TLDR
The management decision is the federal agency's final word on a single audit finding. It determines whether questioned costs must be repaid and what corrective actions are required. Organizations have corrective action obligations that flow from the management decision — and those obligations are tracked on the next single audit.
The management decision is the federal agency’s formal response to a single audit finding. It is the point in the audit process where the government’s determination — on questioned costs, corrective actions, and timelines — becomes binding on the organization.
The Management Decision Timeline
Six months. That is the window federal awarding agencies have to issue management decisions after the audit is accepted into the Federal Audit Clearinghouse. In practice, some agencies are faster; some take longer. Complex cases with multiple findings or large questioned cost amounts may require more time for the agency’s review.
From the organization’s perspective, the six-month window is a period of uncertainty. Questioned costs have been identified, but the final determination — allowable or disallowed — has not been made. Organizations should use this period to gather any additional documentation that supports the allowability of questioned costs, rather than waiting for the management decision and then scrambling to respond.
What the Management Decision Contains
The management decision letter will include:
A description of each finding and the agency’s assessment of it. The agency may accept the auditor’s characterization of the finding, modify it, or in rare cases dispute it.
For questioned costs: the determination of whether each questioned cost amount is allowable (no repayment required), allowable with conditions, or disallowed (repayment required). If disallowed, the specific amount to be repaid and the repayment timeline.
For internal control or compliance findings: the specific corrective actions required, the expected outcome of those actions, and the deadline for completion.
Any conditions to be placed on future awards — for example, additional reporting requirements or enhanced monitoring — resulting from the findings.
Corrective Action Tracking
Once a management decision is issued, the corrective actions become obligations. Progress is tracked in the Summary Schedule of Prior Audit Findings, which is included in every subsequent single audit until each finding is resolved.
A finding is resolved when the federal agency determines that the corrective actions have been implemented satisfactorily. Until then, the finding appears in the prior audit summary as open. If the deadline passes without completion, the finding may be characterized as a repeat finding in the next audit — which is treated as more serious than a new finding.
See Also
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Q&A
How long does the federal agency have to issue a management decision?
Under 2 CFR 200.521, the federal awarding agency or cognizant agency must issue a management decision within six months of the date the audit is accepted by the Federal Audit Clearinghouse. If the audit involves multiple federal agencies, each agency with a finding is responsible for its own management decision within the six-month window.
Q&A
What happens if an organization disagrees with a management decision?
Organizations that disagree with a management decision have the right to appeal through the awarding agency's administrative appeal procedures. The management decision letter specifies the appeal process and time limits. Appeals must generally be filed within 60 to 90 days of receiving the management decision — check the specific agency's procedures.
Q&A
What is the difference between a management decision and a corrective action plan?
A corrective action plan is prepared by the organization and submitted as part of the single audit reporting package — it describes how the organization plans to address each finding. A management decision is issued by the federal agency after reviewing the audit — it is the government's response to the findings, which may accept the corrective action plan or require modifications to it.
Frequently asked