Corrective Action Plans

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CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Longview School District No. 122 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of F...
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Longview School District No. 122 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Joan Parsons, Lead Accountant 2715 Lilac St Longview, WA 98632 (360)575-7177 Corrective action the auditee plans to take in response to the finding: The District has now enhanced its process surrounding collection and verification of certified payroll reports to include sending a weekly inquiry to the point of contact for the prime contractor for each federally-funded construction project. The inquiry requests the prime contractor to: • disclose if the prime contractor performed any work on the project that would be subject to Davis-Bacon prevailing wage requirements and if so, supply the certified payroll reports • identify any subcontractors who performed work on the project that would be subject to Davis-Bacon prevailing wage requirements, and if so, supply the certified payroll reports This communication is sent via email, read receipt requested, and the prime contractor’s response (or lack thereof) is documented and followed up on as necessary. Anticipated date to complete the corrective action: This process was implemented June 2024.
ALN: 84.010, 84.365, 84.367, 84.424, Corrective Action Plan: Inadequate Support for Federal Reimbursement - Title I-IV - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will perform quarterly sampling reviews to determine which receipts and additional data should be ...
ALN: 84.010, 84.365, 84.367, 84.424, Corrective Action Plan: Inadequate Support for Federal Reimbursement - Title I-IV - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will perform quarterly sampling reviews to determine which receipts and additional data should be requested to ensure the agency's compliance. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 12/31/2024
View Audit 317490 Questioned Costs: $1
ALN: Various, Corrective Action Plan: Noncompliant Cost Allocation - DPHHS - The Montana Department of Public Health and Human Services has completed its cost allocation business improvement review, which looked at the department's cost pool allocation methodology, the creation of new pools, and t...
ALN: Various, Corrective Action Plan: Noncompliant Cost Allocation - DPHHS - The Montana Department of Public Health and Human Services has completed its cost allocation business improvement review, which looked at the department's cost pool allocation methodology, the creation of new pools, and the timeliness of updates and appropriateness to the Public Assistance Cost Allocation Plan (PACAP). All internal controls, processes and procedures were updated, training of department staff and training material was implemented, and new processes were effective as of quarter one state fiscal year 2024. The department has moved to quarterly PACAP submissions to assure that changes are caught timely. The department now sets the effective date of amended cost allocation plans to be the first day of the calendar quarter following the date of the amendment. Person(s) Responsible for Corrective Measures: Corinne Kyler, Administrator, Montana Department of Public Health and Human Services, Target Date: Completed
ALN: 97.042, 97.047, Corrective Action Plan: Inadequate Support for Federal Reimbursement - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division, has improved and implemented internal control procedures to ensure proper supporting documentation is sufficient a...
ALN: 97.042, 97.047, Corrective Action Plan: Inadequate Support for Federal Reimbursement - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division, has improved and implemented internal control procedures to ensure proper supporting documentation is sufficient at the time of reimbursement and continues to work with the Federal Emergency Management Agency (FEMA) to ensure compliance with grant guidance. The department reviews and updates the current internal control process to ensure sufficient documentation is received and maintained. Person(s) Responsible for Corrective Measures: Delila Bruno, Administrator, Montana Department of Military Affairs, Target Date: Completed
View Audit 317490 Questioned Costs: $1
ALN: 17.225, Corrective Action Plan: Inaccurate Federal Reporting - UI - DLI - Since the new Unemployment Insurance system launched (MUSE), the Montana Department of Labor and Industry has worked with its system vendor (FAST) to generate additional system reports, which are used to reconcile fisca...
ALN: 17.225, Corrective Action Plan: Inaccurate Federal Reporting - UI - DLI - Since the new Unemployment Insurance system launched (MUSE), the Montana Department of Labor and Industry has worked with its system vendor (FAST) to generate additional system reports, which are used to reconcile fiscal activity. The department has also procured the services of a vendor who will complete a reporting accuracy and efficiency assessment of the Unemployment Insurance program. The department has reconciled accounts and is working to document new processes. The department is also currently reviewing and, if necessary, revising reports. Person(s) Responsible for Corrective Measures: Jay Phillips, Administrator, Montana Department of Labor and Industry, Target Date: 12/31/2024
ALN: 84.010, Corrective Action Plan: Unallowed Indirect Cost Recovery - Title I - OPI - The Centralized Services Division (CSD) Senior Manager of the Montana Office of Public Instruction has implemented corrections such that the office is now in compliance with federal regulations. The Chief Fina...
