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DEPARTMENT OF THE TREASURY
W ASHINGTON, D. C. 20220
OFFICE OF
December 18, 2024
INSPECTOR GENERAL
MEMORANDUM FOR JESSICA MILANO, CHIEF PROGRAM OFFICER, OFFICE OF
CAPITAL ACCESS, DEPARTMENT OF THE TREASURY
FROM: Deborah L. Harker /s/
Assistant Inspector General for Audit
SUBJECT: Desk Review of Oklahoma County, Oklahoma’s Use of
Coronavirus Relief Fund Proceeds
(OIG-CA-25-022)
Please find the attached desk review memorandum 1 on Oklahoma County,
Oklahoma’s (Oklahoma County) use of Coronavirus Relief Fund (CRF) proceeds.
The CRF is authorized under Title VI of the Social Security Act, as amended by
Title V, Division A of the Coronavirus Aid, Relief, and Economic Security Act
(CARES Act). Under a contract monitored by our office, Castro & Company, LLC
(Castro), a certified independent public accounting firm, performed the desk
review. Castro performed the desk review in accordance with the Council of the
Inspectors General on Integrity and Efficiency Quality Standards for Federal
Offices of Inspector General standards of independence, due professional care,
and quality assurance.
In its desk review, Castro personnel reviewed documentation for a non-statistical
selection of 20 transactions reported in the quarterly Financial Progress Reports
(FPR) and identified unsupported and ineligible questioned costs of $91,218 and
$326,664, respectively, resulting in total questioned costs of $417,882 (see
attached schedule of monetary benefits).2
1
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) assigned the Department of
the Treasury Office of Inspector General with responsibility for compliance monitoring and
oversight of the receipt, disbursement, and use of Coronavirus Relief Fund (CRF) payments. The
purpose of the desk review is to perform monitoring procedures of the prime recipient’s receipt,
disbursement, and use of CRF proceeds as reported in the grant-reporting portal on a quarterly
basis.
2 Questioned costs consist of unsupported and ineligible expenditures related to transfers made to
multiple local governments, unsupported air purifying system upgrades, and unsupported payroll
expenses.
Page 2
Castro determined that the expenditures related to Transfers greater than or equal
to $50,000,3 Aggregate Reporting less than $50,000,4 and Aggregate Payments to
Individuals5 payment types did not comply with the CARES Act and the
Department of the Treasury’s (Treasury) Guidance. Castro determined that the
expenditures related to the Contracts greater than or equal to $50,000 payment
type complied with the CARES Act and Treasury’s Guidance. Castro determined
Oklahoma County’s risk of unallowable use of funds is moderate.
Castro recommends that Treasury Office of Inspector General (OIG) follow up with
Oklahoma County’s management to confirm if the $91,218 noted as unsupported
expenditures within the Transfers greater than or equal to $50,000, Aggregate
Reporting less than $50,000, and Aggregate Payments to Individuals payment
types can be supported. If support is not provided, Treasury OIG should recoup
the funds or request Oklahoma County management to provide support for
replacement expenses, not previously charged, that were eligible during the CRF
period of performance.
In addition, Castro recommends that Treasury OIG request Oklahoma County
management to provide support for replacement expenses, not previously
charged, that were eligible during the CRF period of performance for the $326,664
of ineligible costs charged to the Transfers greater than or equal to $50,000
payment type. If support is not provided, Treasury OIG should recoup the funds.
Further, based on Oklahoma County’s responsiveness to Treasury OIG’s requests
and management’s ability to provide sufficient documentation and/or replace
unsupported and ineligible transactions charged to CRF with valid expenditures,
Castro recommends that Treasury OIG determine the feasibility of conducting an
audit for the Transfers greater than or equal to $50,000, Aggregate Reporting less
than $50,000, and Aggregate Payments to Individuals payment types.
At the time of desk review fieldwork, Castro noted that Oklahoma County had
findings in their Single Audit Act Reports for fiscal years (FY) 2021 and 2022.
Castro recommends that Treasury OIG follow-up with Treasury’s Office of Capital
Access to ensure that management decision letters are issued on the findings
identified by the auditor in the Single Audit Act reports, as summarized below:
3 A transfer to another government entity is a disbursement or payment to a government entity
that is legally distinct from the prime recipient.
4
Recipients are required to report CRF transactions greater than or equal to $50,000 in detail in the
grant-reporting portal. Transactions less than $50,000 can be reported as an aggregate lump-sum
amount by type (contracts, grants, loans, direct payments, and transfers to other government
entities).
5
Obligations and expenditures for payments made to individuals, regardless of amount, are
required to be reported in the aggregate in the grant-reporting portal to prevent inappropriate
disclosure of personally identifiable information.
Page 3
o Oklahoma County’s FY 2021 Single Audit Act report was published on
June 30, 2022, and the auditor identified unsupported questioned costs
specific to the CRF in the amount of $36,344,500.
o Oklahoma County’s FY 2022 Single Audit Act report was published on
June 4, 2024, and the auditor identified unsupported questioned costs
specific to the CRF in the amount of $176,562.
Castro also recommends that Treasury OIG follow-up with Oklahoma County to
request that Oklahoma County management performs an assessment over the
$1,288,109 in grant funds paid to the Oklahoma County Home Finance Authority,
which were not tested by Castro, to determine if rental assistance payments and
prepaid debit card payments were made utilizing solely Oklahoma County’s CRF
proceeds, or if these expenses were paid with State of Oklahoma and Oklahoma
City funding sources. If support is not provided, Treasury OIG should recoup the
funds or request Oklahoma County management to provide support for
replacement expenses, not previously charged, that were eligible during the CRF
period of performance.
Treasury OIG and Castro met with Oklahoma County management to discuss the
report. Oklahoma County management stated they would provide additional
documentation to Treasury OIG to support the questioned costs or replace them
with other eligible expenditures.
In connection with our contract with Castro, we reviewed Castro’s desk review
memorandum and related documentation and inquired of its representatives. Our
review, as differentiated from an audit performed in accordance with generally
accepted government auditing standards, was not intended to enable us to
express an opinion on Oklahoma County’s use of CRF proceeds. Castro is
responsible for the attached desk review memorandum and the conclusions
expressed therein. Our review found no instances in which Castro did not comply
in all material respects with the Quality Standards for Federal Offices of Inspectors
General.
We appreciate the courtesies and cooperation provided to Castro and our staff
during the desk review. If you have any questions or require further information,
please contact me at (202) 486-1420, or a member of your staff may contact Lisa
DeAngelis, Audit Director, at (202) 487-8371.
