If your institution receives a federal grant or cooperative agreement and then passes part of that funding to another organization to carry out a defined piece of the work, your institution is the pass-through entity — not the subrecipient, and not a neutral party in the middle. This surprises a lot of research administrators and PIs, because “pass-through entity” reads like a term for someone else’s grant. It isn’t. Under 2 CFR §200.1, a pass-through entity (PTE) is a recipient or subrecipient that provides a subaward to a subrecipient (including lower-tier subrecipients) to carry out part of a federal program. A university receiving an NIH R01 and subawarding a portion of the aims to a collaborating institution is the pass-through entity for that subaward — and PTE status is not optional or symbolic. It carries a specific, enforceable set of obligations under 2 CFR §200.332 that exist independently of whatever the subaward agreement itself says.
This guide covers what makes an organization a pass-through entity, the obligations 2 CFR 200.332 attaches to that status (including the full list of required subaward data elements), and the statement of work (SOW) that has to hold the whole arrangement together — because a vague SOW is where most of the downstream monitoring, invoicing, and audit problems on a subaward actually start.
What makes an organization a pass-through entity
The definitions all sit in 2 CFR §200.1 and interlock:
- Pass-through entity — a recipient or subrecipient that provides a subaward to a subrecipient (including lower-tier subrecipients) to carry out part of a federal program. The PTE’s authority under Part 200 flows through the subaward it makes.
- Subrecipient — an entity that receives a subaward from a pass-through entity to carry out part of a federal award. A subrecipient can simultaneously be a recipient of other federal awards it holds directly from a federal agency; being a subrecipient on one award and a prime recipient on another are not mutually exclusive statuses.
- Subaward — an award a pass-through entity provides to a subrecipient so the subrecipient can contribute to the goals and objectives of the project by carrying out part of a federal award the PTE received. A subaward specifically excludes payments to a contractor, a beneficiary, or a participant, and it can take the form of any legal agreement the PTE considers appropriate — including one the PTE itself calls a “contract” — provided it meets the substance test at 2 CFR §200.331.
- Contractor — defined tersely at 200.1 as “an entity that receives a contract,” with the substantive test for distinguishing a contractor relationship from a subrecipient relationship set out separately at 2 CFR §200.331 (procurement of goods/services in the ordinary course of business, versus carrying out a share of the program’s objectives).
The practical read: PTE status attaches automatically the moment your institution issues a subaward, regardless of whether anyone at the institution has used the term “pass-through entity” internally. See CASRAI’s Prime Recipient vs. Subrecipient comparison for how the obligations divide across the two parties over the life of an award, and the Pass-through entity dictionary entry for the short-form definition.
The obligations 2 CFR 200.332 attaches to PTE status
2 CFR §200.332, “Requirements for pass-through entities,” is the operative section. It is not a suggestion list — it opens with “a pass-through entity must,” and every subsection that follows is a real obligation. Read end to end, it requires a PTE to:
- Verify the subrecipient isn’t excluded or disqualified (200.332(a)) — confirming in SAM.gov that a prospective subrecipient is not suspended, debarred, or otherwise excluded from receiving federal funds, before the subaward is made.
- Clearly identify every subaward as a subaward and provide the required subaward information (200.332(b)) — the data-element list covered in full below, plus flow-down of all applicable federal statutes, regulations, and award terms, any additional PTE-imposed requirements needed for its own reporting, the indirect cost rate treatment, subrecipient record-access rights for monitoring and audit, and closeout terms.
- Evaluate subrecipient risk before the subaward is made (200.332(c)) — prior experience with similar subawards, prior audit results (including Single Audit history), new or substantially changed personnel/systems, and the extent of any direct federal agency monitoring of that subrecipient. See CASRAI’s subrecipient risk assessment guide for how PTEs score this in practice.
- Consider specific award conditions where appropriate (200.332(d)) and notify the federal agency of any imposed.
- Monitor the subrecipient’s activities proportionate to that documented risk (200.332(e)-(f)) — reviewing financial and performance reports, ensuring corrective action on significant developments, issuing management decisions on award-specific audit findings, and resolving subaward-specific findings. CASRAI’s subrecipient monitoring checklist covers this obligation at full working-checklist depth and isn’t repeated here.
- Verify the subrecipient is audited as required under Subpart F (200.332(g)) when it crosses the Single Audit expenditure threshold.
