Corrective Action Plans

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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
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
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 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 GLBA Information Security Controls - SFA - UM - The University of Montana - Missoula has enhanced its annual review process to include verification that each federally required information security program element is supported by a current and formally approved policy or standard. The r...
Noncompliant GLBA Information Security Controls - SFA - UM - The University of Montana - Missoula has enhanced its annual review process to include verification that each federally required information security program element is supported by a current and formally approved policy or standard. The revised review process will also identify and document any required element that lacks supporting policy documentation so corrective action can be taken in a timely manner. The university implemented standards addressing encryption of customer information, multifactor authentication, and logging and monitoring of user activity on January 8, 2024, February 27, 2024, and April 4, 2024, respectively. These standards remain in effect and are reviewed annually as part of the university’s information security program review process to ensure continued compliance with federal requirements and to address any future regulatory changes. Responsible Party - Jonathan Neff, Chief Information Security Officer, University of Montana - Missoula Target Implementation Date - 9/30/2026
Inadequate Assurance Over Controls at Service Organization - SNAP - DPHHS - The Montana Department of Public Health and Human Services does not concur. The department agrees that 7 CFR 274.8(b)(3)(i) requires the state agency to ensure that its electronic benefit transfer system includes storage and...
Inadequate Assurance Over Controls at Service Organization - SNAP - DPHHS - The Montana Department of Public Health and Human Services does not concur. The department agrees that 7 CFR 274.8(b)(3)(i) requires the state agency to ensure that its electronic benefit transfer system includes storage and control measures for blank unissued cards. The department satisfies this requirement through controls operated by its contracted electronic benefit transfer vendor rather than through state‑held card stock. The department does not concur that this control is absent. As provided in 2 CFR 200.511(c), the explanation below describes why corrective action is not required. The department does not issue electronic benefit transfer cards over the counter. All card manufacture, personalization, storage, and mailing occur within the contracted vendor’s centralized issuance environment. No blank unissued cards are held in department offices or accessible to staff or the public. Blank unissued cards contain no benefits, are not associated with a participant account, and cannot be activated without a corresponding record in the electronic benefit transfer system. Their only intrinsic value is the cost of the card stock. The vendor conducts risk assessments and monitors subcontractors responsible for card stock. Independent assurance is provided through the system and Organization Controls (SOC) report, which confirms that these assessments and monitoring controls are fully implemented. Centralized issuance significantly reduces opportunities for unauthorized access, making the risk associated with blank unissued cards very low in Montana. The department also performs reconciliations independent of benefit issuance and redemption. Eligibility determinations in the departments eligibility system (CHIMES) are reconciled to the vendor’s records; retailer transactions are reconciled to the banking system; recipient transactions are reconciled to redeemed benefits; and funds drawn from the federal treasury are reconciled to the federal draw system. The department’s card monitoring controls address replaced, returned, and excessive card requests. These enhanced controls align higher‑risk activities with appropriate safeguards and oversight. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - N/A
Inadequate HAPPY System Access Controls - HVC - Commerce - The Montana Department of Commerce began conducting user access reviews during the audit period. The department’s Chief Information Officer updated the Access Control Policy and distributed it to all employees. Staff received training on acc...
Inadequate HAPPY System Access Controls - HVC - Commerce - The Montana Department of Commerce began conducting user access reviews during the audit period. The department’s Chief Information Officer updated the Access Control Policy and distributed it to all employees. Staff received training on access control requirements on May 28, 2026. The department plans to obtain a new vendor to replace the HAPPY system by October 2028. Responsible Party - Ingrid Mallo, Chief Financial Officer, Montana Department of Commerce Target Implementation Date - 10/31/2028
Inadequate Physical Inventory Procedures - Nutrition - OPI - The Montana Office of Public Instruction partially concurs with this finding. The 1,000 cases of beef arrived on June 12 for the next fiscal year, while the physical inventory count occurred on June 3. The order had been entered into MAPS ...
