Post-Award — Where Awards Are Won or Lost

Module 5: Post-Award — Where Awards Are Won or Lost

Most grant management training stops at submission. You send the application, wait for the decision, and hope for the best.

But if you win the award, that's when the real work begins. The post-award phase — from the moment you receive your Notice of Award through closeout — is where grants succeed or fail. A well-written application that's poorly managed leads to compliance findings, clawed-back funds, and damaged relationships with federal agencies.

This module covers everything that happens after you win.

The Notice of Award

When your application is selected for funding, you receive a Notice of Award (NoA). This is the official document that establishes your grant — it's essentially a contract between your organization and the federal government.

How to Read a Notice of Award

A NoA typically contains:

What You're Agreeing To

By accepting the award (which often happens automatically if you don't decline within a specified period), you agree to:

1. Use the funds only for the purposes described in your approved application

2. Follow all terms and conditions in the NoA

3. Comply with 2 CFR 200 (the Uniform Guidance covered in Module 4)

4. Submit all required reports on time

5. Notify the agency of significant changes to your project, budget, or personnel

6. Maintain records for the required retention period

7. Cooperate with monitoring, audits, and site visits

Action step: When you receive a NoA, read it carefully within the first week. Create a calendar with every deadline mentioned in the document — report due dates, budget period end dates, and any milestones the agency expects.

If you're using GrantsPath, the award importer parses your NoA (PDF or CSV) and extracts award amount, project and budget periods, reporting requirements, program officer contacts, and special terms into structured records. The system flags fields it extracted with high confidence and asks you to verify lower-confidence ones — so you can move from a 30-page NoA to a structured grant record in minutes rather than hours.

Reporting Requirements

Federal grants require regular reporting. Missing a report deadline is one of the fastest ways to jeopardize your funding.

Performance Reports (Progress Reports)

Performance reports describe what you've accomplished during the reporting period. They typically cover:

Frequency: Usually semi-annual (every 6 months) or annual, depending on the agency and program. Check your NoA.

What reviewers of progress reports look for:

Tips for strong progress reports:

1. Track activities continuously — Don't wait until the report is due to figure out what you did. Keep a running log of activities, participant counts, and milestones.

2. Connect activities to objectives — Structure your report around the goals and objectives from your application so the program officer can easily see alignment.

3. Be honest about challenges — Every project encounters problems. Reporting them honestly — along with your solutions — demonstrates competent management. Hiding problems until they become crises is far more damaging.

4. Include data — Quantify everything you can. "We served 147 participants across 12 workshops" is better than "We held workshops and served community members."

Financial Reports (Federal Financial Reports — SF-425)

Financial reports account for how you spent the money. The standard form is the SF-425 (Federal Financial Report).

What the SF-425 captures:

Frequency: Usually quarterly or semi-annual. Some agencies require quarterly financial reports even when progress reports are only semi-annual.

Common financial reporting problems:

What Happens When You Miss a Deadline

If you miss a reporting deadline:

1. First time: You'll usually receive a reminder from your program officer or grants management specialist. Submit as quickly as possible with an explanation.

2. Repeated or extended delays: The agency may place your grant on a specific condition — additional requirements or restrictions until you catch up.

3. Severe cases: The agency can suspend or terminate the grant, or withhold future funding.

The simplest fix: Put every reporting deadline in your calendar with a 30-day advance reminder. Start drafting reports at least 2 weeks before they're due.

GrantsPath's Reporting Deadlines dashboard widget surfaces every active award's upcoming deadlines with status flags — submitted, in progress, overdue. Email notifications go out at configurable intervals (typically 30, 14, and 7 days before due dates) so reports don't slip even when staff change or workloads spike. The reporting events are tracked per award, so a portfolio of active grants doesn't require a portfolio of separately-maintained calendars.

Drawdown Mechanics

"Drawing down" funds means requesting reimbursement for expenses you've incurred. Most federal grants operate on a reimbursement basis — you spend the money, then request it from the federal government.

