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Subrecipient Annual Report (SAR)

If you received a federal grant award through the State of Vermont, then you must complete the Subrecipient Annual Report (SAR) annually as a condition of this award. It helps track federal funds and determine whether or not your municipality met the threshold that requires a Single Audit.  

The  Takeaways
  • Mark your calendar and add the SAR to your list of tasks for fiscal year end
  • Must be completed within 45 days of the end of your FY
  • If you get a 2nd notification letter, you are already delinquent
  • If you see a discrepancy in the list of grants, contact the VT Department of Finance & Management
  • FEMA PA funds are considered “expended” only when FEMA has approved a Project Worksheet and obligated the funds
  • Questions or need help:
The Basics
  • A Subrecipient is an organization that receives a grant or loan of federal funds from a non-federal organization, such as the State of Vermont.
  • The SAR only relates to Federal Funds, not State Funds
  • It is based on the dollar amount of expenditures (not the award amount)
  • Due annually within 45 days of the end date of your fiscal year
  • It is a “condition” (requirement) of your grant agreements with the State of Vermont - see State Grant Agreement Attachment C – Standard Provisions for Contracts and Grants Item 31.A.
The Musts
  • Must be submitted electronically (no more paper submissions!)
  • Must include all your federal expenditures – those passed through the State (subrecipient) AND those received directly from a federal agency (recipient)*
  • Must be submitted regardless of the amount of your federal expenditures
  • Must have a Single Audit if you meet/exceed the federal expenditure threshold of $1,000,000 or more during your most recently completed fiscal year

* FEMA Public Assistance (PA) funds are not considered “expended” until  FEMA has approved the Project Worksheet (PW) and obligated funds. 

Will I Be Notified?  
  • Yes. You will receive a notification letter within two (2) weeks after your fiscal year end date.  
  • This letter contains:
    • Steps to Complete:
    1. Determine if a Single Audit is required ($750K/$1M federal expenditure thresholds)
    2. Submission Responsibility
    3. Completing the SAR
    • A list of grants currently identified in the Vermont Statewide Grants database at the end of the letter (includes ALN,s grant names, #s and total award amounts)
  • A sample of this notification letter can be found HERE.
What Happens If You Don't Do It?
  • You will receive a notification letter immediately after the 45-day window closes
  • It looks almost exactly like your original notification letter but with a few additional critical details within it. 
  • Your town is now in a “delinquent” status*
  • Delinquent status means:
    • Ineligible to receive future grant awards
    • Delay reimbursements from grants until resolved
    • Request for repayment of the grant.
  • A sample of the delinquent letter can be found HERE.
     
How Will I Know If My Grants Are Federal Funds?

Look at your grant agreement:

SOV Grant Agreement Part I

Part 1 – Grant Award Detail*:

Section I – General Grant Information

Section II – Subrecipient Award Information

Section III – Funding Allocation

Section IV – Contact Information

* A sample of the full Part 1 Grant Award Detail can be found HERE

 

The State of Vermont has a SAR Frequently Asked Questions (FAQs) page on their website.  Please note some of the information on their page might be outdated.  

 

 
Publication Date
07/15/2026

Disclaimer: This resource was created by Municipal Operations Support (MOS) staff of non-legal professionals with expertise of the subject matter. It is only intended to provide information and does NOT constitute legal advice. Readers with legal questions are encouraged to contact an attorney. The use or downloading of this resource does NOT create an attorney-client relationship and will not be treated in a confidential manner. Non-legal questions about this resource can be directed to MOS staff at mos@vlct.org.