Assess whether a subrecipient should be suspended (7b305b)

Situation

A grant condition OIG says was never monitored put emergency resource-allocation spreadsheet in front of testimony-prep lead in a pass-through grantor after a subrecipient audit. This Government / Operations and Emergency close is a subrecipient should be suspended from emergency resource-allocation spreadsheet, and the live options are Pay or continue, Recoup, Deny.

Decision

Testimony-prep lead in a pass-through grantor after a subrecipient audit must choose Pay or continue / Recoup / Deny / Hold using emergency resource-allocation spreadsheet after a grant condition OIG says was never monitored.

Hypotheses to test

• Authorize Pay or continue now; emergency resource-allocation spreadsheet already has the discriminator after a grant condition OIG says was never monitored.
• Keep Recoup in force until emergency resource-allocation spreadsheet is completed after a grant condition OIG says was never monitored for testimony-prep lead.
• Treat emergency resource-allocation spreadsheet as Deny because both readings appear after a grant condition OIG says was never monitored.
• Refuse a Government close: testimony-prep lead does not have the page a subrecipient should be suspended turns on in emergency resource-allocation spreadsheet.

Analysis required

• Name the statutory hook that emergency resource-allocation spreadsheet does or does not support.
• Test a single-case exception versus a control gap in a pass-through grantor after a subrecipient audit.
• Check notice and appeal timing around a grant condition OIG says was never monitored.
• For this Government Operations and Emergency file, read emergency resource-allocation spreadsheet against a grant condition OIG says was never monitored and write the one fact that would move a subrecipient should be suspended for testimony-prep lead.

Recommendation

Choose Pay or continue / Recoup / Deny / Hold on this Government / Operations and Emergency packet (emergency resource-allocation spreadsheet after a grant condition OIG says was never monitored). Lead with the Government option emergency resource-allocation spreadsheet can support after a grant condition OIG says was never monitored, then the two facts that force it, then the Monday action for testimony-prep lead in a pass-through grantor after a subrecipient audit.