Corrective Action Plans

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Noncompliant Excess Cash Management Controls - SFA - MSU - The Montana State University - Bozeman concurs. Because this issue was identified in the previous audit, the University implemented corrective action at the conclusion of that audit to prevent excess cash. The University does not expect this...
Noncompliant Excess Cash Management Controls - SFA - MSU - The Montana State University - Bozeman concurs. Because this issue was identified in the previous audit, the University implemented corrective action at the conclusion of that audit to prevent excess cash. The University does not expect this to be an issue in future audits. The Montana State University - Northern concurs. The University added a new internal control process in fiscal year 2025. Staff now receive a daily cash balance report for federal student financial aid funds that is automatically emailed to Business Services personnel. This process allows staff to monitor the balance and issue refunds as needed. The University believes this process will be effective in detecting and preventing noncompliance going forward. The Great Falls College concurs. The College will continue the controls established in July 2024, which have resulted in zero instances of excess cash since implementation. Responsible Party - James Broscheit, Director of Financial Aid, Montana State University - Bozeman Chris Wendland, Controller, Montana State University - Northern Carmen Roberts, Executive Director of Finance and Administration, Great Falls College – Montana State University Target Implementation Date - 1/31/2025
Noncompliant Return of Uncashed Title IV Funds - SFA - MSU - The Montana State University - Bozeman concurs with the finding. A process has now been implemented for Higher Education Act loans in addition to Parent Loans for Undergraduate Students. This process has been formally documented, and the U...
Noncompliant Return of Uncashed Title IV Funds - SFA - MSU - The Montana State University - Bozeman concurs with the finding. A process has now been implemented for Higher Education Act loans in addition to Parent Loans for Undergraduate Students. This process has been formally documented, and the University will continue to provide cross-training on these procedures. Responsible Party - Ryan Christensen, Director of Student Accounts, Montana State University - Bozeman Target Implementation Date - 8/31/2026
Noncompliant Incentive Compensation Controls - SFA - MSU - The Montana State University - Bozeman concurs with the finding. Since approximately 2023, language has been included on the lump-sum bonus form that prohibits any bonus for classified staff related to the recruitment or admission of student...
Noncompliant Incentive Compensation Controls - SFA - MSU - The Montana State University - Bozeman concurs with the finding. Since approximately 2023, language has been included on the lump-sum bonus form that prohibits any bonus for classified staff related to the recruitment or admission of students. Any bonus request submitted to the Office of the Commissioner of Higher Education for contract employees is reviewed and approved by the University's Compensation Advisory Council, which also reviewed these federal regulations. In December 2024, the Montana University System Staff Compensation Plan was updated to explicitly exclude such payments. Responsible Party - Jeannette Grey Gilbert, Chief Human Resources Officer, Montana State University - Bozeman Target Implementation Date - 12/31/2024
Noncompliant GLBA Oversight - SFA - MSU - The Montana State University - Bozeman concurs. The University has hired a Chief Information Security Officer, who is designated as the Qualified Individual as part of the University’s Information Security Plan. Responsible Party - John Williams, Chief Infor...
Noncompliant GLBA Oversight - SFA - MSU - The Montana State University - Bozeman concurs. The University has hired a Chief Information Security Officer, who is designated as the Qualified Individual as part of the University’s Information Security Plan. Responsible Party - John Williams, Chief Information Security Officer, Montana State University - Bozeman Target Implementation Date - 2/28/2025
Inaccurate COA Calculations - SFA - UM - The University of Montana – Missoula conducted additional review and provided supplemental documentation and clarification for the remaining sampled student records; however, one exception could not be fully resolved. The University is committed to strengthen...
