Who is primarily responsible for ensuring that subrecipients comply with federal laws and regulations during the implementation of grants or cooperative agreements?

The primary responsibility for ensuring that subrecipients comply with federal laws and regulations during the implementation of grants or cooperative agreements falls on the pass-through entity. The pass-through entity, which is typically the organization that awards funding to the subrecipient, has the duty to oversee project compliance, including adherence to federal regulations, guidelines, and the terms of the grant.

This encompasses not only monitoring the subrecipient's use of funds but also ensuring the effectiveness of their implementation processes, reporting, and adherence to performance expectations as outlined in the agreement. The pass-through entity acts as a bridge between the federal grant agency and the subrecipients, which includes providing guidance, support, and oversight to help ensure compliance throughout the grant period.

While subrecipients must also adhere to the requirements, their compliance is managed under the oversight of the pass-through entity. The grantor agency does establish the regulations and guidelines but relies on the pass-through entity to implement their oversight responsibilities. An auditing agency may review compliance but does not actively manage or ensure compliance during implementation, thus highlighting the unique role of the pass-through entity in the grants management process.