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Single Audit Report of the State of Oklahoma for the fiscal year ended June 30, 2022

Summary

Oklahoma State Auditor and Inspector Cindy Byrd issued this Single Audit Report of the State of Oklahoma for the fiscal year ended June 30, 2022 on April 23, 2024, under the Uniform Guidance in 2 CFR Part 200. The auditors disclaimed an opinion on Formula Grants for Rural Areas and gave adverse opinions on Emergency Rental Assistance, Immunization Cooperative Agreements, and Epidemiology and Laboratory Capacity for Infectious Diseases. Opinions on Pandemic EBT Food Benefits, the SNAP Cluster, Unemployment Insurance, the Coronavirus Relief Fund, the Education Stabilization Fund, the Medicaid Cluster and other programs were qualified. The auditors identified deficiencies in internal control over compliance that they consider material weaknesses and significant deficiencies, and used $30,000,000 as the threshold between type A and type B programs.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

State of
oklahoma
Single Audit Report

For the fiscal year ended June 30, 2022
           OKLAHOMA
              2022

                            Single Audit Report
                 For the Fiscal Year Ended June 30, 2022




                                Prepared by
                 Office of the State Auditor and Inspector



                           Cindy Byrd, CPA
                   Oklahoma State Auditor and Inspector




This publication, issued by the Oklahoma State Auditor and Inspector’s Office as authorized by 74 O.S. §212,
has not been printed, but is available on the agency’s website (www.sai.ok.gov) and in the Oklahoma
Department of Libraries Publications Clearinghouse Digital Collection, pursuant to 65 O.S. §3-114.
April 23, 2024




To the Honorable J. Kevin Stitt, Governor
   and Members of the Legislature of the
   State of Oklahoma



This is the Single Audit Report of the State of Oklahoma for the fiscal year ended June 30, 2022.
The audit was conducted in accordance with the requirements of Title 2 U.S. Code of Federal
Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements
for Federal Awards (Uniform Guidance). The goal of the State Auditor and Inspector is to promote
accountability and fiscal integrity in state and local government. Maintaining our independence as we
provide this service to the taxpayers of Oklahoma is of utmost importance.

This report is a public document pursuant to the Oklahoma Open Records Act (51 O.S. § 24A.l et seq.)
and shall be open to any person for inspection and copying.

We wish to take this opportunity to express our appreciation for the assistance and cooperation
extended to our office by various state officials and employees during the course of the audit.

Sincerely,




CINDY BYRD, CPA
OKLAHOMA STATE AUDITOR & INSPECTOR
                                                       State of Oklahoma
                                                Single Audit Reporting Package
                                                  Year Ended June 30, 2022

Table of Contents                                                                                                                                       Page
Report on Compliance for Each Major Federal Program; Report on Internal
Control Over Compliance; and Report on Schedule of Expenditures of
Federal Awards Required by the Uniform Guidance..................................................................................................... 1


Auditors’ Section

Schedule of Findings and Questioned Costs

              Summary of Auditor’s Results ...................................................................................................................... 9

              Financial Statement Findings ...................................................................................................................... 12

              Federal Award Findings and Questioned Costs ........................................................................................... 14


State Agency Section

Schedule of Expenditures of Federal Awards by Federal Grantor ............................................................................ 138

Notes to the Schedule of Expenditures of Federal Awards ....................................................................................... 154

Corrective Action Plan .............................................................................................................................................. 158

Summary Schedule of Prior Audit Findings .............................................................................................................. 201
 Independent Auditor’s Report on Compliance for Each Major
Federal Program; Report on Internal Control Over Compliance;
  and Report on Schedule of Expenditures of Federal Awards
              Required by the Uniform Guidance
                               INDEPENDENT AUDITOR’S REPORT


To the Honorable J. Kevin Stitt, Governor
    and Members of the Legislature
    of the State of Oklahoma


Report on Compliance for Each Major Federal Program

Qualified, Adverse, Unmodified, and Disclaimer of Opinions

We have audited the State of Oklahoma’s compliance with the types of compliance requirements
identified as subject to audit in the OMB Compliance Supplement that could have a direct and
material effect on each of the State of Oklahoma’s major federal programs for the year ended June
30, 2022. The State of Oklahoma’s major federal programs are identified in the summary of
auditor’s results section of the accompanying schedule of findings and questioned costs.

We did not audit compliance with those requirements that are applicable to the major federal
programs administered by the Department of Commerce, the Department of Environmental
Quality, the Department of Wildlife Conservation, and the Water Resources Board which were
audited in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 200,
Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal
Awards (Uniform Guidance). The federal programs for the above referenced agencies represent
0.95% of total expenditures for federal programs reported on the Schedule of Expenditures of
Federal Awards. Those entities were audited by other auditors whose reports have been furnished
to us, and our opinion, insofar as it relates to compliance with the compliance requirements for the
above-mentioned entities, is based solely upon the reports of the other auditors.

