CRA Quality Assurance Programs 3 — Questions and Answers
Question 1: Which of the following best describes the role of a corrective action plan (CAP) following a QA finding?
- To document that the finding was not the institution's fault
- To outline specific steps, responsible parties, and timelines to remediate identified deficiencies (Correct answer)
- To request a waiver from the sponsoring agency for the violation
- To transfer the finding to a different departmental unit for resolution
Correct answer: To outline specific steps, responsible parties, and timelines to remediate identified deficiencies
A CAP provides a structured roadmap with accountability measures to ensure identified QA deficiencies are resolved systematically.
Question 2: Under a Uniform Guidance cost-sharing arrangement, which QA documentation practice is essential to demonstrate compliance?
- Tracking cost-share in a separate general ledger account with no connection to the award
- Maintaining records that show cost-share contributions meet the same standards as direct charges (Correct answer)
- Reporting cost-share only in the final financial report
- Using unspent indirect cost recovery as the sole source of cost-share
Correct answer: Maintaining records that show cost-share contributions meet the same standards as direct charges
2 CFR 200.306 requires cost-sharing contributions to be verifiable, necessary, and documented with the same rigor applied to direct costs.
Question 3: A QA review reveals that a PI charged meals for a working lunch to a federal grant without documentation of the business purpose. Which cost principle is implicated?
- Allocability under 2 CFR 200.405
- Reasonableness under 2 CFR 200.404
- Allowability and documentation under 2 CFR 200.403 (Correct answer)
- Consistency under 2 CFR 200.405
Correct answer: Allowability and documentation under 2 CFR 200.403
2 CFR 200.403 requires that costs be adequately documented; without a business purpose, the charge fails the allowability test.
Question 4: What is the primary function of a compliance matrix in a research QA program?
- To calculate the institution's F&A rate
- To map regulatory requirements to internal controls and responsible offices (Correct answer)
- To rank principal investigators by their compliance history
- To replace the need for sponsor-required progress reports
Correct answer: To map regulatory requirements to internal controls and responsible offices
A compliance matrix cross-references applicable regulations, award terms, and internal policies to the controls and personnel responsible for each requirement.
Question 5: Which scenario most likely indicates a systemic QA problem rather than an isolated error?
- One invoice charged to the wrong project in a single department
- Multiple departments consistently misclassifying capital equipment as supplies (Correct answer)
- A single late progress report submitted to one sponsor
- An isolated data entry error corrected within the same fiscal year
Correct answer: Multiple departments consistently misclassifying capital equipment as supplies
Errors appearing across multiple departments with the same pattern suggest a system-level control or training failure, not an individual mistake.
Question 6: In the context of research QA, what does 'continuous monitoring' mean?
- Conducting an annual audit of all federal awards
- Using automated tools and ongoing reviews to detect compliance issues in real time or near real time (Correct answer)
- Hiring a dedicated auditor to observe all PI activities daily
- Requiring monthly sponsor approval for all expenditures
Correct answer: Using automated tools and ongoing reviews to detect compliance issues in real time or near real time
Continuous monitoring leverages technology and periodic data analytics to provide ongoing assurance between formal audits.
Question 7: A CRA is reviewing subrecipient monitoring files and notices that site visit reports are missing for three high-risk subrecipients. Which federal requirement is most directly at risk of non-compliance?
- 2 CFR 200.332(d) requiring pass-through entities to monitor subrecipient activities (Correct answer)
- 2 CFR 200.412 governing direct cost allocation methods
- OMB M-20-26 provisions on grant flexibilities
- 2 CFR 200.514 requirements for auditor qualifications
Correct answer: 2 CFR 200.332(d) requiring pass-through entities to monitor subrecipient activities
2 CFR 200.332 mandates that pass-through entities actively monitor subrecipients, including through site visits for high-risk entities.
CRA Quality Assurance Programs 3
Which of the following best describes the role of a corrective action plan (CAP) following a QA finding?