Corrective Action Plans

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Inadequate Controls Over Indirect Cost Rate Proposals - HPC - MDT - The Montana Department of Transportation has updated its procedures and checklist to ensure required submittals are received on time. These updates were in effect for the 2026 rate. Responsible Party - Kimberly Doherty, Accounting S...
Inadequate Controls Over Indirect Cost Rate Proposals - HPC - MDT - The Montana Department of Transportation has updated its procedures and checklist to ensure required submittals are received on time. These updates were in effect for the 2026 rate. Responsible Party - Kimberly Doherty, Accounting Systems Supervisor, Montana Department of Transportation Dustin Rouse, Chief Engineer, Montana Department of Transportation Target Implementation Date - 12/31/2026
Noncompliant FFATA Reports - ELC- DPHHS - The Montana Department of Public Health and Human Services partially concurs. The department agrees that internal control deficiencies existed in its subaward reporting processes under the Federal Funding Accountability and Transparency Act (FFATA) during fi...
Noncompliant FFATA Reports - ELC- DPHHS - The Montana Department of Public Health and Human Services partially concurs. The department agrees that internal control deficiencies existed in its subaward reporting processes under the Federal Funding Accountability and Transparency Act (FFATA) during fiscal years 2024 and 2025, and that instances of noncompliance occurred. The department does not concur with the quantified extent of the exceptions, including report counts and reporting figures. The department has been unable to replicate the amounts noted and did not receive sufficient detail, as outlined in 2 CFR 200.516(b), to fully understand the specific errors identified. In response to a prior audit recommendation, the department implemented corrective actions to strengthen its internal controls and review processes. These actions included enhanced oversight and the identification and correction of duplicate and inaccurate records. Many of these duplication issues originated from data quality challenges within the former federal reporting system. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 7/1/2025
Noncompliant Annual Reporting Controls - ESSER - OPI - The Montana Office of Public Instruction concurs with the finding. The grant is closed, and the temporary grant-funded staff are no longer with the agency. Moving forward, new grant managers will receive clearer direction on the agency’s interna...
Noncompliant Annual Reporting Controls - ESSER - OPI - The Montana Office of Public Instruction concurs with the finding. The grant is closed, and the temporary grant-funded staff are no longer with the agency. Moving forward, new grant managers will receive clearer direction on the agency’s internal controls. Responsible Party - April Grady, Chief Financial Officer, Montana Office of Public Instruction Target Implementation Date - 12/31/2026
Noncompliant FFATA Reports - ESSER - OPI - The Montana Office of Public Instruction concurs with this finding. This grant is closed. For all future reporting under the Federal Funding Accountability and Transparency Act, the Office will update internal guidance to align with federal regulations and ...
Noncompliant FFATA Reports - ESSER - OPI - The Montana Office of Public Instruction concurs with this finding. This grant is closed. For all future reporting under the Federal Funding Accountability and Transparency Act, the Office will update internal guidance to align with federal regulations and federal oversight requirements. The Office will ensure that required documentation is maintained and that reconciliations verify values in USAspending and SAM. Responsible Party - April Grady, Chief Financial Officer, Montana Office of Public Instruction Target Implementation Date - 12/31/2026
Deficient FFATA Controls - Disaster Grants - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division concurs with the finding. The division has implemented changes in response to prior audit finding 2023-073. When federal reporting systems were updated in March 202...
Deficient FFATA Controls - Disaster Grants - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division concurs with the finding. The division has implemented changes in response to prior audit finding 2023-073. When federal reporting systems were updated in March 2025, the division adjusted its internal processes to align with the System for Award Management (SAM) and trained additional staff to reduce late and inaccurate reporting. Corrective actions have been implemented, and the required appendix is currently under review for approval. Responsible Party - Janae Brower, Chief Financial Officer, Montana Department of Military Affairs Target Implementation Date - 10/31/2026
Untimely Eligibility Determinations - CHIP - Medicaid - DPHHS - The Montana Department of Public Health and Human Services prioritized safeguarding continuous coverage for eligible Montanans during the unwinding period while working to minimize delays for new applicants. No questioned costs were ide...
