2 CFR 200 Subpart D (Post-Federal Award Requirements)

2 CFR 200 Subpart D (“Post Federal Award Requirements,” §§200.300–200.346) is the section of the OMB Uniform Guidance that governs how a federal grant or cooperative agreement is administered once it has been awarded — from the recipient’s financial management system through closeout. It sits between Subpart C (“Pre-Federal Award Requirements and Contents of Federal Awards,” which governs the application and award-making process) and Subpart E (“Cost Principles,” which governs whether a specific cost is allowable). Subpart D does not decide whether a cost is allowable; it sets the administrative machinery — systems, controls, monitoring, and reporting — a recipient must run throughout the life of the award.

What Falls Under Subpart D

A requirement belongs to Subpart D if it governs how an already-made federal award is administered, rather than how it was competed for or costed. The subpart’s roughly 46 sections group into clear functional bands:

• General standards (§§200.300–200.309): statutory/national policy requirements, performance measurement, financial management systems (§200.302), internal controls (§200.303), bonds, federal payment methods, cost sharing (§200.306), program income (§200.307), and budget/period-of-performance revisions.
• Property standards (§§200.310–200.316): insurance coverage, real property, federally owned property, equipment, supplies, and intangible property acquired or improved with federal funds.
• Procurement standards (§§200.317–200.327): the competition, method-selection, small-business/domestic-preference, and contract-provision rules a recipient must follow when it buys goods or services with award funds.
• Performance and financial monitoring and reporting (§§200.328–200.330): financial reports, program performance reports, and real-property status reports due to the awarding agency.
• Subrecipient monitoring (§§200.331–200.333): how a pass-through entity determines subrecipient status, sets subaward terms, and risk-assesses and monitors subrecipients throughout the award.
• Record retention and access (§§200.334–200.338): the retention period, record-transfer, and federal-access rules for financial and programmatic records.
• Remedies and closeout (§§200.339–200.346): remedies for noncompliance, termination, the effects of suspension, closeout procedures, post-closeout adjustments, and collection of amounts due.

Worked Examples

Example 1 — Financial management system (§200.302). A university’s sponsored-programs office must maintain accounting records that identify federal awards distinctly, compare actual expenditures against budget, and support source documentation for every charge. This obligation exists only because the award is active; it is a Subpart D requirement, not a pre-award or cost-principles one.

Example 2 — Subrecipient risk assessment (§200.331–§200.333). Before issuing a subaward, a prime recipient (acting as a pass-through entity) evaluates a prospective subrecipient’s prior audit findings, experience managing federal funds, and internal-control maturity, and sets the frequency and depth of ongoing monitoring accordingly. This risk-based monitoring duty is a Subpart D obligation that continues for as long as the subaward is active.

Counter-Example

Evaluating a proposal’s budget for cost realism before an award decision, or drafting the terms of a Notice of Funding Opportunity, is not a Subpart D matter — those activities are governed by Subpart C (Pre-Federal Award Requirements), because no award yet exists to administer. Likewise, deciding whether a specific expense (say, a piece of equipment or a travel cost) is an allowable charge to the award is governed by the cost principles in Subpart E, not Subpart D — Subpart D requires that the recipient’s financial management system be capable of tracking and supporting such costs, but the allowability test itself lives elsewhere in the regulation.

Why It Matters for Research Administrators

Subpart D is the operational backbone most sponsored-programs and grants-management offices actually work against day to day: it is the source of the internal-controls standard tested in single audits, the procurement rules that determine whether a purchase needs competitive bidding, the subrecipient-monitoring duty that drives risk-tiered subaward oversight, and the closeout timeline that governs how quickly final reports and any unspent balance must be resolved. Institutions that treat Subpart D requirements as a single integrated administrative system — rather than isolated line items — are the ones best positioned to pass a Single Audit and avoid findings.