Compliance Resource · 2 CFR Part 200
Federal Grant Compliance Checklist for 501(c)(3) nonprofits
Every line below maps to a real obligation under the federal Uniform Guidance — rebuilt for the
2024 revisions that took effect October 1, 2024. Work it top to bottom before your next drawdown,
board meeting, or audit. The boxes save as you go.
Updated for 2024 Uniform Guidance
Authority · 2 CFR Part 200
Single-Audit FYs ending on/after Sep 30 2025
What changed in the 2024 overhaul — verify which version applies per award
$750K → $1M
Single Audit threshold (federal $ expended)
10% → 15%
De minimis indirect cost rate (of MTDC)
$5K → $10K
Equipment / capitalization threshold
$25K → $50K
Per-subaward MTDC exclusion
NEW
Cybersecurity is now an internal-control requirement (encryption, MFA)
NEW
Data & evaluation costs are allowable (§ 200.455)
01
Registration & eligibility
Get these right before you accept a dollar — a lapse here can freeze every drawdown.
SAM.gov registration active and renewed annually § 200.300 Unique Entity Identifier (UEI) current — DUNS is fully retiredOrganization not suspended or debarred — confirm in SAM.gov exclusions Current IRS 501(c)(3) determination letter on file Indirect-cost decision documented — negotiated rate (NICRA) or de minimis up to 15% of MTDC § 200.414 Read the NOFO and award terms ; note whether the award follows pre- or post-Oct 1 2024 guidance
02
Written policies & internal controls
If it isn't written down, an auditor treats it as if it doesn't exist.
Written procurement policy with current dollar thresholds § 200.318–327 Written cash-management / drawdown policy Written allowability / cost-principles policy and a travel policy Conflict-of-interest policy — organizational and individual § 200.318 Documented segregation of duties and an approval matrix Cybersecurity controls in your internal controls — encryption, MFA, PII safeguards 2024 Records retained 3 years from final-report submission § 200.334
03
Financial management & accounting
Each award tracked separately by Assistance Listing (CFDA) number § 200.302 Chart of accounts maps to each grant budget (class / program / location) Restricted vs. unrestricted net assets tracked correctly; no commingling of federal fundsBudget vs. actual reviewed monthly; budget revisions approved in writingIndirect costs calculated on a correct MTDC base (exclude capital, and subaward amounts over $50K)
04
Allowable costs — test every charge
A cost must clear all four gates: reasonable, allocable, consistently treated, and adequately documented.
Reasonable, allocable, and necessary to the award § 200.403–405 Conforms to award terms and cost principles Subpart E Consistently treated — never charged as both direct and indirectSupported by documentation — receipts, approvals, allocation basis Data & evaluation costs claimed where applicable § 200.455 2024 Unallowable costs excluded — lobbying, fundraising, fines, alcohol, bad debt
05
Time & effort / personnel
Time-and-effort records support every payroll dollar charged to a federal award § 200.430 Labor distribution reconciles to actual hours and the general ledger Certifications signed by someone with firsthand knowledge of the work
06
Cash management & drawdowns
Minimize the time between drawing federal cash and disbursing it § 200.305 Drawdowns reconcile to actual expenditures , not estimates Interest over $500/year remitted; advances held in interest-bearing accounts Program income tracked and applied per the award terms § 200.307
07
Procurement
Procurement method matches the dollar threshold ; competition documented Micro-purchases ≤ $10,000 — reasonable price, rationale documentedSimplified acquisitions ≤ $250,000 — price or rate quotes obtainedSole-source justification written when competition is bypassedVendor confirmed not suspended or debarred before award
08
Subrecipient monitoring
If you pass funds to another organization, their compliance becomes your compliance.
Subrecipient vs. contractor determination documented § 200.331 Subaward agreement carries all required data elements and the matching UG version Verify the subrecipient is not excluded or debarred 2 CFR 180.300 2024 Risk assessment performed; monitoring plan in place; their audit findings reviewedMTDC excludes subaward amounts over $50,000 each when applying the indirect rate 2024
09
Reporting & closeout
Federal Financial Reports (SF-425) filed on timePerformance / progress reports submitted per the scheduleFFATA subaward reporting in FSRS for qualifying subawards (currently $30,000+)Closeout — final reports within 120 days of period end; obligations liquidated § 200.344
10
Audit readiness & the Single Audit
Determine if federal funds expended ≥ $1,000,000 in the fiscal year → Single Audit required § 200.501 2024 Maintain the Schedule of Expenditures of Federal Awards (SEFA) year-round, not at year-end Prior-year findings have a tracked corrective action plan PBC schedules reconciled day one; auditor liaison assignedSingle audit submitted to the Federal Audit Clearinghouse within 9 months of fiscal year-end