Assess whether a grant special condition is being waived de facto after an IG

Situation

A pass-through grantor after a subrecipient audit cannot treat an IG draft that will go public Thursday as color commentary on performance-measure set that cannot be produced from systems. Regulatory-impact analyst must close a grant special condition from that extract under Government / Budget and Performance.

Decision

Regulatory-impact analyst in a pass-through grantor after a subrecipient audit must choose Pay or continue / Recoup / Deny / Hold using performance-measure set that cannot be produced from systems after an IG draft that will go public Thursday.

Hypotheses to test

• Performance-measure set that cannot be produced from systems reads as Pay or continue once an IG draft that will go public Thursday is lined up to the same Government population.
• Performance-measure set that cannot be produced from systems is closer to Recoup after an IG draft that will go public Thursday; Pay or continue would over-claim this Budget and Performance extract.
• Deny is still live in performance-measure set that cannot be produced from systems for regulatory-impact analyst in a pass-through grantor after a subrecipient audit.
• Performance-measure set that cannot be produced from systems is missing the fact regulatory-impact analyst needs after an IG draft that will go public Thursday; stop this Government close.

Analysis required

• Check notice and appeal timing around an IG draft that will go public Thursday.
• Trace the audit trail regulatory-impact analyst would produce for oversight.
• Map eligibility, appropriation, and program rules in performance-measure set that cannot be produced from systems after an IG draft that will go public Thursday.
• For this Government Budget and Performance file, read performance-measure set that cannot be produced from systems against an IG draft that will go public Thursday 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 / Budget and Performance packet (performance-measure set that cannot be produced from systems after an IG draft that will go public Thursday). The follow-on Budget and Performance action is what regulatory-impact analyst does next: implement the option, assign an owner, and log the missing fact.