Assess whether a subrecipient should be suspended (14778f)

Situation

A department writing an RIA under a tight clock cannot treat a grant condition OIG says was never monitored as color commentary on performance-measure set that cannot be produced from systems. Grant-compliance officer must close a subrecipient should be suspended from that extract under Government / Policy and Grants.

Decision

Grant-compliance officer in a department writing an RIA under a tight clock must choose Pay or continue / Recoup / Deny / Hold using performance-measure set that cannot be produced from systems after a grant condition OIG says was never monitored.

Hypotheses to test

• Grant-compliance officer can defend Pay or continue from performance-measure set that cannot be produced from systems after a grant condition OIG says was never monitored in a Government challenge.
• Grant-compliance officer cannot defend Pay or continue from performance-measure set that cannot be produced from systems; Recoup is what the extract actually supports after a grant condition OIG says was never monitored.
• A grant condition OIG says was never monitored never reached the population in performance-measure set that cannot be produced from systems — reopen intake, do not close a subrecipient should be suspended.
• Two facts in performance-measure set that cannot be produced from systems after a grant condition OIG says was never monitored conflict for grant-compliance officer; hold this Policy and Grants file.

Analysis required

• Map eligibility, appropriation, and program rules in performance-measure set that cannot be produced from systems after a grant condition OIG says was never monitored.
• Name the statutory hook that performance-measure set that cannot be produced from systems does or does not support.
• Test a single-case exception versus a control gap in a department writing an RIA under a tight clock.
• For this Government Policy and Grants file, read performance-measure set that cannot be produced from systems against a grant condition OIG says was never monitored and write the one fact that would move a subrecipient should be suspended for grant-compliance officer.

Recommendation

Choose Pay or continue / Recoup / Deny / Hold on this Government / Policy and Grants packet (performance-measure set that cannot be produced from systems after a grant condition OIG says was never monitored). Lead with the Government option performance-measure set that cannot be produced from systems can support after a grant condition OIG says was never monitored, then the two facts that force it, then the Monday action for grant-compliance officer in a department writing an RIA under a tight clock.