Inaccurate COA Calculations - SFA - UM - The University of Montana – Missoula conducted additional review and provided supplemental documentation and clarification for the remaining sampled student records; however, one exception could not be fully resolved. The University is committed to strengthening its documentation, retention, and review processes to ensure that support for cost-of-attendance calculations and adjustments is consistently maintained, documented, and adequately substantiated going forward. Responsible Party - Morgan Hahn, Interim Financial Aid Director, University of Montana - Missoula Target Implementation Date - 12/31/2026
Inaccurate Enrollment Reporting - SFA - UM - The University of Montana - Missoula partially concurs because the University agrees that accurate and timely enrollment reporting is essential to compliance with federal requirements and recognizes the importance of maintaining effective controls over th...
Inaccurate Enrollment Reporting - SFA - UM - The University of Montana - Missoula partially concurs because the University agrees that accurate and timely enrollment reporting is essential to compliance with federal requirements and recognizes the importance of maintaining effective controls over the enrollment reporting process. However, the University is continuing to review the circumstances underlying this finding, including the interaction between institutional records, third-party reporting processes, and federal systems, and has not yet completed its assessment of all contributing factors. The University will enhance monitoring, reconciliation, and verification procedures to support accurate and timely reporting of enrollment information. Responsible Party - Morgan Hahn, Interim Financial Aid Director, University of Montana - Missoula Target Implementation Date - 3/31/2027
Inaccurate Federal Aid Return Calculations - SFA - UM - The University of Montana - Missoula will continue strengthening controls over Return of Title IV calculations through increased coordination among involved offices, enhanced review of academic calendar and system data, and additional oversight...
Inaccurate Federal Aid Return Calculations - SFA - UM - The University of Montana - Missoula will continue strengthening controls over Return of Title IV calculations through increased coordination among involved offices, enhanced review of academic calendar and system data, and additional oversight of withdrawal-related processes. The University is committed to continuous improvement and to ensuring accurate calculations going forward. Responsible Party - Morgan Hahn, Interim Financial Aid Director, University of Montana - Missoula Target Implementation Date - 1/31/2027
Inadequate FISAP Reporting Controls - SFA - UM - The Montana Technological University will establish a centralized repository and require supporting documentation for all key FISAP report line items to be retained in that location. The Helena College will establish automated procedures to reduce man...
Inadequate FISAP Reporting Controls - SFA - UM - The Montana Technological University will establish a centralized repository and require supporting documentation for all key FISAP report line items to be retained in that location. The Helena College will establish automated procedures to reduce manual processes, as well as a centralized repository for supporting documentation pertaining to all FISAP report line items. The University of Montana - Western will establish a procedure for documenting the required tuition and fees line items that must be reported on the FISAP and that correspond to the student population reported in Section D of the FISAP. The University of Montana - Missoula will strengthen FISAP reporting controls by formalizing procedures, improving documentation retention, centralizing supporting records, and implementing additional review of reported data before submission. The university is also exploring improvements to reporting and data-management processes to support accurate and reliable reporting. Responsible Party - Carleen Cassidy, Director of Finance and Budget, Montana Technological University Valerie Curtin, Executive Director of Compliance & Financial Aid, Helena College of Technology - University of Montana Louise Driver, Financial Aid Director, University of Montana - Western Morgan Hahn, Interim Financial Aid Director, University of Montana - Missoula Target Implementation Date - 9/30/2026
Noncompliant Title IV Disbursement Notification Controls - SFA - UM - The University of Montana - Missoula has implemented changes for the 2026–2027 award year to ensure required Title IV disbursement notifications are generated, reviewed, and retained. The University will maintain documented proced...
Noncompliant Title IV Disbursement Notification Controls - SFA - UM - The University of Montana - Missoula has implemented changes for the 2026–2027 award year to ensure required Title IV disbursement notifications are generated, reviewed, and retained. The University will maintain documented procedures and periodic oversight to support ongoing compliance. Responsible Party - Morgan Hahn, Interim Financial Aid Director, University of Montana - Missoula Target Implementation Date - 10/1/2026
Noncompliant Direct Loan Reconciliation Controls - SFA - UM - The University of Montana - Missoula will strengthen reconciliation procedures by assigning responsibility to designated staff, requiring documented supervisory review, retaining supporting reconciliation documentation, and monitoring tim...