The State of Oklahoma’s basic financial statements include the operations of component units,
some of which received federal awards. Those component units are not included in the Schedule
of Expenditures of Federal Awards for the year ended June 30, 2022. Our audit, described below,
did not include the operations of those component units because they engaged other auditors to
perform audits in accordance with Uniform Guidance.
Disclaimer of Opinion on Formula Grants for Rural Areas

We do not express an opinion on the State of Oklahoma’s compliance requirements identified as
subject to audit in the OMB Compliance Supplement that could have a direct and material effect
on Formula Grants for Rural Areas. Because of the significance of the matter described in the Basis
for Disclaimer of Opinion on Formula Grants for Rural Areas section of our report, we have not
been able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion on
compliance with the types of compliance requirements described in the OMB
Compliance Supplement that could have a direct and material effect on Formula Grants for Rural
Areas.

Adverse Opinion on Emergency Rental Assistance, Immunization Cooperative Agreements, and
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC).

In our opinion, because of the significance of the matter discussed in the Basis for Adverse,
Qualified, and Unmodified Opinions section of our report, the State of Oklahoma did not comply,
in all material respects, with the compliance requirements referred to above that could have a direct
and material effect on Emergency Rental Assistance, Immunization Cooperative Agreements, and
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) for the year ended June 30,
2022.

Qualified Opinion on Pandemic EBT Food Benefits, SNAP Cluster, Unemployment Insurance,
Coronavirus Relief Fund, Emergency Rental Assistance, Education Stabilization Fund, Temporary
Assistance for Needy Families, CCDF Cluster, Foster Care – Title IV-E, Children’s Health
Insurance Program, and Medicaid Cluster

In our opinion, except for the noncompliance described in the Basis for Adverse, Qualified, and
Unmodified Opinions section of our report, the State of Oklahoma complied, in all material
respects, with the compliance requirements referred to above that could have a direct and material
effect on Pandemic EBT Food Benefits, SNAP Cluster, Unemployment Insurance, Coronavirus
Relief Fund, Emergency Rental Assistance, Education Stabilization Fund, Temporary Assistance for
Needy Families, CCDF Cluster, Foster Care – Title IV-E, Children’s Health Insurance Program,
and Medicaid Cluster for the year ended June 30, 2022.

Unmodified Opinion on Each of the Other Major Federal Programs

In our opinion, the State of Oklahoma complied, in all material respects, with the compliance
requirements referred to above that could have a direct and material effect on each of its other major
federal programs identified in the summary of auditor’s results section of the accompanying
schedule of findings and questioned costs for the year ended June 30, 2022.

Basis for Disclaimer of Opinion on Formula Grants for Rural Areas

As described in the accompanying schedule of findings and questioned costs, we were unable to
obtain sufficient appropriate audit evidence supporting the compliance of the State of Oklahoma
with requirements regarding Assistance Listing 20.509, Formula Grants for Rural Areas as
described in finding number 2022-024 for Subrecipient Monitoring; and finding number 2022-056
for Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Subrecipient
Monitoring.

                                                  2
Basis for Adverse, Qualified, and Unmodified Opinions

We conducted our audit of compliance in accordance with auditing standards generally accepted in
the United States of America (GAAS); the standards applicable to financial audits contained in
Government Auditing Standards issued by the Comptroller General of the United States; and the
audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance).
Our responsibilities under those standards and the Uniform Guidance are further described in the
Auditor’s Responsibilities for the Audit of Compliance section of the report.

We are required to be independent of the State of Oklahoma and to meet our other ethical
responsibilities, in accordance with relevant ethical requirements relating to our audit. We believe
that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our
opinion on compliance for each major federal program. Our audit does not provide a legal
determination of the State of Oklahoma’s compliance with the compliance requirements referred to
above.

Matter(s) Giving Rise to Adverse Opinion on Emergency Rental Assistance, Immunization
Cooperative Agreements, and Epidemiology and Laboratory Capacity for Infectious Diseases
(ELC).

As described in the accompanying schedules of findings and questioned costs, the State of
Oklahoma did not comply with requirements regarding the following:

                                          Program (or Cluster)        Compliance
 Finding #     Assistance Listing #       Name                        Requirement

 2022-032
 2022-036
 2022-046
 2022-085
 2022-086                                 Emergency Rental            Activities Allowed/
 2022-087      21.023                     Assistance                  Unallowed
 2022-032
 2022-036
 2022-046
 2022-085
 2022-086                                 Emergency Rental            Allowable Costs/ Cost
 2022-087      21.023                     Assistance                  Principles
                                          Emergency Rental
 2022-032      21.023                     Assistance                  Eligibility
 2022-033                                 Emergency Rental
 2022-034      21.023                     Assistance                  Subrecipient Monitoring
                                          Immunization
                                          Cooperative                 Allowable Costs/Cost
 2022-205      93.268                     Agreements                  Principles
                                          Epidemiology and
                                          Laboratory Capacity
                                          for Infectious Diseases     Allowable Costs/Cost
 2022-205      93.323                     (ELC)                       Principles


