Whether the RIA would survive OIRA and litigation from reorganization FTE

Situation

Reorganization FTE and system-cutover map arrived with a subrecipient that cannot produce payroll for match for grant-compliance officer. That is a Government Budget and Performance decision on the RIA would survive in a reorganization that moves programs across bureaus.

Decision

Grant-compliance officer in a reorganization that moves programs across bureaus must choose Pay or continue / Recoup / Deny / Hold using reorganization FTE and system-cutover map after a subrecipient that cannot produce payroll for match.

Hypotheses to test

• Grant-compliance officer can defend Pay or continue from reorganization FTE and system-cutover map after a subrecipient that cannot produce payroll for match in a Government challenge.
• Grant-compliance officer cannot defend Pay or continue from reorganization FTE and system-cutover map; Recoup is what the extract actually supports after a subrecipient that cannot produce payroll for match.
• A subrecipient that cannot produce payroll for match never reached the population in reorganization FTE and system-cutover map — reopen intake, do not close the RIA would survive.
• Two facts in reorganization FTE and system-cutover map after a subrecipient that cannot produce payroll for match conflict for grant-compliance officer; hold this Budget and Performance file.

Analysis required

• Test a single-case exception versus a control gap in a reorganization that moves programs across bureaus.
• Check notice and appeal timing around a subrecipient that cannot produce payroll for match.
• Trace the audit trail grant-compliance officer would produce for oversight.
• For this Government Budget and Performance file, read reorganization FTE and system-cutover map against a subrecipient that cannot produce payroll for match and write the one fact that would move the RIA would survive for grant-compliance officer.

Recommendation

Choose Pay or continue / Recoup / Deny / Hold on this Government / Budget and Performance packet (reorganization FTE and system-cutover map after a subrecipient that cannot produce payroll for match). If reorganization FTE and system-cutover map cannot force a Government label under Budget and Performance, stop. Do not invent pages a reorganization that moves programs across bureaus does not have.