If you are a federal grant recipient, you probably know that a lot has changed implementing 2 CFR Part 200, aka, the Uniform Guidance for grants.
But you may not realize that one of the goals of this change was to reduce the number of audit findings and the need for corrective action plans.
Better Grant Management Means Less Audit Findings
The guidance has an emphasis on something called “Cooperative Audit Resolution.”
In other words, the funding agencies what to work with you to get problems cleaned up so they don’t occur again.
If you think you are the only one who has experienced audit findings or other deficiencies…it is more common than you may realize.
Our past research noted audit findings of varying levels of severity in nearly 1/3 of the organizations in our sample.
Now no one wants to think about audit findings and corrective action plans.
Still, the reality is that many grant professionals will have experience with either producing or implementing a corrective action plan during their careers.
So how do you write a corrective action plan?
Writing a Corrective Action Plan
We first need to understand what a corrective action plan is.
When a specific system, project, or program has problems, a corrective action plan comes into play.
It can also be defined as the “fix” used when defects in a process, oversight, or training affect the administration or management of the tasks at hand.
A corrective action plan can be designed following a few simple yet systematic steps.
Getting at the Root of the Issues: Root Cause Analysis
For us to be able to give a solution to any problem, we must recognize the nature of the issues involved. Proper analysis is essential.
A good corrective action plan starts with analyzing the “root cause” of the identified issues.
We need to find out the following things:
- What is the exact issue that is causing the problem at hand?
- Are there flaws in the work processes that led to the issues?
- Has this type of issue occurred before?
- If it has, what caused it to recur?
Steps to Implement: Corrective Measures
After understanding the root of the problem, the next step is to devise a way to rectify the mistakes made previously.
This analysis generally involves defining a set of steps through which correction can start.
It is always easier to tackle issues once you know where to begin.
The steps may vary, but the action words used in the corrective measures section of a corrective action plan are eerily familiar.
Well written corrective action plans will often start this section with the following terms:
- Identify
- Strengthen
- Reevaluate
- Improve
- Develop
- Establish
- Implement
Remember that your approach should start from the root cause of the problem and then move forward through the corrective measures to lay out a plan to eliminate the issue.
Making the Plan Reality: Expected Outcomes
The next step in making the corrective action plan a reality is to envision the expected outcomes and critical success measures.
How will you know if corrective measures are working or not?
The expected outcomes section is where you spell out the criteria to know if the plan is working as expected. The outcomes should follow the “SMART” principles:
- Specific
- Measurable
- Attainable
- Relevant
- Time-bound
Other Key Elements:
Finally, the corrective action plan comes together with the actual work: Who will do what, and when will that be done?
A robust corrective action plan contains the following elements as part of the total plan:
- Accomplishments – What have we done so far?
- Actions – What is left to do?
- Responsible Parties – Who is doing what?
- Completion Dates – When will it be done?
Of course, completing the corrective action plan is just the beginning of the process. The areas that gave rise to the findings should be carefully monitored and supervised so that the flaws in the original action plan are not repeated.
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Author:
Lucy Morgan CPA, MBA
CEO, Compliance Warrior
Author of “Decoding Grant Management-The Ultimate Success Guide to the Federal Grant Regulations in 2 CFR Part 200” The 2nd Edition is now available on Amazon in Paperback and Kindle versions.
SENZOTA says
Dear Lucy
Brief, well summarized
Thanks much
admin says
Thanks for your feedback!
All the best,
Lucy