Assess whether a grant special condition is being waived de facto (693b19)

Situation

Operations and Emergency work in an emergency-management shop allocating scarce resources now turns on a grant special condition because a storm that will exhaust the current allocation model put grant special-condition that the program never implemented in play. Regulatory-impact analyst should say what grant special-condition that the program never implemented proves.

Decision

Regulatory-impact analyst in an emergency-management shop allocating scarce resources must choose Pay or continue / Recoup / Deny / Hold using grant special-condition that the program never implemented after a storm that will exhaust the current allocation model.

Hypotheses to test

• Grant special-condition that the program never implemented reads as Pay or continue once a storm that will exhaust the current allocation model is lined up to the same Government population.
• Grant special-condition that the program never implemented is closer to Recoup after a storm that will exhaust the current allocation model; Pay or continue would over-claim this Operations and Emergency extract.
• Deny is still live in grant special-condition that the program never implemented for regulatory-impact analyst in an emergency-management shop allocating scarce resources.
• Grant special-condition that the program never implemented is missing the fact regulatory-impact analyst needs after a storm that will exhaust the current allocation model; stop this Government close.

Analysis required

• Test a single-case exception versus a control gap in an emergency-management shop allocating scarce resources.
• Check notice and appeal timing around a storm that will exhaust the current allocation model.
• Trace the audit trail regulatory-impact analyst would produce for oversight.
• For this Government Operations and Emergency file, read grant special-condition that the program never implemented against a storm that will exhaust the current allocation model and write the one fact that would move a grant special condition for regulatory-impact analyst.

Recommendation

Choose Pay or continue / Recoup / Deny / Hold on this Government / Operations and Emergency packet (grant special-condition that the program never implemented after a storm that will exhaust the current allocation model). The follow-on Operations and Emergency action is what regulatory-impact analyst does next: implement the option, assign an owner, and log the missing fact.