Page 4
cc:
Michelle. A. Dickerman, Deputy Assistant General Counsel, Department of
the Treasury
Danielle Christensen, Deputy Chief Program Officer, Office of Capital
Access, Department of the Treasury
Wayne Ference, Partner, Castro & Company, LLC
Brian Maughan, County Commissioner District 2, County of Oklahoma
Page 5
Attachment
Schedule of Monetary Benefits
According to the Code of Federal Regulations, 6 a questioned cost is a cost that is
questioned due to a finding:
(a) which resulted from a violation or possible violation of a statute,
regulation, or the terms and conditions of a Federal award, including for
funds used to match Federal funds;
(b) where the costs, at the time of the review, are not supported by
adequate documentation; or
(c) where the costs incurred appear unreasonable and do not reflect the
actions a prudent person would take in the circumstances.
Questioned costs are to be recorded in Treasury’s Joint Audit Management
Enterprise System (JAMES).7 The amount will also be included in the OIG
Semiannual Report to Congress. It is Treasury management's responsibility to
report to Congress on the status of the agreed to recommendations with
monetary benefits in accordance with 5 USC 405.
Recommendation Questioned Costs
Recommendation No. 1 $417,882
The questioned costs represent amounts provided by Treasury under the
Coronavirus Relief Fund. As discussed in the attached desk review, $417,882 is
Oklahoma County’s expenditures reported in the grant-reporting portal that were
ineligible or lacked supporting documentation.
6
2 CFR § 200.84 – Questioned Cost
7
JAMES is Treasury’s audit recommendation tracking system.
1635 King Street
Alexandria, VA 22314
Phone: 703.229.4440
Fax: 703.859.7603
www.castroco.com
Desk Review of Oklahoma County, Oklahoma
December 18, 2024
OIG-CA-25-022
MEMORANDUM FOR DEBORAH L. HARKER,
ASSISTANT INSPECTOR GENERAL FOR AUDIT
FROM: Wayne Ference
Partner, Castro & Company, LLC
SUBJECT: Desk Review of Oklahoma County, Oklahoma
On April 3, 2024, we initiated a desk review of Oklahoma County, Oklahoma’s
(Oklahoma County) use of the Coronavirus Relief Fund (CRF) authorized under
Title VI of the Social Security Act, as amended by Title V, Division A of the
Coronavirus Aid, Relief, and Economic Security Act (CARES Act). 1 The objective of
our desk review was to evaluate Oklahoma County’s documentation supporting
its uses of CRF proceeds as reported in the GrantSolutions2 portal and to assess
the risk of unallowable use of funds. The scope of our desk review was limited to
obligation and expenditure data for the period of March 1, 2020 through
September 30, 2022,3 as reported in the GrantSolutions portal.
As part of our desk review, we performed the following:
1) reviewed Oklahoma County’s quarterly Financial Progress Reports (FPRs)
submitted in the GrantSolutions portal through September 30, 2022;
2) reviewed the Department of the Treasury’s (Treasury) Coronavirus Relief
Fund Guidance as published in the Federal Register on January 15, 2021; 4
1
P.L. 116-136 (March 27, 2020).
2
GrantSolutions, a grant and program management Federal shared service provider under the
United States (U.S.) Department of Health and Human Services, developed a customized and user-
friendly reporting solution to capture the use of CRF payments from prime recipients.
3
Oklahoma County fully expended their total CRF proceeds as of September 30, 2022. Castro set
the scope end date to September 30, 2022, which was the date of Oklahoma County’s last
reporting submission within the GrantSolutions portal.
4
Coronavirus Relief Fund Guidance as published in the Federal Register (January 15, 2021)
https://home.treasury.gov/system/files/136/CRF-Guidance-Federal-Register_2021-00827.pdf
1
Desk Review of Oklahoma County, Oklahoma
3) reviewed Treasury’s Office of Inspector General (OIG) Coronavirus Relief
Fund Frequently Asked Questions Related to Reporting and
Recordkeeping;5
4) reviewed Treasury OIG’s monitoring checklists6 of Oklahoma County’s
quarterly FPR submissions for reporting deficiencies;
5) reviewed other audit reports issued, such as Single Audit Act reports, 7 and
those issued by the Government Accountability Office and other applicable
Federal agency OIGs for internal control or other deficiencies that may
pose risk or impact Oklahoma County’s uses of CRF proceeds;
6) reviewed Treasury OIG Office of Investigations, the Council of the
Inspectors General on Integrity and Efficiency Pandemic Response
Accountability Committee,8 and Treasury OIG Office of Counsel input on
issues that may pose risk or impact Oklahoma County’s uses of CRF
proceeds;
7) interviewed key personnel responsible for preparing and certifying
Oklahoma County’s GrantSolutions portal quarterly FPR submissions, as
well as officials responsible for obligating and expending CRF proceeds;
5
Department of the Treasury Office of Inspector General Coronavirus Relief Fund Frequently Asked
Questions Related to Reporting and Recordkeeping OIG-20-028R; March 2, 2021.
6
The checklists were used by Treasury OIG personnel to monitor the progress of prime recipient
reporting in the GrantSolutions portal. GrantSolutions quarterly submission reviews were
designed to identify material omissions and significant errors, and where necessary, included
procedures for notifying prime recipients of misreported data for timely correction. Treasury OIG
followed the CRF Prime Recipient Quarterly GrantSolutions Submissions Monitoring and Review
Procedures Guide, OIG-CA-20-029R to monitor the prime recipients on a quarterly basis.
7
P. L. 104-156 (July 5, 1996) The Single Audit Act of 1984, as amended in 1996, requires entities
who receive federal funds in excess of $750,000 to undergo an annual audit of those Federal funds.
The act was enacted for the purpose of promoting sound financial management, including
effective internal controls, with respect to Federal awards administered by non-Federal entities and
to establish uniform requirements for audits. This prime recipient was subject to those audit
requirements, and Castro reviewed applicable prior year single audit reports as part of our desk
review risk assessment procedures.
8
Section 15010 of P.L. 116-136, the CARES Act, established the Pandemic Response Accountability
Committee within the Council of the Inspectors General on Integrity and Efficiency to promote
transparency and conduct and support oversight of covered funds (see Footnote 15 for a definition
of covered funds) and the coronavirus response to (1) prevent and detect fraud, waste, abuse, and
mismanagement; and (2) mitigate major risks that cut across program and agency boundaries.
2
Desk Review of Oklahoma County, Oklahoma
8) made a non-statistical selection of Contracts, Transfers, 9 Aggregate
Reporting, 10 and Aggregate Payments to Individuals11 data identified
through GrantSolutions reporting; and
9) evaluated documentation and records used to support Oklahoma County’s
quarterly FPRs.
