The subgrantees in question were Boys & Girls Clubs of America, National Youth Service League, Young Men’s Service League, and Boise State. 9/11 Day researched all subgrantees, required each to provide MOUs, program details, and budgets, and verified organizational status using resources such as Candid and Charity Navigator. Financial statements were also reviewed, but documentation of these reviews and verifications was not consistently retained, and certain federal requirements were not fully incorporated into the process. 9/11 Day has now adopted a written policy that ensures that, in its role as a pass-through entity, all subgrants will be made in full compliance with the minimum required elements found under 2 CFR 200.332(b). This shall include implementing a comprehensive tracking and monitoring system for all subgrantees, regardless of funding level, with enhanced verification requirements for those receiving over $30,000. All subaward agreements will be updated to include the minimum required elements under 2 CFR 200.332(b), and the evaluation of subgrantee risk will incorporate all suggested elements under 2 CFR 200.332(c), including consideration of fraud risk and risk of noncompliance. The system will record the time and date of all eligibility verifications and retain supporting documentation, including MOUs, SAM.gov confirmation of suspension and debarment status, IRS Form 990s, financial statements, and audit confirmations. In compliance with 2 CFR 200.332(e)(1), subgrantees will now be required to submit both performance and financial reports, which will be reviewed and compared against project budgets. In addition, 9/11 Day will evaluate subgrantees’ Single Audits, if filed, in accordance with 2 CFR 200.332(e)(2)–(4) and will review any reported deficiencies. All monitoring activities will be documented and logged throughout the life of each project to ensure stronger oversight, complete documentation, and compliance with federal requirements.