Corrective Action Plans

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Inadequate Suspension and Debarment Verifications - SLFRF, ELC - DOA - The Montana Department of Administration Architecture and Engineering Division will incorporate the requirements of Title 2 Code of Federal Regulations sections 180.300(b) and 180.300(c) into its control processes for architectur...
Inadequate Suspension and Debarment Verifications - SLFRF, ELC - DOA - The Montana Department of Administration Architecture and Engineering Division will incorporate the requirements of Title 2 Code of Federal Regulations sections 180.300(b) and 180.300(c) into its control processes for architecture and engineering firm procurements. This will align these controls with those used for construction contract procurements and will include verification of application submissions and verification of contractual obligations. The division considers the risk associated with this issue to be extremely low because no Montana architecture or engineering firm appears as debarred or suspended in the federal System for Award Management database. Responsible Party - Russell Katherman, Administrator of Architecture and Engineering , Montana Long Range Building, Montana Department of Administration Target Implementation Date - 8/26/2026
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
Noncompliant Duplicate Expenditure Recording - ESSER - OPI - The Montana Office of Public Instruction concurs with this finding. The Office has created a procurement unit to ensure contract terms meet program needs. The Office has also implemented approval workflows for contract funding to ensure bu...
Noncompliant Duplicate Expenditure Recording - ESSER - OPI - The Montana Office of Public Instruction concurs with this finding. The Office has created a procurement unit to ensure contract terms meet program needs. The Office has also implemented approval workflows for contract funding to ensure budgets are aligned before contracts are executed. Internal controls between procurement, programs, and accounting will continue to be strengthened to prevent future overpayments. The grant is closed, and the temporary grant-funded staff are no longer with the agency. Moving forward, new grant managers will receive clearer direction on the agency’s internal controls. Responsible Party - April Grady, Chief Financial Officer, Montana Office of Public Instruction Target Implementation Date - 12/31/2026
Noncompliant Contractor Overpayments and Unallowable Charges - ESSER - OPI - The Montana Office of Public Instruction concurs with this finding. The Office and the University of Montana - Western established a teacher residency program originally funded with Elementary and Secondary School Emergency...
Noncompliant Contractor Overpayments and Unallowable Charges - ESSER - OPI - The Montana Office of Public Instruction concurs with this finding. The Office and the University of Montana - Western established a teacher residency program originally funded with Elementary and Secondary School Emergency Relief funds. The agreement set a fixed amount per student, but the University billed the Office for fringe benefits for each participant, which caused total costs to exceed the contract amount. The current agreement and program structure have been updated to prevent this issue. The Office has created a procurement unit to ensure contract terms support program needs. The Office has also implemented approval workflows for contract funding to confirm that budgets are aligned before agreements are executed. Internal controls between procurement, programs, and accounting will continue to be strengthened to prevent future overpayments. Responsible Party - April Grady, Chief Financial Officer, Montana Office of Public Instruction Target Implementation Date - 12/31/2026
Noncompliant Direct and Indirect Cost Charges - ESSER - OPI - The Montana Office of Public Instruction partially concurs with this finding. Spreadsheets supporting items 0005169673 and 0005227738 were provided to the Legislative Audit Division on August 11, 2026. The Central Services Division spent ...
Noncompliant Direct and Indirect Cost Charges - ESSER - OPI - The Montana Office of Public Instruction partially concurs with this finding. Spreadsheets supporting items 0005169673 and 0005227738 were provided to the Legislative Audit Division on August 11, 2026. The Central Services Division spent direct time on the Elementary and Secondary School Emergency Relief (ESSER) reporting, and those hours were charged directly to that program. Administrative and management staff also spent time preparing reports for quarterly briefings, presentations to community partners, responses to school and community inquiries, and newsletter submissions. The Office charged those hours to the ESSER program as they were directly related to the required reporting. However, the Office concurs with the questioned indirect cost charges in addition to personal services. The Office has implemented a tracking mechanism to ensure appropriate time reporting. For fiscal year 2027, the Office has added a monthly review of each federal budget to confirm that time reported aligns with the expected and allocated time for each project. Responsible Party - April Grady, Chief Financial Officer, Montana Office of Public Instruction Target Implementation Date - 12/31/2026
Noncompliant Annual Reporting Controls - ESSER - OPI - The Montana Office of Public Instruction concurs with the finding. The grant is closed, and the temporary grant-funded staff are no longer with the agency. Moving forward, new grant managers will receive clearer direction on the agency’s interna...