Based on our review of Oklahoma County’s documentation supporting the uses of
its CRF proceeds as reported in the GrantSolutions portal, we determined that the
expenditures related to the Contracts greater than or equal to $50,000 payment
type complied with the CARES Act and Treasury’s Guidance. Also, we determined
that the Transfers greater than or equal to $50,000, Aggregate Reporting less than
$50,000, and Aggregate Payments to Individuals payment types did not comply
with the CARES Act and Treasury’s Guidance.
We identified unsupported and ineligible questioned costs of $91,218 and
$326,664, respectively, with total questioned costs of $417,882. We also
determined Oklahoma County’s risk of unallowable use of funds is moderate.
Castro recommends that Treasury OIG follow up with Oklahoma County’s
management to confirm if the $91,218 noted as unsupported expenditures within
the Transfers greater than or equal to $50,000, Aggregate Reporting less than
$50,000, and Aggregate Payments to Individuals can be supported. If support is
not provided, Treasury OIG should recoup the funds or request Oklahoma County
management to provide support for replacement expenses, not previously
charged, that were eligible during the CRF period of performance.
In addition, Castro recommends that Treasury OIG request Oklahoma County
management to provide support for replacement expenses, not previously
charged, that were eligible during the CRF period of performance for the $326,664
of ineligible costs charged to the Transfers greater than or equal to $50,000
payment type. If support is not provided, Treasury OIG should recoup the funds.
9
A transfer to another government entity is a disbursement or payment to a government entity
that is legally distinct from the prime recipient.
10
Prime recipients were required to report CRF transactions greater than or equal to $50,000 in
detail in the GrantSolutions portal. Transactions less than $50,000 could be reported as an
aggregate lump-sum amount by type (contracts, grants, loans, direct payments, and transfers to
other government entities).
11
Obligations and expenditures for payments made to individuals, regardless of amount, were
required to be reported in the aggregate in the GrantSolutions portal to prevent inappropriate
disclosure of personally identifiable information.
3
Desk Review of Oklahoma County, Oklahoma
Further, based on Oklahoma County’s responsiveness to Treasury OIG’s requests
and management’s ability to provide sufficient documentation and/or replace
unsupported and ineligible transactions charged to CRF with valid expenditures,
we recommend Treasury OIG determine the feasibility of conducting an audit for
the Transfers greater than or equal to $50,000, Aggregate Reporting less than
$50,000, and Aggregate Payments to Individuals payment types.
Castro noted that Oklahoma County had findings in their Single Audit Act Reports
for fiscal years (FY) 2021 and 2022 during our desk review. Castro recommends
that Treasury OIG follow-up with Treasury’s Office of Capital Access to ensure that
management decision letters are issued on the findings identified by the auditor
in the Single Audit report, which we have summarized below.
o Oklahoma County’s FY 2021 Single Audit Act report was published on
June 30, 2022, and the auditor identified unsupported questioned costs
specific to the CRF in the amount of $36,344,500.
o Oklahoma County’s FY 2022 Single Audit Act report was published on
June 4, 2024, and the auditor identified unsupported questioned costs
specific to the CRF in the amount of $176,562.
Non-Statistical Transaction Selection Methodology
Treasury issued a $47,291,598 CRF payment to Oklahoma County. As of
September 30, 2022, Oklahoma County expended all of its CRF proceeds.
Oklahoma County’s cumulative obligations and expenditures by payment type are
summarized below.
Cumulative Cumulative
Payment Type Obligations Expenditures
Contracts >= $50,000 $ 4,370,395 $ 4,370,395
Grants >= $50,000 $ - $ -
Loans >= $50,000 $ - $ -
Transfers >= $50,000 $ 33,928,704 $ 33,928,704
Direct Payments >= $50,000 $ - $ -
Aggregate Reporting < $50,000 $ 6,401,369 $ 6,401,369
Aggregate Payments to
Individuals (in any amount) $ 2,591,130 $ 2,591,130
Totals $ 47,291,598 $ 47,291,598
Castro made a non-statistical selection of payments in the Contracts greater than
or equal to $50,000, Transfers greater than or equal to $50,000, Aggregate
Reporting less than $50,000, and Aggregate Payments to Individuals payment
types. Selections were made using auditor judgment based on information and
risks identified in reviewing audit reports, the GrantSolutions portal reporting
4
Desk Review of Oklahoma County, Oklahoma
anomalies12 identified by the Treasury OIG CRF monitoring team, and review of
Oklahoma County’s FPR submissions. Oklahoma County did not obligate or
expend CRF proceeds to the Grants greater than or equal to $50,000, Direct
Payments greater than or equal to $50,000, and Loans greater than or equal
to $50,000 payment types; therefore, we did not select transactions from these
payment types.
The number of transactions (20) we selected to test was based on Oklahoma
County’s total CRF award amount and our overall risk assessment of Oklahoma
County. To allocate the number of transactions (20) by payment type (Contracts
greater than or equal to $50,000, Transfers greater than or equal to $50,000,
Aggregate Reporting less than $50,000, and Aggregate Payments to Individuals),
we compared the payment type dollar amounts as a percentage of cumulative
expenditures as of September 30, 2022. The transactions selected for testing were
not selected statistically, and therefore results could not be extrapolated to the
total universe of transactions.
Background
The CARES Act appropriated $150 billion to establish the CRF. Under the CRF,
Treasury made payments for specified uses to States and certain local
governments; the District of Columbia and U.S. Territories, including the
Commonwealth of Puerto Rico, the U.S. Virgin Islands, Guam, American Samoa,
and the Commonwealth of the Northern Mariana Islands; and Tribal governments
(collectively referred to as “prime recipients”). Treasury issued a $47,291,598 CRF
payment to Oklahoma County. The CARES Act stipulates that a prime recipient
may only use the funds to cover costs that—
(1) were necessary expenditures incurred due to the public health
emergency with respect to the coronavirus disease 2019 (COVID-19);
(2) were not accounted for in the budget most recently approved as of
March 27, 2020; and
(3) were incurred during the covered period between March 1, 2020 and
December 31, 2021.13
12
Treasury OIG had a pre-defined list of risk indicators that were triggered based on data
submitted by prime recipients in the FPR submissions that met certain criteria. Castro reviewed
these results provided by Treasury OIG for the prime recipient.
