Corrective Action Plans

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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
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
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
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
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
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
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
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
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
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 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 Supporting Documentation - SPED - OPI - The Montana Office of Public Instruction partially concurs with this finding. The prior audit was not completed in time for the Office to implement changes before the fiscal years reviewed in the current audit. The Office implemented more stringent ...
Inadequate Supporting Documentation - SPED - OPI - The Montana Office of Public Instruction partially concurs with this finding. The prior audit was not completed in time for the Office to implement changes before the fiscal years reviewed in the current audit. The Office implemented more stringent criteria for cash requests from schools in late 2024, and those requirements have been in place since that time. Although there has been considerable pushback from local education agencies due to the added burden, the Office has remained firm on the information required. Cash requests are audited quarterly by the Internal Control Auditor against submitted budget documents, and any issues identified are addressed. These criteria are fully implemented, and no further corrective action is necessary beyond continuing the current process. Responsible Party - April Grady, Chief Financial Officer, Montana Office of Public Instruction Target Implementation Date - 12/31/2026
Inadequate Payroll Certification Controls - R&D - UM - The University of Montana - Missoula will work with Information Technology to confirm that Personnel Activity Report reminder emails are sent on the correct schedule and to the appropriate individuals, including the Office of Sponsored Programs....
Inadequate Payroll Certification Controls - R&D - UM - The University of Montana - Missoula will work with Information Technology to confirm that Personnel Activity Report reminder emails are sent on the correct schedule and to the appropriate individuals, including the Office of Sponsored Programs. The University will provide Personnel Activity Report certification training to the campus and will conduct targeted outreach for departments with outstanding records. After the current cleanup effort is completed, Grants and Contracts Officers will review outstanding Personnel Activity Reports quarterly and follow up as needed to promote timely certification. Responsible Party - Nicole Thompson, Director, Office of Sponsored Programs, University of Montana - Missoula Target Implementation Date - 2/28/2027
Noncompliant FFATA Reports - Medicaid - DPHHS - The Montana Department of Public Health and Human Services 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 ins...
Noncompliant FFATA Reports - Medicaid - DPHHS - The Montana Department of Public Health and Human Services 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 occurred. The department has implemented additional internal controls and has corrected the Medicaid 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
Inadequate HAP Reconciliation Controls - HVC - Commerce - The Montana Department of Commerce has provided additional staff training to ensure housing assistance payments are issued timely, even though the error rate was less than one percent. Responsible Party - Ingrid Mallo, Chief Financial Officer...
Inadequate HAP Reconciliation Controls - HVC - Commerce - The Montana Department of Commerce has provided additional staff training to ensure housing assistance payments are issued timely, even though the error rate was less than one percent. Responsible Party - Ingrid Mallo, Chief Financial Officer, Montana Department of Commerce Target Implementation Date - 8/19/2026
Noncompliant FFATA Reports - Nutrition - OPI - The Montana Office of Public Instruction does not concur with the portions of the finding related to historical reporting issues that were fully resolved in the prior audit, including the deletion of historical reports and resubmission of final versions...
Noncompliant FFATA Reports - Nutrition - OPI - The Montana Office of Public Instruction does not concur with the portions of the finding related to historical reporting issues that were fully resolved in the prior audit, including the deletion of historical reports and resubmission of final versions. Earlier discrepancies resulted from concurrent reports within the federal reporting system, which caused amounts to duplicate. Federal partners verbally confirmed the system correction, and SAM.gov was updated at the beginning of fiscal year 2026. These issues were attributable to federal system functionality rather than to the Montana Office of Public Instruction, and reporting was completed as directed. The Office concurs with the portion of the finding involving discrepancies associated with prior‑period adjustments. After awards were liquidated and closed, the Office submitted final reports using complete expenditure data. Subsequent adjustments created differences between the Office’s internal records and federal reporting. For ALN 10.582, the Office concurs with the finding but does not agree that the Office is responsible. SAM.gov did not recognize the Federal Award Identification Number, preventing submission of required reports. This issue was later identified as a broader system problem affecting agencies nationwide. To address the recommendation, the Office will update internal FFATA guidance to ensure continued compliance with federal requirements. Documentation will be retained, and reconciliations will verify values reported in both USAspending and SAM.gov. These actions strengthen internal controls and support timely, accurate reporting. 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
Noncompliant FFATA Reports - CCDF - 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 ...
Noncompliant FFATA Reports - CCDF - 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 - 7/23/2025
Controls over Reporting Recommendation: The City should strengthen its internal controls over federal reporting by establishing formal procedures to monitor reporting deadlines, assigning responsibility for report preparation and review, maintaining a reporting calendar, and performing periodic supe...