ALN: 84.010, Corrective Action Plan: Unallowed Indirect Cost Recovery - Title I - OPI - The Centralized Services Division (CSD) Senior Manager of the Montana Office of Public Instruction has implemented corrections such that the office is now in compliance with federal regulations. The Chief Financial Officer and CSD Senior Manager will implement two levels of checks to ensure indirect costs are only recovered for allowable costs. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 08/31/2024
View Audit 317490 Questioned Costs: $1
ALN: 84.010, Corrective Action Plan: Inadequate Tracking of LEA Fiscal Effort - Title I - OPI - The Montana Office of Public Instruction Program Supervisor will create a new process to calculate and monitor Maintenance of Effort in the Title I program. This new process will be outlined and ready t...
ALN: 84.010, Corrective Action Plan: Inadequate Tracking of LEA Fiscal Effort - Title I - OPI - The Montana Office of Public Instruction Program Supervisor will create a new process to calculate and monitor Maintenance of Effort in the Title I program. This new process will be outlined and ready to implement by the end of September 2024. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024
ALN: 84.010, Corrective Action Plan: Inadequate Supporting Documentation - Title 1 - OPI - The Montana Office of Public Instruction management will provide staff training on how to track time and effort functions in the manner required. The training will be performed by the Centralized Services Ma...
ALN: 84.010, Corrective Action Plan: Inadequate Supporting Documentation - Title 1 - OPI - The Montana Office of Public Instruction management will provide staff training on how to track time and effort functions in the manner required. The training will be performed by the Centralized Services Manager and Payroll Manager. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 10/31/2024
View Audit 317490 Questioned Costs: $1
ALN: 84.010, Corrective Action Plan: Inadequate Supporting Documentation - Title I - OPI - The Montana Office of Public Instruction program staff will document specific and detailed purposes for expenditures. Accounting staff will review and ensure that expenditures are in accordance with federal ...
ALN: 84.010, Corrective Action Plan: Inadequate Supporting Documentation - Title I - OPI - The Montana Office of Public Instruction program staff will document specific and detailed purposes for expenditures. Accounting staff will review and ensure that expenditures are in accordance with federal regulations prior to purchase. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024
View Audit 317490 Questioned Costs: $1
ALN: 93.658, Corrective Action Plan: Inadequate Supporting Documentation - Foster Care - DPHHS - The Montana Department of Public Health and Human Services started completing and documenting risk assessments for subrecipients in 2024 and will fully implement in 2025. The department believes the su...
ALN: 93.658, Corrective Action Plan: Inadequate Supporting Documentation - Foster Care - DPHHS - The Montana Department of Public Health and Human Services started completing and documenting risk assessments for subrecipients in 2024 and will fully implement in 2025. The department believes the subrecipients that have the questioned costs are low risk and the department is confident the reimbursements were made for allowable activities. During July 2024, the department requested receipt-level documentation for questioned costs and the reviews have indicated all costs are allowable. Program staff will ensure monitoring procedures align with risk assessments and obtain additional documentation from its subrecipients, as needed. Training was provided on subrecipient risk assessments and the correlation with monitoring procedures in April 2024. Person(s) Responsible for Corrective Measures: Nicole Grossberg, Administrator, Montana Department of Public Health and Human Services, Target Date: 12/31/2024
View Audit 317490 Questioned Costs: $1
ALN: 20.509, Corrective Action Plan: Noncompliance with Federal Procurement Requirements - MDT - The Montana Department of Transportation has hired new leadership for the Transit Section, who are actively working with the Federal Transit Administration (FTA) and the subrecipients to formalize proc...
