21.36% of HHS grant obligations sit with one recipient.
1,000 federal awards across 321 recipients in 15 agencies surfaced 66 findings - 39 critical, 27 high. California's Department of Health Care Services holds 21.36% of all HHS grant obligations: $511.7B concentration in a single recipient, against $2.96T in surveyed federal obligations. Real public USAspending.gov data, deterministic checks, sealed CREB on every finding.
JIL is not a grants management system, not a fundraising platform, not a DAF sponsor, not an accounting system. It is a distribution-integrity layer that scores every proposed disbursement before settlement and anchors the result to CourtChain with FRE 902(14) cryptographic provenance - protocol-enforced compliance instead of discovered-after-the-fact compliance.
Here's what we surface for you.
If you're a federal grant officer (NIH, NSF, DOE, DOD, HHS), a state grant administrator, a sub-recipient compliance lead, a research-institution sponsored-programs office, or an audit firm doing single-audit work, this is what JIL detects in federal grant flows. JIL pulls live data from USAspending.gov (1K seeded awards, $2.96T tracked), SAM.gov exclusions (70K of 167K seeded), OFAC SDN, GLEIF LEI, OpenCorporates, and the OIG LEIE registry to surface compliance issues before disbursement clears or audit finds them.
Grantee eligibility at award and disbursement
Grantee or sub-recipient is on SAM.gov exclusions, OIG LEIE, OFAC SDN, or has a beneficial owner who is. JIL screens at award time AND at every disbursement (debarment can happen mid-grant), with sealed evidence per check.
Sub-award compliance (Uniform Guidance § 200.332)
Sub-recipient pass-through monitoring: prior sub-recipient performance, single-audit findings, indirect-cost-rate compliance, equipment / property tracking. JIL surfaces sub-award concerns before pass-through funds release.
Cost reasonableness
Charged costs are 4x the federal cohort median for the same award type, geographic area, and discipline. Indirect-cost claim is above the negotiated rate. Equipment purchases above the federal threshold without competitive bid. JIL surfaces the outliers with the comparison data your grant officer can act on.
Salary cap + time allocation
Researcher's effort claim across federal awards exceeds 100% (statistical impossibility). Salary charged exceeds the executive-level-II cap. Effort certification doesn't match charged effort. JIL cross-checks effort certifications against the salary distribution before each disbursement.
Duplicate invoice across multiple awards
Same invoice number, same vendor, same dollar amount submitted to 3 different grants in the same month. JIL cross-checks against the federal invoice ledger you have access to and surfaces duplication before second disbursement clears.
Sealed evidence per finding
Every disbursement decision and every audit finding gets a sealed evidence record. Useful for OIG audits, GAO reviews, and (if it ever escalates) DOJ False Claims Act referrals. Court-admissible without an expert witness.
How to use it: integrate at the grant management system layer. Verdict per disbursement in seconds. Pricing per-disbursement (cents), with volume tiers for federal-program scale. See the live POC with 66 findings against 1K real USAspending awards.
$2.96T federal grant obligations surveyed.
On day one, grants-engine pulled 1,000 CY2024 federal assistance awards from USAspending.gov - representing $2.96 trillion in obligated federal dollars - and produced 66 recipient-concentration findings, 39 of them critical-severity. Two stood out: California DHCS holds 21.36% of all HHS obligations in our pull; Amtrak holds 39.33% of DOT.
What we uncovered (top 5)
| Subject | Category | Finding |
|---|---|---|
| California DHCS | Department of Health Care Services | 21.36% of HHS obligations ($511.7B) |
| Amtrak | National Railroad Passenger Corp | 39.33% of DOT obligations ($36.1B) |
| HHS Centers for Disease Control | CDC | Multi-billion concentration in pandemic-era awards |
| DOE Office of Energy Efficiency | EERE | Outsized share of DOE obligations |
| HUD Public and Indian Housing | PIH | Geographic concentration anomaly |
USAspending.gov public API
spending_by_award endpoint, real-time daily refresh. No subscription, no DUA, no per-record licensing. The full ingest manifest is replayable bit-identically.
Deterministic pass
Tier 1 ran a single deterministic pass against the ingested public dataset. SQL aggregates only - no stochastic LLM in the verdict path. Ava, our in-house agentic AI, groups, narrates, and routes findings; it never produces the underlying flag. Same kernel that ships the other 7 verticals.
What this means for your business
For an OIG investigator, GAO auditor, or Congressional appropriations staff, this is the recipient-concentration map you've never had on this dataset. Pre-disbursement, it routes the next $2.96T of federal awards through a deterministic concentration check - flagging the awards that, if granted, would push a recipient over the historical share thresholds your enabling legislation set.
What Tier 2 unlocks. Customer engagement brings the agency's own award files, sub-recipient data, and historical comparison sets. Tier 2 layers on prime-to-sub pass-through detection, period-of-performance overrun analysis, and the False Claims Act 60-Day Rule cooperation timing model. Output is a sealed CREB suitable for DOJ Civil Division referral or HHS-OIG cooperation credit.
Grant and Charitable Distribution Integrity at a glance.
Where the integrity layer sits, what it produces, and how the sealed CREB flows back to the buyer's existing systems.
Where this product earns its place.
The strategic case for Grants as a JIL line of business - what makes the wedge defensible, what makes it economically meaningful, and how it compounds with the rest of the platform.
