What 2 CFR 200.332 requires
Federal regulations require pass-through entities to evaluate each sub-recipient's risk of noncompliance. This isn't optional — it's a condition of your award. The regulation specifies that you must consider prior experience with the same or similar subawards, audit history, new personnel or systems, and the extent and results of federal awarding agency monitoring.
Most intermediaries do this with an annual checklist. The problem is that risk doesn't wait for your annual review cycle. A sub-grantee's financial situation can change mid-year. Key staff can leave. Reporting patterns can deteriorate gradually, and by the time your annual assessment catches it, the damage is done.
How risk scoring works
WeavePulse calculates a risk score for each sub-grantee based on observable, objective indicators — not subjective judgment calls. The score updates continuously as new data comes in, giving you a living picture of risk across your portfolio.
The scoring model weighs multiple factors: reporting timeliness (are they submitting on time?), data completeness (are they submitting everything?), audit findings (do they have open findings?), financial indicators (unexplained budget variances, spending patterns), and corrective action history (have past issues been resolved?).
Early warning indicators
Beyond the composite risk score, WeavePulse surfaces specific indicators that suggest emerging problems. These are the patterns experienced grant managers recognize instinctively but can't track systematically across a large portfolio.
- Deteriorating reporting timeliness — submissions getting later each period
- Declining data completeness — more fields left blank over time
- Repeated corrective actions — the same issue appearing in multiple periods
- Significant budget variances — spending far above or below projections
- Staff turnover flags — new users replacing primary contacts mid-cycle
Corrective action workflow
When monitoring reveals an issue, WeavePulse provides a structured workflow for corrective action. You can create a finding, assign it to the sub-grantee, set a resolution deadline, and track their response — all within the same system where the issue was detected.
The corrective action history becomes part of the sub-grantee's permanent record and feeds back into their risk score. Resolved issues reduce risk over time. Unresolved issues escalate automatically. This creates a documented trail that satisfies your monitoring obligations under 2 CFR 200.332 without maintaining a separate tracking system.