Noncompliant Direct Loan Reconciliation Controls - SFA - UM - The University of Montana - Missoula will strengthen reconciliation procedures by assigning responsibility to designated staff, requiring documented supervisory review, retaining supporting reconciliation documentation, and monitoring timely and consistent completion of reconciliations. Management will conduct periodic oversight to ensure reconciliation requirements are completed in accordance with federal regulations and institutional procedures. Responsible Party - Morgan Hahn, Interim Financial Aid Director, University of Montana - Missoula Target Implementation Date - 12/31/2026
Noncompliant 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 Return of Uncashed Title IV Funds - SFA - UM - The University of Montana - Missoula will implement procedures to identify uncashed Title IV credit balance checks, monitor applicable return deadlines, and return funds to the U.S. Department of Education when required. The university will...
Noncompliant Return of Uncashed Title IV Funds - SFA - UM - The University of Montana - Missoula will implement procedures to identify uncashed Title IV credit balance checks, monitor applicable return deadlines, and return funds to the U.S. Department of Education when required. The university will implement written procedures, staff training, and periodic reviews to support compliance. Responsible Party - Morgan Hahn, Interim Financial Aid Director, University of Montana - Missoula Target Implementation Date - 6/30/2027
Noncompliant Incentive Compensation Controls - SFA - UM - The University of Montana - Missoula will strengthen enforcement of existing procedures by implementing a formal incentive compensation policy that prohibits incentive compensation based on enrollment or financial aid outcomes and helps ensur...
Noncompliant Incentive Compensation Controls - SFA - UM - The University of Montana - Missoula will strengthen enforcement of existing procedures by implementing a formal incentive compensation policy that prohibits incentive compensation based on enrollment or financial aid outcomes and helps ensure compliance with federal regulations. Responsible Party - Jay Stephens, Vice President for People and Culture, University of Montana - Missoula Target Implementation Date - 3/8/2026
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
Noncompliant Direct Loan Reconciliation Controls - SFA - MSUB - The Montana State University - Billings concurs with the finding and has taken corrective action to strengthen segregation of duties within the cash management reconciliation process. While the reconciliation process has historically in...
Noncompliant Direct Loan Reconciliation Controls - SFA - MSUB - The Montana State University - Billings concurs with the finding and has taken corrective action to strengthen segregation of duties within the cash management reconciliation process. While the reconciliation process has historically involved both Financial Aid and Financial Services personnel, the reconciliation and review were performed inconsistently within the Financial Aid office. Effective immediately, Financial Aid and Financial Services have implemented a monthly reconciliation meeting to jointly review and validate the cash management reconciliation. During this meeting, Financial Services provides reconciliation information from the University’s financial records, and Financial Aid independently extracts and reviews corresponding information from the Banner system and the Common Origination and Disbursement system. Any discrepancies identified are discussed and resolved collaboratively. The monthly meeting and review process will be documented and retained as evidence of review and approval. This enhanced process establishes a formal review control involving personnel from separate offices and strengthens segregation of duties over the cash management reconciliation process. Responsible Party - Justin Beach, Director of Financial Aid & Scholarships, Montana State University - Billings Rebecca Bunn, Controller, Montana State University - Billings Target Implementation Date - 8/31/2026
Inadequate Grant Reconciliations - SPED - OPI - The Montana Office of Public Instruction will update procedures and desk manuals to ensure monthly reconciliations for federal programs between the agency’s grant system, the state’s accounting system, and a manually updated tracking spreadsheet contai...
Inadequate Grant Reconciliations - SPED - OPI - The Montana Office of Public Instruction will update procedures and desk manuals to ensure monthly reconciliations for federal programs between the agency’s grant system, the state’s accounting system, and a manually updated tracking spreadsheet contain adequate documentation and verify federal compliance. Responsible Party - April Grady, Chief Financial Officer, Montana Office of Public Instruction 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
Inaccurate and Unsupported Maintenance of State Financial Support - SPED - OPI - The Montana Office of Public Instruction partially concurs with this finding. The Office developed a standardized process and process manual for maintenance of effort in December 2025. The Office will follow this proces...
