Toolkit · Government Contracts

The Federal Grant Application, Subaward, and Single Audit Toolkit

31 U.S.C. § 6304

Type
Toolkit
Jurisdiction
National
Date
2025-05-01
Topic
Government Contracts

Working instruments for federal grant administration. The intake set includes an award readiness screen and a compliance matrix template. The cost set includes an allowability worksheet and an effort documentation form. The procurement set includes a transaction file template and a sole source justification. The subaward set includes a risk assessment, required elements checklist, and monitoring log. The audit set includes a preparation binder index and a corrective action plan template. The response set includes a questioned cost response outline and a voluntary disclosure decision sheet. A closeout package and an authority quick reference complete it.

The Federal Grant Application, Subaward, and Single Audit Toolkit

Government Contracts > Federal Grants and Funding Compliance | Published 1 May 2025 - Updated 27 August 2025 | UpLaw - uplaw.us

How this toolkit is built

Twelve instruments. Bracketed text is for completion.

Three rules organize the set: the matrix is built per award in the first thirty days; documentation is the element that fails; and the pass-through entity answers for the subrecipient.

Tool 1 — Award Readiness Screen

Complete before applying. An award you cannot administer is worse than no award.

Opportunity: [ ] Agency: [ ] Assistance listing: [ ] Deadline: [ ]

☐ Instrument type — ☐ grant 31 U.S.C. § 6304 ☐ cooperative agreement 31 U.S.C. § 6305 ☐ contract 31 U.S.C. § 6303 ☐ Registration current? ☐ yes — expires [ ] ☐ no → cure before applying — 2 C.F.R. Part 25 ☐ Exclusion check on organization and principals ☐ clear — 2 C.F.R. Part 180 ☐ Indirect cost rate: ☐ negotiated — rate [ ]%, base [ ], expires [ ] ☐ de minimis elected ☐ none → elect now ☐ Cost sharing required? ☐ yes — amount $[ ], source [ ] ⚠️ enforceable if committed ☐ Financial system can track by award? ☐ ☐ Effort documentation capability? ☐ ☐ Partners identified and classified: ☐ subrecipient ☐ contractor — basis: [ ] ☐ Single audit likely triggered? ☐ yes — auditor engaged? ☐ ☐ Special requirements in the announcement: human subjects ☐ animal welfare ☐ environmental ☐ domestic preference ☐ data sharing ☐ ☐ Staff capacity to administer: [ ] FTE identified — name [ ] ☐ Decision: ☐ apply ☐ apply with modifications [ ] ☐ do not apply

Tool 2 — Compliance Matrix Template

One per award. Built in the first thirty days. The highest-value hour of the award period.

Award: [ ] FAIN: [ ] Assistance listing: [ ] Period of performance: [ ] to [ ] Budget period: [ ] to [ ]

# Requirement Source Owner (name) Demonstrating record Frequency Last verified
1 Activities allowed/unallowed [ ] [ ] [ ] [ ] [ ]
2 Allowable costs / cost principles 2 C.F.R. Part 200 [ ] [ ] ongoing [ ]
3 Cash management [ ] [ ] drawdown reconciliation monthly [ ]
4 Eligibility [ ] [ ] [ ] [ ] [ ]
5 Equipment and real property [ ] [ ] inventory annual [ ]
6 Matching / cost sharing [ ] [ ] [ ] [ ] [ ]
7 Period of performance [ ] [ ] [ ] ongoing [ ]
8 Procurement, suspension, debarment [ ] [ ] procurement files per transaction [ ]
9 Program income [ ] [ ] [ ] [ ] [ ]
10 Reporting [ ] [ ] filed reports [ ] [ ]
11 Subrecipient monitoring [ ] [ ] monitoring log [ ] [ ]
12 Special tests and provisions compliance supplement [ ] [ ] [ ] [ ]
13 Prior approvals award § [ ] [ ] approval file as needed [ ]
14 Flow-down provisions [ ] [ ] subaward templates per subaward [ ]

