Three Practical Takeaways for Improving Sub-Awardee Oversight
Joey DeSantis and William Treanor of EY were a part of NGMA’s monthly webinar series. In their presentation, How to Get Sub-Awardees to Understand and Follow the Rules: A Lifecycle Approach to Uniform Guidance Compliance, they offered practical strategies for ensuring sub-awardees understand and comply with federal, state and organizational regulations. This article summarizes key takeaways from their presentation.
Access the recording through Grants Management Academy, NGMA’s education portal.
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Over the last year, grant professionals have been operating in a more uncertain environment than usual. Funding pauses, program terminations, legal challenges, and updated federal guidance have created real pressure for both prime recipients and their sub-awardees. In this climate, expectations around sub-awardee oversight have continued to increase, even as capacity remains strained.
Based on recent discussions with grant professionals, three themes consistently stand out when it comes to strengthening sub-awardee oversight in today’s environment.
- Sub-Awardee Oversight Starts Earlier Than Many Organizations Think
Many compliance issues traced back to sub-awardees do not originate during project execution. They begin much earlier, often during pre-award or onboarding, when expectations are not clearly communicated or risks are not fully assessed.
Recent policy changes and audit findings reinforce the importance of treating oversight as a lifecycle responsibility. Risk assessments, eligibility verification, flow-down of requirements, and documentation of expectations all need to happen before funds are released. Waiting until reporting problems or audit findings surface makes issues harder—and more expensive—to correct.
Organizations that invest time upfront tend to spend less time later responding to findings, negotiating corrective actions, or repairing strained relationships with sub-awardees.
- Many Compliance Issues Reflect Capacity Gaps, Not Resistance
In practice, most sub-awardee challenges are not caused by a lack of willingness to comply. They are caused by limited staffing, competing priorities, and unfamiliarity with federal requirements, especially among smaller organizations or first-time recipients.
When oversight is framed purely as enforcement, it can lead to pushback, delays, or breakdowns in communication. When it is paired with clear guidance, onboarding support, and targeted technical assistance, outcomes tend to improve for everyone involved.
Grant managers frequently see better results when they focus on helping sub-awardees understand what is expected, why it matters, and how to meet those expectations within their existing capacity.
- Risk-Based Monitoring Is More Effective Than One-Size-Fits-All Oversight
Not all sub-awardees pose the same level of risk, and monitoring approaches should reflect that reality. A risk-based framework allows organizations to focus attention where it is most needed, rather than applying the same level of scrutiny across the board.
Effective monitoring programs typically include regular desk reviews, periodic site visits for higher-risk partners, follow-up on audit findings, and clear documentation throughout the grant period. Just as important, they build in opportunities to adjust monitoring as circumstances change.
This kind of structured approach helps organizations identify issues earlier, use oversight resources more efficiently, and demonstrate due diligence if questions arise later.
Looking Ahead
Sub-awardee oversight is becoming more visible, more scrutinized, and more consequential. Federal agencies, auditors, and the public all expect stronger accountability across the full chain of grant funding.
For grants professionals, the goal is not simply to avoid findings. It is to create oversight practices that support compliance while allowing programs to operate effectively. Organizations that take a proactive, risk-informed approach are better positioned to meet that challenge—especially in an environment where uncertainty is likely to continue.