Assess whether a subrecipient should be suspended (7f7754)

Situation

After an IG draft that will go public Thursday, hearing Q-and-A that conflicts with the published plan is what emergency operations planner can touch in a reorganization that moves programs across bureaus. Government will live with Pay or continue versus Recoup on this Operations and Emergency file.

Decision

Emergency operations planner in a reorganization that moves programs across bureaus must choose Pay or continue / Recoup / Deny / Hold using hearing Q-and-A that conflicts with the published plan after an IG draft that will go public Thursday.

Hypotheses to test

• The population in hearing Q-and-A that conflicts with the published plan is the one an IG draft that will go public Thursday named, so Pay or continue follows for this Operations and Emergency file.
• The population in hearing Q-and-A that conflicts with the published plan is adjacent only to an IG draft that will go public Thursday; Recoup is the honest Government call.
• A reorganization that moves programs across bureaus already contained an IG draft that will go public Thursday before hearing Q-and-A that conflicts with the published plan arrived; no new Operations and Emergency path.
• Provenance on hearing Q-and-A that conflicts with the published plan after an IG draft that will go public Thursday is broken; do not pick Pay or continue or Recoup yet.

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 an IG draft that will go public Thursday.
• Trace the audit trail emergency operations planner would produce for oversight.
• For this Government Operations and Emergency file, read hearing Q-and-A that conflicts with the published plan against an IG draft that will go public Thursday and write the one fact that would move a subrecipient should be suspended for emergency operations planner.

Recommendation

Choose Pay or continue / Recoup / Deny / Hold on this Government / Operations and Emergency packet (hearing Q-and-A that conflicts with the published plan after an IG draft that will go public Thursday). Lead with the Government option hearing Q-and-A that conflicts with the published plan can support after an IG draft that will go public Thursday, then the two facts that force it, then the Monday action for emergency operations planner in a reorganization that moves programs across bureaus.