Inadequate Physical Inventory Procedures - Nutrition - OPI - The Montana Office of Public Instruction partially concurs with this finding. The 1,000 cases of beef arrived on June 12 for the next fiscal year, while the physical inventory count occurred on June 3. The order had been entered into MAPS before the count, but the product had not yet arrived at the warehouse. When MAPS reporting was run after June 12, during verification, the beef appeared in the system even though it was not present during the physical count. The product was distributed during the following school year. This discrepancy was due solely to timing between delivery, system entry, and the inventory count. Because of staff turnover, the employee entering inventory into MAPS was not aware that items should only be entered once they are physically received. The invoice was entered before delivery, while inventory was being performed, creating a short‑term difference between the MAPS count and the actual inventory. This was a training issue, and staff have now been instructed on correct inventory procedures. Responsible Party - April Grady, Chief Financial Officer, Montana Office of Public Instruction Target Implementation Date - 12/31/2026
Inadequate Subrecipient Communications - CCDF - DPHHS - The Montana Department of Public Health and Human Services developed a new contract template that includes all required elements and implemented it for state fiscal year 2025 subawards. The Department is following its updated processes. Respons...
Inadequate Subrecipient Communications - CCDF - DPHHS - The Montana Department of Public Health and Human Services developed a new contract template that includes all required elements and implemented it for state fiscal year 2025 subawards. The Department is following its updated processes. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 7/1/2024
Inadequate Monthly Subrecipient Case File Reviews - CCDF - DPHHS - The Montana Department of Public Health and Human Services will further strengthen compliance by enhancing its internal control framework. The Department will refine supervisory review protocols, formalize documentation requirements,...
Inadequate Monthly Subrecipient Case File Reviews - CCDF - DPHHS - The Montana Department of Public Health and Human Services will further strengthen compliance by enhancing its internal control framework. The Department will refine supervisory review protocols, formalize documentation requirements, and improve monitoring procedures to ensure full alignment with State Plan objectives. The department will also review its State Plan and submit an amendment if necessary. These improvements will ensure continued compliance with State Plan requirements. The Department anticipates full implementation of these strengthened processes in early 2027. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 3/26/2027
Finding 2025-008: Material Weakness in Internal Control Over Compliance – Housing Choice Voucher Program Agreement or Disagreement: The Agency agrees with the finding. Planned Corrective Action: The Agency will develop and implement a comprehensive system of written internal controls and compliance ...
Finding 2025-008: Material Weakness in Internal Control Over Compliance – Housing Choice Voucher Program Agreement or Disagreement: The Agency agrees with the finding. Planned Corrective Action: The Agency will develop and implement a comprehensive system of written internal controls and compliance procedures for the Housing Choice Voucher Program. The Agency will also: • Develop standardized tenant-file checklists covering eligibility, income, assets, deductions, citizenship or eligible immigration status, Social Security numbers, EIV documentation, rent reasonableness, inspections, leases, HAP contracts, annual and interim reexaminations, portability, and other applicable requirements. • Require the checklist to be completed and maintained in each participant file. • Establish and document supervisory or quality-control reviews of an appropriate sample of applicant and participant files. • Correct deficiencies identified during supervisory reviews and document the corrective action taken. • Update the Administrative Plan to incorporate applicable HOTMA provisions and current HUD guidance. • Establish procedures for reviewing HUD notices, regulations, handbooks, and other program guidance. • Provide regular training to employees responsible for administering the Voucher program. • Clearly assign program responsibilities and develop written procedures to reduce dependence on the knowledge of individual employees. • Maintain a compliance calendar for recurring program responsibilities and reporting deadlines. • Provide the Board with periodic reports regarding compliance reviews, deficiencies identified, and corrective actions completed. Estimated Completion Date: Checklists and supervisory-review procedures will be implemented by October 31, 2026. Written procedures, policy updates, and initial staff training will be completed by December 31, 2026, with ongoing monitoring thereafter. Responsible Parties: Executive Director, Housing Choice Voucher program staff, designated supervisory staff, and Board of Commissioners.
