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B. Responsibilities of Recipients

After FEMA approves the subapplications and awards assistance, the agency transfers assistance to the applicant who, during the award stage, is referred to as the recipient (state, tribe or territory). Therefore, the applicant becomes the recipient and is generally referred to as a pass-through entity. The recipient receives the money and passes it on to the subrecipient. Because recipients/pass-through entities manage the award and subawards provided to their subrecipients, they have additional responsibilities.[201]

All pass-through entities (recipients) must:

  • Ensure every subaward is clearly identified to the subrecipient as a subaward and includes all information required.[202]
  • Evaluate each subrecipient’s risk of non-compliance with federal statutes, regulations and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring.[203]
  • Consider imposing additional specific subaward conditions on a subrecipient, if appropriate, and notify the subrecipient.[204]
  • Monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes; that the activities comply with federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.[205]
  • Review financial and progress reports.[206]
  • Submit quarterly reports to FEMA on time.[207]
  • Follow up and ensure that the subrecipient takes timely and appropriate action for all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews and other monitoring activity.
  • Issue a management decision for audit findings as required.[208]
  • Verify that every subrecipient is audited, as required by 2 CFR Part 200, when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in audit requirements.[209]
  • Consider whether the results of the subrecipient’s audits, on-site reviews or other monitoring indicate conditions that necessitate adjustments to the pass-through entity’s own records.[210]
  • Consider taking enforcement action against non-compliant subrecipients.[211]

Footnotes

201. Recipients may have additional roles and responsibilities as outlined in the respective regulations or Notices of Funding Opportunities governing each program. For example, refer to 44 Code of Federal Regulations (CFR) § 206.433 for the Hazard Mitigation Grant Program and 44 CFR § 77.3 for the Flood Mitigation Assistance program.

202. 2 CFR § 200.332(a)

203. 2 CFR § 200.332(b)

204. 2 CFR § 200.208; 2 CFR § 200.332(c)

205. 2 CFR § 200.332(d)

206. 44 CFR § 206.438(c); 2 CFR § 200.332(d)(1)

207. 2 CFR § 200.332(d)(2)

208. 2 CFR § 200.521; 2 CFR § 200.332(d)(3)

209. 2 CFR § 200.501; 2 CFR § 200.332(f)

210. 2 CFR § 200.332(g)

211. 2 CFR § 200.339; 2 CFR § 200.332(h)

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