Corrective Action Plans

Finding 484432 (2023-045)

Material Weakness 2023

State of Montana

MT

Subrecipient Monitoring Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.303

ALN: 84.425, 84.425D, 84.425U, Corrective Action Plan: Noncompliant FFATA Reports - ESSER - OPI - The Montana Office of Public Instruction will implement a process to reconcile the data between the Federal Funding Accounting and Transparency Act (FFATA) Subaward Reporting System (FSRS) and the USA...

ALN: 84.425, 84.425D, 84.425U, Corrective Action Plan: Noncompliant FFATA Reports - ESSER - OPI - The Montana Office of Public Instruction will implement a process to reconcile the data between the Federal Funding Accounting and Transparency Act (FFATA) Subaward Reporting System (FSRS) and the USASpending system monthly. This finding was based on the federal system not functioning as expected. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024

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Finding 484431 (2023-032)

Material Weakness 2023

State of Montana

MT

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

ALN: 84.425, 84.425D, 84.425U, Corrective Action Plan: Inadequate Support for Federal Reimbursement - ESSER - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will review cash requests and determine if the subrecipient grant expenditures comply with the Elementary and...

ALN: 84.425, 84.425D, 84.425U, Corrective Action Plan: Inadequate Support for Federal Reimbursement - ESSER - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will review cash requests and determine if the subrecipient grant expenditures comply with the Elementary and Secondary School Emergency Relief Fund (ESSER) requirements and ensure costs are related to the pandemic, reasonable and necessary. Additional documentation will be requested of the subrecipient as needed. The Internal Control Auditor will also monitor subrecipient compliance with construction and capital expenditures including wage certifications for construction projects. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024

View Audit 317490 Questioned Costs: $1

Finding 484423 (2023-074)

Material Weakness 2023

State of Montana

MT

Subrecipient Monitoring § 200.303 § 200.332

ALN: 97.036, Corrective Action Plan: Inadequate Subrecipient Communications and Controls - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division, will update the applicant awarding documentation to include the Federal Agency Listing Number (ALN) in compliance w...

ALN: 97.036, Corrective Action Plan: Inadequate Subrecipient Communications and Controls - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division, will update the applicant awarding documentation to include the Federal Agency Listing Number (ALN) in compliance with 2 CFR 200.332(a)(1) and review of subrecipient audit reports as part of the initial risk assessments. Person(s) Responsible for Corrective Measures: Delila Bruno, Administrator, Montana Department of Military Affairs, Target Date: 12/31/2024

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Finding 484422 (2023-073)

Material Weakness 2023

State of Montana

MT

Subrecipient Monitoring Reporting Period of Performance § 200.303

ALN: 97.036, Corrective Action Plan: Deficient FFATA Controls - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division, will update Federal Funding Accountability and Transparent Act (FFATA) reporting procedures to ensure proper controls are in place for timely ...

ALN: 97.036, Corrective Action Plan: Deficient FFATA Controls - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division, will update Federal Funding Accountability and Transparent Act (FFATA) reporting procedures to ensure proper controls are in place for timely and accurate submissions. FFATA procedures will be defined and updated to include saving a copy of each submitted FFATA report and annotating review. The department will reach out to federal partners for additional training and guidance on FFATA reporting to properly comply with federal requirements. Person(s) Responsible for Corrective Measures: Delila Bruno, Administrator, Montana Department of Military Affairs, Target Date: 12/01/2024

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Finding 484413 (2023-015)

Material Weakness 2023

State of Montana

MT

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.332

ALN: 21.027, Corrective Action Plan: Inadequate Subrecipient Monitoring - ARPA - DNRC - The Montana Department of Natural Resources and Conservation partially concurs with finding 2023-015 because it disagrees with the interpretation that subrecipient monitoring must occur within a specified time ...