How Drawdowns Work

1. Your organization incurs an allowable expense (e.g., pays a staff member's salary for the month)

2. You log into the Payment Management System (PMS) or ASAP (Automated Standard Application for Payments) — the system depends on the agency

3. You request the amount you've spent

4. The federal payment system transfers the funds to the bank account on file in SAM.gov

Drawdown Best Practices

Common Drawdown Errors

Compliance Monitoring

Federal agencies monitor their grants to make sure funds are being used properly. This can happen in several ways.

Types of Monitoring

Desk reviews — The program officer reviews your reports, financial records, and other documentation from their office. This is the most common form of monitoring and happens continuously.

Site visits — A program officer or monitoring team visits your organization in person to review records, interview staff, observe program activities, and assess compliance. Site visits may be routine (scheduled in advance) or triggered by concerns.

Conference calls/virtual reviews — Increasingly common, especially for smaller awards. The program officer schedules a call to discuss progress, review documents shared electronically, and assess compliance.

What Monitors Look For

How to Prepare for a Monitoring Visit

1. Organize your files — Financial records, programmatic records, procurement files, and correspondence should be accessible and well-organized

2. Review your application — Refresh your memory on what you proposed and make sure your activities align

3. Prepare a summary — Have a brief project overview ready: what you've accomplished, where you are in the timeline, and any challenges

4. Brief your staff — Key personnel should be available and prepared to discuss their roles

5. Don't panic — Monitoring is normal and expected. A well-managed project has nothing to fear.

Pass-Through Awards: When You're a Subrecipient

If your grant is a federal pass-through award — federal money flowing through a state agency to your Tribe — you're technically a subrecipient of the state, not a direct federal grantee. This changes several aspects of post-award management.

What Changes for Subrecipients

Your primary point of contact is the state. Reporting, communication, drawdown requests, and routine compliance questions all go to the state agency, not the federal agency. Build a relationship with your state program officer the same way you would with a federal one.

The state monitors you. State agencies have their own monitoring schedules — desk reviews, site visits, document requests. The state typically has primary monitoring authority for pass-through subrecipients.

The federal agency can also monitor you. Federal agencies retain the right to audit and monitor subrecipients directly, especially when concerns arise or for high-risk awards. Don't be surprised if a federal monitoring visit happens on a state-administered award.

Reporting is two-tiered. You report to the state. The state aggregates your reports with other subrecipients' reports and reports to the federal agency. Your state reports may be more frequent (often quarterly) than the federal-level aggregated reporting.

Single Audit obligations are unchanged. The Single Audit threshold (currently $750,000 in federal awards in a fiscal year) counts pass-through funding the same as direct federal funding. If your total federal exposure crosses the threshold — direct grants plus pass-through awards — you need a Single Audit.

Sovereign Immunity and Subawards

Sovereign immunity considerations are heightened in pass-through scenarios. Your subrecipients may ask for limited waivers in subaward agreements. Federal pass-through compliance requirements may include language that touches sovereignty. As covered in Module 4, never sign a waiver — even in a routine subaward agreement — without tribal attorney review.

The flip side of being a subrecipient is being the pass-through entity yourself — when your Tribe receives a federal grant and passes some of those funds to other entities. The next section covers what's required.

Issuing Subawards: When You Become the Pass-Through Entity

When your Tribe receives a federal grant and passes some of that funding to other entities — your own departments, partner organizations, consortium tribes — you become a pass-through entity with monitoring obligations of your own.

This is one of the most commonly under-managed areas of tribal grant compliance. Many Tribes issue subawards routinely — to a tribal Health Department, to an Education Department, to a nonprofit running a program — without realizing that 2 CFR 200 imposes specific obligations on them as the pass-through entity. Audit findings related to subrecipient monitoring are common, and they're almost always preventable with a clear procedure.

This section walks through what's required, in the order it happens: classifying the relationship, assessing risk, building the subaward agreement, monitoring during the award, and verifying audits.

