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Plain-English guide · for nonprofits

2 CFR 200.333, explained in plain English

Updated September 2026

§200.333 lets a pass-through entity pay a subrecipient a fixed amount for agreed work, instead of reimbursing costs. It needs prior written approval from the federal agency, and the subaward can be no more than $500,000.

What it is, and why a pass-through entity wants one

Ordinary subawards are cost-reimbursement: the subrecipient spends, documents, invoices, and you verify. A fixed amount subaward instead sets a price for defined deliverables or milestones. The subrecipient is paid on completion, not on receipts.

If you are the group receiving a fixed amount subaward, this is what your pass-through must do first, and what you will certify at the end.

For a small subrecipient that is a large relief. They do not have to report and reconcile actual costs for your $15,000 subaward, though they still certify at the end that costs met §200.403. For the pass-through entity, monitoring shifts from checking invoices to verifying that the work happened.

The conditions

§200.333 is a short section of the Uniform Guidance, and two conditions sit in its first sentence. Its second sentence adds a third:

  1. Prior written approval from the federal awarding agency

    Not from you. Not implied by the budget. You ask the agency and you get it in writing before the subaward is issued. Do not skip it.

  2. The amount is $500,000 or less

    The section sets a flat ceiling of $500,000. It is worth knowing that this used to be tied to the simplified acquisition threshold; the 2024 revision cut that link and wrote a fixed number instead, so guidance published before October 2024 has the wrong test. Above $500,000, a fixed amount subaward is not available.

  3. It must also meet §200.201(b)

    It cannot be used in a program that requires cost sharing (match). The amount is negotiated from cost or pricing data. At the end, the subrecipient certifies in writing that the work was done and that the costs met §200.403.

What does not change

A fixed amount subaward is still a subaward. The subrecipient is still a subrecipient under §200.331, you still owe the monitoring at §200.332, and the amount still counts toward your federal awards expended. What changes is what you monitor: performance and completion rather than allowability of individual costs.

Accountability is based on results. That makes the deliverables the whole agreement, so they have to be written well enough that both sides know what "done" means.

When to reach for one

  • The subrecipient is small and has no grant-compliant accounting system.
  • The work has a clear, verifiable output rather than an open-ended effort.
  • The program does not require match.
  • The amount is modest and the administrative cost of cost-reimbursement would be a real share of it.

And when not to: if you cannot define completion precisely, a fixed amount subaward converts a cost dispute into a performance dispute, which is harder.

This is general information, not legal or accounting advice. Federal grant rules change and are applied differently by different agencies and auditors. Check with your auditor, your grant officer, or an attorney before relying on any of it.

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Sources: 2 CFR Part 200 (eCFR), read 1 September 2026. Federal grant rules change; check the current text before relying on this.

Common questions

What is a fixed amount subaward?

A subaward that pays a set amount for defined deliverables or milestones rather than reimbursing documented costs. Accountability is based on performance and results rather than on the allowability of individual costs.

Do you need approval for a fixed amount subaward?

Yes. 2 CFR 200.333 requires prior written approval from the federal awarding agency before the pass-through entity issues one.

Is there a dollar limit on fixed amount subawards?

Yes. §200.333 caps a fixed amount subaward at $500,000, with prior written approval from the federal agency. Older guidance ties the cap to the simplified acquisition threshold instead; that was the pre-2024 rule and it no longer applies.

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