Inaccurate and Unsupported Maintenance of State Financial Support - SPED - OPI - The Montana Office of Public Instruction partially concurs with this finding. The Office developed a standardized process and process manual for maintenance of effort in December 2025. The Office will follow this process in future years to ensure the tracking spreadsheet uses budget allocations from the same data query for all years and all agencies. During the audit period, this funding allocation for the Office was combined into Base Aid and is separated in the budget system rather than in the accounting system. Staff will continue to follow the standardized process and process manual to ensure consistency. Responsible Party - April Grady, Chief Financial Officer, Montana Office of Public Instruction Target Implementation Date - 12/31/2026
Inadequate Assurance Over Controls at Service Organization - SNAP - DPHHS - The Montana Department of Public Health and Human Services does not concur. The department agrees that 7 CFR 274.8(b)(3)(i) requires the state agency to ensure that its electronic benefit transfer system includes storage and...
Inadequate Assurance Over Controls at Service Organization - SNAP - DPHHS - The Montana Department of Public Health and Human Services does not concur. The department agrees that 7 CFR 274.8(b)(3)(i) requires the state agency to ensure that its electronic benefit transfer system includes storage and control measures for blank unissued cards. The department satisfies this requirement through controls operated by its contracted electronic benefit transfer vendor rather than through state‑held card stock. The department does not concur that this control is absent. As provided in 2 CFR 200.511(c), the explanation below describes why corrective action is not required. The department does not issue electronic benefit transfer cards over the counter. All card manufacture, personalization, storage, and mailing occur within the contracted vendor’s centralized issuance environment. No blank unissued cards are held in department offices or accessible to staff or the public. Blank unissued cards contain no benefits, are not associated with a participant account, and cannot be activated without a corresponding record in the electronic benefit transfer system. Their only intrinsic value is the cost of the card stock. The vendor conducts risk assessments and monitors subcontractors responsible for card stock. Independent assurance is provided through the system and Organization Controls (SOC) report, which confirms that these assessments and monitoring controls are fully implemented. Centralized issuance significantly reduces opportunities for unauthorized access, making the risk associated with blank unissued cards very low in Montana. The department also performs reconciliations independent of benefit issuance and redemption. Eligibility determinations in the departments eligibility system (CHIMES) are reconciled to the vendor’s records; retailer transactions are reconciled to the banking system; recipient transactions are reconciled to redeemed benefits; and funds drawn from the federal treasury are reconciled to the federal draw system. The department’s card monitoring controls address replaced, returned, and excessive card requests. These enhanced controls align higher‑risk activities with appropriate safeguards and oversight. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - N/A
Inadequate HDS System Access Controls - HVC - Commerce - The Montana Department of Commerce has developed a user access review procedure to be performed semiannually. The first review was completed in June 2026. Responsible Party - Ingrid Mallo, Chief Financial Officer, Montana Department of Commerc...
Inadequate HDS System Access Controls - HVC - Commerce - The Montana Department of Commerce has developed a user access review procedure to be performed semiannually. The first review was completed in June 2026. Responsible Party - Ingrid Mallo, Chief Financial Officer, Montana Department of Commerce Target Implementation Date - 12/16/2026
Noncompliant Section 8 Cash Management - HVC - Commerce - The Montana Department of Commerce took steps in September 2023 to update the Treasury State Agreement to clarify that settlement dates occur within five business days after receiving funds from the United States Department of Housing and Urb...
