Assess whether threshold splitting is a procurement-integrity issue (49ab52)

Situation

The desk packet is improper-payment sample that will not extrapolate cleanly after a FinCEN 314(a) list that hits a high-volume customer. Contracting officer's technical representative in an IG shop scoping a whistleblower allegation has to name Pursue or Pursue with conditions for this US Federal Financial Crime and Sanctions file.

Decision

Contracting officer's technical representative in an IG shop scoping a whistleblower allegation must choose Pursue / Pursue with conditions / Partner / No-bid using improper-payment sample that will not extrapolate cleanly after a FinCEN 314(a) list that hits a high-volume customer.

Hypotheses to test

• The population in improper-payment sample that will not extrapolate cleanly is the one a FinCEN 314(a) list that hits a high-volume customer named, so Pursue follows for this Financial Crime and Sanctions file.
• The population in improper-payment sample that will not extrapolate cleanly is adjacent only to a FinCEN 314(a) list that hits a high-volume customer; Pursue with conditions is the honest US Federal call.
• An IG shop scoping a whistleblower allegation already contained a FinCEN 314(a) list that hits a high-volume customer before improper-payment sample that will not extrapolate cleanly arrived; no new Financial Crime and Sanctions path.
• Provenance on improper-payment sample that will not extrapolate cleanly after a FinCEN 314(a) list that hits a high-volume customer is broken; do not pick Pursue or Pursue with conditions yet.

Analysis required

• Name the evaluation right contracting officer's technical representative would forfeit by rushing.
• Normalize pricing and CPARS/QASP evidence that actually supports threshold splitting is a.
• Compare PTW and compliance gates in improper-payment sample that will not extrapolate cleanly to a pursue / partner / no-bid split.
• For this US Federal Financial Crime and Sanctions file, read improper-payment sample that will not extrapolate cleanly against a FinCEN 314(a) list that hits a high-volume customer and write the one fact that would move threshold splitting is a for contracting officer's technical representative.

Recommendation

Choose Pursue / Pursue with conditions / Partner / No-bid on this US Federal / Financial Crime and Sanctions packet (improper-payment sample that will not extrapolate cleanly after a FinCEN 314(a) list that hits a high-volume customer). Lead with the US Federal option improper-payment sample that will not extrapolate cleanly can support after a FinCEN 314(a) list that hits a high-volume customer, then the two facts that force it, then the Monday action for contracting officer's technical representative in an IG shop scoping a whistleblower allegation.