Subrecipient or Contractor? Get the Classification Right

Before any of the subrecipient monitoring rules apply, you have to determine whether the entity receiving your grant funds is actually a subrecipient or a contractor. The distinction is one of the most commonly missed compliance issues, and it changes which rules apply.

The Difference

A subrecipient carries out a portion of your federal program. They make programmatic decisions, their performance is measured against the program's objectives, and they're subject to the federal program's compliance requirements. Examples for tribal grants:

A contractor provides goods or services that support your project but isn't carrying out the program. They operate in a normal commercial relationship — you pay for a service, they deliver it. Examples:

The 2 CFR 200.331 Criteria

Federal regulation (2 CFR 200.331) lays out specific characteristics. An entity is more likely a subrecipient when it:

An entity is more likely a contractor when it:

The substance of the relationship controls — not what the agreement is called. You can't make a subrecipient relationship into a contractor relationship by labeling the agreement "contract" instead of "subaward."

Why Classification Matters

If you classify a subrecipient as a contractor by mistake, you skip the required risk assessment, you miss the required terms in the subaward agreement, you don't monitor the entity the way 2 CFR 200 requires, and you don't verify their audit obligations. All of those are findings waiting to happen.

If you classify a contractor as a subrecipient, you impose unnecessary administrative burden on a vendor relationship — and you confuse the procurement record.

Document your determination. For each entity, note the criteria you applied and the conclusion you reached. Keep that documentation in the grant file. When an auditor asks why you treated a relationship one way and not the other, you want a written answer ready.

Before the Subaward: Risk Assessment

2 CFR 200.332(b) requires you to evaluate each subrecipient's risk of noncompliance before issuing the subaward. The intensity of your monitoring during the award is supposed to be calibrated to the risk you assess.

What to Assess

Federal regulation lists four core factors:

1. Prior experience with the same or similar subawards. Has this entity managed federal funds before? Successfully?

2. Results of previous audits. Has the entity been audited? Were there findings? Have findings been resolved?

3. New personnel or substantially changed systems. Has the entity had recent leadership turnover or major changes to its financial systems? Either signals elevated risk.

4. Extent and results of federal awarding agency monitoring (if the subrecipient also receives federal awards directly). What does the federal record show?

For tribal pass-through entities, additional considerations are useful:

Documenting the Assessment

Most pass-through entities use a simple risk rating: Low, Moderate, High.

The risk rating drives monitoring intensity. A high-risk subrecipient may need monthly desk reviews and a site visit; a low-risk one may need only quarterly check-ins.

Document the assessment in writing. A one-page risk memo per subrecipient — listing what you reviewed, what you found, and what risk level you assigned — satisfies the requirement and creates the record you'll need at audit.

What Must Be in the Subaward Agreement

2 CFR 200.332(a) lists specific data elements that must appear in every subaward agreement. Missing any of these is a finding.

Required Federal Award Identification

The subaward agreement must include:

This list is not optional. Federal auditors check for these elements specifically.

Required Terms and Conditions

Beyond the identification block, the subaward agreement must:

Tribal-Specific Clauses

In addition to the federal requirements, tribal pass-through entities should consider:

Always have a tribal attorney review subaward agreements before they're signed. A boilerplate subaward agreement built without tribal review is one of the most common sources of unintended sovereignty waivers.

Monitoring During the Award

2 CFR 200.332(d) requires pass-through entities to monitor subrecipients' activities to ensure the subaward is used for authorized purposes, in compliance with federal requirements, and that performance goals are achieved.

This is the part most tribal pass-through entities under-do. The federal regulation describes monitoring as a continuous obligation, not a once-a-year check.

