Corrective Action Plans

Finding 1235666 (2025-085)

Material Weakness 2025

State of Montana

MT

Subrecipient Monitoring Period of Performance § 200.303 § 200.332

Incomplete FAIN Award Amount Disclosures – TANF – DPHHS - The Montana Department of Public Health and Human Services will revise its existing subaward agreements to update the required federal award disclosures, specifically by identifying the obligation amount associated with each Federal Award Ide...

Incomplete FAIN Award Amount Disclosures – TANF – DPHHS - The Montana Department of Public Health and Human Services will revise its existing subaward agreements to update the required federal award disclosures, specifically by identifying the obligation amount associated with each Federal Award Identification Number (FAIN). The department will also include the obligation amount by specific FAIN in all new agreements moving forward. The department plans to fully implement this corrective action in October 2026. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 10/30/2026

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Finding 1235664 (2025-083)

Material Weakness 2025

State of Montana

MT

Subrecipient Monitoring § 200.303

Noncompliant FFATA Reports - TANF - DPHHS - The Montana Department of Public Health and Human Services will revise its existing subaward agreements to update the required federal award disclosures, specifically by identifying the obligation amount associated with each Federal Award Identification Nu...

Noncompliant FFATA Reports - TANF - DPHHS - The Montana Department of Public Health and Human Services will revise its existing subaward agreements to update the required federal award disclosures, specifically by identifying the obligation amount associated with each Federal Award Identification Number (FAIN). The department will also include the obligation amount by specific FAIN in all new agreements going forward. These actions will support and strengthen compliance with reporting requirements under the Federal Funding Accountability and Transparency Act (FFATA). Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 11/30/2026

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Finding 1235637 (2025-089)

Material Weakness 2025

State of Montana

MT

Subrecipient Monitoring § 200.303

Noncompliant FFATA Reports - LIHEAP - 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) durin...

Noncompliant FFATA Reports - LIHEAP - 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 the 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, which have been addressed. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 7/1/2025

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Finding 1235629 (2025-074)

Material Weakness 2025

State of Montana

MT

Subrecipient Monitoring § 200.303

Noncompliant FFATA Reports - Immunization - DPHHS - The Montana Department of Public Health and Human Services partially concurs. The department agrees that internal control deficiencies existed in its Federal Funding Accountability and Transparency Act (FFATA) subaward reporting processes during fi...

Noncompliant FFATA Reports - Immunization - DPHHS - The Montana Department of Public Health and Human Services partially concurs. The department agrees that internal control deficiencies existed in its Federal Funding Accountability and Transparency Act (FFATA) subaward reporting processes during fiscal years 2024 and 2025, and that instances of noncompliance existed. 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 the prior audit recommendation, the department implemented corrective actions that strengthened its internal controls and review processes. These actions included enhanced oversight and the identification and correction of duplicate and inaccurate records. Many of the duplication issues stemmed from data quality challenges within the former federal reporting system, which have been addressed. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 7/1/2025

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Finding 1235628 (2025-073)

Material Weakness 2025

State of Montana

MT

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.333 § 200.403

Noncompliant Fixed-Amount Subawards - Immunization - DPHHS - The Montana Department of Public Health and Human Services does not concur. All subawards, including those referenced in the finding, were explicitly listed in the federally approved budget documents and the Notice of Award (NOA). These ma...

Noncompliant Fixed-Amount Subawards - Immunization - DPHHS - The Montana Department of Public Health and Human Services does not concur. All subawards, including those referenced in the finding, were explicitly listed in the federally approved budget documents and the Notice of Award (NOA). These materials contained the subaward amounts that the auditors questioned and were formally reviewed and approved by the Centers for Disease Control and Prevention (CDC). The approval included the fixed-amount subaward methodology and the department’s planned use of funds. In addition, the CDC conducted a technical review during the same period and identified no findings or compliance issues, including none related to fixed-amount subawards or internal controls. In September 2025, the department consulted program officials at the CDC, who reaffirmed that the approved NOAs and budgets are sufficient evidence of federal approval and compliance. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - N/A

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Finding 1235600 (2025-092)

Material Weakness 2025

State of Montana

MT

Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

Noncompliant Risk Assessments - Foster Care - DPHHS - The Montana Department of Public Health and Human Services implemented a new risk assessment format and policy and procedure in June 2024. The department is following the new process, which was fully implemented in June 2024; the subrecipient ris...