Untimely Eligibility Determinations - CHIP - Medicaid - DPHHS - The Montana Department of Public Health and Human Services prioritized safeguarding continuous coverage for eligible Montanans during the unwinding period while working to minimize delays for new applicants. No questioned costs were identified in connection with this finding, underscoring that the issue was related to processing timeliness rather than improper payments. To ensure timely eligibility determinations going forward, the department implemented case-based processing in May 2026 that prioritizes cases based on aging and processing timelines, along with business processes to communicate with clients regarding necessary documentation for eligibility determinations. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 5/15/2026
Inadequate Internal Controls Over Certified Payrolls - AIP - DOA - The Montana Department of Administration partially concurs with the finding. While the department oversees construction activities, it has consistently informed agencies that they retain responsibility for grant administration and fe...
Inadequate Internal Controls Over Certified Payrolls - AIP - DOA - The Montana Department of Administration partially concurs with the finding. While the department oversees construction activities, it has consistently informed agencies that they retain responsibility for grant administration and federal reporting for grants awarded directly to them. Each agency is responsible for notifying the Department of all applicable grant requirements, guidance, and restrictions. In this instance, the department understood that the Montana Department of Transportation approved invoices reflecting the federal and non-federal funding split only after receiving the contractor’s Statement of Compliance for all pay periods included in the invoicing period. Due to limited time to respond to the audit finding, the department was unable to confirm with its contracted engineering firm the specific dates the certified payrolls were received and verified. To strengthen future compliance, the department will include language in project memoranda of understanding assigning responsibility for federal wage-rate compliance and record keeping to the agency that received the federal grant. The department will also implement internal controls requiring agencies to confirm that certified payroll requirements have been verified before payments are processed. Responsible Party - Russell Katherman, Administrator of Architecture and Engineering , Montana Long Range Building, Montana Department of Administration Target Implementation Date - 12/31/2026
Inaccurate Federal Reporting - AIP - MDT - The Montana Department of Transportation will update its procedures and add a secondary review process for the 2026 report submission. The procedures will also be revised to clarify the analysis and reporting of payments and revenues to ensure compliance. R...
Inaccurate Federal Reporting - AIP - MDT - The Montana Department of Transportation will update its procedures and add a secondary review process for the 2026 report submission. The procedures will also be revised to clarify the analysis and reporting of payments and revenues to ensure compliance. Responsible Party - Kimberly Doherty, Accounting Systems Supervisor, Montana Department of Transportation Target Implementation Date - 12/31/2026
Inaccurate Subsidy Payments - Adoption Assistance - DPHHS - The Montana Department of Public Health and Human Services agrees that its prior method for tracking subsidy rate changes was manual and was not sufficient to ensure all scheduled rate changes were applied. The practice of including multipl...
Inaccurate Subsidy Payments - Adoption Assistance - DPHHS - The Montana Department of Public Health and Human Services agrees that its prior method for tracking subsidy rate changes was manual and was not sufficient to ensure all scheduled rate changes were applied. The practice of including multiple rates in adoption subsidy agreements was discontinued in 2023. When the error was identified, the department conducted a full review of the affected activity to determine the scope of the issue, identified additional errors, and reported those errors to the auditors. The department corrected all payment errors, repaid the affected federal funds, and implemented tracking controls over the remaining scheduled subsidy rate changes. The department completed this corrective action in March 2026. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 3/20/2026
Noncompliant FFATA - Innovation Waivers - SAO - The Montana State Auditor’s Office concurs with the finding. The Office has provided additional training to the team responsible for administering the State Innovation Waiver grant. The Office has also strengthened its procedures for monitoring award n...
Noncompliant FFATA - Innovation Waivers - SAO - The Montana State Auditor’s Office concurs with the finding. The Office has provided additional training to the team responsible for administering the State Innovation Waiver grant. The Office has also strengthened its procedures for monitoring award notices to ensure that reports required under the Federal Funding Accountability and Transparency Act are submitted no later than the end of the month following the month in which an obligation is made. Responsible Party - Amber Long-Thorvilson, Chief Financial Officer, Montana State Auditor's Office Target Implementation Date - 9/1/2026
Inaccurate Enrollment Reporting - SFA - MSU - The Montana State University - Bozeman concurs. The audit identified a gap related to unofficial withdrawals. The Office of the Registrar has developed and is implementing a procedure to capture enrollment reporting for unofficial withdrawals. Responsibl...
