Financial Crime World

Grantees Must Respond to Corrective Action Plan (CAP) within 30 Days

The Office for Civilian Finance Operations (OCFO) has recently issued a list of the Top 10 Monitoring Findings from Fiscal Year 2020, highlighting common issues faced by grantees. This article provides an overview of the findings and the importance of responding to Corrective Action Plans (CAPs).

Top 10 Monitoring Findings (Fiscal Year 2020)

  1. Procedures not documented or need improvement
  2. FATA reporting requirements not met
  3. Internal control weakness – procedure not followed
  4. FRs do not reconcile to grantee’s accounting records
  5. Award Special Condition Violated—Unauthorized Expenditures/Drawdowns
  6. Inadequate subrecipient files/documentation
  7. Authorized signing official or contact information not current
  8. Indirect costs charged improperly —rate expired
  9. Excess cash -on-hand identified
  10. (Tie) Audit report package not received at FAC; Unsupported Costs – Personnel/Fringe Benefits

Grantees’ Questions Answered

During the Live Discussion Webinar, grantees posed several questions to OCFO. Some key takeaways include:

  • OCFO does not conduct audits but provides technical assistance and help grantees prepare for audits.
  • Grantees should have adequate policies and procedures, internal controls, and trained staff to ensure compliance with federal regulations.
  • Reconciliations are crucial in detecting and correcting errors, and uncovering fraud.

Corrective Action Plan (CAP)

For grantees who receive a CAP, it is essential to respond within 30 days. The response should include:

  • Acknowledgement of the findings and deficiencies
  • Description of corrective actions taken or planned
  • Timeline for implementation of corrective actions
  • Evidence of completion of corrective actions (e.g., documentation, records)

Grantees who fail to comply with the CAP may face consequences, including suspension or termination of funding.

Contact Information

For more information on OCFO’s training, technical assistance, and resources, please contact: