Assess whether a grant special condition is being waived de facto (c08146)

Situation

In a reorganization that moves programs across bureaus, grant special-condition that the program never implemented is the evidence after a subrecipient that cannot produce payroll for match. FOIA/public-records counsel's program counterpart has to pick Pay or continue or Recoup for this Government Oversight and Records close using grant special-condition that the program never implemented.

Decision

FOIA/public-records counsel's program counterpart in a reorganization that moves programs across bureaus must choose Pay or continue / Recoup / Deny / Hold using grant special-condition that the program never implemented after a subrecipient that cannot produce payroll for match.

Hypotheses to test

• FOIA/public-records counsel's program counterpart can defend Pay or continue from grant special-condition that the program never implemented after a subrecipient that cannot produce payroll for match in a Government challenge.
• FOIA/public-records counsel's program counterpart cannot defend Pay or continue from grant special-condition that the program never implemented; Recoup is what the extract actually supports after a subrecipient that cannot produce payroll for match.
• A subrecipient that cannot produce payroll for match never reached the population in grant special-condition that the program never implemented — reopen intake, do not close a grant special condition.
• Two facts in grant special-condition that the program never implemented after a subrecipient that cannot produce payroll for match conflict for FOIA/public-records counsel's program counterpart; hold this Oversight and Records file.

Analysis required

• Trace the audit trail FOIA/public-records counsel's program counterpart would produce for oversight.
• Map eligibility, appropriation, and program rules in grant special-condition that the program never implemented after a subrecipient that cannot produce payroll for match.
• Name the statutory hook that grant special-condition that the program never implemented does or does not support.
• For this Government Oversight and Records file, read grant special-condition that the program never implemented against a subrecipient that cannot produce payroll for match and write the one fact that would move a grant special condition for FOIA/public-records counsel's program counterpart.