Noncompliant Annual Reporting Controls - ESSER - OPI - The Montana Office of Public Instruction concurs with the finding. The grant is closed, and the temporary grant-funded staff are no longer with the agency. Moving forward, new grant managers will receive clearer direction on the agency’s internal controls. Responsible Party - April Grady, Chief Financial Officer, Montana Office of Public Instruction Target Implementation Date - 12/31/2026
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
Misstated Obligation Reporting - SLFRF - GOV - The Montana Governor's Office of Budget and Program Planning does not agree that this matter represents material noncompliance. As the finding itself confirms, cumulative obligations were accurate as of the federal December 31, 2024 obligation deadline....
Misstated Obligation Reporting - SLFRF - GOV - The Montana Governor's Office of Budget and Program Planning does not agree that this matter represents material noncompliance. As the finding itself confirms, cumulative obligations were accurate as of the federal December 31, 2024 obligation deadline. No evidence supports the assertion that Treasury drew any incorrect conclusions from the one-quarter reporting delay, and the statement that the federal government “may have concluded” funds would be returned is speculative rather than fact based. The Office maintained documented controls over SLFRF administration and reporting, and the assertion that the Office had “no control” for verifying current obligations is factually incorrect, as the finding itself describes multiple control activities, including portal validations, MOU delegations, SABHRS budgetary accounting limitations, and standardized form checks. Additionally, the auditors identified no unsupported obligations under these controls or from the Office's interagency agreements, demonstrating that the Office’s control environment provided adequate assurance over current obligations and that additional internal audit procedures were not warranted given the low assessed risk of noncompliance before the obligation deadline. Ultimately, the one-quarter timing difference reflected a prudent and immaterial verification of accumulating budgetary reservations under newly issued Treasury guidance and had no impact on current or future financial integrity, state or federal appropriations, federal program outcomes, or compliance with cumulative obligation reporting requirements. Responsible Party - Chet McLean, Internal Control Coordinator, Montana Office of the Governor and Lieutenant Governor Target Implementation Date - N/A
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
Untimely Eligibility Determinations - CHIP - Medicaid - DPHHS - The Montana Department of Public Health and Human Services prioritized safeguarding continuous coverage for eligible Montanans during the unwinding period while working to minimize delays for new applicants. No questioned costs were ide...
Untimely Eligibility Determinations - CHIP - Medicaid - DPHHS - The Montana Department of Public Health and Human Services prioritized safeguarding continuous coverage for eligible Montanans during the unwinding period while working to minimize delays for new applicants. No questioned costs were identified in connection with this finding, underscoring that the issue was related to processing timeliness rather than improper payments. To ensure timely eligibility determinations going forward, the department implemented case-based processing in May 2026 that prioritizes cases based on aging and processing timelines, along with business processes to communicate with clients regarding necessary documentation for eligibility determinations. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 5/15/2026
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
Inadequate Provider Eligibility Controls - CHIP - DPHHS - The Montana Department of Public Health and Human Services does not concur. The department’s existing screening and enrollment controls satisfy the requirements of 42 CFR 455.410 and 455.412, and the federal grantor agency has already reviewe...
