic aims or invoices.
  • More frequent communication with PI.
  • On-site review of the sub-recipient’s program operations.
  • Stringent review of audits and prompt action when instances of non-compliance are identified.
  • Enforcement action for non-compliance, including temporary withholding of payments, disallowing a cost when all or part of the cost is non-compliant, wholly or partially suspending or terminating the sub-award, withholding further funds from the project, or any other legally available remedies.