Inaccurate Enrollment Reporting - SFA - MSU - The Montana State University - Bozeman concurs. The audit identified a gap related to unofficial withdrawals. The Office of the Registrar has developed and is implementing a procedure to capture enrollment reporting for unofficial withdrawals. Responsible Party - Antoni Campeau, Registrar, Montana State University - Bozeman Target Implementation Date - 9/30/2026
Inaccurate FISAP Reporting - SFA - MSU - The Montana State University – Bozeman partially concurs. The University concurs that additional efforts can be made to ensure data elements are reported accurately. The University has operated with transparency regarding known challenges in validating the FI...
Inaccurate FISAP Reporting - SFA - MSU - The Montana State University – Bozeman partially concurs. The University concurs that additional efforts can be made to ensure data elements are reported accurately. The University has operated with transparency regarding known challenges in validating the FISAP report with the Federal Student Aid office for the Federal Perkins Loan program dating back to 2019. Reporting for the Perkins Loan, which has been discontinued, now focuses on repayment activity, and the December cash‑on‑hand update is accurate for the distribution of asset calculation. The Montana State University – Billings acknowledges that tuition and fee amounts reported on FISAP Part II, Section E, Lines 22a and 22b for award years 2022-23 and 2023-24 were based on estimates derived from undergraduate and graduate enrollment percentages rather than actual tuition and fee assessments as required by FISAP instructions. To correct this issue, the University will discontinue the use of formulated allocations and implement a process that uses actual tuition and mandatory fee assessment data for students reported in FISAP Part II, Section D. Financial Aid will work with Financial Services, Institutional Research and Business Services to develop a report that identifies actual assessed tuition and fees, net of applicable refunds, and separately reports undergraduate and graduate amounts. To prevent recurrence, the University will establish an independent review of the tuition and fee calculations before each FISAP submission. The review will verify that the reported amounts are based on actual student charges, properly classified by student level, and consistent with FISAP reporting requirements. These actions will ensure future FISAP submissions comply with federal reporting instructions and accurately reflect actual tuition and fee assessments for the reported student population. Responsible Party - James Broscheit, Director of Financial Aid, Montana State University - Bozeman Justin Beach, Director of Financial Aid & Scholarships, Montana State University - Billings Target Implementation Date - 10/31/2026
Noncompliant Excess Cash Management Controls - SFA - MSU - The Montana State University - Bozeman concurs. Because this issue was identified in the previous audit, the University implemented corrective action at the conclusion of that audit to prevent excess cash. The University does not expect this...
Noncompliant Excess Cash Management Controls - SFA - MSU - The Montana State University - Bozeman concurs. Because this issue was identified in the previous audit, the University implemented corrective action at the conclusion of that audit to prevent excess cash. The University does not expect this to be an issue in future audits. The Montana State University - Northern concurs. The University added a new internal control process in fiscal year 2025. Staff now receive a daily cash balance report for federal student financial aid funds that is automatically emailed to Business Services personnel. This process allows staff to monitor the balance and issue refunds as needed. The University believes this process will be effective in detecting and preventing noncompliance going forward. The Great Falls College concurs. The College will continue the controls established in July 2024, which have resulted in zero instances of excess cash since implementation. Responsible Party - James Broscheit, Director of Financial Aid, Montana State University - Bozeman Chris Wendland, Controller, Montana State University - Northern Carmen Roberts, Executive Director of Finance and Administration, Great Falls College – Montana State University Target Implementation Date - 1/31/2025
Noncompliant Return of Uncashed Title IV Funds - SFA - MSU - The Montana State University - Bozeman concurs with the finding. A process has now been implemented for Higher Education Act loans in addition to Parent Loans for Undergraduate Students. This process has been formally documented, and the U...
Noncompliant Return of Uncashed Title IV Funds - SFA - MSU - The Montana State University - Bozeman concurs with the finding. A process has now been implemented for Higher Education Act loans in addition to Parent Loans for Undergraduate Students. This process has been formally documented, and the University will continue to provide cross-training on these procedures. Responsible Party - Ryan Christensen, Director of Student Accounts, Montana State University - Bozeman Target Implementation Date - 8/31/2026
Noncompliant Incentive Compensation Controls - SFA - MSU - The Montana State University - Bozeman concurs with the finding. Since approximately 2023, language has been included on the lump-sum bonus form that prohibits any bonus for classified staff related to the recruitment or admission of student...
