Assess whether a subrecipient should be suspended (6a5df2)

Situation

An OIRA passback gutting the preferred option put grant special-condition that the program never implemented 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 grant special-condition that the program never implemented, 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 grant special-condition that the program never implemented after an OIRA passback gutting the preferred option.

Hypotheses to test

• Testimony-prep lead can defend Pay or continue from grant special-condition that the program never implemented after an OIRA passback gutting the preferred option in a Government challenge.
• Testimony-prep lead cannot defend Pay or continue from grant special-condition that the program never implemented; Recoup is what the extract actually supports after an OIRA passback gutting the preferred option.
• An OIRA passback gutting the preferred option 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 an OIRA passback gutting the preferred option conflict for testimony-prep lead; hold this Operations and Emergency file.

Analysis required

• Test a single-case exception versus a control gap in a pass-through grantor after a subrecipient audit.
• Check notice and appeal timing around an OIRA passback gutting the preferred option.
• Trace the audit trail testimony-prep lead would produce for oversight.
• For this Government Operations and Emergency file, read grant special-condition that the program never implemented against an OIRA passback gutting the preferred option 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 (grant special-condition that the program never implemented after an OIRA passback gutting the preferred option). Lead with the Government option grant special-condition that the program never implemented can support after an OIRA passback gutting the preferred option, then the two facts that force it, then the Monday action for testimony-prep lead in a pass-through grantor after a subrecipient audit.