                                                 3
                                         Epidemiology and
                                         Laboratory Capacity
                                         for Infectious Diseases
 2022-205      93.323                    (ELC)                       Cash Management

Compliance with such requirements is necessary, in our opinion, for the State of Oklahoma to
comply with the requirements applicable to those programs.
Matters Giving Rise to Qualified Opinion on Pandemic EBT Food Benefits, SNAP Cluster,
Unemployment Insurance, Coronavirus Relief Fund, Emergency Rental Assistance, Education
Stabilization Fund, Temporary Assistance for Needy Families, CCDF Cluster, Foster Care – Title
IV-E, Children’s Health Insurance Program, and Medicaid Cluster

As described in the accompanying schedule of findings and questioned costs, the State of Oklahoma
did not comply with requirements regarding the following:

                                         Program (or Cluster)        Compliance
 Finding #     Assistance Listing #      Name                        Requirement
                                         Pandemic EBT Food           Activities Allowed or
 2022-041      10.542                    Benefits                    Unallowed
                                         Pandemic EBT Food
 2022-041      10.542                    Benefits                    Eligibility
                                         Pandemic EBT Food
 2022-042      10.542                    Benefits                    Reporting
 2022-007      10.551/10.561             SNAP Cluster                Special Tests (N3)
 2022-038                                Unemployment
 2022-077      17.225                    Insurance                   Special Tests (N5)
 2022-071
 2022-076                                Coronavirus Relief          Activities Allowed or
 2022-078      21.019                    Fund                        Unallowed
 2022-071
 2022-076                                Coronavirus Relief          Allowable Costs/ Cost
 2022-078      21.019                    Fund                        Principles
 2022-071
 2022-076                                Coronavirus Relief
 2022-078      21.019                    Fund                        Period of Performance
                                         Coronavirus Relief
 2022-071      21.019                    Fund                        Subrecipient Monitoring
 2022-028                                Emergency Rental
 2022-030      21.023                    Assistance                  Reporting
                                         Education Stabilization
 2022-012      84.425                    Fund                        Special Tests (N1)
                                         Education Stabilization
 2022-070      84.425                    Fund                        Special Tests (N3)
 2022-060
 2022-064                                Temporary Assistance
 2022-065      93.558                    for Needy Families          Eligibility
 2022-057                                Temporary Assistance
 2022-061      93.558                    for Needy Families          Special Tests (N1)
 2022-029                                Temporary Assistance
 2022-062      93.558                    for Needy Families          Special Tests (N2)
 2022-014      93.575                    CCDF Cluster                Special Tests (N1)
                                         Foster Care – Title IV-
 2022-018      93.658                    E                           Subrecipient Monitoring
                                                4
                                          Children's Health
 2022-025      93.767                     Insurance Program           Eligibility
 2022-025      93.778                     Medicaid Cluster            Eligibility
 2022-039      93.778                     Medicaid Cluster            Special Tests (N7)
 2022-040      93.778                     Medicaid Cluster            Special Tests (N8)

Compliance with such requirements is necessary, in our opinion, for the State of Oklahoma to
comply with the requirements applicable to those programs.

Responsibilities of Management’s for Compliance

Management is responsible for compliance with the requirements referred to above and for the
design, implementation, and maintenance of effective internal control over compliance with the
requirements of laws, statutes, regulations, rules, and provisions of contracts or grant agreements
applicable to the State of Oklahoma’s federal programs.

Auditor’s Responsibility for the Audit of Compliance

Auditor's Responsibilities for the Audit of Compliance for Formula Grants for Rural Areas

Our responsibility is to conduct an audit of compliance in accordance with GAAS, Government
Auditing Standards, and the Uniform Guidance and to issue an auditor's report. However, because
of the matter described in the Basis for Disclaimer of Opinion on Formula Grants for Rural Areas
section of our report, we were not able to obtain sufficient appropriate audit evidence to provide a
basis for an audit opinion on compliance.

We are required to be independent of State of Oklahoma and to meet our other ethical
responsibilities, in accordance with the relevant ethical requirements relating to our audit.

Auditor's Responsibilities for the Audit of Compliance for Each of the Other Major Federal
Programs

Our objectives are to obtain reasonable assurance about whether material noncompliance with the
compliance requirements referred to above occurred, whether due to fraud or error, and express an
opinion on the State of Oklahoma’s compliance based on our audit. Reasonable assurance is a high
level of assurance but is not absolute assurance and therefore is not a guarantee that an audit
conducted in accordance with GAAS, Government Auditing Standards, and the Uniform Guidance
will always detect material noncompliance when it exists. The risk of not detecting material
noncompliance resulting from fraud is higher than for that resulting from error, as fraud may
involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal
control. Noncompliance with the compliance requirements referred to above is considered material
if there is a substantial likelihood that, individually or in the aggregate, it would influence the
judgment made by a reasonable user of the report on compliance about the State of Oklahoma’s
compliance with the requirements of each major federal program as a whole.

