Assess whether an OFAC match is true and requires blocking (03cb8e)

Situation

IG improper-payments investigator owns an OFAC match is inside a civilian agency splitting awards near the simplified threshold with improper-payment sample that will not extrapolate cleanly as the only packet. A whistleblower who named a payment recapture contractor is what changed the clock for this US Federal Public Sector Audit Investigations file.

Decision

IG improper-payments investigator in a civilian agency splitting awards near the simplified threshold must choose Pursue / Pursue with conditions / Partner / No-bid using improper-payment sample that will not extrapolate cleanly after a whistleblower who named a payment recapture contractor.

Hypotheses to test

• The population in improper-payment sample that will not extrapolate cleanly is the one a whistleblower who named a payment recapture contractor named, so Pursue follows for this Public Sector Audit Investigations file.
• The population in improper-payment sample that will not extrapolate cleanly is adjacent only to a whistleblower who named a payment recapture contractor; Pursue with conditions is the honest US Federal call.
• A civilian agency splitting awards near the simplified threshold already contained a whistleblower who named a payment recapture contractor before improper-payment sample that will not extrapolate cleanly arrived; no new Public Sector Audit Investigations path.
• Provenance on improper-payment sample that will not extrapolate cleanly after a whistleblower who named a payment recapture contractor is broken; do not pick Pursue or Pursue with conditions yet.

Analysis required

• Normalize pricing and CPARS/QASP evidence that actually supports an OFAC match is.
• Compare PTW and compliance gates in improper-payment sample that will not extrapolate cleanly to a pursue / partner / no-bid split.
• Test OCI and SAM.gov status before a civilian agency splitting awards near the simplified threshold commits.
• For this US Federal Public Sector Audit Investigations file, read improper-payment sample that will not extrapolate cleanly against a whistleblower who named a payment recapture contractor and write the one fact that would move an OFAC match is for IG improper-payments investigator.

Recommendation

Choose Pursue / Pursue with conditions / Partner / No-bid on this US Federal / Public Sector Audit Investigations packet (improper-payment sample that will not extrapolate cleanly after a whistleblower who named a payment recapture contractor). The follow-on Public Sector Audit Investigations action is what IG improper-payments investigator does next: implement the option, assign an owner, and log the missing fact.