Assess whether a grant special condition is being waived de facto (189c7f)

Situation

Budget and Performance work in a pass-through grantor after a subrecipient audit now turns on a grant special condition because an OIRA passback gutting the preferred option put reorganization FTE and system-cutover map in play. Regulatory-impact analyst should say what reorganization FTE and system-cutover map proves.

Decision

Regulatory-impact analyst in a pass-through grantor after a subrecipient audit must choose Pay or continue / Recoup / Deny / Hold using reorganization FTE and system-cutover map after an OIRA passback gutting the preferred option.

Hypotheses to test

• Reorganization FTE and system-cutover map reads as Pay or continue once an OIRA passback gutting the preferred option is lined up to the same Government population.
• Reorganization FTE and system-cutover map is closer to Recoup after an OIRA passback gutting the preferred option; Pay or continue would over-claim this Budget and Performance extract.
• Deny is still live in reorganization FTE and system-cutover map for regulatory-impact analyst in a pass-through grantor after a subrecipient audit.
• Reorganization FTE and system-cutover map is missing the fact regulatory-impact analyst needs after an OIRA passback gutting the preferred option; stop this Government close.

Analysis required

• Test a single-case exception versus a control gap in a pass-through grantor after a subrecipient audit.
• 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 Budget and Performance file, read reorganization FTE and system-cutover map against an OIRA passback gutting the preferred option and write the one fact that would move a grant special condition for regulatory-impact analyst.

Recommendation

Choose Pay or continue / Recoup / Deny / Hold on this Government / Budget and Performance packet (reorganization FTE and system-cutover map after an OIRA passback gutting the preferred option). If reorganization FTE and system-cutover map cannot force a Government label under Budget and Performance, stop. Do not invent pages a pass-through grantor after a subrecipient audit does not have.