Housing Voucher Cluster – FALN No. 14.871 & 14.879 – HQS Failed Inspections - N Recommendation: We recommend that the Commission review their abatement procedures to ensure any unit that has not met the HQS standards is properly abated as well as review their procedures for enforcing correction of d...
Housing Voucher Cluster – FALN No. 14.871 & 14.879 – HQS Failed Inspections - N Recommendation: We recommend that the Commission review their abatement procedures to ensure any unit that has not met the HQS standards is properly abated as well as review their procedures for enforcing correction of deficiencies to tenants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HCHC believes that this finding was caused by the previous inspection company failing to properly communicate the results of its inspections. The new inspection companies are required to use the Commission’s Yardi software to schedule, perform and enter results. This will enhance the speed and accuracy of inspection reporting. In addition, the inspection companies are required to provide weekly reports that will be discussed and reviewed with the voucher team. Based on the results of the inspection the voucher team will be able to send abatement letters, warning letters, and/or proposed termination letters to ensure compliance with the inspection and abatement process. Name(s) of the contact person(s) responsible for corrective action: Crystal Gorham, Director of Rental Assistance Planned completion date for corrective action plan: All corrections should be reflected by December 2026.
Housing Voucher Cluster – FALN No. 14.871 & 14.879 – HQS Inspections - N Recommendation: We recommend the Commission review its HQS inspection policies and procedures and discuss these standards with the third-party inspection company that it utilizes for these inspections to ensure all inspections ...
Housing Voucher Cluster – FALN No. 14.871 & 14.879 – HQS Inspections - N Recommendation: We recommend the Commission review its HQS inspection policies and procedures and discuss these standards with the third-party inspection company that it utilizes for these inspections to ensure all inspections are performed timely and that all necessary documentation is maintained for each inspection. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HCHC’s third-part inspection company was not able to meet the terms of its contract or the HCVP requirements, partly due to staff turnover. As a result, HCHC terminated the contract as of the end of June, 2026, and hired two new contractors. HCHC has a third inspection company under contract to fill in when needed. Staff is providing the new contractors with a detailed SOP to ensure a mutual understanding of all necessary inspection actions. HCHC staff will meet with the inspection companies weekly to discuss progress, results and issues that arise during inspections. Name(s) of the contact person(s) responsible for corrective action: Crystal Gorham, Director of Rental Assistance Planned completion date for corrective action plan: in progress all correction should be reflected by December 2026.
Finding 2025 – 004 Internal Controls over Financial Reporting Name of Contact Person: David Rosado, Executive Director Corrective Action: The Council agrees with this finding. The Council has hired a new Finance Director effective January 2, 2025, with the appropriate skills, knowledge, and experien...
Finding 2025 – 004 Internal Controls over Financial Reporting Name of Contact Person: David Rosado, Executive Director Corrective Action: The Council agrees with this finding. The Council has hired a new Finance Director effective January 2, 2025, with the appropriate skills, knowledge, and experience to oversee the Finance Department. The Finance Director has identified and corrected internal control issues. All coding and processing of Aging Expenditures has been updated, and documents complied with State and Federal policies are in place. Completion Date: December 8, 2025
In September 2025, the Cooperative entered into a management agreement with Paramark Real Estate Services to manage the Cooperative. The management company maintains sufficient controls and procedures related to financial reporting and have proper segregation of duties in place to safeguard the asse...
In September 2025, the Cooperative entered into a management agreement with Paramark Real Estate Services to manage the Cooperative. The management company maintains sufficient controls and procedures related to financial reporting and have proper segregation of duties in place to safeguard the assets of the Cooperative.
