Corrective Action Plans

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3. Strengthening Documentation Requirements
3. Strengthening Documentation Requirements
• Implement standardized documentation checklists for all disbursements
• Implement standardized documentation checklists for all disbursements
• Require complete supporting documentation prior to payment approval
• Require complete supporting documentation prior to payment approval
4. Enhanced Review and Approval Process
4. Enhanced Review and Approval Process
• Establish formal pre-payment approval workflows
• Establish formal pre-payment approval workflows
• Require documented supervisory approval for all expenditures
• Require documented supervisory approval for all expenditures
• Implement secondary review for federally funded transactions
• Implement secondary review for federally funded transactions
5. Segregation of Duties
5. Segregation of Duties
• Reassign roles to separate authorization, processing, and reconciliation functions
• Reassign roles to separate authorization, processing, and reconciliation functions
• Implement compensating controls where staffing limitations exist
• Implement compensating controls where staffing limitations exist
6. Staff Training and Compliance Education
6. Staff Training and Compliance Education
• Provide mandatory training on Uniform Guidance (2 CFR Part 200)
• Provide mandatory training on Uniform Guidance (2 CFR Part 200)
• Conduct annual refresher training for all relevant staff
• Conduct annual refresher training for all relevant staff
7. Review of Questioned Costs
7. Review of Questioned Costs
• Conduct a detailed review of all identified transactions
• Conduct a detailed review of all identified transactions
• Determine allowability in accordance with federal requirements
• Determine allowability in accordance with federal requirements
• Reimburse the federal program for any unallowable costs
• Reimburse the federal program for any unallowable costs
8. Monitoring and Oversight
8. Monitoring and Oversight
• Implement periodic internal audits of disbursement activity
• Implement periodic internal audits of disbursement activity
• Establish ongoing management review and compliance monitoring
• Establish ongoing management review and compliance monitoring
• Immediate corrective actions (documentation and approvals): In progress
• Immediate corrective actions (documentation and approvals): In progress
• Staff training: Within 60 days
• Staff training: Within 60 days
• Full implementation: Within 90 days
• Full implementation: Within 90 days
• Ongoing monitoring: Continuous
• Ongoing monitoring: Continuous
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