⚠️ Assign a named person, not a department. Requirements assigned to "finance" are the ones nobody does. ☐ Reviewed quarterly ☐ Updated on each modification ☐ Provided to the auditor at engagement ☐

Tool 3 — Cost Allowability Worksheet

Cost: [ ] Amount: $[ ] Award: [ ] Date incurred: [ ]

# Element Analysis Met?
1 Necessary and reasonable — would a prudent person incur it? [ ] ☐
2 Allocable — benefits this award, in what proportion and why [ ] ☐
3 Within limitations in the guidance, the award, and the statute [ ] ☐
4 Consistently treated — not both direct and indirect [ ] ☐
5 GAAP, except as otherwise provided [ ] ☐
6 Not used for other federal cost sharing [ ] ☐
7 ⚠️ Adequately documented — what record exists? [ ] ☐

Category screens ☐ Is it in an unallowable category? alcohol ☐ entertainment ☐ fundraising ☐ lobbying ☐ fines/penalties ☐ bad debts ☐ defense of government proceedings ☐ — compare 41 U.S.C. § 4304, 41 U.S.C. § 4310 ☐ Prior approval required? ☐ yes — obtained [date] ☐ Within the period of performance? ☐ ☐ Participant support cost? ☐ — excluded from indirect base ☐ ☐ Equipment or capital? ☐ — prior approval ☐, tagged and inventoried ☐

Conclusion: ☐ allowable ☐ unallowable ☐ allowable if documented — action: [ ]

Tool 4 — Effort Documentation Form

Employee: [ ] Position: [ ] Period: [ ] Pay period charges: [ ]

Award / activity % of total effort Hours Description of work performed
Award [FAIN] [ ]% [ ] [ ]
Award [FAIN] [ ]% [ ] [ ]
Non-federal / institutional [ ]% [ ] [ ]
TOTAL 100% [ ]

☐ Reflects work actually performed, not the budget ☐ ☐ Encompasses total activity for which the employee is compensated ☐ ☐ Completed by the employee or by someone with direct knowledge ☐ ☐ Reconciled to payroll this period ☐ — variance [ ]% — adjustment processed [date] ☐ Committed effort across all awards for this individual: [ ]% ⚠️ must not exceed 100%

Signature: ____________ Date: [ ] Reviewer: ____________ Date: [ ]

⚠️ Identical percentages every period for years are not evidence of measurement. They are the most common finding in this category.

Tool 5 — Procurement Transaction File

One per purchase. Thirty minutes. Eliminates the most common finding category.

Purchase: [ ] Amount: $[ ] Award(s) charged: [ ] Date: [ ]

☐ 1. Requirement. What is needed and why: [ ] · Necessary and not duplicative ☐ ☐ 2. Method based on dollar value: ☐ micro-purchase ☐ small purchase ☐ sealed bids ☐ competitive proposals ☐ noncompetitive → Tool 6 ☐ 3. Specifications — attached; do not unduly restrict competition ☐ ☐ 4. Sources solicited: [ ] — number of quotes or proposals received: [ ] ☐ 5. Responses — attached ☐ ☐ 6. Evaluation — criteria and the basis for selection: [ ] ☐ 7. Cost or price analysis (required above the simplified acquisition threshold): [ ] — attached ☐ ☐ 8. Conflict of interest certification from each person involved in selection ☐ — attached ☐ 9. Exclusion check — 2 C.F.R. Part 180 — performed [date], result: ☐ clear — screenshot attached ☐ ☐ 10. Domestic preference analysis where infrastructure — 2 C.F.R. Part 184 ☐ n/a ☐ 11. Required contract provisions included: remedies ☐ termination ☐ equal opportunity ☐ record access ☐ flow-downs ☐ ☐ 12. Executed agreement — attached ☐ ☐ 13. Prepared by: [ ] Reviewed by: [ ] Date: [ ]

Tool 6 — Sole Source Justification

Complete BEFORE the award. A reconstruction is not a justification.