Inadequate Provider Eligibility Controls - CHIP - DPHHS - The Montana Department of Public Health and Human Services does not concur. The department’s existing screening and enrollment controls satisfy the requirements of 42 CFR 455.410 and 455.412, and the federal grantor agency has already reviewed and formally closed this finding based on those controls, as described below. The department implemented enhanced internal controls in fiscal year 2025 in direct response to prior single audit recommendations. Under these controls, the department receives and reviews a comprehensive quarterly screening report from its contractor and requires documented follow‑up when necessary. The federal grantor agency reviewed the department’s enhanced procedures, the contractor’s screening methodology, and the validation results, and closed the single audit finding, confirming the controls were adequate. In January 2025, the contractor provided a validation in which active National Provider Identifiers (NPIs) were compared against the Montana Medicaid file and the Provider Enrollment, Chain and Ownership System (PECOS). The validation confirmed a 96‑percent match rate requiring no further screening or enrollment actions, leaving only 4 percent of providers for the contractor to screen and enroll under federal requirements. Upon later audit inquiry, the department again consulted the federal agency. While reiterating regulatory expectations, the federal agency clarified that “the form and manner” of oversight activities remain within the state agency’s discretion. Given this explicit federal affirmation, together with the agency’s prior closure of the finding, the department maintains that its controls are fully compliant and effective and respectfully disagrees with the audit finding. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - N/A
Erroneous Beneficiary Payments - CHIP - DPHHS - The Montana Department of Public Health and Human Services does not concur. The department identified an interface issue with its contractor and promptly corrected the affected payments. The unadjusted claim amount totaled approximately $26,000 and aff...
Erroneous Beneficiary Payments - CHIP - DPHHS - The Montana Department of Public Health and Human Services does not concur. The department identified an interface issue with its contractor and promptly corrected the affected payments. The unadjusted claim amount totaled approximately $26,000 and affected 48 beneficiaries out of $146.6 million in total contractor‑paid claims during the audit period, representing approximately 0.018 percent of total claims paid. The department determined this amount to be immaterial to the fiscal year‑end financial statements. Had the amount been significant, the department would have corrected the affected payments before fiscal year‑end. The department worked with its contractor to resolve the interface issue, which was fully corrected in April 2026. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - N/A
Inadequate Internal Controls Over Certified Payrolls - AIP - DOA - The Montana Department of Administration partially concurs with the finding. While the department oversees construction activities, it has consistently informed agencies that they retain responsibility for grant administration and fe...
Inadequate Internal Controls Over Certified Payrolls - AIP - DOA - The Montana Department of Administration partially concurs with the finding. While the department oversees construction activities, it has consistently informed agencies that they retain responsibility for grant administration and federal reporting for grants awarded directly to them. Each agency is responsible for notifying the Department of all applicable grant requirements, guidance, and restrictions. In this instance, the department understood that the Montana Department of Transportation approved invoices reflecting the federal and non-federal funding split only after receiving the contractor’s Statement of Compliance for all pay periods included in the invoicing period. Due to limited time to respond to the audit finding, the department was unable to confirm with its contracted engineering firm the specific dates the certified payrolls were received and verified. To strengthen future compliance, the department will include language in project memoranda of understanding assigning responsibility for federal wage-rate compliance and record keeping to the agency that received the federal grant. The department will also implement internal controls requiring agencies to confirm that certified payroll requirements have been verified before payments are processed. Responsible Party - Russell Katherman, Administrator of Architecture and Engineering , Montana Long Range Building, Montana Department of Administration Target Implementation Date - 12/31/2026
Inaccurate Federal Reporting - AIP - MDT - The Montana Department of Transportation will update its procedures and add a secondary review process for the 2026 report submission. The procedures will also be revised to clarify the analysis and reporting of payments and revenues to ensure compliance. R...
Inaccurate Federal Reporting - AIP - MDT - The Montana Department of Transportation will update its procedures and add a secondary review process for the 2026 report submission. The procedures will also be revised to clarify the analysis and reporting of payments and revenues to ensure compliance. Responsible Party - Kimberly Doherty, Accounting Systems Supervisor, Montana Department of Transportation Target Implementation Date - 12/31/2026
Inaccurate Federal Reporting - AIP - MDT - The Montana Department of Transportation will be reviewing and updating its SF425 and SF270 procedures and adding a secondary review. This process began in January 2025, and the updated procedure will be completed by December 2026. Responsible Party - Kimbe...
Inaccurate Federal Reporting - AIP - MDT - The Montana Department of Transportation will be reviewing and updating its SF425 and SF270 procedures and adding a secondary review. This process began in January 2025, and the updated procedure will be completed by December 2026. Responsible Party - Kimberly Doherty, Accounting Systems Supervisor, Montana Department of Transportation Target Implementation Date - 12/31/2026
Inaccurate Subsidy Payments - Adoption Assistance - DPHHS - The Montana Department of Public Health and Human Services agrees that its prior method for tracking subsidy rate changes was manual and was not sufficient to ensure all scheduled rate changes were applied. The practice of including multipl...
