The Federal Audit Clearinghouse (FAC) recently rejected certain single audit submissions, citing that the submissions lacked a required Corrective Action Plan (CAP) — despite a CAP being successfully uploaded with the original submission. This issue may arise if the FAC determines that the CAPs do not explicitly contain all of the required elements outlined in 2 CFR 200.511(c). And auditees may receive a rejection after an initial acceptance of the submission, which could result in a missed reporting deadline if remediation is not completed within the required reporting timeframe.

As a reminder to auditees, a CAP is required for each finding included in the single audit report. These findings may be related to:

• Internal controls over financial reporting identified during the financial statement audit, otherwise known as Government Auditing Standards findings.
• Compliance findings over federal (and/or state) awards identified during the single audit.
• Internal controls over compliance findings over federal (and/or state) awards identified during the single audit.

Auditees are responsible for drafting the CAP as part of the reporting package submitted to the FAC. The Uniform Guidance (2 CFR 200.511(c)) states that for each finding, the CAP must include the following information:

• The name(s) of the contact person(s) responsible for corrective action
• The corrective action planned
• The anticipated completion date

Auditees should ensure that each of these elements are clearly stated in the CAP and may consider incorporating a process to explicitly caption each of these elements directly in the CAP to avoid any confusion. An example of a template that can be used to meet these requirements can be found below.

For more information on this topic, or to learn how Baker Tilly specialists can help, contact our team.