Required Monitoring Activities

The regulation specifies, at minimum:

1. Reviewing financial and performance reports required by the pass-through entity

2. Following up to ensure subrecipient takes timely and appropriate action on all deficiencies

3. Issuing management decisions for audit findings (covered below)

4. Verifying every subrecipient is audited as required when they expend $750,000 or more in federal awards in a fiscal year

Calibrating Monitoring to Risk

The intensity should match the risk assessment. A practical pattern:

Low-risk subrecipients:

Moderate-risk subrecipients:

High-risk subrecipients:

What to Document

For each monitoring activity, keep a record showing:

This documentation is what auditors look for when they assess your subrecipient monitoring program. A monitoring program that exists in practice but isn't documented may as well not exist for audit purposes.

Audit Verification and Management Decisions

If a subrecipient expends $750,000 or more in federal awards in a fiscal year (across all federal sources, not just your subaward), they're required to have a Single Audit. As the pass-through entity, you have to verify they comply.

Verifying the Single Audit

For subrecipients above the threshold:

1. Confirm the audit is performed by a qualified independent auditor

2. Obtain a copy of the audit report within 30 days of issuance, or directly from the Federal Audit Clearinghouse

3. Review findings related to your subaward specifically

If the subrecipient is below the $750,000 threshold, no Single Audit is required — but you can require alternative financial verification (audited financial statements, agreed-upon-procedures engagement) if your risk assessment warrants it.

Issuing Management Decisions

When a subrecipient has audit findings related to your subaward, you (the pass-through entity) are required to issue a management decision within six months of the audit's acceptance.

A management decision states:

Management decisions are formal letters, kept in the grant file, and provided to the federal awarding agency on request. Failing to issue management decisions on subrecipient findings is itself a common finding against the pass-through entity.

Common Subaward Scenarios for Tribal Pass-Through Entities

Different subaward relationships raise different practical considerations.

Internal Departmental Subawards

When a Tribe receives a federal grant and assigns part of the work to its own Health Department, Education Department, or other internal entity, the relationship looks internal — but if the department is a separately-organized entity for federal purposes (its own accounting, its own reporting, sometimes its own UEI), the federal compliance rules treat it as a subaward.

Even when the department is fully integrated with the Tribe, internal cost allocations need to be documented carefully. A federal auditor will ask how the funds moved, who decided, and how time and effort was tracked. "We just transferred it" is not a compliant answer.

Partner Nonprofit Subawards

When a Tribe subawards to an external nonprofit partner, the full subrecipient monitoring framework applies in its strongest form. The partner is a separate legal entity with its own systems, its own staff, and its own audit obligations.

This is the scenario where the risk assessment most matters. A partner nonprofit may be excellent programmatically but weak on federal compliance. Your role as pass-through entity is to either build their capacity (technical assistance, training) or monitor closely enough to catch problems early.

Consortium and Inter-Tribal Subawards

When a lead Tribe issues subawards to consortium members — common in climate resilience, broadband, transportation, and large-scale planning grants — the relationships are intergovernmental and require more careful structuring than typical subawards.

Considerations specific to inter-tribal subawards:

A Joint MOU (Memorandum of Understanding) between the lead Tribe and consortium members often provides the foundation for these relationships, with the subaward agreements implementing the MOU's principles. The MOU sets the intergovernmental terms (sovereignty, jurisdiction, decision authority); the subaward implements the federal grant management terms.

Vendor Agreements (Not Subawards)

Reminder: when you contract with a vendor for goods or services, that's not a subaward. Procurement rules apply (covered in Module 4 under 2 CFR 200 procurement standards), not subrecipient monitoring rules. Don't confuse the two.

Subaward Closeout

Subaward closeout mirrors prime award closeout, but it happens earlier — your subrecipient closes out their subaward to your Tribe before your Tribe closes out the prime grant to the federal agency.

