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EMU Research

Subrecipient and Subrecipient Monitoring

Uniform Guidance, also referred to as the grants Omni Circular (2 CFR 200), governs the management of federally funded sponsored projects across the entire project lifecycle. The Uniformed Guidance took effect on December 26, 2014 and it is now being implemented by individual federal granting agencies.  This guidance supersedes requirements from OMB Circulars A-21, A-110 and A-133 and streamlines the federal government’s guidance on Administrative Requirements, Cost Principles, and Audit Requirements for federal awards, regardless of type of organization and contains additional requirements pertaining to Subrecipients, including:


  • Subaward proposals must use a Subrecipient’s federally negotiated IDC rate, and if none exists, a 10% de minimis rate is allowable.
  • An institution must make and document a deliberate decision whether or not a pass-through entity is a Subrecipient or a Vendor.
  • While it has long been the case that the PI, along with EMU, is responsible for monitoring all Subrecipients, including Subrecipient progress reports and Subrecipient expenditures; EMU is now required to provide systematic oversight of both administrative and financial management practices. This may include more restricted contract terms, site-visits, and financial audits, etc.
  • Subrecipient(s) have a shorter period of time to submit final invoices.


On this page, you will find the following documents necessary for subcontracting a portion of a grant award to a separate entity:


Elevating Communities, Inspiring Generations

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