Subrecipient monitoring that scores risk from cited sources and checks every invoice line before the university pays
Risk scored before signing and every invoice line checked before the university pays.
See one case, screen by screen ↓Subrecipient monitoring is the oversight a pass-through entity, such as a university that passes part of a federal award to another organization, owes under 2 CFR 200.332: evaluate each subrecipient's risk, set the agreement's terms, review what it bills against the approved budget, and follow up on its audit findings. Subrecipient Risk Assessment & Monitoring puts seven agents in front of that reading and drafting, and a named person decides every hold, payment and tier change.
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Subrecipient monitoring is the work a pass-through entity owes under 2 CFR 200.332 for every subaward it issues: check exclusions, put the required elements in the agreement, evaluate each subrecipient's risk, set specific conditions where the risk calls for them, review what it bills, and follow up on its Single Audit findings. Under the Uniform Guidance the subrecipient risk assessment must weigh prior experience with similar subawards, the results of previous audits (including whether a Single Audit was required), new personnel or changed systems, and the results of federal agency monitoring.
Today the subrecipient risk assessment questionnaire goes out by email, the score is added up once in a spreadsheet at signing, invoices arrive in a shared inbox and are approved on their total, and accounts payable pays in the ERP. Since the 2024 revision raised the Single Audit threshold from $750,000 to $1,000,000, many subrecipients have no audit at all, and a clearinghouse search that returns nothing reads like good news. A cost outside the approved budget is then found by an auditor after the university has paid it, and the university repays the sponsor. Subrecipient Risk Assessment & Monitoring puts seven agents in front of that reading, so a grants accountant decides on the line that matters, with the evidence beside it.
Estimated split of a grants accountant's minutes on one invoice that needs a hold, by hand and with the agents; the 'after' column is the person's own review and decision time. Our arithmetic, kept modest.
Seven agents check every invoice line and re-score each subrecipient on cited evidence; people hold the keys to pay.
Halden State University, Tuesday, March 17, 2026. Subaward SUB-2025-0418 passes NSF money for a soil carbon and drought sensing network to Pellinore Field Institute, and invoice #7 for January arrived on March 2. Here is what happens to it, screen by screen, in the working solution.
Each of Halden State's 1,150 active subawards is drawn as a rail from the prime award to the subrecipient: the risk score, the signed agreement, every invoice and the audit check. The rails are sorted by the nearest held invoice, so Pellinore's amber invoice #7, with 15 days left on its 30-day payment clock, is on the top line.
Needs a person today: invoice #7, the tier change, the management decision due March 24 and 41 subaward reports due March 31.
The agents read the $48,210 invoice and its backup line by line: salaries $20,300, fringe $5,887, travel $1,240, equipment $9,400, supplies $3,621 and indirect costs of $7,762 at 25% of $31,048. Five lines are on budget, with their backup cited. Line 4 is held, because the approved budget has $0 for equipment.
Line 4 is a soil gas flux analyzer at $9,400, on a vendor invoice dated December 18, 2025. It sits beside the approved budget's equipment line of $0 and clause 7 of the agreement, which requires Halden State's prior written approval to rebudget into equipment. None is on file.
The Invoice agent links it to Pellinore's FY2024 audit finding 2024-001, equipment bought without prior approval, $12,600 questioned, with 96% confidence.
The Federal Audit Clearinghouse has no FY2025 Single Audit for Pellinore. The agent reads why instead of scoring it as clean: the audit certification letter of March 10, 2026 states $870,000 of federal expenditures, under the $1,000,000 threshold. A year earlier, the $750,000 threshold would have required one.
Pellinore's score was 58, Medium, at the annual review on October 1, 2025. Three events move it to 72, High: no FY2025 Single Audit (+6), invoice #7 repeating the cost in finding 2024-001 (+5), and a new controller and accounting system (+3). Each of the ten factors from 2 CFR 200.332(c) and office policy shows its points then and now, and its source.
The Risk agent proposes the tier. It never changes it.
Ruth holds all $48,210 of invoice #7 with reason code HLD-02, unbudgeted category, prior approval not on file. The note is prefilled, and the hold is signed as Ruth Abernathy, Post-Award Grants Accountant.
