In audits associated with voluntary repayment or disclosure under SDP for potentially fraudulent conduct, who develops the corrective action plan?

In audits associated with voluntary repayment or disclosure under SDP for potentially fraudulent conduct, who develops the corrective action plan?

• A. Auditee's internal audit team
• B. OIG inspector
• C. Entity's legal counsel
• D. External consultant

Answer: (C)

The corrective action plan in this context is developed by the entity's legal counsel. This is because voluntary repayment or disclosure under the Self-Disclosure Program involves legal risk and regulatory obligations, so counsel is responsible for crafting remediation steps that align with the SDP terms, protect the organization, and coordinate with regulators. Legal counsel ensures the plan addresses root causes, outlines specific corrective actions, timelines, and monitoring, and integrates the disclosure with appropriate governance. Other roles, like the auditee’s internal audit team, focus on evaluating controls rather than producing the formal remediation plan; an OIG inspector oversees the investigation and audit process rather than drafting the plan; and an external consultant might assist, but ownership and accountability for the plan typically rest with the entity’s legal counsel.

The corrective action plan in this context is developed by the entity's legal counsel. This is because voluntary repayment or disclosure under the Self-Disclosure Program involves legal risk and regulatory obligations, so counsel is responsible for crafting remediation steps that align with the SDP terms, protect the organization, and coordinate with regulators. Legal counsel ensures the plan addresses root causes, outlines specific corrective actions, timelines, and monitoring, and integrates the disclosure with appropriate governance. Other roles, like the auditee’s internal audit team, focus on evaluating controls rather than producing the formal remediation plan; an OIG inspector oversees the investigation and audit process rather than drafting the plan; and an external consultant might assist, but ownership and accountability for the plan typically rest with the entity’s legal counsel.