Assess whether a subrecipient should be suspended (298d43)

Situation

After an OIRA passback gutting the preferred option, subrecipient single-audit exception list is what regulatory-impact analyst can touch in a cabinet agency defending a budget increase. Government will live with Pay or continue versus Recoup on this Policy and Grants file.

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 OIRA passback gutting the preferred option.

Hypotheses to test

• An OIRA passback gutting the preferred option is noise around an already-controlled Policy and Grants process in a cabinet agency defending a budget increase, given subrecipient single-audit exception list.
• An OIRA passback gutting the preferred option is the event in subrecipient single-audit exception list that forces Pay or continue for regulatory-impact analyst under Government.
• Subrecipient single-audit exception list shows a one-file miss after an OIRA passback gutting the preferred option, not a Policy and Grants program failure.
• Subrecipient single-audit exception list cannot decide a subrecipient should be suspended yet after an OIRA passback gutting the preferred option; hold is the only Government close a cabinet agency defending a budget increase can defend.

Analysis required

• Test a single-case exception versus a control gap in a cabinet agency defending a budget increase.
• Check notice and appeal timing around an OIRA passback gutting the preferred option.
• Trace the audit trail regulatory-impact analyst would produce for oversight.
• For this Government Policy and Grants file, read subrecipient single-audit exception list against an OIRA passback gutting the preferred option 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 OIRA passback gutting the preferred option). 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.