At our latest A-133 audit a question came up about the new
requirement/threshold for monitoring sub-recipients,
particularly how they apply to for-profit private firms.  My
take was satisfactory performance in the opinion of the PI,
and our standard review of invoices before payment was
sufficient.  Our auditor seemed to think we should consider
more review, up to considering on-site audits.  Any rational
suggestions for policy or procedures to handle this would be
appreciated.

Thanks,

Jim Romaggi
Desert Research Institute
Reno, Nevada