- Adjust its own records based on subrecipient audit or monitoring results (200.332(h)), and consider enforcement action against a noncompliant subrecipient under 200.339 where warranted (200.332(i)).
The obligations that most catch first-time PTEs off guard are the two that happen before the subaward is even issued — the debarment check and the risk assessment — because both have to be documented at the point of award, not reconstructed after the fact if a question comes up later.
The 14 required subaward data elements (2 CFR 200.332(b)(1))
Every subaward has to be clearly identified to the subrecipient as a subaward and has to carry a specific set of information. Where any item isn’t yet available, the PTE must provide its best available information and update it once the real figure is known — this list isn’t optional paperwork, it’s what a federal auditor checks a subaward file against. The current regulatory text lists 14 elements under 200.332(b)(1)(i)–(xiv); older practitioner summaries sometimes describe “13 required elements,” reflecting how the list has been split and re-numbered across successive Uniform Guidance revisions — treat the table below, not a remembered count, as the current standard.
| # | Required data element | What it captures |
|---|---|---|
| 1 | Subrecipient’s name | Must match the name associated with the subrecipient’s unique entity identifier. |
| 2 | Subrecipient’s unique entity identifier (UEI) | The SAM.gov-issued UEI, not a legacy DUNS number. |
| 3 | Federal Award Identification Number (FAIN) | The prime federal award’s own identifying number. |
| 4 | Federal award date | The date of the prime federal award. |
| 5 | Subaward period of performance | Start and end date of the subaward itself. |
| 6 | Subaward budget period | Start and end date of the current budget period under the subaward. |
| 7 | Amount of federal funds obligated in the subaward | The dollar amount obligated in this specific subaward action. |
| 8 | Total federal funds obligated to the subrecipient | Cumulative obligation to this subrecipient by this PTE, including the current action. |
| 9 | Total amount of the federal award committed to the subrecipient | The full committed amount, not just what’s currently obligated. |
| 10 | Federal award project description | Per FFATA (Federal Funding Accountability and Transparency Act) requirements. |
| 11 | Federal agency, PTE name, and PTE awarding-official contact information | Who to contact on both the federal and pass-through sides. |
| 12 | Assistance Listings title and number | With the dollar amount made available under each at the time of disbursement. |
| 13 | R&D indicator | Whether the federal award is for research and development. |
| 14 | Indirect cost rate for the federal award | Including whether the de minimis rate is being used, per 200.414. |
Beyond this data set, the subaward document also has to flow down every applicable federal statute, regulation, and award term; state any additional reporting the PTE itself needs to meet its own obligations to the federal agency; grant the PTE and its auditors record-access rights; and set out closeout terms — all separately required by 200.332(b)(2)–(6), alongside the 14-item list above.
The indirect cost rate obligation toward subrecipients
2 CFR §200.332(b)(4) sets a specific, easy-to-miss rule: a pass-through entity must accept a subrecipient’s existing federally negotiated indirect cost rate, and must not require the subrecipient to use the de minimis rate instead. Where a subrecipient has no current negotiated rate, it may elect the de minimis rate (currently up to 15% of Modified Total Direct Costs) or negotiate a rate directly with the PTE — and that negotiated rate can reuse a rate the subrecipient previously negotiated with a different PTE, without the current PTE requiring new justification, though it may still elect to collect supporting documentation. This is one of the more common points of friction in subaward negotiation, because it removes a PTE’s ability to unilaterally impose the de minimis rate on a subrecipient purely to simplify its own budgeting.
The statement of work as an artifact
A statement of work (SOW) is the document — usually a discrete exhibit incorporated by reference into the subaward agreement — that defines the specific tasks, deliverables, timeline, and milestones the subrecipient is actually agreeing to complete. On a subaward, the SOW is doing more work than it looks like: it’s the artifact 2 CFR 200.331 points to when asking whether the subrecipient has “responsibility for programmatic decision-making” and is being “measured against whether the objectives of the federal program were met,” and it’s what a PTE’s own monitoring under 200.332(e) reviews financial and performance reports against.