In performing an audit in accordance with GAAS, Government Auditing Standards, and the
Uniform Guidance, we:

    •   Exercise professional judgment and maintain professional skepticism throughout the audit.



                                                 5
    •   Identify and assess the risks of material noncompliance, whether due to fraud or error, and
        design and perform audit procedures responsive to those risks. Such procedures include
        examining, on a test basis, evidence regarding the State of Oklahoma’s compliance with
        the compliance requirements referred to above and performing such other procedures as
        we considered necessary in the circumstances.

    •   Obtain an understanding of the State of Oklahoma’s internal control over compliance
        relevant to the audit in order to design audit procedures that are appropriate in the
        circumstances and to test and report on internal control over compliance in accordance with
        the Uniform Guidance, but not for the purpose of expressing an opinion on the effectiveness
        of the State of Oklahoma’s internal control over compliance. Accordingly, no such opinion
        is expressed.

We are required to communicate with those charged with governance regarding, among other
matters, the planned scope and timing of the audit and any significant deficiencies and material
weaknesses in internal control over compliance that we identified during the audit.

Other Matters

The results of our auditing procedures disclosed other instances of NONCOMPLIANCE which
are required to be reported in accordance with the Uniform Guidance and which are described in
the accompanying schedule of findings and questioned costs as items:

    2022-002        2022-004         2022-006        2022-010         2022-017        2022-022
    2022-023        2022-025         2022-029        2022-031         2022-037        2022-043
    2022-044        2022-048         2022-049        2022-051         2022-053        2022-054
    2022-058        2022-059         2022-060        2022-063         2022-066        2022-067
    2022-068        2022-074         2022-081        2022-082         2022-084        2022-088
    2022-090        2022-101         2022-205        2022-206

Our opinion on each major federal program is not modified with respect to these matters.

Government Auditing Standards require the auditor to perform limited procedures on the State of
Oklahoma’s response to the noncompliance findings identified in our compliance audit described
in the accompanying schedule of findings and questioned costs. The State of Oklahoma’s response
was not subjected to the other auditing procedures applied in the audit of compliance and,
accordingly, we express no opinion on the response.

Report on Internal Control Over Compliance

Our consideration of internal control over compliance was for the limited purpose described in the
Auditor’s Responsibilities for the Audit of Compliance section above and was not designed to
identity all deficiencies in internal control over compliance that might be material weaknesses or
significant deficiencies in internal control over compliance and therefore, material weaknesses or
significant deficiencies may exist that were not identified. However, as discussed below, we did
identify certain deficiencies in internal control over compliance that we consider to be material
weaknesses and significant deficiencies.

A deficiency in internal control over compliance exists when the design or operation of a control
over compliance does not allow management or employees, in the normal course of performing

                                                6
their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance
requirement of a federal program on a timely basis. A Material Weakness in internal control over
compliance is a deficiency, or combination of deficiencies, in internal control over compliance,
such that there is reasonable possibility that material noncompliance with a type of compliance
requirement of a federal program will not be prevented, or detected and corrected, on a timely basis.
We consider the deficiencies in internal control over compliance described in the accompanying
schedule of findings and questioned costs as items (see list below) to be material weaknesses.

    2022-007         2022-012         2022-014         2022-018        2022-024         2022-025
    2022-028         2022-029         2022-030         2022-032        2022-033         2022-034
    2022-036         2022-038         2022-039         2022-040        2022-041         2022-042
    2022-046         2022-051         2022-056         2022-060        2022-064         2022-067
    2022-071         2022-076         2022-077         2022-085        2022-086         2022-087
    2022-090         2022-202         2022-205

A Significant Deficiency in internal control over compliance is a deficiency, or a combination of
deficiencies, in internal control over compliance with a type of compliance requirement of a federal
program that is less severe than a material weakness in internal control over compliance, yet
important enough to merit attention by those charged with governance. We consider the
deficiencies in internal control over compliance described in the accompanying schedule of
findings and questioned costs as items (see list below) to be significant deficiencies.

    2022-006         2022-020         2022-022         2022-025        2022-031          2022-043
    2022-044         2022-049         2022-053         2022-054        2022-057          2022-059
    2022-061         2022-062         2022-063         2022-065        2022-066          2022-070
    2022-074         2022-078         2022-079         2022-081        2022-082          2022-084
    2022-088         2022-201         2022-203         2022-204        2022-206

Our audit was not designed for the purpose of expressing an opinion on the effectiveness of internal
control over compliance. Accordingly, no such opinion is expressed.

Government Auditing Standards requires the auditor to perform limited procedures on the State of
Oklahoma’s response to the internal control over compliance findings identified in our compliance
audit described in the accompanying schedule of findings and questioned costs. The State of
Oklahoma’s response was not subjected to the other auditing procedures applied in the audit of
compliance and, accordingly, we express no opinion on the response.

The purpose of this report on internal control over compliance is solely to describe the scope of
our testing of internal control over compliance and the results of that testing based on the
requirements of the Uniform Guidance. Accordingly, this report is not suitable for any other
purpose.