ALN: 21.027, Corrective Action Plan: Inadequate Subrecipient Monitoring - ARPA - DNRC - The Montana Department of Natural Resources and Conservation partially concurs with finding 2023-015 because it disagrees with the interpretation that subrecipient monitoring must occur within a specified time period and believes controls were in place during the audit period. Additionally, because the department's policy is to assign every subrecipient the same risk level until an assessment is completed, it believes it is following subrecipient monitoring requirements. As such, the department will continue to evaluate risk through a subrecipient survey and designate any subrecipient as medium risk if a survey is not completed and returned. The department has enhanced related internal controls by noting in its Risk Assessment and Subrecipient Monitoring Guidance that the agency may withhold reimbursement payments if a subrecipient fails to complete a risk survey. Additionally, the DNRC continues to perform subrecipient monitoring requirements, including verifying compliance with the Single Audit Act. The agency has enhanced related internal controls by adding a process to review the Montana Department of Administration’s Local Government Audit Findings Report and requesting corrective actions from noncompliant subrecipients. Person(s) Responsible for Corrective Measures: Meaghan Bjerke, Chief Financial Officer, Montana Department of Natural Resources and Conservation, Target Date: Completed

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Finding 484407 (2023-042)

Material Weakness 2023

State of Montana

MT

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303 § 200.334

ALN: 84.371, Corrective Action Plan: Noncompliant Federal Reporting - Literacy- OPI - The Montana Office of Public Instruction grant staff and Literacy Program Instructional Coordinator will document reports and expenses in a single file to reduce duplication and to confirm expenditures are proper...

ALN: 84.371, Corrective Action Plan: Noncompliant Federal Reporting - Literacy- OPI - The Montana Office of Public Instruction grant staff and Literacy Program Instructional Coordinator will document reports and expenses in a single file to reduce duplication and to confirm expenditures are properly recorded. The reports will be gathered and reviewed quarterly. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024

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Finding 484406 (2023-041)

Material Weakness 2023

State of Montana

MT

Questioned Costs Eligibility Subrecipient Monitoring § 200.303

ALN: 84.371, Corrective Action Plan: Noncompliant Eligibility Determinations - Literacy - OPI - The Montana Office of Public Instruction does not concur with finding 2023-041. The Office notes that the United States Department of Education approved the application eligibility requirements. Perso...

ALN: 84.371, Corrective Action Plan: Noncompliant Eligibility Determinations - Literacy - OPI - The Montana Office of Public Instruction does not concur with finding 2023-041. The Office notes that the United States Department of Education approved the application eligibility requirements. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: N/A

View Audit 317490 Questioned Costs: $1

Finding 484405 (2023-046)

Material Weakness 2023

State of Montana

MT

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303

ALN: 84.371, Corrective Action Plan: Noncompliant FFATA Reports - Literacy - OPI - The Montana Office of Public Instruction will implement a process to reconcile the data between the Federal Funding Accounting and Transparency Act (FFATA) Subaward Reporting System (FSRS) and the USASpending system...

ALN: 84.371, Corrective Action Plan: Noncompliant FFATA Reports - Literacy - OPI - The Montana Office of Public Instruction will implement a process to reconcile the data between the Federal Funding Accounting and Transparency Act (FFATA) Subaward Reporting System (FSRS) and the USASpending system monthly. This finding was based on the federal system not functioning as expected. This reconciliation process will be completed monthly. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024

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Finding 484404 (2023-040)

Material Weakness 2023

State of Montana

MT

Subrecipient Monitoring § 200.303 § 200.332

ALN: 84.371, Corrective Action Plan: Inadequate Subrecipient Monitoring - Literacy - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will review cash requests and determine if the subrecipient grant expenditures comply with federal program requirements. Additional do...

ALN: 84.371, Corrective Action Plan: Inadequate Subrecipient Monitoring - Literacy - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will review cash requests and determine if the subrecipient grant expenditures comply with federal program requirements. Additional documentation will be requested of the subrecipients as needed. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024

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Finding 484403 (2023-039)

Material Weakness 2023

State of Montana

MT

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

ALN: 84.371, Corrective Action Plan: Inadequate Support for Federal Reimbursement - Literacy - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will review cash requests and determine if the subrecipient grant expenditures comply with federal program requirements. Add...

ALN: 84.371, Corrective Action Plan: Inadequate Support for Federal Reimbursement - Literacy - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will review cash requests and determine if the subrecipient grant expenditures comply with federal program requirements. Additional documentation will be requested of the subrecipient as needed. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024

View Audit 317490 Questioned Costs: $1

Finding 484377 (2023-048)

Material Weakness 2023

State of Montana

MT

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.214 § 200.303

ALN: 93.423, Corrective Action Plan: Unperformed Duties for Waiver Program Subgrants - SAO - The Montana State Auditor's Office's calendar of required tasks has since been updated to include the additional federal requirements. The calendar lists each requirement, the timeline of completion, and t...

