New Thompson Publication Explains Fixed Amount Subawards

June 22, 2015 | By Jerry Ashworth | Post a Comment

WATCHbook-2Pass-through entities have traditionally made subawards and contracts under a federal award, but the Office of Management and Budget’s (OMB’s) uniform grant guidance offers a new option, the fixed amount subaward. A pass-through entity may offer fixed amount subawards to subrecipients, but must request prior approval from the federal awarding agency first. Once approved, pass-through entities may provide a fixed amount subaward up to the simplified acquisition threshold, currently set at $150,000 (§200.332). Under a fixed amount subaward, payment to the subawardee is based on meeting specific performance expectations, without regard to actual costs incurred under the federal award. (§200.201(b)).

The fixed amount payments may be issued in several ways including: partial payments (the amount of each must be agreed upon in advance, with “milestones” pinpointed to release payments); unit price basis; or one lump-sum payment at award completion (§200.201(b)(1)(i-iii)).

The pass-through entity may use fixed amount subawards only if the project scope is specific and if adequate cost, historical or unit pricing data is available to establish a fixed amount award based on a reasonable estimate of cost (§200.201(b)(1)). A fixed amount subaward cannot be used in programs that require mandatory cost sharing or match (§200.201(b)(2)). The subrecipient must certify in writing to the pass-through entity at the end of the subaward that the project or activity was completed or the level of effort was expended. If the required level of activity or effort was not carried out, the amount of the subaward must be adjusted (§200.201(b)(3)).

The uniform guidance describes a fixed amount award, but offers few details how to implement and monitor them. This creates some level of flexibility for pass-through entities; however, it would be important that pass-through entities define expectations and standards in a new written policy and procedure in advance of using this award instrument. It may be of benefit to confer with auditors. Even though cost data is not required for the award instrument, an auditor may still need cost data.

Thompson Information Services covers requirements under the new fixed amount subaward, and other details and requirements for subrecipient monitoring in its newly released Techniques for Monitoring Federal Subawards, 4th Edition.  Go to to order.

Let us know your opinions on the new fixed amount subaward option.


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