Welcome to Agentic Subaward Determination thatweighs the 200.331 factors on every outgoing agreement.
The subrecipient-versus-contractor call looks clerical and carries federal teeth. Risely's agents weigh the 200.331 factors on every outgoing agreement and draft the memo, and an authorized official signs the determination.
Determination · a partner lab's agreement
weighing factor 1 of 4
Performance measured against the award's objectives?
Programmatic decision-making?
Responsible for adherence to program requirements?
Providing goods or services ancillary to the program?
The memo drafts once every factor is weighed.
A clerical-looking call with federal teeth.
Classify the agreement wrong and the flow-down requirements, the risk assessment, and the monitoring obligations are all wrong with it. One early call sets the entire relationship's compliance posture.
What hangs on the call
Called a subrecipient
flow-downs, a risk assessment, and monitoring obligations
Called a contractor
procurement rules and none of the above
Called wrong
every one of those settings is wrong with it
The call looks clerical and carries federal teeth, which is exactly the kind of call that deserves a written reason.
Factors get weighed, and habits do not.
Risely's agents read the draft agreement and the award, then run the 200.331 factors one by one. The verdict comes with reasons attached, which is the difference between a decision and a guess that happened to work.
The full 200.331 test
weighing
Most shops decide by habit and write nothing down. The habit usually gets it right, and the silence is what audits punish.
The memo exists before anyone asks.
One page: the verdict, the four factors cited, an authorized official's signature, filed with the agreement. The single-audit review reads it and moves on.
One page, one defense
DETERMINATION MEMO
The verdict: subrecipient
All four factors cited with their reasons
Signed by an authorized official
Filed with the agreement, where the auditor looks
The single-audit review reads this page and moves on. The memo that never existed is the finding that always does.
Monitoring starts at determination.
The risk assessment queues automatically for every subrecipient, the flow-downs attach before signature, and the reporting cadence schedules for the award's life. Year three arrives with nothing to remember.
What queues the moment the call is made
Monitoring used to be the thing everyone remembered in year three. Now it starts the day the ink dries.
One agreement arrives. The test re-runs.
A new partner lab, an amended scope, a renewal that changes who decides what. Any of them can flip the classification, and every one runs the same way.
An outgoing agreement drafts
a partner lab takes on an aim
The factors weigh
the 200.331 test, run in full
The memo drafts itself
each factor cited, ready to sign
An official signs the call
the determination stays a person's
Monitoring queues
risk assessment and flow-downs attach
What changes, and how it runs.
Every determination has its memo
It is signed, cited, and filed where the auditor looks.
Flow-downs go out right the first time
The sub's audit posture is set before money moves.
The single audit reads one page
Four factors are weighed and cited, and there is nothing to reconstruct.
The technical read
Connects read-only to your grants system and agreement records to start
An authorized official signs every determination
Every action lands on an append-only log
Runs alongside what you have. Nothing rips out.