Whether a grant special condition is being waived de facto from subrecipient

Situation

A pass-through grantor after a subrecipient audit cannot treat an OIRA passback gutting the preferred option as color commentary on subrecipient single-audit exception list. Regulatory-impact analyst must close a grant special condition from that extract under Government / Budget and Performance.

Decision

Regulatory-impact analyst in a pass-through grantor after a subrecipient audit must choose Pay or continue / Recoup / Deny / Hold using subrecipient single-audit exception list after an OIRA passback gutting the preferred option.

Hypotheses to test

• Subrecipient single-audit exception list reads as Pay or continue once an OIRA passback gutting the preferred option is lined up to the same Government population.
• Subrecipient single-audit exception list 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 subrecipient single-audit exception list for regulatory-impact analyst in a pass-through grantor after a subrecipient audit.
• Subrecipient single-audit exception list is missing the fact regulatory-impact analyst needs after an OIRA passback gutting the preferred option; stop this Government close.

Analysis required

• Check notice and appeal timing around an OIRA passback gutting the preferred option.
• Trace the audit trail regulatory-impact analyst would produce for oversight.
• Map eligibility, appropriation, and program rules in subrecipient single-audit exception list after an OIRA passback gutting the preferred option.
• For this Government Budget and Performance file, read subrecipient single-audit exception list 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 (subrecipient single-audit exception list after an OIRA passback gutting the preferred option). If subrecipient single-audit exception list 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.