Noncompliant Incentive Compensation Controls - SFA - MSU - The Montana State University - Bozeman concurs with the finding. Since approximately 2023, language has been included on the lump-sum bonus form that prohibits any bonus for classified staff related to the recruitment or admission of students. Any bonus request submitted to the Office of the Commissioner of Higher Education for contract employees is reviewed and approved by the University's Compensation Advisory Council, which also reviewed these federal regulations. In December 2024, the Montana University System Staff Compensation Plan was updated to explicitly exclude such payments. Responsible Party - Jeannette Grey Gilbert, Chief Human Resources Officer, Montana State University - Bozeman Target Implementation Date - 12/31/2024
Noncompliant GLBA Oversight - SFA - MSU - The Montana State University - Bozeman concurs. The University has hired a Chief Information Security Officer, who is designated as the Qualified Individual as part of the University’s Information Security Plan. Responsible Party - John Williams, Chief Infor...
Noncompliant GLBA Oversight - SFA - MSU - The Montana State University - Bozeman concurs. The University has hired a Chief Information Security Officer, who is designated as the Qualified Individual as part of the University’s Information Security Plan. Responsible Party - John Williams, Chief Information Security Officer, Montana State University - Bozeman Target Implementation Date - 2/28/2025
Inaccurate COA Calculations - SFA - UM - The University of Montana – Missoula conducted additional review and provided supplemental documentation and clarification for the remaining sampled student records; however, one exception could not be fully resolved. The University is committed to strengthen...
Inaccurate COA Calculations - SFA - UM - The University of Montana – Missoula conducted additional review and provided supplemental documentation and clarification for the remaining sampled student records; however, one exception could not be fully resolved. The University is committed to strengthening its documentation, retention, and review processes to ensure that support for cost-of-attendance calculations and adjustments is consistently maintained, documented, and adequately substantiated going forward. Responsible Party - Morgan Hahn, Interim Financial Aid Director, University of Montana - Missoula Target Implementation Date - 12/31/2026
Inaccurate Enrollment Reporting - SFA - UM - The University of Montana - Missoula partially concurs because the University agrees that accurate and timely enrollment reporting is essential to compliance with federal requirements and recognizes the importance of maintaining effective controls over th...
Inaccurate Enrollment Reporting - SFA - UM - The University of Montana - Missoula partially concurs because the University agrees that accurate and timely enrollment reporting is essential to compliance with federal requirements and recognizes the importance of maintaining effective controls over the enrollment reporting process. However, the University is continuing to review the circumstances underlying this finding, including the interaction between institutional records, third-party reporting processes, and federal systems, and has not yet completed its assessment of all contributing factors. The University will enhance monitoring, reconciliation, and verification procedures to support accurate and timely reporting of enrollment information. Responsible Party - Morgan Hahn, Interim Financial Aid Director, University of Montana - Missoula Target Implementation Date - 3/31/2027
Inaccurate Federal Aid Return Calculations - SFA - UM - The University of Montana - Missoula will continue strengthening controls over Return of Title IV calculations through increased coordination among involved offices, enhanced review of academic calendar and system data, and additional oversight...
Inaccurate Federal Aid Return Calculations - SFA - UM - The University of Montana - Missoula will continue strengthening controls over Return of Title IV calculations through increased coordination among involved offices, enhanced review of academic calendar and system data, and additional oversight of withdrawal-related processes. The University is committed to continuous improvement and to ensuring accurate calculations going forward. Responsible Party - Morgan Hahn, Interim Financial Aid Director, University of Montana - Missoula Target Implementation Date - 1/31/2027
Inadequate FISAP Reporting Controls - SFA - UM - The Montana Technological University will establish a centralized repository and require supporting documentation for all key FISAP report line items to be retained in that location. The Helena College will establish automated procedures to reduce man...
