Regulatory-impact analyst must resolve whether emergency allocation criteria

Situation

Reorganization FTE and system-cutover map arrived with an OIRA passback gutting the preferred option for regulatory-impact analyst. That is a Government Budget and Performance decision on emergency allocation criteria are in a pass-through grantor after a subrecipient audit.

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

• An OIRA passback gutting the preferred option is already priced into reorganization FTE and system-cutover map; regulatory-impact analyst can take Pay or continue on emergency allocation criteria are inside a pass-through grantor after a subrecipient audit.
• An OIRA passback gutting the preferred option is the event in reorganization FTE and system-cutover map that forces Recoup rather than Pay or continue for this Budget and Performance file.
• Reorganization FTE and system-cutover map shows a one-file miss after an OIRA passback gutting the preferred option, not a Government program failure across a pass-through grantor after a subrecipient audit.
• Emergency allocation criteria are cannot be closed from reorganization FTE and system-cutover map after an OIRA passback gutting the preferred option; regulatory-impact analyst should keep Hold in force.

Analysis required

• Name the statutory hook that reorganization FTE and system-cutover map does or does not support.
• 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.
• 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 emergency allocation criteria are 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). The follow-on Budget and Performance action is what regulatory-impact analyst does next: implement the option, assign an owner, and log the missing fact.