Purchase: [ ] Vendor: [ ] Amount: $[ ] Award(s): [ ]

Ground relied on — check exactly one: ☐ Available from only a single source. Basis: [describe the unique capability, and what search established uniqueness] ☐ Public exigency or emergency will not permit delay. Basis: [the exigency, when it arose, and why delay is not possible] ☐ Express written authorization from the awarding agency. Attached ☐ dated [ ] ☐ Competition determined inadequate after solicitation. Basis: [when solicited, to whom, responses received]

⚠️ Not permitted grounds: familiarity · prior satisfactory performance · convenience · staff preference · time pressure created by the recipient's own delay.

Market research performed: [ ] Price reasonableness established how: [ ] — analysis attached ☐ Prepared by: [ ] Approved by: [ ] Date (must precede award): [ ]

📌 Sole-source is the most common procurement finding, and the failure is usually documentation rather than judgment.

Tool 7 — Subrecipient Classification and Risk Assessment

Entity: [ ] Proposed amount: $[ ] Award: [ ]

CLASSIFICATION — ⚠️ substance controls, not the label | Indicator | Subrecipient | Contractor | This entity | |---|---|---|---| | Determines eligibility | ✓ | | ☐ | | Performance measured against program objectives | ✓ | | ☐ | | Responsible for programmatic decision-making | ✓ | | ☐ | | Responsible for adherence to program compliance requirements | ✓ | | ☐ | | Uses funds to carry out a program | ✓ | | ☐ | | Provides goods/services within normal business operations | | ✓ | ☐ | | Provides similar goods/services to many purchasers | | ✓ | ☐ | | Operates in a competitive environment | | ✓ | ☐ | | Ancillary to the program | | ✓ | ☐ |

Determination: ☐ subrecipient ☐ contractor — basis: [ ]

RISK ASSESSMENT (subrecipients only) | Factor | Assessment | Risk | |---|---|---| | Prior experience with same or similar subawards | [ ] | ☐ L ☐ M ☐ H | | Results of previous audits | [ ] | ☐ L ☐ M ☐ H | | New personnel or new/substantially changed systems | [ ] | ☐ L ☐ M ☐ H | | Extent and results of federal agency monitoring | [ ] | ☐ L ☐ M ☐ H | | Dollar amount relative to entity size | [ ] | ☐ L ☐ M ☐ H | | Complexity of the compliance requirements | [ ] | ☐ L ☐ M ☐ H |

Overall risk: ☐ low ☐ moderate ☐ high Monitoring plan proportionate to risk: [ ] — see Tool 9 Assessed by: [ ] Date: [ ]

Tool 8 — Subaward Required Elements Checklist

Every subaward must contain these. Missing elements are a finding by themselves.

☐ 1. Subrecipient name and unique entity identifier ☐ 2. Federal Award Identification Number (FAIN) ☐ 3. Federal award date ☐ 4. Subaward period of performance start and end dates ☐ 5. Budget period start and end dates ☐ 6. Amount of federal funds obligated by this action ☐ 7. Total amount of federal funds obligated to the subrecipient ☐ 8. Total amount of the federal award committed to the subrecipient ☐ 9. Federal award project description ☐ 10. Name of the federal awarding agency, pass-through entity, and contact for the awarding official ☐ 11. Assistance listing number and title ☐ 12. Identification of whether the award is research and development ☐ 13. Indirect cost rate — negotiated rate, de minimis rate, or negotiated rate between the parties ☐ 14. All requirements imposed by the pass-through entity so the award is used in accordance with federal statutes, regulations, and the terms and conditions ☐ 15. Any additional requirements the pass-through entity imposes to meet its own responsibilities ☐ 16. Access to records and financial statements as necessary ☐ 17. Terms and conditions for closeout ☐ 18. Flow-downs: procurement standards · suspension and debarment 2 C.F.R. Part 180 · drug-free workplace 2 C.F.R. Part 182 · reporting 2 C.F.R. Part 170 · domestic preference 2 C.F.R. Part 184 where applicable ☐ 19. Exclusion verification performed before execution ☐ [date] ☐ 20. Subaward reported — 2 C.F.R. Part 170 ☐ [date]

