Examples
Worked examples
- Is an instance
A university's Single Audit reports a significant deficiency in subrecipient risk assessment for 3 of 15 subawards tested. The university's corrective action plan names the Office of Sponsored Programs director as the responsible contact, describes the corrective action as revising the subaward issuance checklist to require a documented risk assessment before issuance, and sets a completion date six months out.
- Is an instance
A finding cites late effort-reporting certifications. The auditee's corrective action plan assigns responsibility to the payroll compliance manager, describes moving to a quarterly automated reminder workflow as the corrective action, and gives an implementation date tied to the next payroll cycle.
Counter-examples
Looks similar, but isn't
- Not an instance
A one-line reply stating 'Finding noted, will be addressed' with no named responsible contact, no description of the actual corrective action, and no completion date does not satisfy 2 CFR 200.511(c) -- it omits every one of the required elements and would not be an acceptable corrective action plan for the reporting package.
Editorial commentary
An audit corrective action plan is the document a grantee institution submits in response to findings in its US federal Single Audit, prepared under 2 CFR 200.511(c) of the Uniform Guidance. It is one of the required components of the Single Audit reporting package submitted to the Federal Audit Clearinghouse (FAC), sitting alongside the auditor’s opinions, the Schedule of Expenditures of Federal Awards, and the Schedule of Findings and Questioned Costs — but unlike those, it is written entirely by the auditee, not the auditor.
This is a distinct document from a clinical-research quality-system CAPA (Corrective and Preventive Action). Both share the same underlying logic — identify a problem, fix it, prevent recurrence — but the audit corrective action plan responds specifically to a federal grants-compliance finding under the Uniform Guidance, follows a fixed regulatory format, and becomes part of a public federal filing rather than an internal quality record.
What the plan must contain
2 CFR 200.511(c) requires the corrective action plan to be a document separate from the auditor’s own findings, and to address each current-year finding in the Schedule of Findings and Questioned Costs individually. For every finding, it must include:
- The name(s) of the contact person(s) responsible for the corrective action
- A description of the corrective action to be taken
- The anticipated completion date
If the auditee does not agree with a finding, or believes corrective action isn’t warranted, the plan must instead include a detailed explanation of the reasons for the disagreement, in place of a planned corrective action. Silence, a vague acknowledgment, or a single sentence promising to “address” a finding without naming a responsible person and a completion date does not meet the regulation’s requirements.
Template structure
There is no single federally-mandated form for the corrective action plan (it is not a numbered SF form the way the SF-425 or the SF-SAC data collection form are), but because 200.511(c) specifies exactly what each entry must contain, a usable template repeats a consistent block per finding:
- Finding reference number (matching the number assigned in the Schedule of Findings and Questioned Costs, e.g. “Finding 2025-001”)
- Brief restatement of the finding and the federal program it relates to
- Name and title of the responsible contact person
- Description of the planned corrective action (or a detailed explanation of disagreement, if applicable)
- Anticipated completion date
Institutions that carry a finding forward from a prior year should also reconcile the current plan against the summary schedule of prior audit findings required under 200.511(b), which separately tracks whether each older finding was resolved, is still in progress, or is no longer valid — a corrective action plan that doesn’t line up with what the prior-year schedule reports is itself a common point of scrutiny.
Submission timing and what happens next
The corrective action plan is submitted together with the rest of the reporting package to the Federal Audit Clearinghouse within 30 calendar days of the auditee receiving the auditor’s report(s), or nine months after the end of the audit period, whichever is earlier (2 CFR 200.512). It doesn’t stand alone as a compliance step — the federal awarding agency or pass-through entity reviews the finding together with the auditee’s corrective action plan and issues a management decision on the finding, required within six months of the FAC accepting the audit report under 2 CFR 200.521. That management decision determines whether a questioned cost is allowed, disallowed, or needs further documentation, and whether the agency considers the finding closed.
A corrective action plan that repeatedly promises the same fix without follow-through is itself a risk signal: unresolved repeat findings feed directly into whether a federal awarding agency treats an auditee as high-risk for future awards, and oversight bodies such as agency Offices of Inspector General may review an entity’s audit and corrective-action history when planning further review or audit activity.
Who prepares it
The auditee — typically the institution’s grants/sponsored-programs office working with the finance office and whichever department or unit the finding concerns — prepares the corrective action plan. The independent auditor does not draft it, though the auditor’s Schedule of Findings and Questioned Costs is what the plan responds to, finding by finding.
Related CASRAI Dictionary terms and guides
Single Audit (US) · Single Audit Report Example: Inside a Reporting Package’s Structure · Grant audit · CAPA (Corrective and Preventive Action) · Subrecipient monitoring · Closeout phase · OIG Reports
Machine-readable encodings
Use in your systems
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