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54 <br /> Accordingly,your organization should develop written policies and procedures for subrecipient <br /> monitoring and risk assessment and maintain records of all award agreements identifying or <br /> otherwise documenting subrecipients' compliance obligations. <br /> Recipients should note that non-entitlement units of local government (NEUs) are not <br /> subrecipients under the SLFRF program.They are SLFRF recipients that will report directly to <br /> Treasury. <br /> Recipients should also note that subrecipients do not include individuals and organizations that <br /> received SLFRF funds as end users to respond to the negative economic impacts of COVID-19 on <br /> these organizations. Such individuals and organizations are beneficiaries and not subject to audit <br /> pursuant to the Single Audit Act and 2 C.F.R. Part 200, Subpart F. <br /> Separately or in addition, many recipients may choose to provide a subaward (e.g.,via contract <br /> or grant)to other entities to provide services to other end—users. For example, a recipient may <br /> provide a grant to a nonprofit to provide homeless services to individuals experiencing <br /> homelessness. In this case,the subaward to a nonprofit is based on the services that the <br /> Recipient intends to provide, assistance to households experiencing homelessness, and the <br /> nonprofit is serving as the subrecipient, providing services on behalf of the recipient. <br /> Subrecipients are subject to audit pursuant to the Single Audit Act and 2 CFR part 200, subpart F <br /> regarding audit requirements; and <br /> WHEREAS Subpart D of the UG dictates subrecipient and award requirements for expenditure of <br /> [ARP/CSLFRF] funds; and <br /> WHEREAS 2 CFR 200.332 states that: <br /> All pass-through entities must: <br /> (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward <br /> and includes the [required] information at the time of the subaward . . . When <br /> some of[the required information] is not available,the pass-through entity must <br /> provide the best information available to describe the Federal award and <br /> subaward. <br /> (b) Evaluate each subrecipient's risk of noncompliance with Federal statues, <br /> regulations, and the terms and conditions of the subaward for purposes of <br /> determining the appropriate subrecipient monitoring. <br /> (c) Consider imposing specific subaward conditions upon a subrecipient if <br /> appropriate as described by 2 CFR 200.208. <br /> (d) Monitor the activities of the subrecipient as necessary to ensure that the <br /> subaward is used for authorized purposes, in compliance with Federal statues, <br /> regulations, and the terms and conditions of the subaward; and that subaward <br /> performance goals are achieved. <br /> (e) Depending upon the pass-through entity's assessment of risk posed by the <br /> subrecipient, [specific] monitoring tools may be useful forthe pass-through entity <br /> to ensure proper accountability and compliance with program requirements an <br /> achievement of performance goals. <br /> (f) Verify that every subrecipient is audited as required by [2 CFR 200, Subpart F] <br /> when it is expected that the subrecipient's Federal awards expended during the <br /> respective fiscal year equaled or exceeded the threshold set forth in 2 CFR <br /> 200.501. <br /> 2 of 39 <br />