Tool 9 — Subrecipient Monitoring Log

Subrecipient: [ ] Risk level: [ ] Subaward: [ ] Amount: $[ ]

Planned monitoring for this risk level ☐ Financial report review — frequency [ ] ☐ Performance report review — frequency [ ] ☐ Invoice/expenditure detail review — frequency [ ] ☐ Single audit report obtained and reviewed — annually ☐ ☐ Site visit — ☐ required ☐ not required — planned [ ] ☐ Agreed-upon procedures or additional testing — ☐ required — scope [ ] ☐ Training or technical assistance provided — [ ]

Monitoring performed | Date | Activity | Performed by | Findings / issues | Follow-up required | Closed | |---|---|---|---|---|---| | [ ] | [ ] | [ ] | [ ] | [ ] | ☐ |

Audit tracking ☐ Subrecipient required to have a single audit? ☐ yes ☐ no — basis: [ ] ☐ Audit reporting package obtained [date] ☐ Findings affecting our award: [ ] ☐ Management decision issued [date] ☐ Corrective action plan obtained ☐ Follow-up complete ☐

⚠️ The pass-through entity is answerable for the subrecipient's disallowed costs.

Tool 10 — Single Audit Preparation Binder

Per major program. Assemble before the auditor arrives.

☐ 1. Notice of award, all amendments, and all incorporated terms ☐ 2. The compliance matrix (Tool 2) ☐ 3. The relevant compliance supplement pages — and evidence you self-tested against them ☐ 4. Approved budget and every revision, with approvals ☐ 5. Schedule of expenditures of federal awards, maintained continuously and reconciled to the general ledger ☐ 6. All prior approvals with dates ☐ 7. Drawdown records reconciled to expenditures, monthly ☐ 8. All reports as filed, with submission confirmations ☐ 9. Effort documentation for every individual charged, reconciled to payroll (Tool 4) ☐ 10. Procurement files for every transaction charged (Tools 5 and 6) ☐ 11. Subaward agreements, risk assessments, and monitoring logs (Tools 7, 8, 9) ☐ 12. Equipment records and the most recent physical inventory ☐ 13. Cost sharing documentation ☐ 14. Program income records and treatment ☐ 15. Summary schedule of prior audit findings with status ☐ 16. Indirect cost rate agreement or de minimis election documentation ☐ 17. Registration status confirmation — 2 C.F.R. Part 25 ☐ 18. All agency correspondence

📌 Statutory framework: 31 U.S.C. § 7501 · 31 U.S.C. § 7502 · 31 U.S.C. § 7503 · 31 U.S.C. § 7504 · 31 U.S.C. § 7505

Tool 11 — Corrective Action Plan and Questioned Cost Response

CORRECTIVE ACTION PLAN Finding number: [ ] Program: [ ] Questioned costs: $[ ]

☐ Condition (what the auditor found): [ ] ☐ Criteria (the requirement): [ ] ☐ Cause (the actual root cause, not a restatement of the condition): [ ] ☐ Effect: [ ] ☐ Auditee response: ☐ concur ☐ concur in part ☐ do not concur — basis: [ ] ☐ Corrective action — specific: [ ] ☐ Responsible person by name: [ ] ☐ Completion date: [ ] ☐ How completion will be verified: [ ] ☐ Systemic change to prevent recurrence: [ ]

⚠️ Generic plans produce repeat findings, and repeat findings are treated far more severely.