13
P.L. 116-260 (December 27, 2020). The covered period end date of the CRF was extended through
December 31, 2021 by the Consolidated Appropriations Act, 2021. The covered period end date for
tribal entities was further extended to December 31, 2022 by the State, Local, Tribal, and Territorial
Fiscal Recovery, Infrastructure, and Disaster Relief Flexibility Act, Division LL of the Consolidated
Appropriations Act, 2023, P.L. 117-328, December 29, 2022, 136 Stat. 4459.
5
Desk Review of Oklahoma County, Oklahoma
Section 15011 of the CARES Act required each covered recipient 14 to submit to
Treasury and the Pandemic Response Accountability Committee, no later than 10
days after the end of each calendar quarter, a report that contained (1) the total
amount of large, covered funds15,16 received from Treasury; (2) the amount of
large, covered funds received that were expended or obligated for each project or
activity; (3) a detailed list of all projects or activities for which large, covered funds
were expended or obligated; and (4) detailed information on any level of sub-
contracts or sub-grants awarded by the covered recipient or its sub-recipients.
The CARES Act assigned Treasury OIG the responsibility for compliance
monitoring and oversight of the receipt, disbursement, and use of CRF proceeds.
Treasury OIG also has the authority to recoup funds in the event that it is
determined a recipient failed to comply with requirements of subsection 601(d) of
the Social Security Act, as amended, (42 U.S.C. 801(d)).
Desk Review Results
Financial Progress Reports
We reviewed Oklahoma County’s quarterly FPRs through September 30, 2022, and
found that Oklahoma County timely filed quarterly FPRs in the GrantSolutions
portal in compliance with Treasury OIG’s reporting requirements for the periods
ending June 30, 2020 through September 30, 2022.
Summary of Testing Results
We found that the Contracts greater than or equal to $50,000 payment type
complied with the CARES Act and Treasury’s Guidance. We also found that the
Transfers greater than or equal to $50,000, Aggregate Reporting less than $50,000,
and Aggregate Payments to Individuals payment types did not comply with the
CARES Act and Treasury’s Guidance because we were unable to determine if all
tested expenditures were necessary due to the COVID-19 public health
emergency, were not accounted for in the budget most recently approved as of
March 27, 2020, and were incurred during the covered period. The transactions
14
Section 15011 of P.L. 116-136, the CARES Act, defined a covered recipient as any entity that
received large, covered funds and included any State, the District of Columbia, and any territory or
possession of the United States.
15
Section 15010 of P.L. 116-136, the CARES Act, defined covered funds as any funds, including
loans, that were made available in any form to any non-Federal entity, not including an individual,
under Public Laws 116-123, 127, and 136, as well as any other law which primarily made
appropriations for Coronavirus response and related activities.
16
Section 15011 of P.L. 116-136 defined large, covered funds as covered funds that amounted to
more than $150,000.
6
Desk Review of Oklahoma County, Oklahoma
selected for testing were not selected statistically, and therefore results could not
be extrapolated to the total universe of transactions.
Within Table 1 below, we have included a summary of $30,751 in unsupported
and ineligible expenditures identified as questioned costs through our testing of
detailed transactions, which did not comply with the CARES Act and Treasury’s
Guidance. Castro also identified other matters throughout the course of our desk
review procedures which we considered to be questioned costs that were not part
of our testing of detailed transactions. Table 2 below combines the questioned
costs identified in Table 1 with the other questioned costs of 387,131 identified
separately from our detailed transaction testing to account for total questioned
costs of $417,882. See the Desk Review Results section below Table 2 for a
detailed discussion of questioned costs and other issues identified throughout the
course of our desk review.
Table 1 - Summary of Expenditures Testing and Recommended Results
As of September 30, 2022
Cumulative Unsupported Ineligible
Expenditure Cumulative Tested Tested Total Tested
Population Expenditure Questioned Questioned Questioned
Payment Type Amount Tested Amount Costs Costs Costs
Contracts >=
$50,000 $ 4,370,395 $ 1,987,115 $ - $ - $ -
Grants >= $50,000
$ - $ - $ - $ - $ -
Loans >= $50,000
$ - $ - $ - $ - $ -
Transfers >=
$50,000 $ 33,928,704 $ 8,066,776 $ 8,260 $ - $ 8,260
Direct Payments
>= $50,000 $ - $ - $ - $ - $ -
Aggregate
Reporting <
$50,000 $ 6,401,369 $ 1,079,367 $ 22,491 $ - $ 22,491
Aggregate
Payments to
Individuals (in any
amount) $ 2,591,130 $ 1,254,307 $ - $ - $ -
Totals $ 47,291,598 $ 12,387,565 $ 30,751 $ - $ 30,751
7
Desk Review of Oklahoma County, Oklahoma
Table 2 – Summary of Tested and Other Matters Identified Questioned Costs
As of September 30, 2022
(B) (C=A+B) (D) (E)
(A) Unsupported Total Ineligible Total Ineligible (F=D+E)
Unsupported Questioned Unsupported Questioned Questioned Total Ineligible (G=C+F)
Questioned Costs Costs Questioned Costs Costs (Other Questioned Total Questioned
Payment Type (Tested) (Other Matter) Costs (Tested) Matter) Costs Costs
Contracts >= $50,000 $ - $ - $ - $ - $ - $ - $ -
Grants >= $50,000 $ - $ - $ - $ - $ - $ - $ -
Loans >= $50,000 $ - $ - $ - $ - $ - $ - $ -
Transfers to Other
Government Agencies
>= $50,000 $ 8,260 $ 60,148 $ 68,408 $ - $ 326,664 $ 326,664 $ 395,072
Direct Payments =>
$50,000 $ - $ - $ - $ - $ - $ - $ -
Aggregate Reporting <
$50,000 $ 22,491 $ - $ 22,491 $ - $ - $ - $ 22,491
Aggregate Payments to
Individuals (in any
amount) $ - $ 319 $ 319 $ - $ - $ - $ 319
Totals $ 30,751 $ 60,467 $ 91,218 $ -$ 326,664 $ 326,664 $ 417,882
8
Desk Review of Oklahoma County, Oklahoma
Contracts Greater Than or Equal to $50,000
We determined Oklahoma County’s Contracts greater than or equal to $50,000
complied with the CARES Act and Treasury’s Guidance. We tested a total of
$1,987,115 of transaction expenditures for four contracts and identified no
exceptions. The contracts tested included expenditures for the purchase of mobile
data computers for the Sherrif’s Office deputies to promote remote working
during the pandemic; specially outfitted safety vehicles for the Sheriff's Office for
social distancing in the patrol vehicles to allow separate airflows in the driver’s
section and the inmate or arrestee's sections of the vehicles; air purification
systems within the Oklahoma County Juvenile Bureau to prevent the spread of
COVID-19; and map/sketching software utilized to promote remote working for
real estate appraisers.