Inaccurate Subsidy Payments - Adoption Assistance - DPHHS - The Montana Department of Public Health and Human Services agrees that its prior method for tracking subsidy rate changes was manual and was not sufficient to ensure all scheduled rate changes were applied. The practice of including multiple rates in adoption subsidy agreements was discontinued in 2023. When the error was identified, the department conducted a full review of the affected activity to determine the scope of the issue, identified additional errors, and reported those errors to the auditors. The department corrected all payment errors, repaid the affected federal funds, and implemented tracking controls over the remaining scheduled subsidy rate changes. The department completed this corrective action in March 2026. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 3/20/2026
Noncompliant FFATA - Innovation Waivers - SAO - The Montana State Auditor’s Office concurs with the finding. The Office has provided additional training to the team responsible for administering the State Innovation Waiver grant. The Office has also strengthened its procedures for monitoring award n...
Noncompliant FFATA - Innovation Waivers - SAO - The Montana State Auditor’s Office concurs with the finding. The Office has provided additional training to the team responsible for administering the State Innovation Waiver grant. The Office has also strengthened its procedures for monitoring award notices to ensure that reports required under the Federal Funding Accountability and Transparency Act are submitted no later than the end of the month following the month in which an obligation is made. Responsible Party - Amber Long-Thorvilson, Chief Financial Officer, Montana State Auditor's Office Target Implementation Date - 9/1/2026
Inaccurate Enrollment Reporting - SFA - MSU - The Montana State University - Bozeman concurs. The audit identified a gap related to unofficial withdrawals. The Office of the Registrar has developed and is implementing a procedure to capture enrollment reporting for unofficial withdrawals. Responsibl...
Inaccurate Enrollment Reporting - SFA - MSU - The Montana State University - Bozeman concurs. The audit identified a gap related to unofficial withdrawals. The Office of the Registrar has developed and is implementing a procedure to capture enrollment reporting for unofficial withdrawals. Responsible Party - Antoni Campeau, Registrar, Montana State University - Bozeman Target Implementation Date - 9/30/2026
Inaccurate FISAP Reporting - SFA - MSU - The Montana State University – Bozeman partially concurs. The University concurs that additional efforts can be made to ensure data elements are reported accurately. The University has operated with transparency regarding known challenges in validating the FI...
Inaccurate FISAP Reporting - SFA - MSU - The Montana State University – Bozeman partially concurs. The University concurs that additional efforts can be made to ensure data elements are reported accurately. The University has operated with transparency regarding known challenges in validating the FISAP report with the Federal Student Aid office for the Federal Perkins Loan program dating back to 2019. Reporting for the Perkins Loan, which has been discontinued, now focuses on repayment activity, and the December cash‑on‑hand update is accurate for the distribution of asset calculation. The Montana State University – Billings acknowledges that tuition and fee amounts reported on FISAP Part II, Section E, Lines 22a and 22b for award years 2022-23 and 2023-24 were based on estimates derived from undergraduate and graduate enrollment percentages rather than actual tuition and fee assessments as required by FISAP instructions. To correct this issue, the University will discontinue the use of formulated allocations and implement a process that uses actual tuition and mandatory fee assessment data for students reported in FISAP Part II, Section D. Financial Aid will work with Financial Services, Institutional Research and Business Services to develop a report that identifies actual assessed tuition and fees, net of applicable refunds, and separately reports undergraduate and graduate amounts. To prevent recurrence, the University will establish an independent review of the tuition and fee calculations before each FISAP submission. The review will verify that the reported amounts are based on actual student charges, properly classified by student level, and consistent with FISAP reporting requirements. These actions will ensure future FISAP submissions comply with federal reporting instructions and accurately reflect actual tuition and fee assessments for the reported student population. Responsible Party - James Broscheit, Director of Financial Aid, Montana State University - Bozeman Justin Beach, Director of Financial Aid & Scholarships, Montana State University - Billings Target Implementation Date - 10/31/2026
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