An agency whose sanctions all arrive in the last quarter looks identical. This is a spending pattern, not a finding.

The whole population fails the textbook test — the median agency scores 6.2 where Nigrini calls 1.5 nonconformant — because MPLADS amounts are capped, rounded and repeated by design. This ranks agencies against each other, not against the law. It is the weakest signal here and is never evidence on its own.