Subaward SOW vs. the prime’s SOW
The prime award’s own statement of work (or, for an NIH-style grant, its Specific Aims/Research Strategy) describes the full scope of the project the PTE is accountable for to the federal agency. The subaward SOW has to be a clearly bounded subset of that scope — the specific tasks, deliverables, and aims the subrecipient is taking on — not a restatement of the whole project with the subrecipient’s name attached. A subaward SOW that simply says “collaborate on Aim 2” without breaking Aim 2 down into the subrecipient’s actual tasks and deliverables gives a PTE nothing concrete to monitor against later, and gives an auditor nothing concrete to test the subrecipient/contractor determination against either.
Why a vague SOW causes downstream problems
A thin or vague subaward SOW doesn’t cause a problem at signature — it causes problems six, twelve, and eighteen months later, when:
- Monitoring has nothing to check against. 200.332(e)(1) requires the PTE to review financial and performance reports against the subaward’s scope of work; if the SOW never specified concrete tasks or deliverables, “review” collapses into rubber-stamping whatever the subrecipient submits.
- Invoicing disputes follow. Deliverable- or milestone-based payment tranches only work if the SOW actually defines the deliverable or milestone being paid for; an ambiguous SOW is a predictable source of disagreement about whether a payment has been earned.
- Scope creep goes undetected. Without task-level specificity, it’s hard to tell whether a subrecipient has quietly expanded or drifted from the agreed work until a report or site visit surfaces it well after the fact.
- The subrecipient/contractor determination gets harder to defend. An auditor testing whether a relationship was correctly classified as a subaward (rather than a contractor arrangement dressed up as one) looks at whether the subrecipient genuinely exercised programmatic judgment against defined objectives — a SOW with no real task or deliverable structure weakens that case.
How the SOW interacts with budget and period of performance
The SOW doesn’t stand alone — it has to reconcile with two other required elements of the subaward from the data-element table above: the subaward period of performance and the subaward budget period. In practice, a well-structured subaward SOW breaks work into tasks or phases that map to the subrecipient’s budget periods (particularly on multi-year awards funded incrementally), so that a budget-period renewal or a no-cost extension has a clear SOW reference point rather than requiring the PTE to reconstruct what was actually agreed. When a subrecipient’s budget is restructured mid-award — a rebudgeting request, a change in scope, a supplement — the SOW should be amended at the same time, not left to describe a scope of work the budget no longer matches. A subaward file where the SOW, budget, and period of performance tell three different stories is exactly the kind of inconsistency subrecipient monitoring and Single Audit testing are designed to catch.
See CASRAI’s Statement of Work vs. Scope of Work comparison for the related terminology question research offices field constantly, and the subaward agreement negotiation guide for how the SOW gets negotiated alongside the rest of the subaward instrument.
Subrecipient vs. contractor: a determination checklist
Before any of the 200.332 obligations above apply, the relationship has to actually be a subaward in substance — not a procurement contract labeled as one. 2 CFR §200.331 sets out a substance-over-form test with no single decisive factor:
| Subrecipient (subaward) characteristics | Contractor (procurement) characteristics |
|---|---|
| Determines who is eligible to receive federal assistance | Provides goods or services within its normal business operations |
| Performance measured against whether the federal program’s objectives were met | Provides similar goods or services to many different purchasers |
| Has responsibility for programmatic decision-making | Operates in a competitive environment |
| Responsible for adherence to applicable federal program requirements | Provides goods/services that are ancillary to the federal program’s operation |
| Uses the federal funds to carry out a program of its own organization | Is not subject to the federal program’s compliance requirements as a result of the agreement |
Use this sequence to make and document the call before the agreement is executed:
- Does the organization exercise independent judgment over how the funded work gets done, or is it following the PTE’s specifications for a defined deliverable? Independent programmatic judgment points toward subrecipient.
- Is performance measured against the federal program’s own objectives, or against a commercial delivery/acceptance standard? Program-objective measurement points toward subrecipient.
- Does the organization provide this same good or service to other customers in a competitive market, unrelated to this specific federal program? That points toward contractor.
- Is the funded work central to the federal program’s goals, or ancillary support to it (e.g., a service that could just as easily support a non-federal project)? Central/programmatic points toward subrecipient; ancillary/support points toward contractor.
- Document the determination in the file at the time the decision is made — not reconstructed later if a question comes up, since 200.331 expects the PTE to make this call up front.
For the full test with worked scenarios, see CASRAI’s Subrecipient vs. Contractor vs. Vendor comparison.