Transfers Greater Than or Equal to $50,000
We determined Oklahoma County’s Transfers greater than or equal to $50,000 did
not comply with the CARES Act and Treasury’s Guidance. We tested four transfers
totaling $8,066,776 of transaction expenditures and identified two overall
exceptions. The transfers tested included expenditures for public health and
safety payroll; capital expenditures to make the Oklahoma County Detention
Center more COVID-19 resistant (including plumbing and air handling items);
Oklahoma County small business and nonprofit grants; telecommunication
equipment to allow court proceedings over video rather than in person; and a
facial recognition system implementation for the Oklahoma County Sheriff’s
Office to prevent the spread of COVID-19.
We identified $8,260 of unsupported questioned costs through our testing of
detailed transactions. We also identified questioned costs, identified separate
from our detailed transaction testing, of $386,812, which consisted of $60,148 and
$326,664 in unsupported and ineligible questioned costs, respectively.
Transfers Exception #1 Summary – Other Matter for Treasury OIG Consideration -
Questioned Costs for Calculation Errors, Population Reconciling Errors, and
Management Fees / Indirect Cost Rates Claimed Related to the Oklahoma
Industries Authority
Castro noted that Oklahoma County claimed $17,470,033 in grant funding for a
small business and nonprofit grant program managed by the Oklahoma Industries
Authority (OIA), a public trust (and separate legal entity) where Oklahoma County
was the sole beneficiary. Castro tested $200,000 out of the $17,470,033 in grant
funding that Oklahoma County claimed related to OIA transactions, and all were
tested without exception; however, we identified total questioned costs of
9
Desk Review of Oklahoma County, Oklahoma
$234,112 during our OIA grant reconciliation procedures, which consisted of
$59,119 and $174,993 in unsupported and ineligible questioned costs,
respectively, as detailed in the Transfers Exception #1 section below.
Transfers Exception #1 – Other Matters Questioned Costs for Treasury OIG
Consideration - Oklahoma Industries Authority Overall GrantSolutions Portal to
GL Detail Population Reconciling Error
Castro identified reconciliation errors within the grants portal as of September 30,
2022, compared to Oklahoma County’s general ledger (GL) detail. Castro identified
a $315 variance between the amount reported in the grants portal of $33,928,704
and the amount reported in the GL of $33,928,389. Oklahoma County
management told us that the variance was interest income for the OIA and was
reported as expended as part of CRF proceeds. As such, Castro questioned the
reconciling error of $315 as Other Matter unsupported questioned costs.
Transfers Exception #1 – Other Matter Questioned Costs for Treasury OIG
Consideration - Sub-recipient GL Detail Payroll Allocation Calculation Errors
Related to the Oklahoma Industries Authority
As part of our sub-recipient GL detail reconciliation procedures, Castro
determined that Oklahoma County claimed $18,083 in OIA payroll expenses
incurred during the period of December 2020 through June 2021. Castro
questioned $9,431 out of the $18,083 payroll allocation calculations, which
consisted of $8,570 and $861 in other matter unsupported and ineligible costs,
respectively, as detailed below.
For the $8,570 of other matter unsupported questioned costs, Oklahoma County’s
sub-recipient provided timesheets with COVID-19 hours listed but used the
employee’s monthly salaries to perform an allocation for determining CRF
proceeds claimed. We noted that the full payroll dollar amount for each month
was used in the calculation of the allocation amount, but only bi-weekly pay
period hours were used in the Oklahoma County sub-recipient's hourly rate
calculations. Considering the full amount of monthly payroll was used to calculate
the claimed amount, Castro determined the hourly rate was incorrectly calculated,
and it should have been calculated with the total number of hours within the given
month. This caused Oklahoma County’s sub-recipient to incorrectly calculate the
amount claimed, resulting in an $8,570 overstatement of the payroll claimed.
Castro provided our calculations to Oklahoma County who agreed with Castro’s
calculations of using total hours worked in the month and confirmed the amount
as an exception. Castro questioned $8,570 as unsupported.
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Desk Review of Oklahoma County, Oklahoma
For the $861 of ineligible questioned costs, Castro noted Oklahoma County's sub-
recipient applied a five percent overhead cost rate to the total monthly payroll
costs. Castro determined Oklahoma County and its sub-recipient claimed indirect
cost rates by employing guidance from the Code of Federal Regulations (CFR), 2
CFR 200.414(f)), Grants and Agreements, Uniform Administrative Requirements,
Cost Principles, and Audit Requirements for Federal Awards, Direct and Indirect
(F&A) Costs.17 This guidance defined indirect cost rates and sets forth the 10
percent de minimis18 indirect cost rate that could be used indefinitely instead of
charging the actual administrative costs. However, Treasury’s CRF guidance
published in the Federal Register stated this provision did not apply to the use of
CRF funds and recipients could not apply their indirect cost rates to payments
received from CRF. Therefore, Oklahoma County, by applying the indirect cost
rate, did not comply with Treasury’s requirements. Castro questioned $861 as
ineligible.
Transfers Exception #1 – Other Matter Questioned Costs for Treasury OIG
Consideration - Sub-recipient GL detail Population Reconciling Errors Related to
the Oklahoma Industries Authority
As part of our sub-recipient GL detail population reconciliation procedures, we
identified $4,621,152 without sufficient sub-recipient GL transaction details. We
asked Oklahoma County to provide additional sub-recipient GL details to support
this balance, and Oklahoma County responded by providing an invoice to support
the amount; however, we noted a variance of $50,234 when comparing the
invoice total of $4,621,152 to the itemized GL total of $4,570,918. Oklahoma
County’s sub-recipient indicated the variance could be attributed to a potential
duplicate payment. We followed up with Oklahoma County requesting
documentation to support this amount; however, Oklahoma County did not
provide additional support to confirm that the transaction was not a duplicate
payment. As such, we questioned the $50,234 as unsupported costs.
17
Code of Federal Regulations (CFR), 2 CFR 200.414(f)), Grants and Agreements, Uniform
Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Direct
and Indirect (F&A) Costs states: “…any non-Federal entity that does not have a current negotiated
(including provisional) rate…may elect to charge a de minimis rate of 10% of modified total direct
costs (MTDC) which may be used indefinitely. No documentation is required to justify the 10% de
minimis indirect cost rate. As described in § 200.403, costs must be consistently charged as either
indirect or direct costs but may not be double charged or inconsistently charged as both. If chosen,
this methodology once elected must be used consistently for all Federal awards until such time as
a non-Federal entity chooses to negotiate for a rate, which the non-Federal entity may apply to do
at any time.”