Noncompliant Risk Assessments - Foster Care - DPHHS - The Montana Department of Public Health and Human Services implemented a new risk assessment format and policy and procedure in June 2024. The department is following the new process, which was fully implemented in June 2024; the subrecipient risk assessments cited in the finding were performed before that date. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 7/25/2024

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Finding 1235598 (2025-090)

Material Weakness 2025

State of Montana

MT

Subrecipient Monitoring § 200.303

Noncompliant FFATA Reports - Foster Care - 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) ...

Noncompliant FFATA Reports - Foster Care - 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. When the federal reporting system transitioned to the System for Award Management in state fiscal year 2026, many of those data quality concerns were eliminated. The department corrected most of the duplicated and inaccurate records that migrated from the former system to the new one. The department also enhanced its internal controls and revised its policies and procedures for reporting under FFATA. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 7/1/2025

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Finding 1235578 (2025-034)

Material Weakness 2025

State of Montana

MT

Subrecipient Monitoring § 200.303

Inadequate Subrecipient Communications and Controls - Transit - MDT - The Montana Department of Transportation’s Transit Section has established deadlines to ensure all agreements are fully executed before the start of the period of performance and prior to authorizing any payments. These measures r...

Inadequate Subrecipient Communications and Controls - Transit - MDT - The Montana Department of Transportation’s Transit Section has established deadlines to ensure all agreements are fully executed before the start of the period of performance and prior to authorizing any payments. These measures reinforce clear communication of requirements and support continued compliance with federal regulations. Responsible Party - Kimberly Doherty, Accounting Systems Supervisor, Montana Department of Transportation Target Implementation Date - 12/31/2026

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Finding 1235574 (2025-030)

Material Weakness 2025

State of Montana

MT

Subrecipient Monitoring § 200.303 § 200.332 § 200.521

Inadequate Subrecipient Audit Monitoring - Transit - MDT - The Montana Department of Transportation concurs with the finding. A. The department is strengthening its evaluation of subrecipient Single Audit requirements by integrating external data sources into its verification process. When external ...

Inadequate Subrecipient Audit Monitoring - Transit - MDT - The Montana Department of Transportation concurs with the finding. A. The department is strengthening its evaluation of subrecipient Single Audit requirements by integrating external data sources into its verification process. When external sources do not show audit activity for a subrecipient, the department will request and document confirmation through email to verify audit status. For the state fiscal year 2027 grant cycle, the Transit Section has implemented a process to email each subrecipient to confirm Single Audit eligibility, and beginning in state fiscal year 2028, this certification will be included in the application packet. The department established a subrecipient team prior to this audit to oversee recipients of federal funds, determine Single Audit applicability, and assess whether identified issues warrant additional monitoring. The Global Accountant coordinates these reviews, and new procedures are being introduced to address identified issues and ensure consistent application of federal requirements. B. The Transit Section has instituted an application review tracking sheet beginning in state fiscal year 2027 to ensure fiscal and programmatic components are reviewed by the appropriate staff. This measure improves documentation, accountability, and internal monitoring. C. The department is developing a revised subrecipient risk assessment that incorporates information provided by subrecipients, applies clearer criteria for identifying higher-risk entities, and aligns risk-reducing factors with elements that directly reduce the likelihood of undetected material noncompliance. As part of this effort, the department will establish and document procedures that clearly outline federal requirements for issuing management decisions to ensure they consistently contain all required elements. The revised assessment and associated procedures will be implemented for state fiscal year 2028 applications during the state fiscal year 2027 cycle. Responsible Party - Kimberly Doherty, Accounting Systems Supervisor, Montana Department of Transportation Target Implementation Date - 12/31/2026

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Finding 1235573 (2025-029)

Material Weakness 2025

State of Montana

MT

Subrecipient Monitoring § 200.303

Noncompliance with Subrecipient Monitoring Requirements - Transit - MDT - The Montana Department of Transportation is developing a revised subrecipient risk assessment that incorporates information provided by subrecipients, applies clearer criteria for identifying higher-risk entities, and aligns r...

