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Grant review course · Lesson 5 deep dive

How do you build a grant audit trail?

Horizon's auditor wants proof of the A-31 decision by Friday, and finance wants to know why Eastgate's budget changed. Build a trail that lets someone who was not in the room reconstruct what was decided, what changed and who approved it.

Academy / Applications, awards & grants / Deep dive

Lesson 5 · Deep dive 2 of 3 · About 30 minutes with practice

How do you build a grant audit trail?

Horizon's auditor wants proof of the A-31 decision by Friday, and finance wants to know why Eastgate's budget changed. Build a trail that lets someone who was not in the room reconstruct what was decided, what changed and who approved it.

Additional course links

You leave with: An evidence index for Eastgate's award and a reconstruction test a colleague can pass without asking you.

Where this fits: Lesson 5 sends you here when the auditor's Monday question arrives: prove how A-31 was decided. Its exercise asks whether the pilot leaves evidence at every step. This page shows what that evidence has to connect, and you bring back an evidence index and a reconstruction test for step 5 of the workbook.

Build a grant audit trail by linking each material decision, budget change and reported result to its source, the person responsible and the version that applied. Keep changes and approvals instead of overwriting them, so another reviewer can reconstruct what happened. A folder of documents is evidence, but it is not a trail until the relationships and decisions are recorded too.

Decide what the trail must explain

In a configured system, the evidence for a decision is usually all there. It is spread across a scoring module, an email thread, a budget attachment and a payment record, and the person who knew how they fit together may have left. The auditor's question becomes a week of reconstruction.

Start from the questions a reviewer must be able to answer. Who approved the award? Which terms applied? Which changes were authorized, and by whom? What was paid, and against which condition? How were the reported results checked?

Scope depends on your side of the grant. Horizon's disbursement record is not Eastgate's expenditure record. Keep both where they belong, and read a payment as what Horizon released, not as a record of how the money was used.

For U.S. federal awards, 2 CFR 200.302 sets financial-management requirements, including award identification and records supported by source documentation. The Youth Pathways Fund is private money, so treat that as a useful reference point rather than Horizon's rulebook.

Record changes without erasing the earlier view

A useful change record holds the prior value, the new value, the reason, the date and the person responsible. When a change affects terms or reporting, keep the approval beside it.

Separate a correction from an amendment. Fixing a mistyped date is not the same as approving a later deadline. Both change a field, but they mean different things to a reviewer.

Check version history, permissions, export behavior and retention in your own setup before you describe any record as immutable.

Worked example: reconstruct Eastgate's budget change

Horizon example · fictional

Eastgate's award is $24,000, as requested. In Q1, Eastgate asks to move $2,000 from materials to transport stipends and gives its reason. The program owner approves the change in Q1. The award total does not change.

RecordWhat it holdsEvidence link
Budget version 1Lines as approved at award; total $24,000Signed agreement
Change requestMove $2,000 from materials to transport stipendsEastgate's request and stated reason
ApprovalProgram owner approves in Q1Approval record with name and date
Budget version 2Materials down $2,000, transport stipends up $2,000; total $24,000Points to the approval

A reviewer who sees only version 2 cannot tell whether it was the original plan, a correction or an approved change. The trail answers that in four rows.

What Eastgate spent is a separate question: read Eastgate's budget workbook against version 2 for the period after approval, as the budget versus actual deep dive describes.

Worked example: reconstruct the A-31 award decision

The auditor's request is the harder one, because the decision was made by people using AI-read evidence. The trail has to show which was which.

Horizon example · fictional

RecordWhat it holdsAuthor
Application as submittedNarrative answers, budget, employer letterEastgate
Suggested scoresA score per criterion with the passage behind eachIntelligence Cell (analysis, not a decision)
Reviewer scoresDelivery feasibility scored 4 and 2Two named reviewers
Calibration noteAnchor applied: an expression of interest is not a confirmed placement role; agreed score 3Calibration session
Final assessment4 / 3 / 4 / 3: 24 + 18 + 16 + 12 = 70/100Review lead
DecisionApproved with a condition: confirm the employer placement role before the second paymentCommittee, members and date recorded
Condition statusOpen, or met with the confirming documentProgram owner; finance holds the payment

Keep AI findings apart from human decisions. The suggested scores are analysis. The reviewer scores, the calibration note and the committee decision are judgments, each with an author. If someone accepted, changed or rejected an AI-assisted finding, keep the reason and the source.

The condition is where trails most often break. If the second payment went out, the trail should point to the document confirming the placement role, dated before the payment. If it cannot, that is the finding.