Inadequate FISAP Reporting Controls - SFA - UM - The Montana Technological University will establish a centralized repository and require supporting documentation for all key FISAP report line items to be retained in that location. The Helena College will establish automated procedures to reduce manual processes, as well as a centralized repository for supporting documentation pertaining to all FISAP report line items. The University of Montana - Western will establish a procedure for documenting the required tuition and fees line items that must be reported on the FISAP and that correspond to the student population reported in Section D of the FISAP. The University of Montana - Missoula will strengthen FISAP reporting controls by formalizing procedures, improving documentation retention, centralizing supporting records, and implementing additional review of reported data before submission. The university is also exploring improvements to reporting and data-management processes to support accurate and reliable reporting. Responsible Party - Carleen Cassidy, Director of Finance and Budget, Montana Technological University Valerie Curtin, Executive Director of Compliance & Financial Aid, Helena College of Technology - University of Montana Louise Driver, Financial Aid Director, University of Montana - Western Morgan Hahn, Interim Financial Aid Director, University of Montana - Missoula Target Implementation Date - 9/30/2026
Noncompliant Title IV Disbursement Notification Controls - SFA - UM - The University of Montana - Missoula has implemented changes for the 2026–2027 award year to ensure required Title IV disbursement notifications are generated, reviewed, and retained. The University will maintain documented proced...
Noncompliant Title IV Disbursement Notification Controls - SFA - UM - The University of Montana - Missoula has implemented changes for the 2026–2027 award year to ensure required Title IV disbursement notifications are generated, reviewed, and retained. The University will maintain documented procedures and periodic oversight to support ongoing compliance. Responsible Party - Morgan Hahn, Interim Financial Aid Director, University of Montana - Missoula Target Implementation Date - 10/1/2026
Noncompliant Direct Loan Reconciliation Controls - SFA - UM - The University of Montana - Missoula will strengthen reconciliation procedures by assigning responsibility to designated staff, requiring documented supervisory review, retaining supporting reconciliation documentation, and monitoring tim...
Noncompliant Direct Loan Reconciliation Controls - SFA - UM - The University of Montana - Missoula will strengthen reconciliation procedures by assigning responsibility to designated staff, requiring documented supervisory review, retaining supporting reconciliation documentation, and monitoring timely and consistent completion of reconciliations. Management will conduct periodic oversight to ensure reconciliation requirements are completed in accordance with federal regulations and institutional procedures. Responsible Party - Morgan Hahn, Interim Financial Aid Director, University of Montana - Missoula Target Implementation Date - 12/31/2026
Noncompliant Title IV Disbursement Controls - SFA - UM - The University of Montana - Missoula has strengthened fraud prevention and detection efforts through enhanced identity verification procedures, targeted review of higher-risk populations, ongoing monitoring of suspicious activity, and increase...
Noncompliant Title IV Disbursement Controls - SFA - UM - The University of Montana - Missoula has strengthened fraud prevention and detection efforts through enhanced identity verification procedures, targeted review of higher-risk populations, ongoing monitoring of suspicious activity, and increased collaboration across university departments. The university will continue to evaluate emerging fraud trends, federal guidance, and institutional controls to reduce the risk of future improper disbursements. Responsible Party - Morgan Hahn, Interim Financial Aid Director, University of Montana - Missoula Target Implementation Date - 6/30/2027
Noncompliant Return of Uncashed Title IV Funds - SFA - UM - The University of Montana - Missoula will implement procedures to identify uncashed Title IV credit balance checks, monitor applicable return deadlines, and return funds to the U.S. Department of Education when required. The university will...
Noncompliant Return of Uncashed Title IV Funds - SFA - UM - The University of Montana - Missoula will implement procedures to identify uncashed Title IV credit balance checks, monitor applicable return deadlines, and return funds to the U.S. Department of Education when required. The university will implement written procedures, staff training, and periodic reviews to support compliance. Responsible Party - Morgan Hahn, Interim Financial Aid Director, University of Montana - Missoula Target Implementation Date - 6/30/2027
Noncompliant Incentive Compensation Controls - SFA - UM - The University of Montana - Missoula will strengthen enforcement of existing procedures by implementing a formal incentive compensation policy that prohibits incentive compensation based on enrollment or financial aid outcomes and helps ensur...
Noncompliant Incentive Compensation Controls - SFA - UM - The University of Montana - Missoula will strengthen enforcement of existing procedures by implementing a formal incentive compensation policy that prohibits incentive compensation based on enrollment or financial aid outcomes and helps ensure compliance with federal regulations. Responsible Party - Jay Stephens, Vice President for People and Culture, University of Montana - Missoula Target Implementation Date - 3/8/2026
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