Report on Schedule of Expenditures of Federal Awards Required by the Uniform Guidance

We have audited the financial statements of the governmental activities, the business-type
activities, the aggregate discretely presented component units, each major fund, and the aggregate




                                                  7
remaining fund information of the State of Oklahoma as of and for the year ended June 30, 2022,
and the related notes to the financial statements, which collectively comprise the State of
Oklahoma’s basic financial statements. We issued our report thereon dated August 30, 2023, which
contained unmodified opinions on those financial statements. Our report included a reference to
our reliance on other auditors. Our report also included emphasis paragraphs on the net deficit of
the Multiple Injury Trust Fund and the adopted provisions of GASB Statement No. 87, Leases,
GASB Statement No. 89, Accounting for Interest Cost Incurred before the End of Construction
Period, GASB Statement No. 92, Omnibus 2020, GASB Statements No. 93, Replacement of
Interbank Offered Rates, effective July 2021; and GASB Statement No. 99, Omnibus 2022,
paragraphs 26-32, effective April 2022.

Our audit was conducted for the purpose of forming opinions on the financial statements that
collectively comprise the State of Oklahoma’s basic financial statements. The accompanying
schedule of expenditures of federal awards is presented for purposes of additional analysis as
required by the Uniform Guidance and is not a required part of the basic financial statements. Such
information is the responsibility of management and was derived from and relates directly to the
underlying accounting and other records used to prepare the basic financial statements. The
information has been subjected to the auditing procedures applied in the audit of the financial
statements and certain additional procedures, including comparing and reconciling such
information directly to the underlying accounting and other records used to prepare the basic
financial statements or to the basic financial statements themselves, and other additional
procedures in accordance with auditing standards generally accepted in the United States of
America. In our opinion, the schedule of expenditure of federal awards is fairly stated in all material
respects in relation to the basic financial statements as a whole.



CINDY BYRD, CPA
OKLAHOMA STATE AUDITOR AND INSPECTOR

March 25, 2024 except for our report on the Schedule of
Expenditures of Federal Awards, for which the date is August 30,
2023




                                                   8
Schedule of Findings and Questioned Costs
Schedule of Findings
Summary of Auditor’s Results

Financial Statements

Type of auditor’s report issued: .................................................................................................... unmodified

Internal control over financial reporting:

            Material weakness(es) identified? ...............................................................................................Yes

            Significant deficiencies identified that are not
              considered to be material weakness(es)? .................................................................................Yes

Noncompliance material to financial statements noted?............................................................................. No

For fiscal year 2022, the Report on Internal Control Over Financial Reporting and on Compliance and Other
Matters Based on an Audit of Financial Statements Performed In Accordance With Government Auditing
Standards was issued under separate cover from the Annual Comprehensive Financial Report for the State of
Oklahoma for the year ended June 30, 2022, dated August 30, 2023.

Federal Awards

Internal control over major programs:

            Material weakness(es) identified? ...............................................................................................Yes

            Significant deficiencies identified that are not
              considered to be material weakness(es)? .................................................................................Yes

Type of auditor’s report issued on compliance for major programs - Unmodified for all major programs except
for the following:

    #10.542 – Pandemic EBT Food Benefits                                                                                      Qualified
    SNAP Cluster                                                                                                              Qualified
    #17.225 - Unemployment Insurance                                                                                          Qualified
    #20.509 - Formula Grants for Rural Areas                                                                                  Disclaimer
    #21.019 – Coronavirus Relief Fund                                                                                         Qualified
    #21.023 – Emergency Rental Assistance                                                                                  Adverse/Qualified
    #84.425 – Education Stabilization Fund                                                                                    Qualified
    #93.268 – Immunization Cooperative Agreements                                                                              Adverse
    #93.323 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)                                               Adverse

    #93.558 – Temporary Assistance for Needy Families                                                                            Qualified
    CCDF Cluster                                                                                                                 Qualified
    #93.658 - Foster Care – Title IV-E                                                                                           Qualified
    #93.767 - Children’s Health Insurance Program                                                                                Qualified
    Medicaid Cluster                                                                                                             Qualified

Any audit findings disclosed that are required to be reported
 in accordance with 2 CFR 200.516(a)? ..................................................................................................Yes

Dollar threshold used to distinguish between type A and type B programs: ……………………$30,000,000

Auditee qualified as low-risk auditee?........................................................................................................ No




                                                                              9
Schedule of Findings
Summary of Auditor's Results


Identification of Major Programs:

                                 Assistance Listing Number and Program                     State Agency Name
                         10.093 Voluntary Public Access and Habitat Incentive              Department of Wildlife Conservation

                         10.542 Pandemic EBT Food Benefits                                 Department of Human Services

    SNAP Cluster         10.551 Supplemental Nutrition Assistance Program                  Department of Human Services
                         10.561 State Administrative Matching Grants for the
                                Supplemental Nutrition Assistance Program

                         14.228 Community Development Block Grants/State's Program         Department of Commerce
                                and Non-Entitlement Grants in Hawaii

