01
Pass-through is a fiduciary role
An entity that disburses funds carries the same compliance obligations as the one that received them.
Service Engagement
Move the Funding.
Account for It All.
A pass-through entity receives funds under one set of terms and re-grants them under terms that carry those obligations down. It is a fiduciary role, and it answers for how subrecipients spend long after the money has left its account. CAMPBELL designs the award process, executes the agreements, moves the funds, and holds the monitoring and compliance obligations attached to them.
The Basics
The Core Concepts.
Subgrant administration is a lifecycle with documentation obligations at every stage. Each one is designed before the application opens, not improvised once funds are moving.
02
Terms flow down or they vanish
Anything the subgrant agreement omits cannot be enforced later, however clearly it bound the original award.
03
Structured awards beat first-come
A published application, declared criteria, and documented scoring direct funding by need and readiness, and withstand scrutiny.
04
Monitoring catches what closeout cannot
A program that only reviews spending at the end has a reporting function, not a monitoring one.
Our Approach
Accountable in Both Directions.
An intermediary sits between a funder with obligations and organizations with needs, and answers to both. The division of responsibility has to be settled before the first dollar moves.
01
Directed by the funder
The funder sets priorities, approves the application before release, participates in scoring and award decisions, and receives reporting against the terms attached to the original source.
02
Administered by CAMPBELL
We build the application and scoring process, execute subgrant agreements, disburse and monitor funds, handle closeout, and document the whole of it for audit.
The Lifecycle
From Application to Closeout.
Six stages, each with its own documentation obligation. All of them designed before the application opens.
01
Application design
Eligibility, required attachments, review criteria, and scoring rubric, built with the funder and approved before release.
02
Outreach and intake
Published timeline, applicant guidance, and a question period, so smaller organizations are not screened out by process alone.
03
Scoring and award
Documented scoring against the published rubric, funder participation in decisions, and a written basis for every award and denial.
04
Agreements and disbursement
Subgrant agreements that carry the terms from the original award down, with a payment schedule matched to each subrecipient’s capacity.
05
Monitoring
Financial and programmatic reporting, expenditure review, scheduled check-ins, and corrective action where it is needed.
06
Closeout
Final reporting, reconciliation, document retention, and a written record of what the subrecipient gained.
Award Design
What a Fair Process Requires.
The application is the first and often the only impression a small organization forms of a program. It is also where most inadvertent exclusion happens.
Rubric before application
Write the scoring criteria first, then the questions that let an applicant earn those points.
Reachable requirements
Audit thresholds, match requirements, and portal-only submission each screen out organizations by size rather than by merit.
A real question period
Published answers, shared with every applicant, so knowing whom to call is not an advantage.
Contemporaneous records
The basis for each award and denial, recorded when the decision is made rather than reconstructed later.
Problems We Solve.
These engagements address why funding aimed at small organizations so often fails to land.
Funds that cannot move
Subrecipients lack the bank arrangements, accounting, or documentation to receive an award, and disbursement stalls.
Reimbursement that excludes
Paying in arrears requires working capital, and quietly removes the smallest organizations from the pool.
Compliance discovered at closeout
Allowable cost rules, match requirements, and retention obligations surface after the spending, when nothing can be fixed.
An award process that cannot be defended
Scoring was informal, the basis went unrecorded, and a disappointed applicant asks why.
Monitoring that only counts spending
Reports track burn rate while the subrecipient’s actual condition goes unexamined until it is too late.
No capacity to absorb the next award
Funds are spent allowably, and the organization ends no better able to manage funding than it began.
The Benefits
What You Gain.
A defensible award process, a compliant pass-through, and a record that holds up under review.
A defensible award process
Published criteria, documented scoring, and a written basis for every decision.
A compliant pass-through
Agreements, disbursement controls, monitoring, and retention aligned to the terms of the originating award.
Problems caught in time
Risk-based monitoring that surfaces issues while corrective action is still possible.
An audit-ready record
Contemporaneous documentation at every stage, assembled as the work happens rather than reconstructed.
Engagement Options
Scalable Options to Meet Your Needs.
Three levels, depending on whether funds flow through CAMPBELL and how much of the lifecycle we hold.
Level 01
Award Design
Build the application and scoring process.
Funds flowFunder disburses directly
Best fit
Funders who will hold the money and run the award themselves, and need the process designed properly.
- Eligibility criteria and required attachments
- Application instrument and applicant guidance
- Scoring rubric and reviewer instructions
- Outreach plan and published timeline
- Question period management and published answers
- Scoring facilitation and award recommendations
Process Design
Discuss This LevelLevel 02
Pass-Through Administration
Hold the funds and move them under agreement.