QUESTIONED COST RESPONSE ☐ 1. A questioned cost is not a disallowance. The agency issues a management decision. ☐ 2. Is the cost genuinely unallowable, or merely undocumented and reconstructable? [ ] ☐ 3. Reconstruct support where the underlying cost was proper: [ ] ☐ 4. Test against the seven allowability elements (Tool 3) and present the analysis. ☐ 5. Identify the appeal route — for example 20 U.S.C. § 1234, 20 U.S.C. § 1234a, with general authority at 20 U.S.C. § 1221e-3. ☐ 6. Preserve judicial review — 5 U.S.C. § 706. ☐ 7. Plan for offset against future payments. ☐ 8. Fiscal law context: 31 U.S.C. § 1301 · 31 U.S.C. § 1341 · 31 U.S.C. § 1517 · 31 U.S.C. § 1552 · 2 U.S.C. § 1501

Tool 12 — Closeout Package, Disclosure Decision, and Authority Reference

CLOSEOUT PACKAGE ☐ Notice to vendors and subrecipients that final invoices are due by [date] — sent [date] ☐ All costs confirmed within the period of performance ☐ ☐ All obligations liquidated ☐ ☐ Final performance report submitted [date] ☐ Final financial report submitted [date] ☐ Unobligated balance refunded $[ ] on [date] ☐ Equipment accounted for; disposition instructions requested where the federal share exceeds the threshold ☐ ☐ Cost sharing reconciled and documented ☐ ☐ Program income treatment confirmed through the end ☐ ☐ Record retention date computed from final report submission: [ ] ☐ Complete closeout package filed in the award file ☐

VOLUNTARY DISCLOSURE DECISION ☐ 1. Conduct stopped and documented ☐ [date] ☐ 2. Records preserved; hold issued ☐ ☐ 3. Exposure quantified: $[ ] over [period] on awards [ ] ☐ 4. ⚠️ Certification accuracy assessed — every drawdown and report is a representation — 31 U.S.C. § 3729 ☐ 5. Qui tam risk — is there an internal complainant? ☐ — 31 U.S.C. § 3730; address retaliation risk immediately ☐ 6. Civil investigative demand received or likely? ☐ — 31 U.S.C. § 3733 ☐ 7. Administrative remedy exposure — 31 U.S.C. § 3801, 31 U.S.C. § 3802 ☐ 8. Exclusion exposure — 2 C.F.R. Part 180 — present-responsibility narrative: what happened [ ] · what changed [ ] · who is accountable [ ] · why it will not recur [ ] ☐ 9. Decision: ☐ disclose ☐ repay only ☐ monitor — approved by [ ] on [ ]

AUTHORITY QUICK REFERENCE ☐ Instrument: 31 U.S.C. § 6301 · § 6303 · § 6304 · § 6305 · § 6307 ☐ Framework: 2 C.F.R. Part 200 · Part 25 · Part 170 · Part 180 · Part 182 · Part 183 · Part 184 ☐ Audits: 31 U.S.C. § 7501–§ 7505 ☐ False claims: 31 U.S.C. § 3729 · § 3730 · § 3733 · § 3801 · § 3802 ☐ Fiscal law: 31 U.S.C. § 1301 · § 1341 · § 1517 · § 1552 · 2 U.S.C. § 1501 ☐ Cost rules by analogy: 41 U.S.C. § 4304 · 41 U.S.C. § 4310 ☐ Review: 5 U.S.C. § 706 · 20 U.S.C. § 1234 · 20 U.S.C. § 1234a · 20 U.S.C. § 1221e-3 ☐ Spending clause: Pennhurst · Dole · NFIB v. Sebelius · AOSI · AOSI II · Rust v. Sullivan · Gonzaga · Davis v. Monroe County Bd. of Educ.

📌 The three rules again: build the matrix in the first thirty days; documentation is the element that fails; and the pass-through entity answers for the subrecipient.

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