                         14.231 Emergency Solutions Grant Program                          Department of Commerce

                         14.269 Hurricane Sandy Community Development Block Grant          Department of Commerce
                                Disaster Recovery Grants

   Fish and Wildlife     15.605 Sport Fish Restoration Program                             Department of Wildlife Conservation
        Cluster          15.611 Wildlife Restoration and Basic Hunter Education
                         15.626 Enhanced Hunter and Safety Education

                         15.634 State Wildlife Grants                                      Department of Wildlife Conservation

                         17.225 Unemployment Insurance                                     Employment Security Commission

    WIOA Cluster         17.258 WIOA Adult Programs                                        Department of Commerce
                         17.259 WIOA Youth Activities
                         17.278 WIOA Dislocated Worker Formula Grants

                         20.509 Formula Grants for Rural Areas                             Department of Transportation

                         21.019 Coronavirus Relief Fund                                    State of Oklahoma (numerous agencies)

                         21.023 Emergency Rental Assistance                                State of Oklahoma - CARES Forward

  Clean Water State    66.458 Capitalization Grants for Clean Water State Revolving        Water Resources Board
Revolving Fund Cluster        Funds


 Drinking Water State 66.468 Capitalization Grants for Drinking Water State Revolving Department of Environmental Quality
Revolving Fund Cluster       Funds


                         84.126 Rehabilitation Services Vocational Rehabilitation Grants
                                to States                                                  Department of Rehabilitation Services

Education Stabilization 84.425C Governor’s Emergency Education Relief (GEER) Fund       Department of Education, Governor's
        Fund                                                                            Office, Office of Management and
                        84.425D Elementary and Secondary School Emergency Relief        Enterprise Services
                                (ESSER) Fund
                        84.425R Coronavirus Response and Relief Supplemental
                                Appropriations Act, 2021 - Emergency Assistance to Non-
                                Public Schools (CRRSA EANS) Program




                                                            10
Schedule of Findings
Summary of Auditor's Results

                     84.425U American Rescue Plan - Elementary and Secondary
                             School Emergency Relief (ARP ESSER)
                     84.425W American Rescue Plan - Elementary and Secondary
                             School Emergency Relief - Homeless Children and Youth


                      93.268 Immunization Cooperative Agreements                       Department of Health



                      93.323 Epidemiology and Laboratory Capacity for Infectious       Department of Health
                             Diseases (ELC)


                      93.558 Temporary Assistance for Needy Families                   Department of Human Services,
                                                                                       Department of Libraries, Department of
                                                                                       Career and Technology Education, Mental
                                                                                       Health and Substance Abuse Services


                      93.569 Community Services Block Grant                            Department of Commerce

   CCDF Cluster       93.575 Child Care and Development Block Grant                    Department of Human Services
                      93.596 Child Care Mandatory and Matching Funds of the Child
                             Care and Development Fund

                      93.658 Foster Care IV-E                                          Department of Human Services, Office of
                                                                                       Juvenile Affairs

                      93.659 Adoption Assistance                                       Department of Human Services

                      93.767 Children’s Health Insurance Program                       Health Care Authority, Department of
                                                                                       Health


  Medicaid Cluster    93.775 State Medicaid Fraud Control Units                        Attorney General
                      93.777 State Survey and Certification of Health Care Providers   Department of Health
                             and Suppliers (TitleXVIII) Medicare
                      93.778 Medical Assistance Program                                Health Care Authority, Department of
                                                                                       Human Services, Department of Health




                                                         11
Schedule of Findings
And Questioned Costs

                               Financial Statement Findings
Reference Number: 22-290-035
State Agency: Oklahoma Employment Security Commission (OESC)
Fund Type: Government-Wide – Business Type Activities; Enterprise Fund
Other Information: Unemployment Insurance Benefit Expenditures

Criteria: The Government Accountability Office (GAO) Standards for Internal Control in the Federal Government
9.04 states, in part, “As part of risk assessment or a similar process, management analyzes and responds to identified
changes and related risks in order to maintain an effective internal control system. Changes in conditions affecting the
entity and its environment often require changes to the entity’s internal control system, as existing controls may not
be effective for meeting objectives or addressing risks under changed conditions. Management analyzes the effect of
identified changes on the internal control system and responds by revising the internal control system on a timely
basis, when necessary, to maintain its effectiveness.”

The Government Accountability Office (GAO) Standards for Internal Control in the Federal Government 10.03 states,
in part, “Management designs appropriate types of control activities for the entity’s internal control system. Control
activities help management fulfill responsibilities and address identified risk responses in the internal control system.
… Management establishes physical control to secure and safeguard vulnerable assets. Examples include security for
and limited access to assets such as cash, securities, inventories, and equipment that might be vulnerable to risk of
loss or unauthorized use. Management periodically counts and compares such assets to control records.”

