Federal Award Intake and Compliance Matrix for Nonprofits

Federal award intake turns a signed award into working instructions for your staff and systems. For each requirement, intake should answer what governs it, who must act, when, in which system, and what proves the work was done. Neither QuickBooks Online nor GrantLink makes you compliant. Compliance comes from your organization's conduct, controls, and records, and from following the award.

Always read the program statute, the agency's regulations, the award, the terms it incorporates, and later amendments. If you receive the award through a pass-through entity, the subaward may add terms.

The citations in this guide refer to the 2024 revision of 2 CFR 200, which took effect on October 1, 2024. On May 29, 2026, OMB published a proposed rule (91 FR 32198) that would revise parts of 2 CFR 200. As of October 2026, OMB has not issued a final rule, so the 2024 text still applies. Check the Federal Register for any final rule and its effective date.

Separate each party's duties first

Not every sentence in 2 CFR 200 is a duty for the recipient. Many sections set duties for the federal agency or the pass-through entity.

Duties of the federal agency or pass-through entity

• Under 2 CFR 200.208(d) and (e), before it imposes a specific condition, the agency or pass-through entity must tell you the condition, the reason, the action needed to remove it, the time allowed, and how to ask for reconsideration. It must promptly remove the condition once you meet it.
• Under 2 CFR 200.211, the federal agency must include required information and terms in the award. The rule tells the agency what to put in the award. It doesn't require the recipient to create anything.
• Under 2 CFR 200.308(d), the agency or pass-through entity must review a revision request. It should respond within 30 days, and if it needs longer, it must tell you in writing when to expect a decision.
• A pass-through entity has its own duties under 2 CFR 200.332, including identifying subawards, evaluating subrecipient risk, monitoring, following up on corrective action and audit findings, and getting access to records. A nonprofit has those duties only when it acts as a pass-through entity, not merely because it receives federal funds.

Duties of the recipient or subrecipient

• Keep a financial management system that meets 2 CFR 200.302(b). The system must identify each award, support required reports, trace funds to source documents, and safeguard assets. It must also compare spending with each award budget, and you need written procedures for cash management and for deciding whether costs are allowable.
• Under 2 CFR 200.303, set up, document, and keep effective internal controls. You also monitor compliance, act promptly on noncompliance, and take reasonable cybersecurity measures.
• Under 2 CFR 200.329(a) and (b), monitor each program, function, or activity. In performance reports, relate financial data and accomplishments to the award's goals.
• Keep records and give access to them under 2 CFR 200.334 to 200.337.

The intake matrix

The matrix below is a suggested internal practice. 2 CFR 200 doesn't prescribe this form. Add rows for agency and program requirements.

Intake item	Where the requirement comes from	Owner	Action in your systems	Evidence it's done
Legal recipient, UEI, Assistance Listing, federal award ID, agency or pass-through entity	Signed award and 200.211	Executive or finance lead	Confirm the legal entity and QuickBooks Online company, and create one grant record	Identity check signed by a reviewer
Award date, budget periods, period of performance	Award cover page and amendments	Program and finance	Enter the exact dates, and flag coding outside those dates for review	Comparison of the date fields
Federal and non-federal shares, approved budget	Award budget	Finance	Load the approved budget by category and the cost share commitment	Reconciliation of totals to the award
Scope, objectives, milestones, performance measures	Award narrative and the application it incorporates	Program	Assign an owner for each deliverable and its evidence	Milestone calendar
Financial, performance, property, subaward, and closeout reports	Award reporting schedule	Finance and program	Calendar the preparer, reviewer, submission method, and due date	Submission receipt and accepted report
Payment method and cash rules	Award, agency payment instructions, 200.305	Finance	Document the draw or reimbursement process and who does each step	Draw support tied to the bank and QuickBooks Online
Statutes, regulations, general terms, and program terms	The award's order of precedence clause	Compliance	Save or link the exact versions the award incorporates	Dated index of terms
Specific conditions	Notice under 200.208	Named control owner	Record the required action, deadline, reconsideration path, and status	The funder's notice that it removed the condition
Cost principles and item-specific approvals	Award and 200.403 to 200.476	Finance	Set up allowability and approval checks before anyone commits funds	Approval attached to the transaction file
Prior approval triggers	Award and 200.308	Program and finance	Route proposed changes for approval before you make them	Written approval, and the amendment if one is issued
QuickBooks Online tracking	Your approved accounting design	Controller	List every Customer, Project, Class or subclass, or Location used for this grant	Control total from QuickBooks Online detail
Subaward or procurement contract	The substance of the agreement and 200.331 to 200.332	Compliance or procurement	Document the classification, and set up monitoring if you pass funds through	Classification decision and monitoring file
Record retention start date and exceptions	200.334 and the award	Records owner	Set holds based on the triggering events, not only on an award end date	Log of holds and disposals

For more detail, see the grant compliance checklist, the subaward monitoring guide, and the federal budget revision guide.

