Assess whether a subrecipient should be suspended (4fd0c6)

Situation

Grant-compliance officer owns a subrecipient should be suspended inside a department writing an RIA under a tight clock with public-records request that hits deliberative drafts as the only packet. An IG draft that will go public Thursday is what changed the clock for this Government Policy and Grants file.

Decision

Grant-compliance officer in a department writing an RIA under a tight clock must choose Pay or continue / Recoup / Deny / Hold using public-records request that hits deliberative drafts after an IG draft that will go public Thursday.

Hypotheses to test

• Authorize Pay or continue now; public-records request that hits deliberative drafts already has the discriminator after an IG draft that will go public Thursday.
• Keep Recoup in force until public-records request that hits deliberative drafts is completed after an IG draft that will go public Thursday for grant-compliance officer.
• Treat public-records request that hits deliberative drafts as Deny because both readings appear after an IG draft that will go public Thursday.
• Refuse a Government close: grant-compliance officer does not have the page a subrecipient should be suspended turns on in public-records request that hits deliberative drafts.

Analysis required

• Test a single-case exception versus a control gap in a department writing an RIA under a tight clock.
• Check notice and appeal timing around an IG draft that will go public Thursday.
• Trace the audit trail grant-compliance officer would produce for oversight.
• For this Government Policy and Grants file, read public-records request that hits deliberative drafts against an IG draft that will go public Thursday 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 (public-records request that hits deliberative drafts after an IG draft that will go public Thursday). Lead with the Government option public-records request that hits deliberative drafts can support after an IG draft that will go public Thursday, 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.