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Federal grant subrecipient monitoring policy

Grants    Subrecipient policy

Learn about Metro's policy for monitoring subrecipients of federal awards and how to comply with applicable state and federal laws and regulations.


The Single Audit Act Amendments of 1996 ("Amendments") were enacted to establish uniform requirements for audits of Federal awards administered by states, local governments, and non-profit organizations. OMB Circular A-133 (Audits of States, Local Governments, and Non-Profit Organizations) is the regulation issued by OMB to implement the Amendments of 1996. The responsibilities include ensuring compliance with laws and regulations, maintaining adequate internal control, and having an audit completed. Among other changes, the circular strengthened the monitoring role of the pass-through entity and added new requirements that reflect the increased importance of subrecipient monitoring. The approach of simply reviewing single audit reports is no longer sufficient and pass-through entities must devise and implement other methods to obtain needed information to fulfill their monitoring responsibilities.

Policy statement

Metro will monitor its subrecipients of Federal funds to ensure that Federal awards are used for authorized purposes in accordance with laws, regulations, and the provisions of contract or grant agreements, and that the performance goals are achieved. Metro is further responsible to ensure that subrecipients meet the audit requirements of OMB Circular A-133, whenever applicable. The subrecipient agreements that Metro executes will be structured to contain these requirements. The Chief Financial Officer is responsible for all subrecipient monitoring at Metro.

A subrecipient is a non-federal third-party entity that expends Federal awards received from a pass-through entity to carry out a Federal program, but does not include a beneficiary of such a program.  The terms of Metro subrecipient and vendor relationships are documented in the subcontract agreements. When Federal funds are involved, a determination will be made whether the third-party entity is a subrecipient or a vendor in accordance with OMB Circular A-133 definitions, and Metro will include that determination in the contract. Vendors are not subject to the same level of monitoring required for subrecipients, however Metro will require that its vendors comply with all applicable Federal, state, and local laws and regulations, and with the provisions of the subcontract agreements. 

As part of this policy, Metro will:

  1. Inform subrecipients of the Federal award information and compliance requirements, including any additional requirements imposed by the state of Oregon and/or Metro.
  2. Monitor subrecipient activities throughout the program period via reporting and regular contact.
  3. Obtain and review subrecipient audit reports for each applicable fiscal year, and ensure appropriate and timely corrective action has been taken in response to any audit findings.

Metro has established monitoring procedures to implement this policy and ensure compliance with Federal requirements. The procedures are provided to delineate responsibility and assist staff in ensuring that subrecipients are in compliance with those requirements, and that the costs incurred are allowable, allocable, and reasonable.

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