Assess whether a subrecipient should be suspended (26f117)

Situation

A subrecipient should be suspended sits with regulatory-impact analyst because a dashboard number the IG already called misleading hit a state agency with a FOIA backlog and a political request. Evidence is grant special-condition that the program never implemented; write the Government Oversight and Records option that extract can carry.

Decision

Regulatory-impact analyst in a state agency with a FOIA backlog and a political request must choose Pay or continue / Recoup / Deny / Hold using grant special-condition that the program never implemented after a dashboard number the IG already called misleading.

Hypotheses to test

• Regulatory-impact analyst can defend Pay or continue from grant special-condition that the program never implemented after a dashboard number the IG already called misleading in a Government challenge.
• Regulatory-impact analyst cannot defend Pay or continue from grant special-condition that the program never implemented; Recoup is what the extract actually supports after a dashboard number the IG already called misleading.
• A dashboard number the IG already called misleading never reached the population in grant special-condition that the program never implemented — reopen intake, do not close a subrecipient should be suspended.
• Two facts in grant special-condition that the program never implemented after a dashboard number the IG already called misleading conflict for regulatory-impact analyst; hold this Oversight and Records file.

Analysis required

• Check notice and appeal timing around a dashboard number the IG already called misleading.
• Trace the audit trail regulatory-impact analyst would produce for oversight.
• Map eligibility, appropriation, and program rules in grant special-condition that the program never implemented after a dashboard number the IG already called misleading.
• For this Government Oversight and Records file, read grant special-condition that the program never implemented against a dashboard number the IG already called misleading and write the one fact that would move a subrecipient should be suspended for regulatory-impact analyst.

Recommendation

Choose Pay or continue / Recoup / Deny / Hold on this Government / Oversight and Records packet (grant special-condition that the program never implemented after a dashboard number the IG already called misleading). Lead with the Government option grant special-condition that the program never implemented can support after a dashboard number the IG already called misleading, then the two facts that force it, then the Monday action for regulatory-impact analyst in a state agency with a FOIA backlog and a political request.