In Finding 2025-008, it was reported that the Organization did not properly apply sliding fee discounts for certain patients with visits to the Organization during the year ended December 31, 2025. In response to Finding 2025-008, Management recognizes the importance of complying with sliding fee gu...
In Finding 2025-008, it was reported that the Organization did not properly apply sliding fee discounts for certain patients with visits to the Organization during the year ended December 31, 2025. In response to Finding 2025-008, Management recognizes the importance of complying with sliding fee guidelines. The Patient Services Manager has trained all Patient Services Representatives on the sliding fee; performance improvement plans have been developed on employees with errors. Currently the manager has assigned a team to review all sliding fee applications with the goal of 100% reviewed by the end of 2026. Sliding fee applications with errors are returned for correction and communication to the patient. The manager will continue reviewing the sliding fee process in the team's monthly meeting.
In Finding 2025-006, a condition was noted that during the year, the Organization failed to reconcile expenditures prior to drawing federal grant funds. In response to Finding 2025-006, Management recognizes the importance of the requirements to draw federal grant funds only after making qualifying ...
In Finding 2025-006, a condition was noted that during the year, the Organization failed to reconcile expenditures prior to drawing federal grant funds. In response to Finding 2025-006, Management recognizes the importance of the requirements to draw federal grant funds only after making qualifying expenditures. Additionally the policy has been reviewed and FHC has implemented an approval process for grant draw which include: • Ongoing reconciliation spreadsheets are monitored and balanced to Payment Management System monthly. • Draw request is prepared by Interim Chief Financial Officer and approved by the Chief Executive Officer before the draw is implemented. The CEO verifies documentation for the draw prior to approval. • Documentation is maintained that supports the draw and all expenditures.
Management will reconfigure the system to require after-the-fact entry of actual hours worked and to restrict advance entry and approval, reinforce supervisory review procedures to ensure timely and accurate approval of timecards, and provide training to employees and supervisors on federal timekeep...
Management will reconfigure the system to require after-the-fact entry of actual hours worked and to restrict advance entry and approval, reinforce supervisory review procedures to ensure timely and accurate approval of timecards, and provide training to employees and supervisors on federal timekeeping requirements under 2 CFR 200.430. These actions will strengthen internal controls and ensure payroll costs charged to federal awards accurately reflect work performed going forward.
2025-003 Finding – Material Weakness in Internal Controls over Compliance Responsible official: Patti Lawrence, Accounting Manager Context and Cause: The Organization has a documented fiscal policy; however the policy does not include procedures that cover specific compliance attributes associated w...
2025-003 Finding – Material Weakness in Internal Controls over Compliance Responsible official: Patti Lawrence, Accounting Manager Context and Cause: The Organization has a documented fiscal policy; however the policy does not include procedures that cover specific compliance attributes associated with federal award requirements. 2 CFR 200.303 requires the recipient to establish, document, and maintain effective internal control over federal awards. Recommendation: It was recommended the Organization develop, document, and implement policies and procedures that address the recent guidance regarding applicable federal compliance requirements. Corrective Action Planned: The Organization has engaged a CPA firm as a 3rd party CFO service and accounting department. The firm is helping develop written policies over federal award attributes. Implementation date: October 31, 2026
Corrective Action Plan: The Housing Authority concurs with the auditor's recommendation. The outstanding inter-entity balance has been identified as a legacy balance associated with the RAD conversion and the transfer of assets and liabilities to Athens Housing Management, LLC. Management's review a...