Controls over Reporting Recommendation: The City should strengthen its internal controls over federal reporting by establishing formal procedures to monitor reporting deadlines, assigning responsibility for report preparation and review, maintaining a reporting calendar, and performing periodic supervisory reviews to ensure all required reports are submitted accurately and timely. Management Response: Management concurs with the recommendation. The Management Analyst will ensure accurate and timely grant reporting. Anticipated Completion Date: September 30, 2026 Responsible Party: GIna Sherman, Management Analyst
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Pierce County January 1, 2025 through December 31, 2025 This schedule presents the corrective action the County is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CF...
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Pierce County January 1, 2025 through December 31, 2025 This schedule presents the corrective action the County is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2025-001 Finding caption: The County did not have adequate internal controls for ensuring compliance with federal subrecipient monitoring requirements. Name, address, and telephone of County contact person: Jackie Ota 1501 Market Street, Suite 102 Tacoma, WA 98402 (253) 798-7231 Corrective action the auditee plans to take in response to the finding: Internal controls have been strengthened to ensure compliance with federal program requirements. Anticipated date to complete the corrective action: 09/09/2026
Management concurs with the finding above and recognizes the importance of maintaining compliance with federal award requirements. To address the matter, management will implement the following corrective actions: Update procurement policies and procedures to properly document suspension and debarme...
Management concurs with the finding above and recognizes the importance of maintaining compliance with federal award requirements. To address the matter, management will implement the following corrective actions: Update procurement policies and procedures to properly document suspension and debarment verification through SAM.gov for all applicable vendors and contracts receiving federal funds. If vendors or contractors are not verifiable through SAM.gov, additional procedures will be performed to ensure vendors and contractors are not suspended or debarred. Implement a standardized checklist to ensure all compliance requirements are met Management will perform semi-annual monitoring of federal award transactions and compliance requirements throughout the year Management believes these actions will adequately address the condition noted and reduce the likelihood of recurrence. The Chief Financial Officer is responsible for implementing and monitoring these corrective actions, which are expected to be fully implemented by December 31, 2026
City Response and Corrective Action Plan: Management agrees with the recommendation. Moving forward the City will check vendors in SAM.gov before awarding contracts and will recheck them at least once a year for multi year agreements. Each check will be recorded in a central log, and supporting docu...
City Response and Corrective Action Plan: Management agrees with the recommendation. Moving forward the City will check vendors in SAM.gov before awarding contracts and will recheck them at least once a year for multi year agreements. Each check will be recorded in a central log, and supporting documentation will be kept in our contract and grant files. When needed, the City will collect a vendor certification at the time of award and review compliance annually. The City expects full implementation of these procedures within 60 days, with ongoing monitoring after that.
2025-003: Reporting – Temporary Assistance for Needy Families Name of Contact Person(s): Bobbie Crooker, Director of Energy and Housing Management’s Views and Corrective Action Plan: The Department of Energy and Housing Services (EHS) at MaineHousing agrees that for 2025 the Program Delivery Report,...
2025-003: Reporting – Temporary Assistance for Needy Families Name of Contact Person(s): Bobbie Crooker, Director of Energy and Housing Management’s Views and Corrective Action Plan: The Department of Energy and Housing Services (EHS) at MaineHousing agrees that for 2025 the Program Delivery Report, the Program Projections Report, and many of the Monthly Household reports did not have evidence of submission and that the Closeout Report was not filed timely. This issue occurred due to staff turnover within the LIHEAP Team, within the Fiscal Team, and within the EHS Department overall, as well as due to an insufficient monitoring process regarding reporting requirements. The State of Maine DHHS verbally informed MaineHousing that all 2025 reporting requirements have been satisfied. EHS is in the process of developing and implementing the use of an up-to-date report tracking spreadsheet for the Department. As part of the training for newly onboarded staff, such as the new department Director, the newly hired Quality Control Specialist, and the newly hired Fiscal Compliance Coordinator, EHS has also identified who is responsible for maintaining the tracking spreadsheet, identified who is responsible for the information contained in specific reports, identified who is responsible for submitting each report, and identified who is responsible for updating the department calendar with reminders for report due dates. This spreadsheet will help ensure that all reports for all programs are submitted accurately and in a timely manner in accordance with state guidelines for report submission. Additionally, EHS walked through the process and what is required with a representative from Maine DHHS. For TANF, this process and tracking has been fully implemented. This program was administered as part of a subrecipient agreement with the Maine Department of Health and Human Services (DHHS). Due to structural and fiscal changes at DHHS, MaineHousing concluded its administration of these TANF funds effective July 1, 2026. Proposed Completion Date: Completed in fall of 2025
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