ALN: 93.423, Corrective Action Plan: Unperformed Duties for Waiver Program Subgrants - SAO - The Montana State Auditor's Office's calendar of required tasks has since been updated to include the additional federal requirements. The calendar lists each requirement, the timeline of completion, and the assigned individual or team. The calendar includes searching SAM.gov for debarment status, making subaward disclosures to the association, and ensuring Federal Funding Accounting and Transparency Act (FFATA) reports are filed. These measures are in addition to existing oversight, which has included regularly communicating with the association's board chair and administrator and attending quarterly meetings as an ex officio member per § 33-22-1307(1)(e), MCA. Prior to its creation by 2019 Montana Senate Bill 125, the association was not (and practically could not be) debarred from federal contracting, nor has the association been debarred from federal contracting at any time since its creation. In addition, the association has obtained a Unique Entity Identifier. Person(s) Responsible for Corrective Measures: Amber Long-Thorvilson, Chief Financial Officer, Montana State Auditor's Office, Target Date: Completed

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Finding 484217 (2023-021)

Material Weakness 2023

State of Montana

MT

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.303

ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 93.264, 93.364, 93.925, Corrective Action Plan: Internal Controls and Compliance - GLBA Requirements - MSU - The Montana State University (MSU) has made significant progress in meeting Gramm-Leach-Bliley Act (GLBA) requirements and has already completed...

ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 93.264, 93.364, 93.925, Corrective Action Plan: Internal Controls and Compliance - GLBA Requirements - MSU - The Montana State University (MSU) has made significant progress in meeting Gramm-Leach-Bliley Act (GLBA) requirements and has already completed the majority of the components. Active efforts are underway to quickly complete the implementation of the remaining GLBA internal controls as recommended. These include transitioning from ad-hoc to regular reviews of user access appropriateness; completing security plans for systems storing or processing GLBA data; testing third-party companies for compliance with GLBA; and completion of security polices for affiliate campuses. Person(s) Responsible for Corrective Measures: Justin van Almelo, Chief Information Security Officer, Montana State University - Bozeman, Target Date: 12/31/2024

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Finding 484212 (2023-022)

Material Weakness 2023

State of Montana

MT

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.303

ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342, Corrective Action Plan: Internal Controls and Compliance - GLBA Requirements - UM - The University of Montana - Missoula (UM) has implemented and will continue to implement internal controls to comply with the Gramm-Leach-Bliley Act (GLB...

ALN: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.342, Corrective Action Plan: Internal Controls and Compliance - GLBA Requirements - UM - The University of Montana - Missoula (UM) has implemented and will continue to implement internal controls to comply with the Gramm-Leach-Bliley Act (GLBA) requirements. The Information Technology department will collaborate with the Financial Aid Data Stewards to conduct an inventory of financial aid data. Person(s) Responsible for Corrective Measures: Jonathan Neff, Chief Information Security Officer, University of Montana - Missoula, Target Date: 12/31/2024

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Finding 481559 (2023-078)

Significant Deficiency 2023

State of Montana

MT

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

ALN: Various R&D, Corrective Action Plan: Grant Management Internal Controls - UM - The University of Montana - Missoula will train all new staff members and ensure sufficient staffing levels to manage the workload effectively. UM Missoula has also established a dedicated training position with...

ALN: Various R&D, Corrective Action Plan: Grant Management Internal Controls - UM - The University of Montana - Missoula will train all new staff members and ensure sufficient staffing levels to manage the workload effectively. UM Missoula has also established a dedicated training position within the Office of Sponsored Programs to ensure all employees have the training and resources needed to manage federal Research and Development Program awards in compliance with applicable federal statutes and regulations. The training position is currently posted and is waiting to be filled. Person(s) Responsible for Corrective Measures: Nicole Thompson, Director, Office of Sponsored Programs, University of Montana - Missoula, Target Date: 12/31/2024 9/30/2024

View Audit 317490 Questioned Costs: $1

Finding 481532 (2023-005)

Material Weakness 2023

State of Montana

MT

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

ALN: 14.871, 14.879, Corrective Action Plan: Untimely or Not Completed Housing Assistance Inspections - DOC - The Montana Department of Commerce has developed inspection procedures, provided training (and plans to continue to provide training) to field agents and contract managers, and established...

