Regulatory-impact analyst must resolve whether the RIA would survive OIRA

Situation

Regulatory-impact analyst in a pass-through grantor after a subrecipient audit has one working extract — hearing Q-and-A that conflicts with the published plan — after an OIRA passback gutting the preferred option. If hearing Q-and-A that conflicts with the published plan cannot support the RIA would survive, the honest Government output is hold.

Decision

Regulatory-impact analyst in a pass-through grantor after a subrecipient audit must choose Pay or continue / Recoup / Deny / Hold using hearing Q-and-A that conflicts with the published plan after an OIRA passback gutting the preferred option.

Hypotheses to test

• Hearing Q-and-A that conflicts with the published plan reads as Pay or continue once an OIRA passback gutting the preferred option is lined up to the same Government population.
• Hearing Q-and-A that conflicts with the published plan is closer to Recoup after an OIRA passback gutting the preferred option; Pay or continue would over-claim this Budget and Performance extract.
• Deny is still live in hearing Q-and-A that conflicts with the published plan for regulatory-impact analyst in a pass-through grantor after a subrecipient audit.
• Hearing Q-and-A that conflicts with the published plan is missing the fact regulatory-impact analyst needs after an OIRA passback gutting the preferred option; stop this Government close.

Analysis required

• Map eligibility, appropriation, and program rules in hearing Q-and-A that conflicts with the published plan after an OIRA passback gutting the preferred option.
• Name the statutory hook that hearing Q-and-A that conflicts with the published plan does or does not support.
• Test a single-case exception versus a control gap in a pass-through grantor after a subrecipient audit.
• For this Government Budget and Performance file, read hearing Q-and-A that conflicts with the published plan against an OIRA passback gutting the preferred option and write the one fact that would move the RIA would survive for regulatory-impact analyst.

Recommendation

Choose Pay or continue / Recoup / Deny / Hold on this Government / Budget and Performance packet (hearing Q-and-A that conflicts with the published plan after an OIRA passback gutting the preferred option). 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.