The Government Accountability Office (GAO) Standards for Internal Control in the Federal Government 10.06 states,
“Control activities can be implemented in either an automated or a manual manner. Automated control activities are
either wholly or partially automated through the entity’s information technology. … Automated control activities tend
to be more reliable because they are less susceptible to human error and are typically more efficient. If the entity relies
on information technology in its operations, management designs control activities so that the information technology
continues to operate properly.”

The Government Accountability Office (GAO) Standards for Internal Control in the Federal Government 11.13 states,
in part, “Management evaluates security threats to information technology, which can be from both internal and
external sources. External threats are particularly important for entities that depend on telecommunications networks
and the Internet. External threats have become prevalent in today’s highly interconnected business environments, and
continual effort is required to address these risks.”

A component objective of an effective internal control system is to ensure accurate and reliable information through
a proper review and approval process.

Condition: When testing a sample of 62 Unemployment Insurance claim payments totaling $21,413 (identified by
check number per payment data), we noted 2 unallowable payments due to unresolved fraud stops totaling $629 were
paid to 2 claimants, which is a 3.23% error rate of claims tested and a 2.94% error rate of dollars tested. We isolated
these 2 claimants from all state fiscal year 2022 payments per the applicant identifier (SSN per payment data) and
identified 68 benefit payments totaling $15,979 on those 2 claimants.

Cause: The agency’s internal controls were insufficient to detect and/or prevent unallowable unemployment benefit
payments. The lack of controls over the Unemployment Insurance benefit payments that led to the increase in
unallowable payments was a result of the following factors:
    • Antiquated system that didn’t have the capacity for proper automated edits or matching of all necessary fields
        at the time a claim was filed.
    • Large number of stolen identities.
    • Lack of adequate staffing to handle the volume of claims paid for all Unemployment Insurance programs.
    • Lack of adequate training for all staff related to the various Unemployment Insurance program requirements.
    • Delays in the process for employers to dispute claims since the process was largely manual through the




                                                            12
Schedule of Findings
And Questioned Costs
         mailing of notifications.

Effect: Unallowable benefit payments were made, which contributed to the depletion of the Unemployment Insurance
Trust Fund.

With a dollar error rate of 2.94% and benefit payments data total of $275,005,155, we project the amount of
unallowable benefit expenditures were $8,085,152 in state fiscal year 2022. Efforts by OESC to identify and
investigate known and suspected claims, and recover fraudulent and overpayment claims, are ongoing. However,
OESC has made improvements in identifying trends or anomalies in the data that has allowed the agency to suspend
large amounts of potentially fraudulent claims until they can be examined. In addition, OESC implemented VerifyOK
in November of 2022 to further deter and prevent identity theft fraud.

Recommendation: We recommend the OESC perform the following:
   • Continue to work to strengthen internal controls over the automated system to better detect and prevent
      unemployment insurance benefit overpayments related to fraudulent or administrative errors.
   • Continue to refine the analytics process that will help better identify trends or anomalies in the data to catch
      fraudulent claims timely and save taxpayer monies.
   • Work to strengthen their eligibility verification process to help prevent fraudulent claims.
   • Continue to work with the U.S. Department of Labor to recover the remaining fraudulent payments.
   • Continue to work to establish overpayment resolution for unemployment benefit claims.

Agency Management Response: Management does not completely disagree with the Condition, Cause and Effect
as documented by the auditors. Please see the corrective action plan located in the corrective action plan section of
this report.

Auditor Response: The claims identified as errors were based on the information available to the auditor at the time
of testing. In addition, based on Audit Sampling section AU-C 530.13, the auditor should project the results of audit
sampling to the population.

Reference Number: 22-807-008
State Agency: Oklahoma Health Care Authority (OHCA)
Fund Type: General Fund
Other Information: Accounts Payable & Federal Receivable (GAAP Pkg. Q - Medicaid Payable and Receivable &
GAAP Pkg. Z – Schedule of Expenditures of Federal Awards)

Criteria: The Government Accountability Office (GAO) Standards for Internal Control in the Federal Government
10.03 states, in part, “Transactions are promptly recorded to maintain their relevance and value to management in
controlling operations and making decisions. This applies to the entire process or life cycle of a transaction or event
from its initiation and authorization through its final classification in summary records. In addition, management
designs control activities so that all transactions are completely and accurately recorded.”

A basic objective of Generally Accepted Accounting Principles is to provide accurate and reliable information.

A component objective of an effective internal control system is to ensure accurate and reliable information through
a proper review and approval process.

Condition: Based upon testwork performed on GAAP Package Q - Medicaid Payable and Receivable, we noted
Medicaid Accounts Payable was recorded at $866,894,715 and Medicaid Federal Receivable was recorded at
$584,001,412. However, based on errors in the calculations for both accounts, the Medicaid Accounts Payable amount
should have been $781,270,299 and the Medicaid Federal Receivable amount should have been $514,300,444.

Cause: We noted that amounts were incorrectly transferred from the “Service Date Reimbursement Analysis” Report
(MAR-2300-M reports) to the “Encumbered Funds by Date of Service” excel spreadsheet. The variances occurred
when amounts were manually entered incorrectly onto the Encumbered Funds by Date of Service spreadsheet.