Corrective Action Plan: The Housing Authority concurs with the auditor's recommendation. The outstanding inter-entity balance has been identified as a legacy balance associated with the RAD conversion and the transfer of assets and liabilities to Athens Housing Management, LLC. Management's review and reconciliation of the balance are in progress. Before recording any final disposition, the Authority will determine the balance's origin, funding source, supporting documentation, legal obligation, and collectability, including whether federally restricted or RAD/PBRA project funds are involved. The Board of Commissioners may authorize the accounting disposition of the balance, subject to the Authority's governing documents and applicable law; however, a Board vote alone will not be treated as authority to forgive or extinguish a federally restricted or project-level receivable. The Authority will complete the following process: 1. Complete and document the reconciliation and proposed accounting treatment in both entities' records, with management and legal review, and provide the supporting documentation to the Authority's auditor. 2. Determine whether the balance is subject to the RAD closing documents, HAP Contract, RAD Use Agreement, Surplus Cash requirements, or other Federal restrictions. If so, submit the reconciliation, proposed entries, supporting documentation, and draft resolutions to the appropriate HUD Field Office or Multifamily Account Executive and obtain written direction or concurrence, as applicable. 3.Present conditional resolutions to the governing boards of the Housing Authority and Athens Housing Management, LLC, as applicable, authorizing the Chief Executive Officer to record the disposition only after all required HUD approvals or concurrences have been received. 4. Record corresponding entries in both entities, retain the complete reconciliation and approval package, and disclose the final resolution to the auditor. This process is consistent with 2 CFR §§ 200.302 and 200.303, which require accurate, supported financial records, accountability for Federal funds and assets, and documented internal controls. It also recognizes the RAD Notice requirements governing Surplus Cash and related-party advances. Going forward, inter-entity balances will be reconciled monthly, reviewed by management, and any unresolved items will be reported to the Chief Executive Officer as part of the monthly financial review.
Finding 2025-002 Information on the federal program: Subject: Home Investment Partnerships Program – Internal Controls Federal Agency: Department of Housing and Urban Development Federal Program: Home Investment Partnerships Program Assistance Listing Number: 14.239 Pass-Through Entity: N/A - Direct...
Finding 2025-002 Information on the federal program: Subject: Home Investment Partnerships Program – Internal Controls Federal Agency: Department of Housing and Urban Development Federal Program: Home Investment Partnerships Program Assistance Listing Number: 14.239 Pass-Through Entity: N/A - Direct Grant Compliance Requirement: Special Tests and Provisions – Maximum Per Unit Subsidy Audit Findings: Material Weakness Condition: The Consortium did not have a documented review control in place to ensure the per-unit subsidy calculation was prepared and calculated accurately. There was no documented proof of segregation of duties. Context: In a sample of two, the following instances were noted: • For the first selection, the per-unit subsidy information was entered into the HUD system (IDIS) during the project close out. There is no evidence of segregation of duties over the preparation and review of IDIS inputs. • For the second selection, the calculation was prepared by a former employee in 2025 and did not have sign off by the preparer or reviewer. A secondary review with evidence of sign off was performed subsequent to the audit period in 2026. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will implement a system of internal controls to ensure the required per unit subsidy calculations are prepared, reviewed, and maintained. Responsible Party and Timeline for Completion: The Consortium Director (or their designee) and the Federal Grant Administrator are responsible for implementation. The Consortium has implemented additional controls effective September 2026.
FINDING 2025-002 – SLIDING SCALE FEES CPH is implementing more robust review process for information that is input into the billing system. This will include new, simplified forms for patients to complete for the sliding fee scale application and an enhanced review process including review of each a...
FINDING 2025-002 – SLIDING SCALE FEES CPH is implementing more robust review process for information that is input into the billing system. This will include new, simplified forms for patients to complete for the sliding fee scale application and an enhanced review process including review of each application within the first 30 days of initial application. Crystal Wolf, Revenue Cycle Director, will oversee this effort. The implementation of the new forms and the training to correct the finding is scheduled to be completed by December 31, 2026.
Policies and procedures for review of quarterly financial and performance reports will be followed on a consistent basis.
Policies and procedures for review of quarterly financial and performance reports will be followed on a consistent basis.
Policies and procedures for review of payroll will be followed on a consistent basis.
Policies and procedures for review of payroll will be followed on a consistent basis.
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