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Insights on AI, Finance, and Compliance

Practical perspectives from 10 years in nonprofit finance and a growing obsession with automation.

Subrecipient or Contractor? A Practitioner's Guide to §200.331

Ten indicators explained in plain language, with a free downloadable determination worksheet for your award files.

Getting the subrecipient-vs-contractor classification wrong isn't just an academic exercise — it has real consequences. This post breaks down the full §200.331 framework and includes a printable worksheet you can keep in your award file.

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What Automation Vendors Get Wrong About Subrecipient Risk Assessments

If you manage federal awards, you've done this: opened a spreadsheet, pulled up SAM.gov in another tab, navigated to the Federal Audit Clearinghouse in a third, and started piecing together a risk assessment for a subrecipient you've worked with for years. Most automation vendors have never actually performed one.

This post includes an interactive 11-point checklist to evaluate whether your vendor covers the regulatory requirements of 2 CFR 200.332 — and whether the person building it understands why those requirements exist.

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Why Your AI Finance Implementation Needs a CPA Who Knows Federal Compliance, Not Just an Engineer

Every week, another company announces an AI tool for financial operations. Automated reconciliation. AI-powered reporting. Intelligent compliance monitoring. Most of them are built by engineers who have never reconciled a bank statement.

That's not a knock on engineers — they're brilliant at building systems. But financial operations automation in regulated environments isn't just a technical problem.

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