The invoice now reads held by Ruth Abernathy at 11:15 with HLD-02. The 30-day clock is paused on an improper request, as 2 CFR 200.305(b)(3) allows, and restarts when the ledger detail arrives. The PI has certified the work; accounts payable cannot pay.
Celeste Navarro signs the move from Medium to High at 11:18. Malcolm Ferreira, Director of Sponsored Programs, approves it at 11:22. The person who signs cannot approve, and no agent signs.
With Pellinore at High, the plan in force is general ledger detail with every invoice, starting with #7, due March 31; a site visit on April 21, 2026; amendment 3 with reimbursement-only terms and prior approval for equipment under 2 CFR 200.208; notice to NSF; and the management decision on finding 2024-001 due March 24. Each item has an owner, and a person sends, confirms or approves it.
The director's approval at 11:22, Celeste's signature at 11:18, Ruth's hold at 11:15 and the agents' checks from 10:51 sit on one trail, people and agents together, each with the evidence it used. The evidence pack exports for the Single Audit, an NSF review or internal audit. $9,400 was stopped before it was paid, not found by an auditor after.
The same subaward, seen by the five people who carry it: what their day looked like, and what it looks like now.
Seven agents check every invoice line and re-score each subrecipient on cited evidence; people hold the keys to pay.
Reads each invoice and its backup from the invoice inbox and document management, extracts the lines and matches them to the subaward and budget period.
Checks every line against the approved budget category, the period of performance, the backup and the indirect base, holds what is outside tolerance, and links a held line to the subrecipient's prior audit findings of the same kind.
Searches the Federal Audit Clearinghouse for every subrecipient, applies the threshold for its fiscal year, reads findings and tracks the six-month management decision.
Scores each subrecipient against the 2 CFR 200.332(c) factors and office policy, re-scores when the evidence changes, cites every factor and shows what moved the score.
Builds the monitoring plan the tier requires and drafts every item: ledger requests, site visits, specific conditions and agency notices.
Checks a draft subaward against the 2 CFR 200.332(b) required elements and the prime award's terms, and drafts any missing clause.
Drafts subaward reports of $30,000 or more for the federal subaward reporting system and tracks the month-after deadline.
Hold, sign, approve. The agents propose; a named person decides.
The assistant answers from the subaward's own documents, cites each one, and takes you to the screen where you act on the answer.
Why is invoice 7 held?
Line 4 bills $9,400 of equipment, a soil gas flux analyzer. The approved budget for budget period 1 has $0 for equipment, and clause 7 of the agreement requires Halden State's prior written approval to rebudget into it. None is on file. It is the same kind of cost as Pellinore's FY2024 audit finding 2024-001. The other five lines, $38,810, are supported by their backup.
Why did Pellinore's risk go up?
Three pieces of evidence moved it from 58 to 72, Medium to High: no FY2025 Single Audit, because $870,000 is under $1,000,000 (+6); invoice #7 repeats the cost in finding 2024-001 (+5); the controller left and there is a new accounting system (+3). The other seven factors did not move. The agent proposes; Celeste Navarro signs and Malcolm Ferreira approves.
Who lost their Single Audit this year?
37 subrecipients spent between $750,000 and $1,000,000 of federal money in FY2025, so they were audited under the old threshold and are not now. Pellinore is one, at $870,000. For these, the office does the monitoring an auditor used to: ledger detail on a sample of invoices, and a desk review of their financial statements.
Draft the ledger request
Drafted. It asks Pellinore for the January 2026 ledger for the subaward's cost center, the purchase order and vendor invoice for line 4, and any prior approval or a rebudget request, due March 31. Nothing goes until you press Send.
13 screens from the working solution, on its sample data. Pick one to see it large.