18
De minimis means lacking significance or importance: so minor as to merit disregard.
11
Desk Review of Oklahoma County, Oklahoma
Transfers Exception #1 – Other Matter Questioned Costs for Treasury OIG
Consideration for Ineligible Indirect Costs Related to the Oklahoma Industries
Authority
Castro identified a 10 percent management fee on each invoice within the OIA
transfers selection population which totaled $174,132. Castro determined the 10
percent management fee was an indirect administrative cost. Treasury’s Guidance
published in the Federal Register explicitly disallows CRF recipients from charging
indirect cost rates to calculate their CRF award. Castro questioned $174,132 as
ineligible indirect costs.
Transfers Exception #2 Summary: Oklahoma County Home Finance Authority
Rent Relief Fund Household Support Program
Castro selected a $1,500,000 transfer to the Oklahoma County Home Finance
Authority (OCHFA), a public trust (and separate legal entity), designating
Oklahoma County was the sole beneficiary. OCHFA incurred expenses related to
the Rent Relief Fund Household Support Program. Castro selected two GL level
transactions for testing from OCHFA’s sub-recipient GL: 1) $6,460 transaction to a
landlord and 2) $1,800 beneficiary level transaction, which we summarized
directly below.
As a result of testing, Castro identified total unsupported questioned costs of
$8,260, as detailed in the Transfers Exception #2.01 and #2.02 sections below. As a
result of reconciliation procedures performed, Castro also identified total other
questioned costs of $152,700, which consisted of unsupported and ineligible
questioned costs of $1,029 and $151,671, respectively. These Other Matter
questioned costs increased our Transfers questioned costs to $160,960.
Transfers Exception #2.01 – Oklahoma County Home Finance Authority Rent
Assistance Program
The $6,460 transaction was part of a grant program administered by the sub-
recipient to assist qualified individuals suffering financial hardships due to COVID-
19 with the payment of overdue rent to avoid eviction or prevent homelessness
and relieve the burden of missed payments on landlords. Oklahoma County and
OCHFA provided a COVID-19 Landlord-Tenant Rent Assistance Agreement that
listed a total rent assistance payment of $6,460, which agreed to our transaction
selection amount. However, the agreement indicated that the $6,460 rent
assistance payment would be split between the State of Oklahoma required
payment of $3,600 and an Oklahoma County required payment of $2,860. We
noted Oklahoma County claimed the entire $6,460 expense using CRF proceeds
despite the shared funding responsibility outlined in the agreement.
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Desk Review of Oklahoma County, Oklahoma
Castro requested the application and self-certification form to verify the eligibility
of the applicant, but Oklahoma County did not provide the supporting
documentation requested for our transaction selection prior to the end of
fieldwork. Additionally, Oklahoma County was unable to provide documentation
to show that the rent was past due starting after the pandemic or that the expense
was reasonable and could not be paid, as required by its grant program
requirements. Without this information, Castro could not confirm that Oklahoma
County ensured that its sub-recipient followed their grant program requirements
for verifying eligibility of applicants. Castro questioned the $6,460 as unsupported
costs.
Transfers Exception #2.02 – Oklahoma County Home Finance Authority Prepaid
Debit Card Distribution
Out of the $1,500,000 original transaction selection, Castro selected a $200,000
transaction related to prepaid debit cards to individuals who had already received
COVID-19 related grant program rental assistance. Castro determined the
$200,000 transaction included multiple transactions and comingling of funds
between the State of Oklahoma, Oklahoma County, and Oklahoma City. As a
result, we selected a beneficiary level transaction totaling $1,800 for testing.
For the $1,800 beneficiary level transaction tested related to OCHFA loading grant
awards onto prepaid debit cards for use by eligible applicants, Castro requested
and Oklahoma County and OCHFA provided the eligibility guidelines provided for
the prepaid debit cards and noted a list of required information to be provided to
receive the card. Castro noted that the listing required the grant applicant to
identify their most pressing need that could be fulfilled with the debit card. Castro
followed up with Oklahoma County requesting the documentation showing the
information that the grant applicant submitted fulfilling this requirement;
however, Oklahoma County did not provide the requested documentation by the
end of fieldwork. Without this response, Castro could not confirm that Oklahoma
County ensured that its sub-recipients followed their grant program requirements
for verifying eligibility of the applicants.
Castro requested Oklahoma County provide supporting documentation for the
$1,800 including a receipt or other evidence that the card was created and
processed for distribution to the grant recipient. Oklahoma County stated that they
had source documentation from the vendor, which used a "Card ID" to identify the
cards, but that it did not match the tracking spreadsheet. Oklahoma County was
unable to provide the source documentation from the vendor that matched the
card’s serial number and demonstrated the $1,800 card being created and loaded
for the grant applicant. Without this information, Castro could not verify the grant
applicant received this debit card. Castro questioned the $1,800 as unsupported.
13
Desk Review of Oklahoma County, Oklahoma
Other Matter for Treasury OIG Consideration – Exceptions #2.01 and #2.02 –
Oklahoma County Home Finance Authority Rental Assistance Program
Of the $1,500,000 transfer provided to OCHFA, Castro noted that $1,296,369 was
distributed as grant program expenses (such as payments to grant beneficiaries),
while the remaining $203,631 consisted of administrative related expenditures.
Out of the $1,296,369 in grant program expenses, Castro tested $8,260, resulting
in $1,288,109 in untested grant program expenses. Castro identified instances of
cost sharing between the State of Oklahoma, Oklahoma County, and Oklahoma
City for the following transactions as a result of our testing:
For the #2.01 tested amount of $6,460, Castro identified an instance of cost
sharing between the State of Oklahoma and Oklahoma County. Specifically,
the contract indicated the rental assistance payment was to be split, and a
portion paid by the State of Oklahoma and Oklahoma County; however,
Oklahoma County claimed the entire $6,460 within the grants portal.
For the #2.02 tested amount of $1,800, Castro identified $1,800 in
unsupported costs through testing related to the $200,000 population,
leaving $198,200 in funds not tested. During our review of the population,
Castro determined this balance may have additional potential questioned
costs because the funds were commingled into this program between the
State of Oklahoma, Oklahoma County, and Oklahoma City.
Castro recommends Treasury OIG follow-up to request that Oklahoma County
management performs an assessment over the remaining untested amount of
$1,288,109 to determine if rental assistance payments and prepaid debit card
payments were made utilizing solely Oklahoma County’s CRF proceeds, or if these
expenses were paid with State of Oklahoma and Oklahoma City funding sources.