Noncompliance with Subrecipient Monitoring Requirements - Transit - MDT - The Montana Department of Transportation is developing a revised subrecipient risk assessment that incorporates information provided by subrecipients, applies clearer criteria for identifying higher-risk entities, and aligns risk-reducing factors with elements that directly decrease the likelihood of undetected material noncompliance. The revised assessment will be implemented for state fiscal year 2028 applications during the state fiscal year 2027 cycle. The Transit Section has also instituted an application review tracking sheet beginning in state fiscal year 2027 to ensure fiscal and programmatic components are reviewed by the appropriate staff. This measure improves documentation, accountability, and internal monitoring. The department will continue refining and strengthening these processes to ensure consistent, accurate, and compliance-focused risk assessments going forward. Responsible Party - Kimberly Doherty, Accounting Systems Supervisor, Montana Department of Transportation Target Implementation Date - 12/31/2026

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Finding 1235550 (2025-077)

Material Weakness 2025

State of Montana

MT

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

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

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Finding 1235549 (2025-076)

Material Weakness 2025

State of Montana

MT

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.332

Inadequate Subrecipient Monitoring Controls - ELC - DPHHS - The Montana Department of Public Health and Human Services has implemented a new risk-assessment template and created additional tools to document subrecipient monitoring activities in state fiscal year 2025. The department has also updated...

Inadequate Subrecipient Monitoring Controls - ELC - DPHHS - The Montana Department of Public Health and Human Services has implemented a new risk-assessment template and created additional tools to document subrecipient monitoring activities in state fiscal year 2025. The department has also updated its policies and procedures. The department will continue to review and enhance its subaward processes to ensure full compliance. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 6/30/2025

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Finding 1235548 (2025-075)

Material Weakness 2025

State of Montana

MT

Subrecipient Monitoring Allowable Costs / Cost Principles Significant Deficiency § 200.303

Inadequate Supporting Documentation - ELC - DPHHS - The Montana Department of Public Health and Human Services established a procedure and a shared location for project documentation in 2023. The department will verify compliance through periodic reviews to ensure it is used. In addition, management...

Inadequate Supporting Documentation - ELC - DPHHS - The Montana Department of Public Health and Human Services established a procedure and a shared location for project documentation in 2023. The department will verify compliance through periodic reviews to ensure it is used. In addition, management will periodically remind staff of the procedures for storing all files in the designated shared location. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 8/21/2026

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Finding 1235531 (2025-072)

Material Weakness 2025

State of Montana

MT

Subrecipient Monitoring Allowable Costs / Cost Principles Equipment & Real Property Management § 200.303 § 200.313 § 200.332 § 200.439

Noncompliant Equipment and Construction Controls – ESSER – OPI - The Montana Office of Public Instruction notes that the grant is closed and the temporary grant-funded staff are no longer with the agency. Moving forward, new grant managers will have better direction on the agency’s internal controls...

Noncompliant Equipment and Construction Controls – ESSER – OPI - The Montana Office of Public Instruction notes that the grant is closed and the temporary grant-funded staff are no longer with the agency. Moving forward, new grant managers will have better direction on the agency’s internal controls. Responsible Party - April Grady, Chief Financial Officer, Montana Office of Public Instruction Target Implementation Date - 9/30/2026

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Finding 1235526 (2025-067)

Material Weakness 2025

State of Montana

MT

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.332 § 200.403

Inadequate Support for Federal Reimbursement - ESSER - OPI - The Montana Office of Public Instruction has already implemented more stringent criteria for cash requests from schools. Although this has created additional burden for local education agencies, the Office has remained firm on the informat...

Inadequate Support for Federal Reimbursement - ESSER - OPI - The Montana Office of Public Instruction has already implemented more stringent criteria for cash requests from schools. Although this has created additional burden for local education agencies, the Office has remained firm on the information required. These criteria were implemented in late 2024 and have been required since that time. Cash requests are audited quarterly by the Internal Control Auditor against the budget documents submitted, and any issues identified are addressed. No further action is needed other than continuing the current process. Responsible Party - April Grady, Chief Financial Officer, Montana Office of Public Instruction Target Implementation Date - 12/31/2026

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Finding 1235525 (2025-066)

Material Weakness 2025

State of Montana

MT

Reporting Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

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

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Finding 1235510 (2025-104)

Material Weakness 2025

State of Montana

MT

Subrecipient Monitoring Material Weakness Reporting § 200.303

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

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Finding 1235509 (2025-103)

Material Weakness 2025

State of Montana

MT

Subrecipient Monitoring § 200.303 § 200.332

Inadequate ALN Disclosure - Disaster Grants - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division concurs with the finding. The Assistance Listing Number was not included in payment information from approximately December 2022 through July 2024. Following Audit...

