Alpha Covenant Holdings · Duty Sheet · generated 2026-10-25 16:55 UTC · free · all sheets

2 CFR 200.332 — Pass-through entity: pre-award risk assessment and subrecipient monitoring record (with 200.214 / 180.300)

Applies to: State agencies, counties and nonprofits that pass federal funds down to subrecipients; their grants-finance and monitoring staff; auditors testing Part 3 §M · Rule text: https://www.ecfr.gov/current/title-2/subtitle-A/chapter-I/part-200/subpart-D/subject-group-ECFR031321e29ac5bbd/section-200.332

The question the rule asks

200.332(b): evaluate each subrecipient's risk of noncompliance before the subaward — considering prior experience with similar subawards, the results of previous audits (including whether the subrecipient receives a Single Audit under Subpart F), new personnel or systems, and the extent of federal monitoring. 200.332(d)/(f): monitor, and verify every subrecipient expending $1,000,000 or more is audited as required. 200.214 / 180.300: verify the subrecipient is not excluded before the subaward.

The party this sheet is about

Wellpath LLC · keys supplied: UEI JL99G1YPJKK9 · matching: screening-2026-06f: every check is an exact-name (or exact-UEI / exact-NPI / exact-EIN / exact-CIK) lookup against the official file named on the line; nothing is inferred from similar names, owners or affiliates

Receipt r_64bcbfedba4245d7 · read 2026-10-25 16:55:53 UTC · SHA-256 d57e12d63e9a32cf32034cecd7d2b392fe28bcf432e73bdef02d1cfa615819fa · verify: https://alphacovenantholdings.com/r/r_64bcbfedba4245d7

The official files that answer it, as read on that date

SourceRoleStateRecordsWhat it printed
SAM.gov Exclusions — Public Extract V2 (GSA, daily)answers the questionanswered0No entry under this exact name/UEI in the SAM extract fetched 2026-10-24 (SAM_Exclusions_Public_Extract_V2_26297.ZIP).
Federal Audit Clearinghouse (GSA) — single audit filings under 2 CFR 200 Subpart Fanswers the questionansweredNo single-audit filing is on file for this exact UEI. Entities below the federal-spending threshold do not file; this is not a finding.
IRS Tax Exempt Organization Search — Automatic Revocation of Exemption list and Publication 78 data (bulk files)supportinganswered00 automatic-revocation entries under this exact printed legal name. Publication 78: no organization listed under this exact printed legal name (absence is not a statement about exemption).
USAspending.gov (recipient name equals this name)supportinganswered1 registered recipient(s) equal this name; 24 active prime award(s), $3,830,809 obligated
HHS Office of Inspector General — LEIE (monthly downloadable file)supportinganswered0No entry under this exact name in the OIG file fetched 2026-10-18.
U.S. Treasury OFAC — Specially Designated Nationals and Blocked Persons List (SDN.CSV)supportinganswered0No entry under this exact name or listed alias on the SDN list fetched 2026-10-24.
Consolidated Screening List (trade.gov) — BIS, State and Treasury lists, OFAC SDN excluded here because it is read directlysupportinganswered00 export-control or sanctions list entries (BIS, State, Treasury non-SDN) under this exact printed name
SAM.gov entity registrationcross-sourcedid not answer — nothing stands in for it
IRS Form 990 (as filed by the organisation)cross-sourceanswered0No IRS Form 990 organization matches this exact printed name; provide the EIN for an exact read.
USAspending subawards (money received beneath others' primes)cross-sourceanswered3USAspending reports 3 sub-award(s) totalling $14,345,605.38 received under this exact printed sub-awardee name, beneath other parties' prime awards.
State checkbooks & UCC (VT, DE, CT)cross-sourceanswered2VT $105,557,157 over 17 payments; CT $5,064 over 3 payments

What to record in the file

One dated receipt per subrecipient at pre-award and at each monitoring cycle: the SAM.gov Exclusions read with its file date; the Federal Audit Clearinghouse filings for the UEI or name (years filed, findings as the FAC printed them, or that none is on file); the IRS Pub 78 / revocation status where the subrecipient is a nonprofit; the subrecipient's own prime awards and subawards from USAspending; its SAM registration row; its Form 990 facts as filed; and what other states' checkbooks printed for the same name. The risk level, monitoring plan and award decision are the pass-through entity's own and belong in its file; this sheet puts the dated public record beside them.

What this sheet does not decide

The receipt does not decide eligibility, responsibility, identity or compliance. It records what each official file printed for an exact key or exact printed name on a date. A same-name row is a candidate to be resolved by the reader, not a match. Answering the form's question is the applicant's or reviewer's act; this sheet puts the dated record beside it.

Full receipt (all sources, known limits, print record): screening record · Methodology: https://alphacovenantholdings.com/methodology · Corrections (free, public log): https://alphacovenantholdings.com/corrections