Funds flowDisbursed by CAMPBELL
Best fit
Funders who need an intermediary to execute agreements, disburse, and monitor.
- Everything in Award Design
- Subgrant agreements carrying the originating terms down
- Payment schedules matched to subrecipient capacity
- Disbursement and expenditure review
- Financial and programmatic reporting collection
- Closeout, reconciliation, and document retention
Pass-Through Entity
Discuss This LevelRecommended
Level 03
Full Subgrant Office
Run the whole lifecycle, with monitoring that acts.
Funds flowDisbursed by CAMPBELL
Best fit
Multi-year programs placing a defined sum with a cohort over several award cycles.
- Everything in Pass-Through Administration
- Risk-based monitoring plan, by subrecipient
- Scheduled check-ins with finance staff, not only leadership
- Written corrective action and follow-through to closure
- Consolidated reporting across the full portfolio
- Audit preparation and response support
End to End
Discuss This LevelCompare Engagement Levels
What Each Level Includes.
Each level carries everything in the level before it.
| Service | Award Design | Pass-Through Administration | Full Subgrant Office |
|---|---|---|---|
| Scope | |||
| Who disburses funds | Funder | CAMPBELL | CAMPBELL |
| Who holds compliance | Funder | Shared | CAMPBELL |
| Award Process | |||
| Eligibility and application instrument | Included | Included | Included |
| Scoring rubric and reviewer instructions | Included | Included | Included |
| Outreach, question period, published answers | Included | Included | Included |
| Documented scoring and award basis | Included | Included | Included |
| Fiscal Administration | |||
| Subgrant agreements | Not included | Included | Included |
| Disbursement and payment scheduling | Not included | Included | Included |
| Expenditure review | Not included | Included | Included |
| Closeout, reconciliation, and retention | Not included | Included | Included |
| Monitoring | |||
| Report collection and review | Not included | Included | Included |
| Risk-based monitoring plan | Not included | Not included | Included |
| Scheduled check-ins with finance staff | Not included | Not included | Included |
| Corrective action through to closure | Not included | Not included | Included |
| Audit preparation and response | Not included | Not included | Included |
Statewide Delivery
Statewide and multi-state subrecipient portfolios are administered virtually, with check-ins scheduled against each subrecipient’s own reporting calendar. Geography sets the site visit plan, not the reach.
Our Recommendation
Full Subgrant Office.
For multi-year programs where someone has to answer for how every dollar was spent, and by whom.
Why this is the strongest fit
Collecting reports is not monitoring. The difference shows up at audit, when the question is not whether a report arrived but whether anyone read it in time to act.
- Concentrates contact on the subrecipients that actually carry risk, rather than treating a first-time grantee like an experienced one
- Puts a finding in front of someone while there is still time to correct it
- Builds the audit record as the work happens, instead of assembling it under deadline afterward
- Consolidates a whole portfolio into reporting the funder can take upward without rework
An Alternative to Consider
Pass-Through Administration remains the right choice for single-cycle programs with experienced subrecipients.
Next Steps
How to Get Started.
Every engagement begins the same way, with a conversation. There is no cost and no obligation to schedule one.
01
Schedule a consultation
Share the funds, the terms they arrived under, and the timeline.
02
Define the award structure
Eligibility, criteria, award sizes, and the funder’s role in scoring.
03
Confirm the scope of work
Design alone, administration, or the full lifecycle.
04
Finalize the agreement and schedule kickoff
Application release date and reporting calendar are set.
What We Need From You
What we need from you: the terms of the originating award, any restrictions on allowable cost, the reporting you owe upward, and the eligibility boundary you have in mind.
The Guide
Read the Whole Method.
The operating practice behind the engagement, written for funders and intermediaries structuring a pass-through program.
Subgrant Management Guide
Ten pages covering the full lifecycle from application design through closeout, how to build a rubric before the application, the award barriers that quietly exclude the organizations you meant to reach, what a subgrant agreement has to carry down, and risk-based monitoring that catches problems while they can still be fixed.
Related Engagements
What Surrounds This Work.
These engagements sit on either side of the work, and are regularly scoped together.
Technical Assistance
Capacity building for the organizations receiving the subgrants, so the funds land somewhere able to hold them.
Learn More →The Grants Engagement
Readiness and proposal development for organizations on the receiving end of an award.
Learn More →Performance Measurement
Indicators and baselines that turn subrecipient activity into evidence a funder can act on.
Learn More →Schedule a Consultation
Let’s talk about what your organization needs.
A consultation is a conversation, not a sales call. We will discuss where you are, what you are trying to resolve, and whether this engagement is the right fit.
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Strategy, program design, performance measurement, grants, operations, and more, delivered virtually to organizations across all 50 states.
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