Subrecipient Stewardship
GLC helps prime recipients design and implement subrecipient systems that meet federal requirements while supporting strong, effective partnerships. We support right-sized oversight, capacity assessment, and collaborative monitoring approaches that reduce risk and improve performance. While rooted in federal compliance expectations, this work strengthens partner relationships, delivery systems, and program outcomes across all funding environments.
The Challenge
Does Your Subrecipient Oversight Protect You from Risk While Enabling Partner Success?
Prime recipients (pass-through entities) assume significant financial and legal risk for their subrecipients' compliance. Relying on simple compliance checklists or applying one-size-fits-all monitoring often fails to accurately assess true risk or support the partner's success, leading to strained relationships and high audit vulnerability.
Common challenges that undermine effective subrecipient stewardship include:
- Unassessed Risk: Failure to perform initial and ongoing risk assessments, or applying assessments that don't account for the partner's specific Internal Capacity profile, leading to over- or under-monitoring.
- Compliance Breakdown: Lack of formalized subaward agreements, missing terms and conditions flow-down, or insufficient monitoring of high-risk areas like procurement and Single Audit requirements (2 CFR 200.332).
- Strained Partnerships: Oversight is perceived as punitive auditing rather than collaborative capacity building, resulting in friction, poor data sharing, and limited collective performance improvement.
- Ineffective Capacity Building: Interventions focus on compliance paperwork rather than addressing the root systemic issues that prevent the subrecipient from achieving high external performance, wasting resources and perpetuating low performance.
Our Approach
Risk-Balanced Partnership: Right-Sized Oversight for Collective Impact
Our approach ensures you meet all federal compliance obligations while nurturing strong, productive partnerships. We move beyond basic monitoring to build a relationship of stewardship, accountability, and collective performance.
Capacity-Based Risk Assessment
We design and implement a structured risk assessment process, often utilizing aspects of the Organizational Capacity-to-Performance Index (CPI) framework to diagnose a subrecipient's true internal capacity maturity. This allows you to apply right-sized monitoring — allocating more resources to high-risk partners and freeing up time for those that demonstrate strong systems.
Subaward Policy & Compliance Design
We develop compliant subrecipient management policies and procedures, including clear guidance on funder flow-down requirements, mandatory terms and conditions, and a clear process for issuing, modifying, and closing out subawards in adherence to 2 CFR 200.
Collaborative Monitoring & Performance Support
We help you shift monitoring from a reactive audit function to a proactive learning function. This includes designing collaborative site visit protocols, creating performance dashboards that track both financial expenditure and programmatic outcomes, and facilitating capacity strengthening interventions targeted to the subrecipient's identified needs.
Audit & Documentation Readiness
We establish and standardize all necessary documentation, including evidence of risk assessment, subaward management files, and monitoring records, ensuring the pass-through entity is fully prepared to demonstrate compliance during an audit of its subrecipient management systems.
The Results
The Measurable Value of Strong Subrecipient Stewardship
Mitigated Prime Recipient Risk
Full compliance with 2 CFR 200.332, ensuring the pass-through entity is legally protected by verifiable, documented oversight of all partners.
Effective Resource Allocation
Right-sized monitoring ensures resources are focused on high-risk areas, minimizing unnecessary oversight of stable, high-capacity subrecipients.
Strengthened Partner Performance
Collaborative monitoring and targeted capacity support empower subrecipients to improve their own systems, leading to better programmatic outcomes and stronger overall results.
Enhanced Funder Trust
Demonstrable commitment to effective stewardship positions the prime recipient as a highly reliable and responsible manager of complex federal funding streams.
This website uses cookies.
We use cookies to analyze website traffic and optimize your website experience. By accepting our use of cookies, your data will be aggregated with all other user data.