Whether a subrecipient should be suspended from grant special-condition that

Situation

Regulatory-impact analyst in a pass-through grantor after a subrecipient audit has one working extract — grant special-condition that the program never implemented — after an IG draft that will go public Thursday. If grant special-condition that the program never implemented cannot support a subrecipient should be suspended, 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 grant special-condition that the program never implemented after an IG draft that will go public Thursday.

Hypotheses to test

• Grant special-condition that the program never implemented reads as Pay or continue once an IG draft that will go public Thursday is lined up to the same Government population.
• Grant special-condition that the program never implemented 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 grant special-condition that the program never implemented for regulatory-impact analyst in a pass-through grantor after a subrecipient audit.
• Grant special-condition that the program never implemented is missing the fact regulatory-impact analyst needs after an IG draft that will go public Thursday; stop this Government close.

Analysis required

• 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 an IG draft that will go public Thursday.
• Name the statutory hook that grant special-condition that the program never implemented does or does not support.
• For this Government Budget and Performance file, read grant special-condition that the program never implemented against an IG draft that will go public Thursday 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 / Budget and Performance packet (grant special-condition that the program never implemented after an IG draft that will go public Thursday). If grant special-condition that the program never implemented cannot force a Government label under Budget and Performance, stop. Do not invent pages a pass-through grantor after a subrecipient audit does not have.