ALN: 14.871, 14.879, Corrective Action Plan: Untimely or Not Completed Housing Assistance Inspections - DOC - The Montana Department of Commerce has developed inspection procedures, provided training (and plans to continue to provide training) to field agents and contract managers, and established software to track inspections. The department has also revised field agency contracts to clearly define inspection requirements and to include compliance incentives. Person(s) Responsible for Corrective Measures: Ingrid Mallo, Chief Financial Officer, Montana Department of Commerce, Target Date: Completed

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Finding 481518 (2023-001)

Material Weakness 2023

State of Montana

MT

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles § 200.303

ALN: 10.553, 10.555, 10.559, 10.582, Corrective Action Plan: Noncompliant FFATA Reports - Nutrition - OPI - The values were being duplicated due to an error in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The Office of Public Instruction has reached out...

ALN: 10.553, 10.555, 10.559, 10.582, Corrective Action Plan: Noncompliant FFATA Reports - Nutrition - OPI - The values were being duplicated due to an error in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The Office of Public Instruction has reached out to its federal partners who are correcting their system to allow the office to report monthly without duplicating the reported values. The office will then begin reporting monthly as required. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 10/31/2024

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Finding 481476 (2023-062)

None 2023

State of Montana

MT

Questioned Costs Period of Performance Subrecipient Monitoring

ALN: 93.575, 93.596, Corrective Action Plan: Expenditures Not Within Obligation Period - CCDF - PHHS - The Montana Department of Public Health and Human Services, Child Care and Development Fund programs will improve internal controls to ensure federal funds are used in the correct obligation peri...

ALN: 93.575, 93.596, Corrective Action Plan: Expenditures Not Within Obligation Period - CCDF - PHHS - The Montana Department of Public Health and Human Services, Child Care and Development Fund programs will improve internal controls to ensure federal funds are used in the correct obligation period. Significant improvements were made in state fiscal year 2023. Additional controls were developed to ensure inactivation of cost centers to prevent payroll or other expenses to post beyond the first year of the grant. Guidelines were created to provide additional time and review of the ACF-696 reports prior to submission. The department has identified set-aside costs for grant funds that are allowable and will offset portions of the questioned costs. Person(s) Responsible for Corrective Measures: Tracy Moseman, Administrator, Montana Department of Public Health and Human Services, Target Date: Completed

View Audit 317490 Questioned Costs: $1

Finding 481475 (2023-068)

Material Weakness 2023

State of Montana

MT

Reporting Subrecipient Monitoring § 200.303

ALN: 93.575, 93.596, Corrective Action Plan: Noncompliant FFATA Reports - CCDF - DPHHS - The Montana Department of Public Health and Human Services, Child Care and Development Fund programs will enhance existing internal controls and instructions to ensure timely and accurate submission of Federal...

ALN: 93.575, 93.596, Corrective Action Plan: Noncompliant FFATA Reports - CCDF - DPHHS - The Montana Department of Public Health and Human Services, Child Care and Development Fund programs will enhance existing internal controls and instructions to ensure timely and accurate submission of Federal Funding Accountability and Transparent Act (FFATA) reports in accordance with federal regulations. Person(s) Responsible for Corrective Measures: Corinne Kyler, Administrator, Montana Department of Public Health and Human Services, Target Date: 03/31/2025

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Finding 481473 (2023-064)

Material Weakness 2023

State of Montana

MT

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

ALN: 93.575, 93.596, Corrective Action Plan: Inadequate Documentation of Recipient Eligibility - CCDF - DPHHS - The Montana Department of Public Health and Human Services, Child Care and Development Fund programs are continuing to review questioned costs per the guidance received from Office of Ch...

