Corrective Action Plans

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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
Equipment Inventory Controls - R&D - UM - The University of Montana - Missoula will establish a system-level inventory monitoring process by generating an annual listing from the Banner system to identify all departments required to perform inventories. This listing will serve as the official invent...
Equipment Inventory Controls - R&D - UM - The University of Montana - Missoula will establish a system-level inventory monitoring process by generating an annual listing from the Banner system to identify all departments required to perform inventories. This listing will serve as the official inventory checklist and will be used to track and verify inventory completion. The University will continue to use the dedicated staff member responsible for capital asset management and will perform physical inventories every two years to verify asset existence and ensure all capital assets are properly tagged. Responsible Party - Rachel Buswell, Controller, University of Montana - Missoula Target Implementation Date - 3/31/2027
Noncompliant FFATA Reports - Medicaid - DPHHS - The Montana Department of Public Health and Human Services agrees that internal control deficiencies existed in its Federal Funding Accountability and Transparency Act (FFATA) subaward reporting processes during fiscal years 2024 and 2025, and that ins...
Noncompliant FFATA Reports - Medicaid - DPHHS - The Montana Department of Public Health and Human Services agrees that internal control deficiencies existed in its Federal Funding Accountability and Transparency Act (FFATA) subaward reporting processes during fiscal years 2024 and 2025, and that instances of noncompliance occurred. The department has implemented additional internal controls and has corrected the Medicaid FFATA reports. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 7/1/2025
Inadequate HAP Reconciliation Controls - HVC - Commerce - The Montana Department of Commerce has provided additional staff training to ensure housing assistance payments are issued timely, even though the error rate was less than one percent. Responsible Party - Ingrid Mallo, Chief Financial Officer...
Inadequate HAP Reconciliation Controls - HVC - Commerce - The Montana Department of Commerce has provided additional staff training to ensure housing assistance payments are issued timely, even though the error rate was less than one percent. Responsible Party - Ingrid Mallo, Chief Financial Officer, Montana Department of Commerce Target Implementation Date - 8/19/2026
Inadequate Inspection Controls - HVC - Commerce - The Montana Department of Commerce implemented the United States Department of Housing and Urban Development’s new inspection protocol on July 1, 2026. This protocol will ensure staff are able to perform the required inspections. Responsible Party - ...
Inadequate Inspection Controls - HVC - Commerce - The Montana Department of Commerce implemented the United States Department of Housing and Urban Development’s new inspection protocol on July 1, 2026. This protocol will ensure staff are able to perform the required inspections. Responsible Party - Ingrid Mallo, Chief Financial Officer, Montana Department of Commerce Target Implementation Date - 9/18/2025
Inadequate HAPPY System Access Controls - HVC - Commerce - The Montana Department of Commerce began conducting user access reviews during the audit period. The department’s Chief Information Officer updated the Access Control Policy and distributed it to all employees. Staff received training on acc...
Inadequate HAPPY System Access Controls - HVC - Commerce - The Montana Department of Commerce began conducting user access reviews during the audit period. The department’s Chief Information Officer updated the Access Control Policy and distributed it to all employees. Staff received training on access control requirements on May 28, 2026. The department plans to obtain a new vendor to replace the HAPPY system by October 2028. Responsible Party - Ingrid Mallo, Chief Financial Officer, Montana Department of Commerce Target Implementation Date - 10/31/2028
Inadequate Field Agent Payment Controls - HVC - Commerce - The Montana Department of Commerce has updated its processes to ensure that contract limits are reviewed prior to payments being issued and that contract amendments are pursued when needed. Responsible Party - Ingrid Mallo, Chief Financial O...
Inadequate Field Agent Payment Controls - HVC - Commerce - The Montana Department of Commerce has updated its processes to ensure that contract limits are reviewed prior to payments being issued and that contract amendments are pursued when needed. Responsible Party - Ingrid Mallo, Chief Financial Officer, Montana Department of Commerce Target Implementation Date - 8/24/2026
Inadequate HQS Inspection Controls - HVC - Commerce - The Montana Department of Commerce has updated its inspection procedures to clearly outline requirements, including annual reexaminations. While the department may have lacked documentation of certain monthly reports, both the fiscal year 2024 an...
Inadequate HQS Inspection Controls - HVC - Commerce - The Montana Department of Commerce has updated its inspection procedures to clearly outline requirements, including annual reexaminations. While the department may have lacked documentation of certain monthly reports, both the fiscal year 2024 and fiscal year 2025 Section 8 Management Assessment Program Indicator 12 inspection reviews received all available points. The department is also transitioning to the National Standards for the Physical Inspection of Real Estate (NSPIRE) model for inspections. Staff completed training on June 16, 2026, and have begun using the federal inspection checklist to ensure compliance with current standards. Responsible Party - Ingrid Mallo, Chief Financial Officer, Montana Department of Commerce Target Implementation Date - 9/18/2025
Inadequate FASS Reporting Controls - HVC - Commerce - The Montana Department of Commerce has developed procedures for the Financial Assessment Subsystem (FASS) reports to ensure they are complete and accurate and that the reviews of these reports are sufficiently documented. Responsible Party - Ingr...
Inadequate FASS Reporting Controls - HVC - Commerce - The Montana Department of Commerce has developed procedures for the Financial Assessment Subsystem (FASS) reports to ensure they are complete and accurate and that the reviews of these reports are sufficiently documented. Responsible Party - Ingrid Mallo, Chief Financial Officer, Montana Department of Commerce Target Implementation Date - 8/20/2026
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