Examples
Worked examples
- Is an instance
A university receives an NIH prime award and subcontracts a defined portion of the research to a partner institution -- the university is the pass-through entity for that subaward.
- Is an instance
A large nonprofit health system holding a CDC cooperative agreement issues subawards to three community clinics to carry out part of the funded program, making the health system the PTE for each subaward.
Counter-examples
Looks similar, but isn't
- Not an instance
A university purchasing lab reagents from a commercial supplier is not acting as a pass-through entity -- that is a procurement relationship with a contractor, not a subaward to a subrecipient.
Editorial commentary
The pass-through entity (PTE) is the party in the middle of a subaward relationship: it holds a prime award directly from a federal awarding agency and, in turn, issues one or more subawards to carry out part of that program. 2 CFR 200.1 defines the term specifically — it is not a general label for any organisation that distributes money — and whether a given downstream party is actually a subrecipient, as opposed to a contractor or vendor, is a separate determination under 2 CFR 200.331.
What PTE status obligates an institution to do
2 CFR 200.332 requires a pass-through entity to flow down all applicable federal award requirements to its subrecipients, evaluate each subrecipient’s risk of noncompliance before issuing the subaward, and then monitor subrecipient activities proportionate to that assessed risk throughout the subaward’s life. Monitoring covers reviewing financial and programmatic reports, following up on audit findings, and issuing management decisions on any Single Audit findings that affect the subaward. If a subrecipient itself expends $1,000,000 or more in federal awards in a fiscal year, it is separately subject to a Single Audit under 2 CFR 200.501, and the pass-through entity must confirm that requirement was met — see subrecipient monitoring for the full obligation set.
Who acts as a PTE
Universities are the most common pass-through entities in research, issuing subawards to partner institutions, but nonprofits, hospitals, and state agencies also serve as PTEs whenever they hold a prime award and subcontract part of the funded work. An institution can be a recipient with respect to one award and simultaneously a pass-through entity with respect to a subaward it issues from that same award — both roles attach to the same award, at different points in the funding chain.
References
- 2 CFR 200.1 (Pass-through entity definition), 200.331 (subrecipient vs. contractor determination), 200.332 (Requirements for pass-through entities), 200.501 (Single Audit threshold) — Uniform Guidance.
Also known as
PTE · Pass-through organisation
Machine-readable encodings
Use in your systems
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