ALN: 93.575, 93.596, Corrective Action Plan: Inadequate Documentation of Recipient Eligibility - CCDF - DPHHS - The Montana Department of Public Health and Human Services, Child Care and Development Fund programs are continuing to review questioned costs per the guidance received from Office of Child Care (OCC). The department documents the extent to which families receiving the 2021 Coronavirus Response and Relief Supplemental Appropriations Act (CRRSA) funded subsidies were eligible, including income-eligible or essential workers. The department additionally documents the extent to which providers who served families met applicable health and safety requirements. Program staff will enhance controls and training and will work with federal partners to ensure funding is in alignment with applicable terms and conditions. Person(s) Responsible for Corrective Measures: Tracy Moseman, Administrator, Montana Department of Public Health and Human Services, Target Date: 12/31/2024

View Audit 317490 Questioned Costs: $1

Finding 481472 (2023-060)

Material Weakness 2023

State of Montana

MT

Subrecipient Monitoring Matching / Level of Effort / Earmarking Eligibility § 200.303 § 200.334

ALN: 93.575, 93.596, Corrective Action Plan: Inadequate Subrecipient Monitoring - CCDF - DPHHS - The Montana Department of Public Health and Human Services, Child Care and Development Fund programs will develop monitoring procedures to coordinate state plan requirements with contract requirements ...

ALN: 93.575, 93.596, Corrective Action Plan: Inadequate Subrecipient Monitoring - CCDF - DPHHS - The Montana Department of Public Health and Human Services, Child Care and Development Fund programs will develop monitoring procedures to coordinate state plan requirements with contract requirements and make amendments to contracts when State Plan changes. Person(s) Responsible for Corrective Measures: Tracy Moseman, Administrator, Montana Department of Public Health and Human Services, Target Date: 12/31/2024

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Finding 481471 (2023-059)

Material Weakness 2023

State of Montana

MT

Subrecipient Monitoring § 200.303 § 200.332 § 200.334

ALN: 93.575, 93.596, Corrective Action Plan: Inadequate Subrecipient Monitoring - CCDF - DPHHS - The Montana Department of Public Health and Human Services, Child Care and Development Fund programs have updated their 2023 contracts to include required disclosures. Risk assessments were completed a...

ALN: 93.575, 93.596, Corrective Action Plan: Inadequate Subrecipient Monitoring - CCDF - DPHHS - The Montana Department of Public Health and Human Services, Child Care and Development Fund programs have updated their 2023 contracts to include required disclosures. Risk assessments were completed annually, as required. However, the 2022 risk assessments were accidently copied over when completing the 2023 risk assessments. Controls have been updated to ensure copies of each risk assessment are now saved with procurement files to ensure files are not accidentally replaced. Person(s) Responsible for Corrective Measures: Tracy Moseman, Administrator, Montana Department of Public Health and Human Services, Target Date: Completed

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Finding 481470 (2023-063)

Significant Deficiency 2023

State of Montana

MT

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

ALN: 93.575, 93.596, Corrective Action Plan: Inadequate Obligations - ARPA Stabilization - DPHHS - The Montana Department of Public Health and Human Services does not concur with finding 2023-063. The department obligated all funds and then reallocated the surplus to providers that had not recei...

ALN: 93.575, 93.596, Corrective Action Plan: Inadequate Obligations - ARPA Stabilization - DPHHS - The Montana Department of Public Health and Human Services does not concur with finding 2023-063. The department obligated all funds and then reallocated the surplus to providers that had not received prior stabilization funds. Providers that received reallotted funds were required to provide email confirmation of their express intent to receive and utilize unliquidated funds prior to 09/30/2022, thereby meeting the intent of the obligation as defined in 45 CFR 75.2. The email from the department stated funding amounts will be determined based on other Montana providers by size. Child care providers responded to the email confirming they agreed to accept the funds. Once the providers confirmed they agreed to accept funds, the department had a valid obligation, and therefore did not request the waiver offered by our federal cognizant to extend the obligation period from Administration for Children and Families (ACF). The waiver was extended to all states in recognition of the difficulty states were experiencing meeting the obligation criteria. The desert payment amounts were based on a formula using the total previously obligated unliquidated grant funds and the size of the provider. In November 2022, letters were sent to providers outlining their portion of the previously obligated allotment. Person(s) Responsible for Corrective Measures: Tracy Moseman, Administrator, Montana Department of Public Health and Human Services, Target Date: N/A

View Audit 317490 Questioned Costs: $1

Finding 481450 (2023-002)

None 2023

Nasmhpd Research Institute, Inc.

