OMB Guidance - Key Impacts - Requirements for Pass-Through Entities

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9/11 Volunteer and Student

OMB Uniform Guidance
Key Impacts on CNCS Grantee
4 - Requirements for Pass-Through Entites

Dear Colleagues,

 This is the fourth in a series of messages concerning the Uniform Guidance, and what it means to CNCS grantees. The regulation section number denotes where in the Uniform Guidance the rule being discussed in this bulletin is found.

§200.331 Requirements for Pass-Through Entities - Delineates the responsibilities of those recipients that have subrecipients of federal funds.

* All of the requirements placed on the prime grantee must flow through to the subrecipients, and

While grant requirements specific to the type of organization have been consolidated, some specific requirements, notably indirect costs, continue to apply based on the type of organization.  As such, recipients and subrecipients must follow the indirect cost requirements which are applicable to their type of organization, i.e., subrecipients do not follow the requirements of the type of organization which is granting them funds.

Why is this important?

CNCS will be focused on ensuring that prime grantees are acting in accordance with their duties under 2 CFR § 200.331 if they are subawarding funds, and that they have comprehensive policies and procedures in place which ensure that all terms and conditions are met by their subrecipients.  CNCS is also focused on ensuring that pass-through entities have effective monitoring tools that they are utilizing to confirm subrecipients are in compliance with all Uniform Guidance requirements.

What You Should Do:

All grantees that subaward should obtain training to ensure that they are well positioned to carry out all of the duties and requirements placed on them under 2 CFR §200.331.   Grantees that are pass-through entities must be prepared to evaluate subrecipients’ compliance with their subawards, monitor the activities of their subrecipients, impose specific conditions under 2 CFR § 200.207 as necessary, ensure required audits are completed, and take enforcement actions under 2 CFR § 200.338 when and if necessary.

Grantees should ensure that they have taken the necessary steps to be in compliance with the Uniform Guidance. Adherence to the Uniform Guidance is important to meet grant requirements and to be found fully compliant in any future audits or monitoring reviews.

Do not send documentation to CNCS to demonstrate compliance. When conducting future grant oversight, CNCS staff will request specific documents and records when necessary.

If you have concerns or questions regarding requirements for pass-through entities, please send them to  Your feedback and questions will help guide us in developing additional information and assistance.

In Service,

Dana Bourne, Chief Grants Officer
Corporation for National and Community Service Grant Offices
Washington, DC and Philadelphia, Pennsylvania