An assistant can draft the index for you, provided the instruction keeps it honest:

Build an evidence index for [award] and [review scope] from the authorized records. For each material decision or figure, give the source, date, version and recorded approver where available. Label AI-generated observations separately from recorded human decisions. List missing links and conflicting versions without inventing approvals or declaring compliance. Do not change or publish any record.

Test whether a reviewer can reconstruct it

Pick one figure and one decision: the $2,000 reallocation and the A-31 award. Ask a colleague who did not prepare the packet to trace each to its source and explain which version applied.

Check more than whether a link opens. Does it open the right document, at the right page? Can the reviewer tell the final approval from a draft? If access is denied, is there an authorized way to get the evidence?

Record the result and fix the specific gap. More files are not always the fix. Often the missing piece is the link between a file you already have and the decision it supports.

Agree retention and access rules

Use a written retention schedule based on the award, the legal requirements that apply and your own policy. Do not apply one number of years to every grant, or delete records because a project closed.

As an example, NIH's retention guidance distinguishes reporting situations and sets exceptions for unresolved claims and audits, and it addresses the integrity of electronic records. Check the rules for your own awards rather than copying the example.

Match access to role and purpose. The auditor's packet, the board summary and a public impact report need different detail and different permissions, even when they draw on the same record.

Prepare a review packet with an index

Lead with scope, period and preparation date. Then a short index linking each decision and figure to its source. Then open items, each with an owner and a next step.

Auditor packet index · A-31, fictional

Scope: A-31, Eastgate Youth Works, Youth Pathways Fund R-2; award through end of Q1; prepared for the auditor.

1. Decision: application as submitted → reviewer scores → calibration note → committee decision with condition.

2. Budget: version 1 → change request → approval → version 2; total $24,000 throughout.

3. Payments: first payment record; second payment held pending the placement-role condition.

4. Reporting: Q1 program report and budget workbook as accepted; clarification on 30 registrations open.

Open items: placement-role confirmation (program owner); registration statuses (Eastgate, via program owner).

Keep the version that was actually reviewed or sent. A live dashboard will update later, and it cannot show what the committee saw at its meeting.

In Sopact Sense, the persistent unique ID carries A-31 from application to award to reporting, so the index draws on one record rather than six systems. The software prepares the evidence; the responsible reviewer decides whether it is sufficient.

Put it into practice

Find the missing approval

  1. Using step 5 of the workbook, build the four-row trail for Eastgate's $2,000 reallocation, then remove the approval record.
  2. Ask a colleague to reconstruct the change. The correct result is an open authorization question, not a newly written approval.
  3. Restore the approval with its date. Check that version 2 points to it, version 1 is still available and the total reconciles to $24,000.
  4. Build the A-31 decision trail and mark each row as AI analysis or human decision.
  5. Check the condition: can you show the placement-role status before the second payment, from the record alone?

Download the workbook (PDF)
Practice data: horizon-r2-applications.csv · horizon-rubric.csv · calibration-scores.csv · eastgate-q1-update.csv

Check your reasoning before moving on

Without the approval, the colleague can see that the budget changed but not who authorized it. That is an unresolved question to raise, and neither the current value nor an AI summary fills it. With the approval restored, version 2 points to a named approver and a Q1 date, version 1 is intact, and $24,000 holds in both.

In the A-31 trail, only the suggested scores are AI analysis; the reviewer scores, calibration note, final assessment and decision are human. If the placement role has not been confirmed, the second payment should show as held, and the packet lists the condition as an open item with an owner.

Questions grant teams ask

What is a grant audit trail?

A connected record of material grant decisions, budget changes, payments and reported results, each with its source, date, version and responsible person. It lets someone who was not involved reconstruct what happened. For Eastgate, that means the award decision, the $2,000 reallocation and the condition on the second payment, each traceable to its evidence.

Is a document folder enough?

Not on its own. The folder may hold every file, but the trail also has to show how each document relates to a decision or figure and which version applied. The approval that sits in a folder without a link to the budget change it authorized is the most common gap a reviewer finds.

Does connected data mean the grant has been audited?

No. Connected, source-linked records make an audit faster and clearer, but an audit is a separate process carried out by the people responsible for it. Label it ready for review once the index, versions and open items are complete.

Should old versions be overwritten?

No. Keep the history the review and retention process needs, and distinguish corrections from approved amendments. A corrected typo and an approved budget change both alter a field, but a reviewer needs to know which one happened and who authorized it.

Can AI create the audit trail?

AI can organize authorized evidence, draft an index and flag missing links. It must not invent approvals or certify compliance. Keep its output labeled as analysis, keep human decisions labeled with their authors, and check the system's actual history and access controls before relying on the trail.

Put this guide into practice.

Bring one grant decision and its evidence. Explore how to keep the source, version and review history connected.

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