Closeout Steps for Each Subrecipient

1. Final performance report from the subrecipient describing what was accomplished

2. Final financial report accounting for all funds received and spent

3. Final drawdown for any remaining authorized expenses

4. Return of unexpended funds to the pass-through entity (your Tribe), if applicable

5. Property inventory for any equipment over $5,000 purchased with subaward funds

6. Records turnover or retention — agreement on which entity retains which records and for how long

You then aggregate subrecipient closeout data into your prime award closeout. This is why it's critical to start subaward closeout 60–90 days before *your* prime grant period ends — you need time to receive subrecipient final reports, review them, request corrections, and incorporate them into your federal closeout.

Executive Order and Policy Change Impacts

Federal policy can change during your grant period. Executive orders, agency policy changes, and legislative shifts can affect active awards.

What Can Change

What You Should Do

1. Stay informed — Monitor federal policy announcements relevant to your funding agency

2. Read agency communications — Program officers will usually notify grantees of changes that affect their awards

3. Don't assume — If you're unsure whether a policy change affects your grant, ask your program officer directly

4. Document everything — If a policy change requires you to modify your project, keep a record of the change and your response

Important: Don't make major changes to your project based on news reports alone. Wait for official guidance from your funding agency. And never stop spending or reporting without written direction from your program officer.

Findings Management

A finding is a problem identified during an audit or monitoring review. Findings range from minor procedural issues to serious compliance violations.

Types of Findings

How to Respond to Findings

1. Don't panic or get defensive. Findings are common, even in well-managed organizations. What matters is how you respond.

2. Understand the finding. Read it carefully and make sure you know exactly what the issue is.

3. Develop a Corrective Action Plan (CAP). This document explains:

4. Implement the CAP. Do what you said you'd do, on the timeline you committed to.

5. Document the resolution. Keep records showing that you completed each corrective action.

Tip: A finding that's promptly corrected with a solid CAP actually demonstrates management competence. Federal agencies care more about your response than the initial problem.

Closeout

Closeout is the final phase of a grant — the administrative steps you complete after the project period ends.

Closeout Steps

1. Final performance report — A comprehensive summary of what the project accomplished over its entire period

2. Final financial report (SF-425) — Accounting for all funds received and spent

3. Final drawdown — Request any remaining funds for expenses incurred before the project period ended

4. Return of unexpended funds — If you drew down more than you spent, return the excess

5. Invention/patent disclosure — If applicable, report any inventions resulting from the project

6. Final property inventory — Account for any equipment purchased with grant funds

7. Record retention begins — The retention clock starts when you submit your final expenditure report

Common Closeout Mistakes

Exercise: Review a Notice of Award

For this exercise, use a NoA from one of your organization's current or past grants (or ask your grants administrator for a sample). Work through these questions:

1. What is the project period vs. the budget period?

2. List all reporting deadlines (type of report, frequency, due dates)

3. Identify the program officer and grants management specialist contact information

4. List any special terms and conditions beyond standard requirements

5. What is the total award amount vs. the current budget period amount?

If you don't have access to a NoA, the same analysis applies to any grant award letter — the goal is to identify your obligations before you start spending.

Key Takeaways

How GrantsPath Helps

GrantsPath's Active Awards tab is the operational hub for post-award management — every imported NoA becomes a structured award record with reporting deadlines, compliance flags, executive order risk markers, and links to source documents. The Reporting Deadlines dashboard widget surfaces upcoming deadlines across the full portfolio at a glance, with email notifications keyed to each report type.

The calendar integrates grant deadlines with personal events and briefing overlays so post-award work coexists with the rest of your team's planning. Executive order impact alerts flag policy changes that may affect your active grants, giving you time to assess and respond before the agency reaches out. Council Summary PDFs export portfolio status — active awards, reporting status, executive order risks — into a formatted report you can share with tribal leadership without rebuilding the document each quarter.

For consortium and inter-tribal subawards, the Joint MOU Templates (Nation tier) provide reference clauses for inter-tribal agreements — sovereignty language, jurisdictional provisions, decision authority frameworks — that you can customize and review with counsel rather than drafting from scratch.

Related guides: Post-Award Compliance · Calendar & Reminders · Joint MOU Templates