Build the QuickBooks Online control plan

QuickBooks Online remains your accounting system. A suggested plan has five steps:

1. Define the population. List the exact QuickBooks Online tracking values that identify the award, including full parent and child names and any exclusions. In GrantLink, a grant can link several QuickBooks Online Classes or subclasses, and you set those links on each grant.
2. Keep the source lines. Keep the original QuickBooks Online transaction ID and amount. Record the grant allocation separately instead of overwriting the source transaction.
3. Map accounts to the funder's categories. Keep a dated crosswalk from QuickBooks Online accounts and allocation rules to the approved budget categories. In GrantLink, you set budget categories on each grant's budget. The shared Settings > QuickBooks > Mapping page holds organization-wide QuickBooks settings and does not hold this crosswalk.
4. Reconcile on a set schedule. Tie the QuickBooks Online transactions to the grant allocations, the budget category totals, draws, reports, and cash receipts. Investigate lines that are unmapped, duplicated, out of date, reversed, or outside the award period.
5. Keep accounting and allowability separate. A correctly posted QuickBooks Online expense isn't automatically allowable or claimable. Record each exclusion and its reason.

See how to reconcile a grant report to the QuickBooks general ledger and cost allocation methods.

GrantLink can hold each grant's QuickBooks links, allocations of QuickBooks Online activity, budgets, documents, and activity history. To draft a report, choose New chat under Chats in the sidebar. GrantLink is read-only toward QuickBooks Online by default. Its records don't replace the signed award, source documents, or professional judgment.

Control versions and amendments

Treat the accepted award as version 1, and never overwrite it. A suggested internal control has six steps:

1. Record an identifier for the accepted award package, e.g., a file hash, along with the effective date and the date you received it.
2. Keep the original award, the application and budget it incorporates, the terms, and the correspondence together.
3. Log each proposed change with its effect on scope, budget, milestones, cost share, reporting, and systems.
4. Track each proposal's status as draft, submitted, approved, denied, or withdrawn. A submitted request is not approved.
5. When you get written approval, create a new baseline that you don't edit, with a dated summary of the changes. Keep all earlier versions.
6. Update QuickBooks Online coding instructions, the grant budget and links in GrantLink, calendars, purchasing controls, and subaward instructions only as far as the approval allows. Reconcile the first report under the new baseline.

When terms conflict, follow the award's order of precedence clause and get written clarification. Don't pick whichever version gives the most convenient result.

Monitoring, recovery, and retention

Under 200.329, monitoring is continuous oversight and covers more than filing reports. A suggested monthly review compares accomplishments, obligations, spending, cost share, cash, forecasts, and conditions against the current approved baseline. Under 200.329(e), you must tell the agency or pass-through entity about significant developments between reports, including problems or delays that affect your ability to meet the award's objectives.

If intake was incomplete or you used the wrong version, take these steps:

1. Where practical, stop affected commitments, draws, allocations, and submissions.
2. Keep the original QuickBooks Online entries and all submitted records.
3. Identify the affected period and all affected transactions and reports.
4. Compare what you did with the terms that were in effect at that time.
5. Notify the authorized official, finance, the program lead, and legal or CPA advisers, as appropriate.
6. Ask the funder for direction or retroactive approval, and don't say approval is certain.
7. Correct QuickBooks Online only when the books are wrong, using your controlled adjustment process. Correct grant links or allocations in GrantLink when those are wrong.
8. Resubmit, repay, or disclose when required, and keep the decision and the reconciliation.

2 CFR 200.334 generally requires you to keep financial and supporting records for three years from the date you submit your final financial report. For awards renewed quarterly or annually, the three years run from the quarterly or annual financial report. The section changes the timing for litigation, claims, audits, written extension notices, property and equipment, records transferred to the federal agency, indirect cost proposals, and certain program income. State law, the award, tax rules, insurance, litigation holds, or your policy may require longer retention. We recommend that you calculate the disposal date from the correct reporting event, and that you stop any destruction whenever an exception applies.

Sources

• 2 CFR 200.208, Specific conditions
• 2 CFR 200.211, Information contained in a Federal award
• 2 CFR 200.302, Financial management, and 200.303, Internal controls
• 2 CFR 200.308, Revision of budget and program plans
• 2 CFR 200.329, Monitoring and reporting program performance
• 2 CFR 200.332, Requirements for pass-through entities
• 2 CFR 200.334, Record retention requirements

This guide is general information and is not legal or accounting advice.