The rules every subaward and invoice is checked against are settings, versioned and on the audit trail. A change to the risk model waits for an approver.
| Setting | Default | Choose from |
|---|---|---|
| Invoice tolerance | Hold a category more than 10% over its cumulative pace | A line in a category with no approved budget is always held |
| Risk model | v2026.2, ten factors | Low 0–39 · Medium 40–64 · High 65–100; a change waits for an approver |
| Re-score on | Clearinghouse result, invoice finding, questionnaire update, exclusion change | Set by the director |
| Single Audit threshold | $1,000,000 for fiscal years beginning on or after October 1, 2024 | $750,000 for earlier fiscal years |
| Enhanced monitoring for High | Ledger detail with every invoice; site visit within 60 days | Reimbursement-only, with prior approval for equipment |
| Hold and override reason codes | HLD-01 to HLD-05 · OVR-01 to OVR-03 | Kept by the administrator |
| Agent confidence threshold | 85% | Below it, a finding goes to a person |
| Models and prompts | Pinned per agent | A change is a new version with an approver |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
Sources: 2 CFR 200.332 (requirements for pass-through entities, 2024 revision) · 2 CFR 200.501 (Single Audit threshold of $1,000,000 for fiscal years beginning on or after October 1, 2024; previously $750,000) · 2 CFR 200.305(b)(3) (payment within 30 days of a proper invoice) · 2 CFR 200.521 (management decision within six months) · 2 CFR 200.208 (specific conditions) · 2 CFR 200.334 (record retention) · "target" = design goal, measured in the live solution · "demo" = seen in the working solution, on its sample data · "typical" = published figures, here the federal rules above · "estimated" = our arithmetic, kept modest. Halden State University, Pellinore Field Institute and the people named on this page are fictional: characters and sample data in the working solution.
Subrecipient monitoring is the oversight a pass-through entity, such as a university that passes part of a federal award to another organization, owes under 2 CFR 200.332: evaluate each subrecipient's risk, set the agreement's terms, review what it bills against the approved budget, and follow up on its audit findings. Subrecipient Risk Assessment & Monitoring puts seven agents in front of that reading and drafting, and a named person decides every hold, payment and tier change.
Under the 2024 revision of the Uniform Guidance, 2 CFR 200.332 covers checking exclusions, putting the required elements in the subaward, evaluating each subrecipient's risk, imposing specific conditions where needed, monitoring the subrecipient, and verifying its Single Audit. The solution works through that checklist subaward by subaward: the Flow-down agent checks the required elements before signing, the Risk agent scores the factors, and the Clearinghouse agent follows the audit.
The Risk agent scores ten factors, from 2 CFR 200.332(c) and office policy: previous audits, Single Audit coverage, prior experience, new personnel or systems, federal agency monitoring, financial condition and others. Each factor shows its points, its maximum and the source it was read from, including the questionnaire. When the evidence changes, it re-scores and shows what moved the score; it proposes a tier, and the subaward manager and the director decide.
For fiscal years beginning on or after October 1, 2024, the threshold is $1,000,000 of federal expenditures, up from $750,000, so some subrecipients no longer have a Single Audit. The Clearinghouse agent applies the threshold that fits each fiscal year, flags the subrecipients who lost coverage instead of scoring "no audit found" as clean, and the monitoring an auditor used to do moves onto the office.
The Invoice agent checks every line against the approved budget category and its pace, the period of performance, the backup and the indirect base, and links a held line to the subrecipient's prior audit findings of the same kind. The grants accountant holds, short-pays or approves with a reason code, and the 30-day payment clock is shown on every invoice.
Yes. No agent approves, pays, signs, changes a tier, sends a letter or files a report. The PI certifies the work, the grants accountant approves and accounts payable pays, in that order; a tier change needs the subaward manager's signature and the director's approval, and the person who signs cannot approve. Findings below the office's confidence threshold go to a person.
Yes. The invoice tolerance, the risk model and its tiers, what triggers a re-score, the enhanced monitoring for High, the hold and override reason codes, the agents' confidence threshold, masking and retention are all settings, versioned and on the audit trail.
The Agentic Solution Engine builds and deploys it from your requirements and documents, such as your subaward templates, risk questionnaire and monitoring procedures, and it goes live once every quality gate has passed. We will walk you through it on a sample of your own subawards and invoices first.
Five high-fit calls in minutes, each limit and cost share cited to the sponsor's own text.
1-min demoGrant Proposal ReviewEvery proposal reviewed inside the five-day window, every value tied to its clause.
1-min demoIRB Protocol Pre-ReviewEvery protocol back to its investigator on the first day, each fix tied to its rule.
1-min demoWe'll run Subrecipient Risk Assessment & Monitoring on a sample of your own subawards and invoices.