Corrective Action Plans

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1. In May 2024, SCMRC adopted a new Purchasing and Procurement Policy aligned with 2 CFR §§ 200.317–327. The policy includes required contract clauses, competition thresholds, conflict-of-interest standards, and documentation requirements.
1. In May 2024, SCMRC adopted a new Purchasing and Procurement Policy aligned with 2 CFR §§ 200.317–327. The policy includes required contract clauses, competition thresholds, conflict-of-interest standards, and documentation requirements.
2. Procurement responsibilities were centralized under the CEO and Controller, with all federally funded purchases above the micro-purchase threshold requiring formal documentation and pre-approval.
2. Procurement responsibilities were centralized under the CEO and Controller, with all federally funded purchases above the micro-purchase threshold requiring formal documentation and pre-approval.
3. Standardized templates for vendor selection, procurement method, and price justification were implemented.
3. Standardized templates for vendor selection, procurement method, and price justification were implemented.
4. SCMRC initiated monthly internal procurement audits in 2025.
4. SCMRC initiated monthly internal procurement audits in 2025.
1. The CEO and Controller will continue to review and approve all procurement actions above the micro-purchase threshold, ensuring compliance with policy and federal regulations.
1. The CEO and Controller will continue to review and approve all procurement actions above the micro-purchase threshold, ensuring compliance with policy and federal regulations.
2. Internal procurement audits will be conducted quarterly, with findings reviewed by leadership and incorporated into SCMRC’s CQI process.
2. Internal procurement audits will be conducted quarterly, with findings reviewed by leadership and incorporated into SCMRC’s CQI process.
3. SCMRC will include procurement compliance in the annual fiscal compliance review and maintain documentation for all purchases in accordance with the updated policy.
3. SCMRC will include procurement compliance in the annual fiscal compliance review and maintain documentation for all purchases in accordance with the updated policy.
4. Ongoing staff training will be provided at least annually, with procurement compliance
4. Ongoing staff training will be provided at least annually, with procurement compliance
1. Policy Adoption: A formal disbursement approval policy was adopted in 2024. The policy defines required documentation, establishes tiered approval thresholds, and assigns authorization responsibility based on role.
1. Policy Adoption: A formal disbursement approval policy was adopted in 2024. The policy defines required documentation, establishes tiered approval thresholds, and assigns authorization responsibility based on role.
2. System Controls: SCMRC’s accounting system was configured to require digital documentation of disbursement approvals. All disbursements are now traceable to authorized personnel.
2. System Controls: SCMRC’s accounting system was configured to require digital documentation of disbursement approvals. All disbursements are now traceable to authorized personnel.
3. Routine Oversight: The CEO and contract accountant conduct quarterly sampling of disbursement activity to verify proper documentation and authorization.
3. Routine Oversight: The CEO and contract accountant conduct quarterly sampling of disbursement activity to verify proper documentation and authorization.
4. Board Involvement: SCMRC’s Finance Committee reviews disbursement policies and internal controls annually as part of the broader fiscal oversight process.
4. Board Involvement: SCMRC’s Finance Committee reviews disbursement policies and internal controls annually as part of the broader fiscal oversight process.
5. Staff Training: Finance and administrative staff received updated training in 2024 on disbursement procedures and documentation protocols.
5. Staff Training: Finance and administrative staff received updated training in 2024 on disbursement procedures and documentation protocols.
1. SCMRC will conduct internal audits twice per year to verify continued compliance with disbursement approval and documentation requirements.
1. SCMRC will conduct internal audits twice per year to verify continued compliance with disbursement approval and documentation requirements.
2. A dashboard tracking disbursement approval timeliness and compliance will be developed in FY26 to support real-time monitoring.
2. A dashboard tracking disbursement approval timeliness and compliance will be developed in FY26 to support real-time monitoring.
3. The Controller will maintain a master log of all disbursement approvals and provide quarterly updates to the CEO.
3. The Controller will maintain a master log of all disbursement approvals and provide quarterly updates to the CEO.
4. SCMRC’s Disbursement Approval Policy will be reviewed and updated annually, with proposed revisions presented to the Finance Committee.
4. SCMRC’s Disbursement Approval Policy will be reviewed and updated annually, with proposed revisions presented to the Finance Committee.
5. Refresher training on approval protocols will be incorporated into the annual finance team training calendar beginning Q1 FY26.
5. Refresher training on approval protocols will be incorporated into the annual finance team training calendar beginning Q1 FY26.
Corrective Actions Taken:
Corrective Actions Taken:
1. Committee Oversight: Credentialing and privileging files are reviewed quarterly by the Board’s Compliance Committee, with findings and approval status documented in meeting minutes.
1. Committee Oversight: Credentialing and privileging files are reviewed quarterly by the Board’s Compliance Committee, with findings and approval status documented in meeting minutes.
2. Internal Logs: The CEO and Compliance Officer maintain credentialing logs, including license verification, expiration tracking, and privileging status.
2. Internal Logs: The CEO and Compliance Officer maintain credentialing logs, including license verification, expiration tracking, and privileging status.
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