If support is not provided, Treasury OIG should recoup the funds or request
Oklahoma County management to provide support for replacement expenses, not
previously charged, that were eligible during the CRF period of performance.
14
Desk Review of Oklahoma County, Oklahoma
Transfers Exception #2 - Other Matters Questioned Costs for Treasury OIG
Consideration - Oklahoma County Home Finance Authority Population
Reconciling Errors and Indirect Cost Rates Claimed
Castro obtained a population and noted that Oklahoma County's sub-recipient, the
OCHFA, claimed $1,500,000 in CRF proceeds for the OCHFA’s Rent Relief Fund
Household Support Program. Castro identified total questioned costs of $152,700,
which consisted of $151,671 and $1,029 in ineligible and unsupported questioned
costs, respectively, as detailed below.
Castro noted within the population that OCHFA indicated it had only expended
$1,498,971 of the $1,500,000 that had been awarded from Oklahoma County,
resulting in a variance of $1,029. Castro requested an explanation on the status of
the remaining CRF proceeds that were unspent, and Oklahoma County confirmed
that $1,029 needed to be returned to Treasury. Castro determined that since there
was no evidence that this amount was expended on CRF related expenditures or
that these funds were returned to Treasury, we questioned $1,029 as unsupported
costs.
Additionally, Castro identified an indirect administrative expense line item of
$22,034 (with no details behind the calculation) and an administrative fee of
$129,637 (calculated as 10 percent of the program expenses claimed) within the
population. Oklahoma County was not able to provide any direct expenditure
detail to account for the $129,637 or the $22,034 expenses incurred by its sub-
recipient. Treasury’s CRF guidance stated that recipients could not apply their
indirect cost rates to payments received from the CRF and that only direct costs
are allowable to be charged to the CRF program. Therefore, by applying the 10
percent administrative rate and the indirect cost rate without claiming direct costs,
Oklahoma County did not comply with Treasury’s requirements, resulting in an
unallowable use of CRF proceeds in the amount of $151,671. As such, Castro
questioned $151,671 as ineligible indirect costs.
Aggregate Reporting less than $50,000
We determined Oklahoma County’s Aggregate Reporting less than $50,000 did
not comply with the CARES Act and Treasury’s Guidance. We tested seven
aggregate reporting transactions totaling $1,079,367 in expenditures and
identified one exception. The transactions tested included costs for the
reimbursement of medical claims paid by Oklahoma County for employees with a
COVID-19 diagnosis code; inmate transportation costs charged to the Oklahoma
County Sheriff's Office due to COVID-19 implemented specific safety measures;
costs for School Resource Officers who did not work their contractual amount of
hours due to COVID-19 pandemic related closures; costs for additional Sheriff's
15
Desk Review of Oklahoma County, Oklahoma
Office deputies to assist with social distancing; costs for additional security of the
courthouse caused by the COVID-19 pandemic; costs for cloud-based
subscriptions for the Sheriff's Office’s new mobile data computers needed for
remote work during the COVID-19 pandemic; and costs for installation of
ultraviolet lighting fixtures and new ionization air purifying systems used to
prevent the spread of COVID-19. Castro questioned $22,491 as unsupported costs,
as detailed below.
Aggregate Reporting Exception – New Ionization Air Purifying Systems
Installation
Castro tested two transactions totaling $282,520. We tested the first transaction of
$97,333 without exception, which related to the installation of ultraviolet lighting
fixtures that were installed to prevent the spread of COVID-19.
The second transaction tested for $185,187 was for new ionization air purifying
systems, which supported the effort of mitigating the spread of COVID-19. Castro
reviewed multiple invoices that totaled $162,696 out of the $185,187 claimed in
the GrantSolutions portal, resulting in a variance of $22,491. This occurred
because Oklahoma County claimed obligated amounts in the GrantSolutions
portal based on its purchase order, but the actual invoice expenditures were less
than the amount included in its purchase order. Oklahoma County confirmed it did
not adjust its reported CRF amounts based on actual amounts ordered. Castro
questioned $22,491 as unsupported costs.
Aggregate Payments to Individuals
CRF payments made to individuals, regardless of amount, were required to be
reported in the aggregate in the GrantSolutions portal to prevent inappropriate
disclosure of personally identifiable information. Castro notes that Aggregate
Payments to Individuals consists of the following broad types of potential costs,
which we have defined from Treasury’s Guidance as published in the Federal
Register.19 Prime recipients may or may not have claimed all of these types of
expenditures.
19
Coronavirus Relief Fund Guidance as published in the Federal Register (January 15, 2021)
https://home.treasury.gov/system/files/136/CRF-Guidance-Federal-Register_2021-00827.pdf
16
Desk Review of Oklahoma County, Oklahoma
Public Safety/Health Payroll20 – consisted of payroll costs for public
health and safety department personnel.
Substantially Dedicated Payroll21 – consisted of payroll costs for non-
public health and safety personnel who were substantially dedicated
to mitigating or responding to the COVID-19 public health
emergency.
Non-Substantially Dedicated Payroll22 – consisted of payroll costs for
personnel who performed COVID-19 related tasks on a part-time
basis.
Non-Payroll Expenditures – consisted of financial assistance
payments to citizens due to hardship or loss of income,
unemployment claims, and other non-payroll related expenses made
to individuals.
20
Treasury’s Federal Register Guidance provides the following examples of public health and safety
employees: “police officers (including state police officers), sheriffs and deputy sheriffs, firefighters,
emergency medical responders, correctional and detention officers, and those who directly support
such employees such as dispatchers and supervisory personnel employees involved in providing
medical and other health services to patients and supervisory personnel, including medical staff
assigned to schools, prisons, and other such institutions, and other support services essential for
patient care (e.g., laboratory technicians) as well as employees of public health departments directly
engaged in matters related to public health and related supervisory personnel.”
21
Substantially dedicated payroll costs means that personnel must have dedicated over 50 percent
of their time to responding or mitigating COVID-19. Treasury’s Federal Register Guidance states that:
“The full amount of payroll and benefits expenses of substantially dedicated employees may be
covered using payments from the Fund. Treasury has not developed a precise definition of what
"substantially dedicated" means given that there is not a precise way to define this term across
different employment types. The relevant unit of government should maintain documentation of the
"substantially dedicated" conclusion with respect to its employees.”
22
Payroll costs that are not substantially dedicated means payroll costs that are not public health
and safety, and which are not substantially dedicated to performing COVID-19 related tasks.
