Assess whether a grant special condition is being waived de facto from FOIA

Situation

The desk packet is FOIA search-term and exemption log after a performance target that was quietly changed mid-year. Grant-compliance officer in a reorganization that moves programs across bureaus has to name Pay or continue or Recoup for this Government Budget and Performance file.

Decision

Grant-compliance officer in a reorganization that moves programs across bureaus must choose Pay or continue / Recoup / Deny / Hold using FOIA search-term and exemption log after a performance target that was quietly changed mid-year.

Hypotheses to test

• Authorize Pay or continue now; FOIA search-term and exemption log already has the discriminator after a performance target that was quietly changed mid-year.
• Keep Recoup in force until FOIA search-term and exemption log is completed after a performance target that was quietly changed mid-year for grant-compliance officer.
• Treat FOIA search-term and exemption log as Deny because both readings appear after a performance target that was quietly changed mid-year.
• Refuse a Government close: grant-compliance officer does not have the page a grant special condition turns on in FOIA search-term and exemption log.

Analysis required

• Name the statutory hook that FOIA search-term and exemption log does or does not support.
• Test a single-case exception versus a control gap in a reorganization that moves programs across bureaus.
• Check notice and appeal timing around a performance target that was quietly changed mid-year.
• For this Government Budget and Performance file, read FOIA search-term and exemption log against a performance target that was quietly changed mid-year and write the one fact that would move a grant special condition for grant-compliance officer.

Recommendation

Choose Pay or continue / Recoup / Deny / Hold on this Government / Budget and Performance packet (FOIA search-term and exemption log after a performance target that was quietly changed mid-year). The follow-on Budget and Performance action is what grant-compliance officer does next: implement the option, assign an owner, and log the missing fact.

Command returns