Inadequate ALN Disclosure - Disaster Grants - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division concurs with the finding. The Assistance Listing Number was not included in payment information from approximately December 2022 through July 2024. Following Audit Finding Number 2023-074, the Assistance Listing Number was added to the payment letter each subrecipient receives. Inclusion of the Assistance Listing Number has also been added to the reimbursement process. Corrective actions have been implemented. Responsible Party - Janae Brower, Chief Financial Officer, Montana Department of Military Affairs Target Implementation Date - 10/30/2026

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Finding 1235508 (2025-102)

Material Weakness 2025

State of Montana

MT

Allowable Costs / Cost Principles Subrecipient Monitoring Procurement, Suspension & Debarment § 200.303 § 200.332 § 200.403

Inadequate Supporting Documentation - Disaster Grants - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division partially concurs. The Division validated the reviewed project costs through its internal review and through additional Federal Emergency Management Agen...

Inadequate Supporting Documentation - Disaster Grants - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division partially concurs. The Division validated the reviewed project costs through its internal review and through additional Federal Emergency Management Agency (FEMA) processes, including the Validate As You Go procedure, and determined the costs to be allowable. The division acknowledges the cited federal compliance criteria and recognizes the opportunity to strengthen the consistency, accessibility, and retention of project documentation. To enhance existing processes, the division has implemented a standardized project file structure that clearly identifies the location of supporting documentation and ensures official grant files are complete rather than relying solely on documentation stored within federal systems. This process is being applied to the disasters that occurred in December 2025 and were federally declared in April 2026. The division will continue to evaluate and refine its documentation practices while maintaining appropriate controls, reviews, validations, payments, and closeout procedures for federally funded projects. Responsible Party - Janae Brower, Chief Financial Officer, Montana Department of Military Affairs Target Implementation Date - 10/31/2026

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Finding 1235507 (2025-101)

Material Weakness 2025

State of Montana

MT

Subrecipient Monitoring § 200.303 § 200.332 § 200.521

Inadequate Subrecipient Monitoring - Disaster Grants - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division concurs with the finding. The division began implementing subrecipient audit report reviews in May 2025 as part of subrecipient monitoring. A standard ope...

Inadequate Subrecipient Monitoring - Disaster Grants - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division concurs with the finding. The division began implementing subrecipient audit report reviews in May 2025 as part of subrecipient monitoring. A standard operating procedure will be completed by September 30, 2026, to provide each program a process for reviewing and conducting necessary follow-up, including management decision letters, in compliance with 2 CFR 200. Responsible Party - Janae Brower, Chief Financial Officer, Montana Department of Military Affairs Target Implementation Date - 9/30/2026

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Finding 1235492 (2025-037)

Material Weakness 2025

State of Montana

MT

Subrecipient Monitoring § 200.303

Noncompliant Subrecipient Communications and Controls - SLFRF - DOA - The Montana Department of Administration Architecture and Engineering Division partially concurs because although the cumulative total for multiple awards was not explicitly listed in Exhibit A of the initial grant agreement, subr...

Noncompliant Subrecipient Communications and Controls - SLFRF - DOA - The Montana Department of Administration Architecture and Engineering Division partially concurs because although the cumulative total for multiple awards was not explicitly listed in Exhibit A of the initial grant agreement, subrecipients executed their agreements at the same time and were formally notified of the total funding amount across all projects. Throughout the grant period, the Euna Grants system maintains full transparency and gives subrecipients continuous access to the Post-Award Status Report, which displays individual award amounts and the cumulative total. Subrecipients can export or print this information at any time. The Architecture and Engineering Division will continue to use the Euna Grants system and will encourage subrecipients to use the system to maintain full transparency and access to the Post-Award Status Report. The division will update its internal controls as necessary to ensure all required subaward elements, including federal award amounts, are communicated to subrecipients in a timely manner. Responsible Party - Russell Katherman, Administrator of Architecture and Engineering , Montana Long Range Building, Montana Department of Administration Target Implementation Date - 6/30/2026

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Finding 1235429 (2025-096)

Material Weakness 2025

State of Montana

MT

Subrecipient Monitoring § 200.303

Noncompliant FFATA Reports - CHIP - DPHHS - The Montana Department of Public Health and Human Services 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 th...

Noncompliant FFATA Reports - CHIP - DPHHS - The Montana Department of Public Health and Human Services 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 implemented additional internal controls and corrected the Children’s Health Insurance Program (CHIP) FFATA reports. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 7/1/2025

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Finding 1235394 (2025-078)

Material Weakness 2025

State of Montana

MT

Subrecipient Monitoring Material Weakness Reporting § 200.303

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

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Finding 1235355 (2025-049)

Material Weakness 2025

State of Montana

MT

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

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

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Finding 1235352 (2025-046)

Material Weakness 2025

State of Montana

MT

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

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

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Corrective Action Plans

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