The Management Decision Deadline Nobody Tracks (2 CFR 200.521)

When a subrecipient's Single Audit turns up a finding tied to money you passed through, you don't get to leave it open indefinitely. 2 CFR 200.521(d) requires the pass-through entity to issue a management decision — a formal statement of whether the finding is sustained, why, and what the auditee must do about it — within six months of the Federal Audit Clearinghouse accepting the audit report. Not six months from when you first saw the finding, not six months from your own fiscal year. Six months from the FAC's acceptance date, which is public record for every submitted audit.

Grinnell Low Rent Housing Authority's most recent audit report was accepted by the FAC on October 17, 2025. Under § 200.521(d), any pass-through entity that funded that audit period and has a management decision to issue on a finding from it had until April 17, 2026 — six months later. Neither the FAC nor this site tracks whether that deadline was met for any given finding; the acceptance date is public, but the compliance clock it starts isn't tracked or published anywhere. If you fund this organization, that calculation is yours to make and yours to keep evidence of.

The FAC records what an audit found. It does not record whether the pass-through entity(ies) on the other end of those findings issued a management decision, or when. That's not a gap this site invented — it's the actual finding of GAO-24-106173, "Single Audits: Improving Federal Audit Clearinghouse Information and Usability Could Strengthen Federal Award Oversight" (April 2024), which examined FAC data quality and usability and recommended OMB take a more active role in improving both.

The gap isn't specific to management decisions — GAO found it at the finding-resolution level generally. As of 2021, 213 findings first reported in 2015 or earlier were still unresolved, and $1.17 trillion of the $6.97 trillion in federal award funds spent from 2017–2021 was linked to findings that were both severe and persistent. If resolution itself isn't tracked government-wide, it follows that the specific step of issuing a timely management decision on any one finding isn't either.

In practice, this means a pass-through entity funding dozens of subrecipients has to build and maintain its own tracker of FAC acceptance dates and six-month deadlines — because no public system does it, and a missed deadline doesn't announce itself anywhere.

Issuing management decisions on time is one piece of the broader subrecipient monitoring obligation under 2 CFR 200.332. For the full sequence of dates — audit due date, FAC submission, this six-month clock, and record retention — see the Single Audit compliance calendar.