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2. The Controller and CEO will complete a comprehensive retrospective review of grant obligations spanning prior period end dates by December 2025, with appropriate documentation and HRSA notification as needed.
2. The Controller and CEO will complete a comprehensive retrospective review of grant obligations spanning prior period end dates by December 2025, with appropriate documentation and HRSA notification as needed.
3. Internal audit checklists will be updated in Q4 2025 to include period-of-performance compliance for all sampled federal expenditures.
3. Internal audit checklists will be updated in Q4 2025 to include period-of-performance compliance for all sampled federal expenditures.
4. Finance staff will receive refresher training on period-of-performance requirements and documentation standards by the end of 2025.
4. Finance staff will receive refresher training on period-of-performance requirements and documentation standards by the end of 2025.
Corrective Actions Taken:
Corrective Actions Taken:
1. SCMRC revised its federal drawdown procedures in 2024 to require documented review and approval of all expenditures before submitting any drawdown request.
1. SCMRC revised its federal drawdown procedures in 2024 to require documented review and approval of all expenditures before submitting any drawdown request.
2. A Draw Down Request Workbook is now prepared by the Controller and reviewed against supporting documentation, including invoices, timecards, and purchase records.
2. A Draw Down Request Workbook is now prepared by the Controller and reviewed against supporting documentation, including invoices, timecards, and purchase records.
3. The CEO reviews and signs off on each Draw Down Request prior to submission.
3. The CEO reviews and signs off on each Draw Down Request prior to submission.
4. Completed Draw Down Request Workbooks are submitted to HRSA for prior approval and retained for audit purposes.
4. Completed Draw Down Request Workbooks are submitted to HRSA for prior approval and retained for audit purposes.
5. Internal drawdown audits are conducted monthly to confirm alignment with federal cash management standards.
5. Internal drawdown audits are conducted monthly to confirm alignment with federal cash management standards.
Corrective Action Plan:
Corrective Action Plan:
1. Updated drawdown procedures have been incorporated into SCMRC’s financial policies and will be re-reviewed annually.
1. Updated drawdown procedures have been incorporated into SCMRC’s financial policies and will be re-reviewed annually.
2. Refresher training on 2 CFR § 200.305 and internal drawdown requirements will be conducted by Q4 2025.
2. Refresher training on 2 CFR § 200.305 and internal drawdown requirements will be conducted by Q4 2025.
3. Results of monthly drawdown audits will be included in the Finance Committee compliance dashboard starting in September 2025.
3. Results of monthly drawdown audits will be included in the Finance Committee compliance dashboard starting in September 2025.
4. SCMRC will continue to require documented CEO approval on all federal drawdown submissions to ensure sustained internal control.
4. SCMRC will continue to require documented CEO approval on all federal drawdown submissions to ensure sustained internal control.
1. In May 2024, SCMRC adopted a revised Purchasing and Procurement Policy that includes specific procedures for suspension and debarment screening for all covered transactions ≥$25,000.
1. In May 2024, SCMRC adopted a revised Purchasing and Procurement Policy that includes specific procedures for suspension and debarment screening for all covered transactions ≥$25,000.
2. SAM.gov verification and/or vendor self-certification is now required prior to contract execution or payment, with documentation filed in the procurement record.
2. SAM.gov verification and/or vendor self-certification is now required prior to contract execution or payment, with documentation filed in the procurement record.
3. Procurement and grant staff received training in Spring 2024 on 2 CFR § 200.214 and Part 180, using materials from HRSA technical assistance and compliance consultants.
3. Procurement and grant staff received training in Spring 2024 on 2 CFR § 200.214 and Part 180, using materials from HRSA technical assistance and compliance consultants.
4. A centralized procurement review process was established in 2024, with required sign-off by the CEO or Controller for all covered transactions.
4. A centralized procurement review process was established in 2024, with required sign-off by the CEO or Controller for all covered transactions.
5. Monthly procurement file audits began in 2025 to verify that S&D documentation is consistently completed and retained.
5. Monthly procurement file audits began in 2025 to verify that S&D documentation is consistently completed and retained.
1. SAM.gov searches or vendor certifications will continue to be required and documented for all covered transactions and reviewed by the CEO or Controller before final approval.
1. SAM.gov searches or vendor certifications will continue to be required and documented for all covered transactions and reviewed by the CEO or Controller before final approval.
2. Beginning Q4 2025, procurement files will be audited quarterly (instead of the current monthly cadence) for S&D compliance, with results reported to the CEO and incorporated into continuous improvement efforts.
2. Beginning Q4 2025, procurement files will be audited quarterly (instead of the current monthly cadence) for S&D compliance, with results reported to the CEO and incorporated into continuous improvement efforts.
3. Procurement compliance, including S&D verification, will be included in SCMRC’s annual fiscal review and addressed in new staff onboarding and annual training.
3. Procurement compliance, including S&D verification, will be included in SCMRC’s annual fiscal review and addressed in new staff onboarding and annual training.
4. SCMRC will maintain documentation for each verification in alignment with federal requirements and internal procurement policy.
4. SCMRC will maintain documentation for each verification in alignment with federal requirements and internal procurement policy.
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