Assess whether a subrecipient should be suspended (5dd0c4)

Situation

Subrecipient single-audit exception list arrived with an IG draft that will go public Thursday for regulatory-impact analyst. That is a Government Policy and Grants decision on a subrecipient should be suspended in a cabinet agency defending a budget increase.

Decision

Regulatory-impact analyst in a cabinet agency defending a budget increase must choose Pay or continue / Recoup / Deny / Hold using subrecipient single-audit exception list after an IG draft that will go public Thursday.

Hypotheses to test

• Authorize Pay or continue now; subrecipient single-audit exception list already has the discriminator after an IG draft that will go public Thursday.
• Keep Recoup in force until subrecipient single-audit exception list is completed after an IG draft that will go public Thursday for regulatory-impact analyst.
• Treat subrecipient single-audit exception list as Deny because both readings appear after an IG draft that will go public Thursday.
• Refuse a Government close: regulatory-impact analyst does not have the page a subrecipient should be suspended turns on in subrecipient single-audit exception list.

Analysis required

• Trace the audit trail regulatory-impact analyst would produce for oversight.
• Map eligibility, appropriation, and program rules in subrecipient single-audit exception list after an IG draft that will go public Thursday.
• Name the statutory hook that subrecipient single-audit exception list does or does not support.
• For this Government Policy and Grants file, read subrecipient single-audit exception list 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 / Policy and Grants packet (subrecipient single-audit exception list after an IG draft that will go public Thursday). The follow-on Policy and Grants action is what regulatory-impact analyst does next: implement the option, assign an owner, and log the missing fact.

Command returns