What if you were certain the world was coming to an end and it wasn’t?
If you followed the disturbing story of the Hawaiian missile alert sent in error, you probably are glad you weren’t there for the “This is not a drill” emergency drill!
Things (obviously) didn’t work as expected!
The Associated Press (AP) article titled “Hawaii man devastated about sending missile alert” cited three fundamental process failures at the Hawaii Emergency Management Agency (HEMA) that contributed to this debacle:
- The agency had a vague checklist for missile alerts, letting workers to interpret the steps they should follow inconsistently.
- There was no requirement for a second person to sign off on alerts before they were sent.
- There was no training or process on how to correct a false warning.
In other words, lacking or poorly written procedures, poor checks and balances and insufficient training allowed this traumatic event to start and continue for 38 excruciating minutes.
Life After A (Near) Disaster
First of all, thank goodness it was NOT an attack!
But whenever something bad happens, the follow up after the event typically requires an examination of what went wrong and how to this from happening in the future.
The document that comes out of that review is called a “Corrective Action Plan” or CAP.
Last night I was watching the movie “Deepwater Horizon” about the BP oil spill, and thinking “They had to have one heck of a corrective action plan!” as well.
Do you see a pattern here?
Sometimes life doesn’t go as expected, but many times the dire circumstances could have been anticipated and prevented with better processes, checks and balances and training.
When Good Grants Go Bad
If you are a federal grant recipient, you probably know that a lot changed with the implementation of the new Uniform Guidance for grants.
You may even have heard me talk about the word that sums up these changes is “Accountability.”
And when I say “accountability” I mean that the Uniform Guidance is chock-full of ways to make grant recipients take the fall when good grants go bad.
But you may not realize that another one of the goals of the new grant regulations is to reduce the number of audit findings.
The federal government wants-no they EXPECT-grant recipients to do a better job with the federal funds they are awarded.
The bar is higher than ever before!
So let’s look at what that means to you as a federal grant recipient…
Better Grant Management Means Fewer Audit Findings
The new grant guidance has an emphasis on something called “Cooperative Audit Resolution”
In other words, the funding agencies want to work with you to get problems cleaned up, and steps put in place so they don’t occur again in the future.
(Just in case you feel like you are the only one who has experienced audit findings or other deficiencies…it is more common than you may realize.)
We researched the data in the Federal Audit Clearinghouse in 2010 and discovered that in our sample, nearly one in three grant recipients have some kind of audit findings.
Now no one wants to think about audit findings and the resulting corrective action plans…
But the reality is that many grant professionals will experience either creating or implementing a corrective action plan during their career.
So how do you write a corrective action plan?
Writing a Corrective Action Plan
The first thing to understand is what a corrective action plan is and is NOT.
Basically, when a certain process, project, or program has problems, a corrective action plan comes into play.
It can also be defined as the “fix it” recipe.
Corrective action plans get created when defects in a process, lack of oversight, or insufficient training affects the administration or management of the key tasks.
A corrective action plan is NOT a magic bullet that will fix problems without having to do any real work.
In other words, the most beautifully written corrective plan is useless if you don’t implement that steps.
Saying people will be trained in the right way to do something is meaningless if no one actually receives training.
You get my point!
Wondering how to put together a good CAP?
Follow these simple, yet systematic five steps.
Step One: Root Cause Analysis
In order for us to be able to give a solution to any problem, we must recognize the nature of the issues involved.
Proper analysis is very necessary.
A good corrective action plan starts with an analysis of 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 to recur?
Step Two: Corrective Measures
After you understand the root cause of the problem, the next step is to devise a way to rectify the mistakes that were made previously.
This generally means you need to define the series of steps through which correction can start. For example, what is the first thing you need to do?
- Re-evaluate a vague procedure?
- Identify someone to conduct training on the right way to do the tasks?
- Strengthen checks and balances to ensure it can’t happen again?
The steps may vary, but the action words that are 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:
Remember that your approach should start from Step One with the identification of the root cause of the problem and then move forward to Step Two through the corrective measures to lay out a plan to eliminate the issue completely.
Step Three: Expected Outcomes
The next step in making the corrective action plan a reality is to envision the expected outcomes and key success measures.
In other words, 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.
Without this critical step, you may find yourself repeating the same audit findings year after year.
(Think of the movie “Groundhog Day” where Bill Murray repeated the same unhappy ending over and over!)
Here are some guidelines for creating expected outcomes and measuring key success measures:
Follow the “SMART” principles:
Step Four: Implement The Plan
Finally, the corrective action plan comes together with the real work: Who is going to do what and when will that be done?
Many corrective action plans failure miserably at this step because this is where the bulk of the work happens.
So build a strong corrective action plan by including 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?
Step Five: Follow Up and Monitor Compliance
Of course, completing the corrective action plan is really just the beginning of the process.
The areas that gave rise to the findings should be carefully monitored and supervised so that the flaws which existed in the original action plan are not repeated.
Ever seen people revert to bad habits in times of stress?
The same thing happens with organizations.
In times of stress…limited resources, new, untrained employees, it’s easy for things to slip back into the unhealthy patterns of the past.
Build regular monitoring into your process well out into the future and you can avoid many of the risks of good grants going bad.
Ready to Improve Your Grant Management?
How about you?
Would you like to be a better grant manager?
We have another grant management training seminar coming soon.
Click here to get all the details!
Hope to see you there!
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.