VA

Subrecipient Monitoring Cash Management Matching / Level of Effort / Earmarking § 200.1 § 200.305

Corrective Action Plan: The Institute implemented the recommendations in the fourth quarter of fiscal year 2024.

View Audit 317483

Finding 481447 (2023-002)

Material Weakness 2023

Mason County

WA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.213

Finding ref number: 2023-002 Finding caption: The County’s internal controls were inadequate for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of County contact person: Leo Kim, Chief Financial Officer 411 N 5th Street Shelton, WA 98584 (360)427...

Finding ref number: 2023-002 Finding caption: The County’s internal controls were inadequate for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of County contact person: Leo Kim, Chief Financial Officer 411 N 5th Street Shelton, WA 98584 (360)427-9670 Corrective action the auditee plans to take in response to the finding: The County is committed to ensuring internal controls are adequate for compliance with federal suspension and debarment requirements. Management understands the seriousness of potentially awarding federal funds to ineligible parties and has taken steps to confirm that compliance is followed in future purchases using federal funds. An updated purchasing and contracting policy and procedures was adopted by the Board of County Commissioners in December of 2023. The document includes an updated section on suspension and debarment regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180, per §200.213. County offices and departments will ensure and document that no agreement for goods or services is entered into with any entity or person who has been disqualified from participation in Federal programs or activities. Program staff will do this by checking the federal System for Award Management (SAM.gov) prior to the contract execution date. If the contractor is not listed in SAM.gov, the County created a “Certification of no debarment or suspension form” that the contractor can attest and/or the attestation may be added to the contract. Both the SAM.gov check and/or the “Certification of no debarment form” must be completed at or before contract execution and documentation will be maintained in each contract file. The County is committed to providing training on federal grants at least annually to all county staff that work with them and anticipates full compliance with the suspension and debarment requirements moving forward. Anticipated date to complete the corrective action: 8/7/2024

View Audit 317478

Finding 481435 (2023-001)

Significant Deficiency 2023

Vail Health Services

CO

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.332

The Grant Accounting Analyst and Director of Operations will ensure that every subaward agreement is clearly identified to the subrecipient and the following information will be included in our subaward agreements. • Federal Award Identification • Name of the Federal and awarding agency and contact ...

The Grant Accounting Analyst and Director of Operations will ensure that every subaward agreement is clearly identified to the subrecipient and the following information will be included in our subaward agreements. • Federal Award Identification • Name of the Federal and awarding agency and contact information. • Subrecipient Name (which must match the name associated with its unique entity identifier). • Subrecipient's Unique Identifier • Federal Award Identification Number • Federal Award Date • Subaward Period of Performance • Subaward Budget Start and End Date • Amount of Federal funds obligated by this action by the Vail Health to the subrecipient. • Total amount of Federal funds obligated to the subrecipient by the Vail Health.The Grant Accounting Analyst and Director of Operations will monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statues, regulations and the terms and conditions of the subaward and that the subaward performance goals are achieved. Vail Health's monitoring of the subrecipient will include: 1. Reviewing financial and program performance reports of the subrecipient. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on any deficiencies pertaining to the subaward agreement. 3. An audit certification letter will be sent out to sub•recipients confirming their eligibility for Single Audit. Sub recipients will certify if they are eligible or not. Single Audits reports will be requested from sub-recipients receiving over $750,000 in federal funds. 4. If a sub-recipient has an audit finding, a copy of their corrective action plan will be requested by Vail Health. The Grant Accounting Analyst will complete an evaluation for risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation will include. • Assessing subrecipient's prior experience with Federal awards or subawards • The results of previous audits including whether the subrecipient receives a single audit in accordance with the Federal regulations. • Whether the subrecipient has new personnel or new or substantially changed systems. • The number and dollar amount of Federal awards received by the subrecipient. Depending upon assessment of risk posed by the subrecipient, the following monitoring tools will be used to ensure proper accountability and compliance with the program requirements and achievement of performance goals. • Providing subrecipients with training and technical assistance on program- related matters Performing on-site reviews of the program operations The Grant Accounting Analyst will take attend grant compliance training to acquire more knowledge on Uniform Guidance. Vail Health Sub-Recipient Monitoring policies will be updated accordingly.

View Audit 317453

Corrective Action Plans

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