Noncompliant Section 8 Cash Management - HVC - Commerce - The Montana Department of Commerce took steps in September 2023 to update the Treasury State Agreement to clarify that settlement dates occur within five business days after receiving funds from the United States Department of Housing and Urban Development. In September 2024, the department again coordinated a revision to the agreement language to reflect mid-month payment practices. These updates are included in the 2026 Treasury State Agreement, signed July 1, 2025. Responsible Party - Ingrid Mallo, Chief Financial Officer, Montana Department of Commerce Target Implementation Date - 7/1/2025
Equipment Inventory Controls - R&D - MSU - The Montana State University - Bozeman concurs and has already engaged in several improvements to its inventory processes. It is increasing proactive communication with department heads and other leaders across campus when physical inventory is taking place...
Equipment Inventory Controls - R&D - MSU - The Montana State University - Bozeman concurs and has already engaged in several improvements to its inventory processes. It is increasing proactive communication with department heads and other leaders across campus when physical inventory is taking place. It is adding more information into the procurement system to identify the location of items at the time of purchase to ensure accurate documentation and future inventory. It is including the property management team in employee termination paperwork to ensure a new responsible party is identified for any assigned asset prior to departure. It is coordinating with a newly hired research asset coordinator to complete cross-training. The University has made significant progress from the last finding to the current finding. Responsible Party - Kristy Colling, Controller, Montana State University - Bozeman Target Implementation Date - 8/31/2026
Noncompliant Procurement Delegation - R&D - DOA, MUS - The Montana Department of Administration State Procurement Services Division is centralizing procurement staff and processes across all agencies to improve consistency in laws, rules, procedures, and policies when agencies procure products and s...
Noncompliant Procurement Delegation - R&D - DOA, MUS - The Montana Department of Administration State Procurement Services Division is centralizing procurement staff and processes across all agencies to improve consistency in laws, rules, procedures, and policies when agencies procure products and services. To modernize and integrate procurement in the Statewide Accounting, Budgeting, and Human Resources System and to strengthen oversight and payment of contractual obligations, the department is soliciting a new procurement system. All agencies will be required to document contract management activities in the new system. Compliance reviews will be conducted by a Department of Administration internal auditor beginning in fiscal year 2027 and will be prioritized according to risk assessment scores, auditor workload, and agency capacity. The department has improved compliance for sole‑source grants by appointing new committee members, and annual training for policies and procedures will be revised as needed. The State Procurement Services Division will develop and distribute a standard form for declaring exigencies to ensure agencies document all information required by statute, rule, and policy. The division is also preparing changes to administrative rules to clarify definitions and help agencies distinguish between exigent purchases and other expedited purchasing methods. The University of Montana - Missoula will continue working with the Montana Office of the Commissioner of Higher Education, which serves as the university’s liaison with the Department of Administration, to ensure written delegation agreements are executed and maintained in a timely manner. Montana State University - Bozeman concurs with the finding and agrees there are no questioned costs associated with the condition. The university will continue to work with the Montana University System office to receive an executed delegation of authority. A draft delegation was received from the Department of Administration in May 2026, and the university system provided feedback. As of the date of the audit report, the university has not received an update from the department. Responsible Party - Molly McLoughlin, Administrator, Montana Department of Administration Bob Hlynosky, Director of Procurement, University of Montana - Missoula Brian O'Connor, Chief Procurement Officer, Montana Office of the Commissioner of Higher Education Target Implementation Date - 6/30/2027
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
Inadequate Grant Expenditure Reconciliations - R&D - UM - The University of Montana - Missoula has implemented the remediation plan from the prior audit by establishing an additional periodic supervisory review to monitor ledger completion. Managers currently review a random sample of five files eac...
Inadequate Grant Expenditure Reconciliations - R&D - UM - The University of Montana - Missoula has implemented the remediation plan from the prior audit by establishing an additional periodic supervisory review to monitor ledger completion. Managers currently review a random sample of five files each month from each grants and contracts officer’s workload to verify that ledgers are current and complete, and any deficiencies identified are promptly addressed to ensure compliance with established procedures. Responsible Party - Nicole Thompson, Director, Office of Sponsored Programs, University of Montana - Missoula Target Implementation Date - 3/1/2026
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