ALN: 20.509, Corrective Action Plan: Noncompliance with Federal Procurement Requirements - MDT - The Montana Department of Transportation has hired new leadership for the Transit Section, who are actively working with the Federal Transit Administration (FTA) and the subrecipients to formalize procedures, document oversight measures, and correct the deficiencies. Person(s) Responsible for Corrective Measures: Rob Stapley, Administrator, Montana Department of Transportation, Target Date: 06/30/2025
View Audit 317490 Questioned Costs: $1
ALN: 93.323, Corrective Action Plan: Inadequate Supporting Documentation - ELC - DPHHS - The Montana Department of Public Health and Human Services is in the process of collecting additional documentation for the Epidemiology and Laboratory Capacity for Infectious Diseases program from our subreci...
ALN: 93.323, Corrective Action Plan: Inadequate Supporting Documentation - ELC - DPHHS - The Montana Department of Public Health and Human Services is in the process of collecting additional documentation for the Epidemiology and Laboratory Capacity for Infectious Diseases program from our subrecipients to support allowable costs. The department will continue to enhance its internal controls and documentation related to its review process. Person(s) Responsible for Corrective Measures: David Gerard, Executive Director, Montana Department of Public Health and Human Services, Target Date: 12/31/2024
View Audit 317490 Questioned Costs: $1
ALN: 84.425, 84.425D, 84.425U, Corrective Action Plan: Noncompliant FFATA Reports - ESSER - OPI - The Montana Office of Public Instruction will implement a process to reconcile the data between the Federal Funding Accounting and Transparency Act (FFATA) Subaward Reporting System (FSRS) and the USA...
ALN: 84.425, 84.425D, 84.425U, Corrective Action Plan: Noncompliant FFATA Reports - ESSER - OPI - The Montana Office of Public Instruction will implement a process to reconcile the data between the Federal Funding Accounting and Transparency Act (FFATA) Subaward Reporting System (FSRS) and the USASpending system monthly. This finding was based on the federal system not functioning as expected. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024
ALN: 84.425, 84.425D, 84.425U, Corrective Action Plan: Inadequate Support for Federal Reimbursement - ESSER - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will review cash requests and determine if the subrecipient grant expenditures comply with the Elementary and...
ALN: 84.425, 84.425D, 84.425U, Corrective Action Plan: Inadequate Support for Federal Reimbursement - ESSER - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will review cash requests and determine if the subrecipient grant expenditures comply with the Elementary and Secondary School Emergency Relief Fund (ESSER) requirements and ensure costs are related to the pandemic, reasonable and necessary. Additional documentation will be requested of the subrecipient as needed. The Internal Control Auditor will also monitor subrecipient compliance with construction and capital expenditures including wage certifications for construction projects. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024
View Audit 317490 Questioned Costs: $1
ALN: 84.425, 84.425D, 84.425U, Corrective Action Plan: Inaccurate Federal Reporting - ESSER - OPI - The Montana Office of Public Instruction will update current data collection tools for the Elementary and Secondary School Emergency Relief Fund (ESSER) to validate data within a range. Validation c...
ALN: 84.425, 84.425D, 84.425U, Corrective Action Plan: Inaccurate Federal Reporting - ESSER - OPI - The Montana Office of Public Instruction will update current data collection tools for the Elementary and Secondary School Emergency Relief Fund (ESSER) to validate data within a range. Validation criteria, including but not limited to data range, type, and values, will be applied to data collection template used for upcoming years of the grant. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024
ALN: 21.027, Corrective Action Plan: Inadequate Subrecipient Monitoring - ARPA - DNRC - The Montana Department of Natural Resources and Conservation partially concurs with finding 2023-015 because it disagrees with the interpretation that subrecipient monitoring must occur within a specified time ...
