Ep. 4 - Pass through Challenges: managing subrecipients and contracts

In this episode, Jasmine Markanday unpacks one of the most confusing compliance areas for grant recipients: how to correctly classify a partner as a subrecipient or a contractor under 2 CFR 200.331.From avoiding costly audit findings to building monitoring plans, Jasmine walks through the rules, real-life examples, and documentation tips every grants professional needs to confidently manage pass-through funding. Whether you’re with a nonprofit, university, or public agency, if you work with subawards or contracts, this episode is for you.What You’ll Learn:How to determine if an entity is a subrecipient or a contractor under 2 CFR 200.331.Why proper classification protects your funding and your organization.Monitoring requirements for subrecipients, from risk assessments to site visits.Contractor compliance essentials, including procurement standards and invoice accuracy.Common pitfalls in pass-through funding and how to avoid them.What to include in subaward agreements to ensure compliance and accountability.Key Takeaways:Misclassifying a partner can lead to audit findings, penalties, or funding loss.Subrecipients carry out a portion of the federal award and are subject to program compliance; contractors provide goods/services and operate in a competitive market.Use a classification checklist to document your decision-making process.Build monitoring plans for subrecipients that include regular reviews, clear deliverables, and risk-based oversight.Tailor agreement templates for each subaward or contract to spell out responsibilities, reporting, and compliance requirements.Pro Tip:Don’t guess when classifying — use documented criteria and keep your reasoning on file. This not only supports compliance but also strengthens your defense in the event of an audit.Connect with Us:Instagram: @markandayconsultingLinkedIn: @markandayconsultingEnjoyed the episode? Leave a review and share with your grants team!Quote to Remember:"Funders may not say it plainly, but they will hold you accountable for how you classify and manage subrecipients and contractors." — Jasmine Markanday