Treasury’s Federal Register Guidance defines more stringent tracking requirements for these types
of payroll costs. Specifically, the Treasury’s Federal Register states that agencies must: “track time
spent by employees related to COVID-19 and apply Fund payments on that basis but would need to
do so consistently within the relevant agency or department. This means, for example, that a
government could cover payroll expenses allocated on an hourly basis to employees' time dedicated
to mitigating or responding to the COVID-19 public health emergency.”
17
Desk Review of Oklahoma County, Oklahoma
Oklahoma County’s Aggregate Payments to Individuals balance consisted of
payroll and other transactions from the following types of claimed costs.
Aggregate Payments to Individuals Category Total Expenses
Types Claimed
Public Health and Safety Payroll $ 2,591,130
Totals $ 2,591,130
Oklahoma County did not claim any substantially dedicated payroll, non-
substantially dedicated payroll, or any non-payroll costs within its Aggregate
Payments to Individuals payment type balance.
Castro noted that public health and safety payroll transactions were subject to
Treasury’s administrative accommodation,23 and therefore, were subject to less
detailed documentation requirements. Castro tested public health and safety
payroll transactions by reviewing itemized payroll distribution reports to support
these balances.
We determined that Oklahoma County’s Aggregate Payments to Individuals did
not comply with the CARES Act and Treasury’s Guidance. We tested a total of
$1,254,307 of transaction expenditures for five public health and safety payroll
transactions and identified no testing exceptions. The public health and safety
payroll tested included balances from the Juvenile Justice Detention Center and
the Sheriff’s Department. However, Castro did find unsupported costs related to
our reconciliation between the GL and the GrantSolutions portal.
Castro reconciled the expenditures identified within the GrantSolutions portal as
of September 30, 2022 to the GL and the Aggregate Payments to Individuals
Analysis provided by Oklahoma County. Castro identified a variance of $319
between the GL detail and amount reported in the GrantSolutions portal. We
followed up with Oklahoma County for an explanation about this variance and
they confirmed the variance was due to two payments that were duplicated in the
GL, causing the balance to be overstated in the GrantSolutions portal. Specifically,
the amounts of $281 and $266 were incorrectly reported twice within the
GrantSolutions portal, however these amounts were offset by a correcting
23
Treasury’s Federal Register guidance stated that an administrative accommodation was, “In
recognition of the particular importance of public health and public safety workers to State, local,
and tribal government responses to the public health emergency, Treasury has provided, as an
administrative accommodation, that a State, local, or tribal government may presume that public
health and public safety employees meet the substantially dedicated test…This means that, if this
presumption applies, work performed by such employees is considered to be a substantially
different use than accounted for in the most recently approved budget as of March 27, 2020. All
costs of such employees may be covered using payments from the Fund for services provided
during the period that begins on March 1, 2020, and ends on December 31, 2021.”
18
Desk Review of Oklahoma County, Oklahoma
adjustment of $228. As such, Castro questioned the $319 reconciling error as
Other Matter unsupported questioned costs.
Conclusion
We determined that the expenditures related to the Contracts greater than or
equal to $50,000 payment type complied with the CARES Act and Treasury’s
Guidance. We also found that the Transfers greater than or equal to $50,000,
Aggregate Reporting less than $50,000, and Aggregate Payments to Individuals
payment types did not comply with the CARES Act and Treasury’s Guidance.
We identified unsupported and ineligible questioned costs of $91,218 and
$326,664, respectively, with total questioned costs of $417,882. Also, we identified
GrantSolutions portal misclassification reporting issues related to the Transfers
greater than or equal to $50,000 payment type that did not comply with Treasury’s
Guidance.
Additionally, Oklahoma County’s risk of unallowable use of funds is moderate.
Castro recommends that Treasury OIG follow up with Oklahoma County’s
management to confirm if the $91,218 noted as unsupported expenditures within
the Transfers greater than or equal to $50,000, Aggregate Reporting less than
$50,000, and Aggregate Payments to Individuals can be supported. If support is
not provided, Treasury OIG should recoup the funds or request Oklahoma County
management to provide support for replacement expenses, not previously
charged, that were eligible during the CRF period of performance.
In addition, Castro recommends that Treasury OIG request Oklahoma County
management to provide support for replacement expenses, not previously
charged, that were eligible during the CRF period of performance for the $326,664
of ineligible costs charged to the Transfers greater than or equal to $50,000
payment type. If support is not provided, Treasury OIG should recoup the funds.
Further, based on Oklahoma County’s responsiveness to Treasury OIG’s requests
and its ability to provide sufficient documentation and/or replace unsupported and
ineligible transactions charged to CRF with valid expenditures, we recommend
Treasury OIG determine the feasibility of conducting an audit for the Transfers
greater than or equal to $50,000, Aggregate Reporting less than $50,000, and
Aggregate Payments to Individuals payment types.
At the time of desk review fieldwork, Castro noted that Oklahoma County had
findings in their Single Audit Act Reports for FY 2021 and 2022. Castro
recommends that Treasury OIG follow-up with Treasury’s Office of Capital Access
19
Desk Review of Oklahoma County, Oklahoma
to ensure that management decision letters are issued on the findings identified
by the auditor in the Single Audit Act report, which we have summarized below.
o Oklahoma County’s FY 2021 Single Audit Act report was published on
June 30, 2022, and the auditor identified unsupported questioned costs
specific to the CRF in the amount of $36,344,500.
o Oklahoma County’s FY 2022 Single Audit Act report was published on
June 4, 2024, and the auditor identified unsupported questioned costs
specific to the CRF in the amount of $176,562.
Castro also identified other matters throughout the course of our desk review,
which warrant recommendations to Treasury OIG for additional action. Castro
recommends Treasury OIG:
o Follow-up to request Oklahoma County perform an assessment over the
remaining untested amount of $1,288,109 to determine if rental
assistance payments and prepaid debit cards payments were made
utilizing solely Oklahoma County’s CRF proceeds, or if these expenses
were paid with State of Oklahoma and Oklahoma City funding sources. If
support is not provided, Treasury OIG should recoup the funds or request
Oklahoma County management to provide support for replacement
expenses, not previously charged, that were eligible during the CRF
period of performance.
*****
All work completed with this letter complies with the Council of the Inspectors
General on Integrity and Efficiency’s Quality Standards for Federal Offices of
Inspectors General, which require that the work adheres to the professional
standards of independence, due professional care, and quality assurance to
ensure the accuracy of the information presented.24 We appreciate the courtesies
and cooperation provided to our staff during the desk review.
Sincerely,
Wayne Ference
Partner, Castro & Company, LLC
24
https://www.ignet.gov/sites/default/files/files/Silver%20Book%20Revision%20-%208-20-12r.pdf
20