Remediation and retesting tracker
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Open one record per finding. Link a record for each agreed action and each test. The action owner reports implementation, the reviewer records what the evidence supports, and the person designated under the applicable methodology records the finding’s disposition. Management owns remediation and any risk acceptance within its authority.
Use approved systems for evidence and enter references here. These fields are a suggested template. Agree the review scope, method and decision authority before using it. Where internal audit performs the follow-up, apply its established methodology and record any limits on reviewer independence.
Define what must be true to close the finding
Turn each material part of the finding into a testable criterion. Include affected routes and historical work where they matter. If scope or criteria change, keep the original version, who authorised the change and its effect on earlier results.
| What to record | Entry or evidence reference |
|---|---|
| Finding ID, original report and issue date | ____________________ |
| Control objective, observed weakness and exposure | ____________________ |
| Affected systems, routes, locations and period | ____________________ |
| Cause supported by evidence and remaining uncertainty | ____________________ |
| Success criteria with IDs, agreed scope and failure conditions | ____________________ |
| Accountable manager, reviewer and mandate, and closure authority | ____________________ |
| Interim control, owner, evidence, and expiry or review date | ____________________ |
Track the action and its deadlines
Use one record per action. Retain the original due date and each authorised change. Record what remains exposed during a delay. Where an action is replaced, link the replacement and assess whether it covers the same success criteria.
| What to record | Entry or evidence reference |
|---|---|
| Action ID, finding ID, criterion IDs and deliverable | ____________________ |
| Action owner, original and current authorised due dates | ____________________ |
| Date-change history, reasons, authority and interim safeguards | ____________________ |
| Management status (Planned, In progress, Reported implemented or Replaced) | ____________________ |
| Claimed implementation date and evidence reference | ____________________ |
| Replacement action, rationale and authority, if applicable | ____________________ |
Plan the test and retain each result
Plan evidence proportionate to the risk. Distinguish whether the design addresses the weakness, whether it was implemented across the scope, and whether it operated during the period assessed. Where operating evidence is needed and no case occurred, record how the absence was established and what a controlled test can demonstrate. Keep any unsupported operating conclusion pending. Record and investigate material failures before retesting.
| What to record | Entry or evidence reference |
|---|---|
| Test ID, linked action and criterion, reviewer and date | ____________________ |
| Route or location, period, evidence type and expected result | ____________________ |
| Population source and completeness, selection and rationale, exclusions and limitations | ____________________ |
| Actual result and evidence reference | ____________________ |
| Outcome (Pass, Fail, Inconclusive or Not performed) and scope supported | ____________________ |
| Failure exposure, containment owner, corrective action and linked retest ID | ____________________ |
Keep the failed test and its evidence when a retest passes. Treat missing or contradictory evidence as unresolved unless the reviewer can support a narrower conclusion and state its limits.
Record verification and decide the finding’s disposition
Mark the action Pending, Evidence insufficient, Failed verification, or Verified within stated scope. Close after verified remediation only when the evidence supports all material success criteria, including necessary linked actions. Where policy permits a transfer or authorised risk acceptance, record that disposition explicitly and keep the remaining exposure visible. For internal audit, apply the methodology for overdue actions and use the chief audit executive’s escalation route when applicable.
| What to record | Entry or evidence reference |
|---|---|
| Reviewer’s conclusion, scope, limitations and linked tests | ____________________ |
| Finding disposition (Open, Closed after verified remediation, Closed under authorised risk acceptance or Superseded with linked tracking) | ____________________ |
| Decision authority, date, rationale and evidence | ____________________ |
| Unresolved exposure, receiving owner and acknowledgement if transferred | ____________________ |
| Risk acceptance reference, permitted authority, interim controls and expiry if applicable | ____________________ |
| Reopening trigger, monitoring owner and next review | ____________________ |
Worked examples
These examples use fictional data.
Verified across the agreed scope
Finding F-31. The criterion is independent approval on every in-scope payment-change route. Reviewer R-31 checks normal entry and import configuration and tests both in a controlled environment. The reconciled register contains 24 changes in October. Six selected across the two routes show separate approvers. The reviewer records the judgemental selection and links test results T-31 and T-32. The closure authority records verified remediation against those results and the stated selection limits.
The retest passes, but the finding stays open
Finding F-32. T-1 shows a normal-screen control works but the import path permits self-approval. Finance restricts import and fixes permissions. T-2 passes on both routes. The reviewer links T-2 to T-1. The historical review is still due under action A-2, so the closure authority keeps F-32 open with a named owner and review date.
Implementation evidence is available before the first run
Finding F-33. Management supplies a deployment record for a quarterly control. The reviewer confirms the deployment and reconciles the schedule to show the first run is still ahead. Operating evidence is required for criterion C-2. The reviewer records that check as Not performed, assigns a follow-up after the next run, and leaves the finding Open.
Sources behind the workflow
- Management implementation, risk-based internal audit follow-up, and escalation of risk acceptance. IIA Global Internal Audit Standards, Standards 14.4, 15.2 and 11.5
- US prosecutorial evaluation perspective on linking remedial actions to underlying causes. US DOJ Evaluation of Corporate Compliance Programs, September 2024, section III.C
Sources
Check the original material below. How we use sources
- Primary sourceDOJ compliance evaluation, September 2024, section III.C
- Supporting sourceGlobal Internal Audit Standards, Standard 15.2