Super Circular Increases Sub-Recipient Monitoring and Risk Assessment Requirements

The Uniform Guidance or “Super Circular” increases the amount of sub-recipient monitoring and risk assessment an organization must perform when providing a sub-grant to another organization. This responsibility transfers to a nonprofit organization that will be sub-granting part of a federal award they receive.

A recent The Nonprofit Times article discussed issues to consider from the federal government’s standpoint but you can apply the same considerations to your organization if you are making sub-grant payments with federal funds to another organization.

The following sample policy for sub-recipient monitoring gives a good overview of reasonable procedures to be undertaken when your organization will be sub-granting federal funds to a sub-recipient organization.

Sub-Reciptient Monitoring policy