State Assessment of Internal Controls Final Report, May 2007

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E. Montana

1. Review Team Process

Prior to the site visit, Montana reviewed the Instrument and all associated criteria. Because of the review, Montana realized that the Instrument was broader in scope than anticipated. The Montana Project Team identified the staff member from each area most appropriate to complete the Instrument. In the few instances where they did not identify the appropriate staff resources, the team approached the Director of that agency for the needed support. Montana had no difficulty obtaining the necessary cooperation with the other participating agencies. The Montana team stressed that, to save time, a core group should first review the Instrument before engaging the larger group.

2. Benefits of the Instrument

Montana was optimistic that the Instrument would inform the work of the child care program and assist in identifying policies, practices, and procedures to prevent errors that could result in improper payments. The Montana Project Team stated that the Instrument was useful and that the information reinforced information identified in other process work in the State. Several areas highlighted weaknesses that the agency needs to address, such as succession planning for staffing, the sharing of IT planning documents, developing future strategies, writing desk manuals to reduce confusion during periods of staff turnover, and disaster planning with agencies contracted with to administer portions of the child care program.

3. Changes to the Instrument

The Montana Project Team proposed the following changes to the Instrument:

• Revising the Instrument to reduce or eliminate redundancy;
• Including a section specific to the child care program;
• Stressing that States must have an upfront understanding of the internal controls in other areas of the organization and how those controls influence the child care program; and
• Requesting guidance from Federal staff in the Central and ACF Regional Offices on how to use the results.

4. Recommendations

Montana Project Team recommendations included:

• Assigning an administrative assistant to the project to coordinate the process to free up the administrator’s time;
• Allowing adequate time to complete the process;
• Establishing an agreed upon timeframe to ensure a timely and thoughtful completion of the Instrument;
• Allowing 90 days to complete the Instrument;
• Scheduling to minimize the conflict of other major activities occurring at the same time as the self-assessment process; and
• Reviewing and updating the Instrument every five years, except in the areas such as the IT plan and the HR manual, which may require more frequent changes.

Posted January 31, 2008