Common mistakes
- Not recognizing your own institution as the PTE. Because “pass-through entity” sounds like it describes some other, larger organization, research offices sometimes treat 200.332’s obligations as someone else’s problem on awards where their own institution is squarely the PTE the moment it issues a subaward.
- Treating the 14 data elements as boilerplate. Several of them (the FAIN, the Assistance Listings number and disbursement amount, the R&D indicator) get pulled from the prime award and have to be kept current as the prime award itself changes — a subaward document that was accurate at issuance can go stale if the prime award is later amended and the subaward isn’t updated to match.
- Writing a subaward SOW that just restates the prime’s aims. Covered above — it leaves nothing concrete for monitoring, invoicing, or the subrecipient/contractor determination to check against.
- Letting the SOW, budget, and period of performance drift apart after a rebudget or scope change without amending all three together.
- Forcing the de minimis indirect cost rate on a subrecipient that already has a negotiated rate — not permitted under 200.332(b)(4).
A note on the pending 2 CFR 200 rewrite
OMB published a proposed rule in the Federal Register (FR 2026-10817, 29 May 2026) that would substantially revise the Uniform Guidance and has been referred to informally in industry commentary as the “Uniform Grants Regulation.” As of this guide’s last-verified date, it is not a final rule — the public comment period closed 13 July 2026, with a proposed effective date of October 1, 2026 if finalized as proposed. Industry summaries of the draft describe it as also eliminating the fixed-amount subaward mechanism currently at 2 CFR §200.333, among other changes, but the definitions, sections, and obligations described in this guide (200.1, 200.331, 200.332) reflect the current, in-force regulatory text. Confirm against the current eCFR text or your institution’s sponsored-programs office before relying on any of this changing before a final rule is actually published.
Frequently asked questions
What are pass-through entities?
A pass-through entity is a non-federal recipient or subrecipient that provides a subaward to a subrecipient (including lower-tier subrecipients) to carry out part of a federal program, per 2 CFR §200.1. Universities, hospitals, and research institutes are the most common pass-through entities in research — and an institution becomes one automatically the moment it issues a subaward, whether or not anyone internally uses that term for it.
What is a statement of work?
A statement of work (SOW) is the contractual document — typically a discrete, incorporated-by-reference exhibit — that defines the specific tasks, deliverables, timeline, and milestones a party must complete under an agreement, including a subaward. Research offices sometimes call the same document a scope of work; see CASRAI’s Statement of Work vs. Scope of Work comparison for that terminology question.
Is my university a pass-through entity if it only received the federal grant and didn’t apply to be one?
Yes. PTE status isn’t something an institution applies for or is designated as separately — it attaches automatically under 2 CFR 200.1 the moment a recipient (or subrecipient) issues a subaward to another subrecipient to carry out part of the federal program. There’s no opt-in step and no separate PTE registration.
How many data elements does a pass-through entity have to include in a subaward?
The current text of 2 CFR §200.332(b)(1) lists 14 required elements — from the subrecipient’s name and unique entity identifier through the indirect cost rate. See the table above for the full list; some older summaries reference “13,” reflecting an earlier version of the same list.
Does a subaward’s statement of work have to match the prime award’s statement of work exactly?
No — and it shouldn’t. The subaward SOW should be a clearly bounded subset of the prime award’s scope: the specific tasks and deliverables assigned to that subrecipient, broken down concretely enough to monitor and invoice against, not a restatement of the entire project.
What happens if a pass-through entity doesn’t monitor its subrecipients?
The PTE remains accountable to the federal awarding agency regardless of whether it actually performed the monitoring 2 CFR 200.332 requires. Inadequate subrecipient monitoring is a recurring federal audit finding, and the PTE — not just the subrecipient — bears the compliance exposure. See CASRAI’s subrecipient monitoring checklist for the full monitoring obligation.
Last verified: August 2026, against 2 CFR §200.1, §200.331, and §200.332 (current in-force text) via law.cornell.edu’s eCFR mirror. Dollar thresholds and rate percentages referenced in passing (the 15% de minimis indirect cost rate ceiling) reflect OMB’s April 2024 Uniform Guidance revision; the status of OMB’s pending further rewrite (FR 2026-10817) should be reconfirmed if this guide is read more than a few months after its last-verified date, since that is the fastest-moving fact on this page. This guide covers US federal awards under the Uniform Guidance; non-federal and non-US funders use comparable but not identical pass-through/subaward frameworks.