ALN: 21.027, Corrective Action Plan: Inadequate Subrecipient Monitoring - ARPA - DNRC - The Montana Department of Natural Resources and Conservation partially concurs with finding 2023-015 because it disagrees with the interpretation that subrecipient monitoring must occur within a specified time period and believes controls were in place during the audit period. Additionally, because the department's policy is to assign every subrecipient the same risk level until an assessment is completed, it believes it is following subrecipient monitoring requirements. As such, the department will continue to evaluate risk through a subrecipient survey and designate any subrecipient as medium risk if a survey is not completed and returned. The department has enhanced related internal controls by noting in its Risk Assessment and Subrecipient Monitoring Guidance that the agency may withhold reimbursement payments if a subrecipient fails to complete a risk survey. Additionally, the DNRC continues to perform subrecipient monitoring requirements, including verifying compliance with the Single Audit Act.  The agency has enhanced related internal controls by adding a process to review the Montana Department of Administration’s Local Government Audit Findings Report and requesting corrective actions from noncompliant subrecipients. Person(s) Responsible for Corrective Measures: Meaghan Bjerke, Chief Financial Officer, Montana Department of Natural Resources and Conservation, Target Date: Completed
ALN: 84.371, Corrective Action Plan: Noncompliant Federal Reporting - Literacy- OPI - The Montana Office of Public Instruction grant staff and Literacy Program Instructional Coordinator will document reports and expenses in a single file to reduce duplication and to confirm expenditures are proper...
ALN: 84.371, Corrective Action Plan: Noncompliant Federal Reporting - Literacy- OPI - The Montana Office of Public Instruction grant staff and Literacy Program Instructional Coordinator will document reports and expenses in a single file to reduce duplication and to confirm expenditures are properly recorded. The reports will be gathered and reviewed quarterly. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024
ALN: 84.371, Corrective Action Plan: Noncompliant Eligibility Determinations - Literacy - OPI - The Montana Office of Public Instruction does not concur with finding 2023-041. The Office notes that the United States Department of Education approved the application eligibility requirements. Perso...
ALN: 84.371, Corrective Action Plan: Noncompliant Eligibility Determinations - Literacy - OPI - The Montana Office of Public Instruction does not concur with finding 2023-041. The Office notes that the United States Department of Education approved the application eligibility requirements. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: N/A
View Audit 317490 Questioned Costs: $1
ALN: 84.371, Corrective Action Plan: Noncompliant FFATA Reports - Literacy - OPI - The Montana Office of Public Instruction will implement a process to reconcile the data between the Federal Funding Accounting and Transparency Act (FFATA) Subaward Reporting System (FSRS) and the USASpending system...
ALN: 84.371, Corrective Action Plan: Noncompliant FFATA Reports - Literacy - OPI - The Montana Office of Public Instruction will implement a process to reconcile the data between the Federal Funding Accounting and Transparency Act (FFATA) Subaward Reporting System (FSRS) and the USASpending system monthly. This finding was based on the federal system not functioning as expected. This reconciliation process will be completed monthly. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024
ALN: 84.371, Corrective Action Plan: Inadequate Support for Federal Reimbursement - Literacy - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will review cash requests and determine if the subrecipient grant expenditures comply with federal program requirements. Add...
ALN: 84.371, Corrective Action Plan: Inadequate Support for Federal Reimbursement - Literacy - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will review cash requests and determine if the subrecipient grant expenditures comply with federal program requirements. Additional documentation will be requested of the subrecipient as needed. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024
View Audit 317490 Questioned Costs: $1
ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 93.264, 93.364, 93.925, Corrective Action Plan: Internal Controls and Compliance - COA - The Montana State University (MSU) plans to take action as follows: MSU-Bozeman has complied since the 2022-23 academic year as indicated in the finding. No furthe...
ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 93.264, 93.364, 93.925, Corrective Action Plan: Internal Controls and Compliance - COA - The Montana State University (MSU) plans to take action as follows: MSU-Bozeman has complied since the 2022-23 academic year as indicated in the finding. No further action is needed. MSU-Billings requires a second review of the Cost of Attendance (COA) calculation and additional documentation before finalizing and creation in it accounting system. For the 2025-26 year, MSU-Billings is implementing the inclusion of a third reviewer within the Financial Aid office to review COA calculations before finalization. MSU Northern put into place internal controls over COA preparation for the 2023-24 award year. The university will have a review sheet that will be signed off by a Student Accounts representative, a member of the Executive Team, and the Financial Aid Director. After the signatures are in place, a copy will be sent to the Chancellor’s Office for final review. Records will be retained for seven years under approved record retention guidelines. Great Falls College-MSU has adjusted the Books and Supply and Other Living Expense components of its COA calculations. The adjustment for Other Living Expense was implemented for the 2023-24 school year, and the Books and Supplies adjustment has been implemented for 2024-25. Great Falls College-MSU has complied with the review of the COA by others not involved in creating the COA since the 2022-23 academic year as indicated in the finding. No further action is needed for this portion of the finding. Person(s) Responsible for Corrective Measures: James Broscheit, Director, Financial Aid Services, Montana State University - Bozeman Justin Beach, Director, Financial Aid and Scholarships, Montana State University - Billings Lourdes Caven, Director, Financial Aid, Montana State University - Northern Leah Habel, Director, Financial Aid, Great Falls College - MSU, Target Date: 12/31/2024
ALN: 84.027, 84.173, Corrective Action Plan: Inadequate Controls and Documentation - State Maintenance of Effort - OPI - The Montana Office of Public Instruction has implemented internal controls for this process. In the 2024 school year, the OPI had multiple reviews on these allocations, includi...
ALN: 84.027, 84.173, Corrective Action Plan: Inadequate Controls and Documentation - State Maintenance of Effort - OPI - The Montana Office of Public Instruction has implemented internal controls for this process. In the 2024 school year, the OPI had multiple reviews on these allocations, including by the Office of Special Education Programs (OSEP) and a funded national technical assistance center, the Center for Individuals with Disabilities Education Act (IDEA) Fiscal Reporting (CIFR). For the 2025/2026 school year, the Data Operations team will complete the special education allocations and submit the allocations to the IDEA Fiscal Manager for review. The IDEA Fiscal Manager will complete the ten percent increase or decrease in overall validated allocations and submit to the Special Education Director for review and sign off. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 08/30/2024
ALN: 84.027, 84.173, Corrective Action Plan: Special Education Allocation Errors - OPI - The Montana Office of Public Instruction is implementing a new software application for allocations. Until the application is in place, the current Excel allocation spreadsheet is being reviewed by program and...
ALN: 84.027, 84.173, Corrective Action Plan: Special Education Allocation Errors - OPI - The Montana Office of Public Instruction is implementing a new software application for allocations. Until the application is in place, the current Excel allocation spreadsheet is being reviewed by program and financial unit staff, who will confirm the accuracy of the data and formulas. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 07/01/2025
ALN: 10.553, 10.555, 10.559, 10.582, Corrective Action Plan: Noncompliant FFATA Reports - Nutrition - OPI - The values were being duplicated due to an error in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The Office of Public Instruction has reached out...
ALN: 10.553, 10.555, 10.559, 10.582, Corrective Action Plan: Noncompliant FFATA Reports - Nutrition - OPI - The values were being duplicated due to an error in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The Office of Public Instruction has reached out to its federal partners who are correcting their system to allow the office to report monthly without duplicating the reported values. The office will then begin reporting monthly as required. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 10/31/2024
Finding 481445 (2023-002)
Significant Deficiency 2023
Finding No. 2023 - 002 Internal Controls Over Allowable Cost Principles Recommendations: We recommend that management implements a comprehensive plan to ensure that all transactions receive proper approval after a thorough review of each transaction Views of Responsible Officials and Planned Corre...
Finding No. 2023 - 002 Internal Controls Over Allowable Cost Principles Recommendations: We recommend that management implements a comprehensive plan to ensure that all transactions receive proper approval after a thorough review of each transaction Views of Responsible Officials and Planned Corrective Actions: We agree with the auditors' comments, and the following actions will be taken to improve the situation. We have now improved our internal process for proper approval from the appropriate level of management. We have put into place an internal process that should eliminate this oversight in the future. We also are in the process of updating our financial policies to be up to date.
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