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D. Agency Response - Corrective Action Plan

Subrecipient Monitoring Reports may include four possible results:

  1. No findings of Noncompliance - OCJP does not identify any area(s), either programmatic or fiscal, that do not comply with specific criteria found in state or federal statutes, rules and/or regulations, OCJP subrecipient grant contract(s), state departmental policy for the subrecipient program, or good business practice.

    If the OCJP monitoring review results in no findings of noncompliance, no further action from the subrecipient is needed.

  2. Findings of Noncompliance - OCJP identifies an area(s), either programmatic or fiscal, that does not comply with specific criteria found in state or federal statutes, rules and/or regulations, OCJP subrecipient grant contract, state departmental policy for subrecipient programs, or good business practice. If the OCJP monitoring review identifies findings of noncompliance, the subrecipient will be allowed thirty (30) calendar days from the issued date of the report to submit a corrective action plan to the Office of Criminal Justice Programs outlining how the agency plans to correct the finding(s). (See OCJP Appendix R for template)
    The Corrective Action Plan must include:

    NOTE:  If the subrecipient has any questions regarding the report or their required written response to a noncompliant finding or observation report then they should contact their OCJP Program Manager for assistance.

    • A statement of whether the subrecipient agency agrees with the finding or not.
    • A detailed plan of how the agency will correct each individual finding to prevent this or similar finding in the future or justification for the subrecipient’s disagreement with the finding(s).
    • Attachment of any subrecipient documents, forms, policy changes, reports, accounting tools, time sheets, data collection forms, etc. that ensures the subrecipient has corrected the finding(s).
    • If the subrecipient disagrees with a finding(s) identified by OCJP, detailed documentation must also be submitted to refute the questioned finding(s).
    • The CAP must be signed by the Authorized Official or their designee (The designee is the person granted permission to sign the Authorizing Official’s signature).
  3. Findings of Noncompliance Resulting in Questioned Costs In addition to all the requirements listed above in Section 2. (b). (Findings of Noncompliance) the subrecipient will need to repay all Questioned Costs listed in the Monitoring Report. To repay the Questioned Costs, a check (made payable to the State of Tennessee) must be submitted for the total of the Questioned Costs with the Corrective Action Plan within the allowed thirty (30) calendar days from the issuance date of the report to:

    Office of Business and Finance
    312 Rosa L. Parks Avenue, Suite 2000
    Nashville, TN 37243-1102

    **Updated**  Please note that checks are to be addressed to the Office of Business and Finance.

    Please list the contract number on the check or in the correspondence attached to the check in order for the repaid questioned costs to be applied to the proper fiscal year and the proper subrecipient contract number.

    Any deviation from this questioned cost repayment policy MUST be approved in writing by the Director of the Office of Criminal Justice Programs prior to the thirty (30) calendar day deadline.

  4. Observations - An observation does not generally result from noncompliance as a finding, but rather is a situation observed by a monitor that is deemed to be a potential problem or of interest to the grantor agency and therefore is reported.
    1. If a monitoring review identifies an observation, the subrecipient will be allowed thirty (30) calendar days from the issued date of the report to submit a response explaining the observation and outlining how the agency plans to correct the observation.
    2. The Corrective Action Plan for Observation(s) should include:
      • A statement of whether the subrecipient agency agrees with the observation or not.
      • A detailed statement of how the agency will address each individual observation to prevent a finding in the future, if needed.
      • Attachment of any subrecipient documents, forms, policy changes, reports, accounting tools, time sheets, data collection forms, etc. that ensures the subrecipient has corrected the observation, if needed.
      • If the subrecipient disagrees with an observation(s) identified by OCJP, detailed documentation must be submitted to refute the questioned observation(s).
      • The CAP must be signed by the Authorized Official or their designee. (The designee is the person granted permission to sign the Authorized Official's signature.)

      Address all observations in the same manner as findings.

Programmatic & Fiscal Monitoring Corrective Action Plans:

Finding(s) of Noncompliance and Observation(s) can be combined and submitted as one document for either one or more contracts managed by the agency. Corrective Action Plans for Finding(s) of Noncompliance and Observation(s) should be emailed to the OCJP Assistant Director, Quality Assurance at OCJP.Compliance@tn.gov.  It is not necessary to mail a hard-copy.  Questioned Cost repayment must be mailed according to the instructions above in #3. 

The Corrective Action Plan must be completed by either the Project Director or their designee, signed by the Authorized Official or their designee (The designee is the person granted permission to sign the Authorized Official's signature.) and be submitted no later than thirty (30) calendar days after the issue date of the OCJP Subrecipient Monitoring Report.

NOTE: A template for the Corrective Action Plan is at OCJP Appendix R: CAP Template. Although the use of the template is not mandatory, information in your Corrective Action Plan must be consistent with that which is included in the template.

 

OCJP RESPONSE:

Upon receipt of a Corrective Action Plan or Observation Report, OCJP will review and determine its adequacy. If OCJP finds the Corrective Action Plan or Observation Report is adequate, then OCJP will issue a letter of approval. In the event concerns remain, OCJP will determine what additional steps are needed and relate those requirements to the subrecipient in writing with an expected date of response by the subrecipient.

As of October 1, 2010 all official correspondence regarding the monitoring report and subrecipient responses will be sent by email to the contract Authorized official, the project director, and other interested individuals as appropriate.

All correspondence, including email, from OCJP to the subrecipient regarding the monitoring report and subrecipient responses must be maintained on site by the subrecipient as part of the subrecipient grant file.

 

CORRECTIVE ACTION PLAN (CAP) GUIDELINES

The Corrective Action Plan must include:

  1. A statement of whether the subrecipient agency agrees with the finding or not.
  2. A detailed plan of how the agency will correct each individual finding to prevent this or similar finding in the future or justification for the subrecipient’s disagreement with the finding(s).
  3. Repayment of all Questioned Costs listed in the Monitoring Report. See instructions in previous Section 3 above.
  4. Attachment of any subrecipient documents, forms, policy changes, reports, accounting tools, time sheets, data collection forms, etc. that ensures the subrecipient has corrected the finding(s) and following the CAP.
  5. If the subrecipient disagrees with a finding(s) identified by OCJP, detailed documentation must also be submitted to refute the questioned finding(s).
  6. The CAP must be signed by the Authorized Official or their designee. (The designee is the person granted permission to sign the Authorized Official’s signature.)

See OCJP Appendix R: CAP Template.