Vault architecture is in production
The 4,926 on-chain protocol vaults that enforce the 10% Human Flourishing commitment already operate the policy-encoded disbursement pattern, the subrecipient pass-through logic, and the on-chain audit trail. External productization is packaging, not net-new build.
Diversion mathematically impossible
Transient tokenization wraps each grant with its policy as metadata. Tokens can only be redeemed in ways that satisfy the policy. Diversion becomes detectable at the protocol level rather than discovered after the fact.
Buyer base sits inside the thesis
Faith-aligned, impact-aligned, and mission-aligned funders hold mandates that explicitly include financial integrity in giving. The 10% Human Flourishing protocol on JIL's own profits is the strongest credential in the market.
Sold as trust, not just enforcement
Charitable distribution integrity has buyers in compliance, in development and donor relations, in board governance, and in regulatory enforcement. The only JIL vertical where the product can be sold as a marketing and trust feature.
Net-new checks, sealed evidence.
A representative slice of the Grants-specific check pack. Each one runs in the same five-stage pipeline as the rest of the platform - intake, profile load, parallel checks, verdict, sealed CREB - and ships with a 14-of-20 BFT signature, a CourtChain L1 anchor, and a reproducibility manifest pinning the exact check-logic version.
Allowable Cost Compliance
Cost-code lookup against the 2 CFR 200 Subpart E unallowable matrix. Agency-specific cost principles applied. Prior-approval requirements flagged. Citation returned with every verdict.
Subrecipient Pass-Through Tracking
Multi-hop graph traversal across the subaward chain. Beneficial-owner intersection detection at each hop. Pass-through fee reasonableness against industry benchmarks. 2 CFR 200.331-200.333.
Form 990 Anomaly Detection
Officer-compensation anomaly versus peer organizations. Schedule J, L, F, and O completeness and consistency. News adverse-event correlation with grant disbursement timing.
Cost-Share Match Verification
Match cannot derive from other federal sources except where statute permits. In-kind valuation against 2 CFR 200.306 fair-market standards. Prior-period match cannot be re-claimed.
OFAC Multi-Jurisdiction Screening
Grantee, full subrecipient chain, beneficial owners, board members, and key vendors screened against OFAC, EU, UN, UK, World Bank Debarred, and USAID Excluded Parties lists.
Beneficial Ownership Verification
Corporate registry lookup, FinCEN BOI cross-reference, OpenCorporates layered-ownership analysis, PEP identification at each layer of the structure.
DAF Distribution Compliance
IRC 4967 personal-benefit prohibition. Pledge fulfillment prohibition. Permitted recipient classification. Anonymous-grant disclosure exception handling.
Cash-Transfer Endpoint
Mobile-money and voucher beneficiary deduplication across programs. Biometric uniqueness where available. Geofencing of redemption points. Velocity pattern matching against legitimate baselines.
Who runs this in production.
The buyer pattern for Grants - who carries the budget, who carries the regulatory exposure, and how the engagement starts. Most first engagements are a Retroactive Proof Audit on a defined lookback window; Pre-Settlement integration follows once the check pack is calibrated to the customer's profile.
Top-25 endowments
Top-25 US foundations by assets - Gates, Ford, MacArthur, Rockefeller, Hewlett, Walton, Bloomberg, Open Society, Lilly Endowment, Robert Wood Johnson, Kellogg, Mellon, Packard, Moore, Sloan, Bezos Family, Pew, Carnegie, Duke.
Commercial and faith-based
Commercial: Fidelity Charitable, Schwab Charitable, Vanguard Charitable, T. Rowe Price Charitable. Faith-based: National Christian Foundation, Jewish Communal Fund, Catholic Foundation network. Mission-aligned: ImpactAssets, RSF Social Finance.
OIGs and oversight
HHS OIG, USAID OIG, DOE OIG, NSF OIG, NIH OER, ED OIG, HUD OIG, EPA OIG, USDA OIG. GAO. DOJ Civil Fraud Section. Standard 18-24 month federal procurement gate; OIG-direct often faster than agency-direct.
Bilateral and multilateral
USAID, State Department INL, MCC, DFC. Multilateral and development banks (IFC, ADB, AfDB, EBRD, IDB) for cross-border implementing-partner integrity.
Four-SKU model. No percentage. No contingency.
Pricing carries over from the canonical four-SKU model unchanged - Retroactive Scan (flat fee), Retroactive Proof Audit (with credit-back against the next subscription tier), Pre-Settlement Subscription (tiered annual), and per-case CREB bundles (Tier 3 court-ready evidence). Asset Intelligence is the standard fifth SKU where the vertical needs it.
No percentage of recovery. No contingency. No success fees. JIL is detection and proof, not recovery. Recovery sits with the customer or its existing partners (subrogation counsel, recovery vendors, regulators). The structure is what allows JIL to operate as neutral integrity infrastructure across plaintiffs and defendants, payers and payees, regulators and the regulated, on the same case.
Ready to scope a Grants engagement?
Initial briefings are 60 minutes. Retroactive Proof Audit lookback windows, check-pack profile design, and integration runbook are available under NDA. We start where the buyer's procurement gate is shortest.
One kernel. Eight industries.
This vertical runs on the same sovereign L1 + attestation network that ships the other 7. Kernel age: 18+ months. Adding a vertical: ~1 week. Competitor moat: build the kernel first.