                                                          13
Schedule of Findings
And Questioned Costs

In addition, it does not appear the Encumbered Funds by Date of Service spreadsheet amounts were being reviewed
to ensure they were being recorded correctly.

Effect: The errors on the Encumbered Funds by Date of Service spreadsheet resulted in Medicaid Accounts Payable
being overstated by $85,624,416 and Medicaid Federal Receivable being overstated by $69,700,968 for GAAP
Package Q.

In addition, the overstatements carried through to GAAP Package Z for ALN # 93.778 Medical Assistance Program
& ALN # 93.767 Children’s Health Insurance Program Current Year Federal Accounts Payable and Accounts
Receivable.

Recommendation: We recommend OHCA continue to work to strengthen their review and reconciliation controls
related to the accuracy of data reported for Medicaid Accounts Payable and Medicaid Federal Receivable.

Agency Management Response: Management concurs with the finding. Please see the corrective action plan located
in the corrective action plan section of this report.


                                    End of Financial Statement Findings


             Federal Award Findings and Questioned Costs
                             Note: Findings are presented alphabetically by state agency


                         STATE OF OKLAHOMA – cares forward

FINDING NO: 2022-028
STATE AGENCY: State of Oklahoma, Office of Management and Enterprise Services (OMES)
FEDERAL AGENCY: US Department of Treasury (Treasury)
ALN: 21.023
FEDERAL PROGRAM NAME: Emergency Rental Assistance (ERA 1 and ERA 2)
FEDERAL AWARD NUMBER: ERA0028 and ERAE0259
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Reporting
QUESTIONED COSTS: $0

Criteria: 2 CFR § 200.303 – Internal Controls states in part, “The Non-Federal entity must; (a) establish and
maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal
entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions
of the Federal award.”

2 CFR § 200.334 – Retention requirements for records states in part, “Financial records, supporting documents,
statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period
of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed
quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as
reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.”




                                                          14
Schedule of Findings
And Questioned Costs
The US Department of Treasury Emergency Rental Assistance Quarterly Reporting Special Tip (as of 1/24/2022)
states, “The sum of the Expenditures in ERA Monthly Reports are expected to equal Quarterly total expenditures for
the respective period less any necessary adjustments (for example, for returned checks)”.

The US Department of Treasury Emergency Rental Assistance Reallocation Guidance (as of 9/6/2022) states,
“Grantees are encouraged to partner with local nonprofit organizations and governmental agencies to expedite the
obligation process and delivery of assistance to eligible households. However, Grantees may not use subrecipient
agreements with these entities to avoid meeting the statutory obligation deadlines, and funds will not be considered
obligated based solely on the fact they are subject to an agreement that provides for another entity to administer
assistance on the Grantee’s behalf.”.

Condition and Context: While documenting controls over monthly and quarterly reports for the ERA 1 and ERA 2
programs, we noted that OMES incorrectly reported the total dollar amount of ERA award funds expended or approved
(obligated) to or for participating households in the reporting period. The State reported all funds distributed to
subrecipients as expended or obligated for the program, which was unallowable per Treasury guidance.

In our analysis of the monthly and quarterly reports for the ERA 1 and ERA 2 programs, we noted variances between
the combined monthly reports and the applicable quarterly reports: ERA 1 – quarterly report was 5.64% higher than
the sum of the monthly reports; ERA 2 – quarterly report was (10.41%) less than the sum of the monthly reports. The
sum of three-monthly reports that comprise a quarterly report should be equal to the amount recorded on the quarterly
report less adjustments. Adjustments should be documented and maintained as part of the reporting support. We noted
the contractor completing the monthly and quarterly reports did not maintain support for adjustments.

OMES relied on a contractor of one of the two subrecipients to complete all compliance reports and did not obtain
any supporting data used to compile the reports. In addition, the other subrecipient did not have a contractual
relationship with this contractor and only provided to the contractor their final numbers to be included in the report.
We verified the contractor did not obtain any supporting data from the subrecipients for any of the reports submitted.
Therefore, the amounts reported were not properly reviewed or verified for accuracy by OMES prior to submission to
Treasury.

One of the subrecipients was unable to provide the underlying data to support the amounts reported on the monthly
reports. The subrecipient provided SAI the same report amounts given to the contractor used to compile the monthly
reports. However, the subrecipient was unable to provide underlying data that would allow SAI to recalculate and
verify the reported amounts were accurate. We noted the following:
     • ERA 1 June 2021 Monthly report had program expenditures of $9,555,349.00 and the unsupported amount
         was $9,524,697.34.
     • ERA 1 January 2022 Monthly report had program expenditures of $7,262,211.00 and the unsupported
         amount was $3,403,282.78.
     • ERA 2 April 2022 Monthly report had program expenditures of $19,685,712.00, of which the entire amount
         was unsupported.

We reviewed 3 monthly reports totaling $36,503,272 of ERA program expenditures, of which $32,613,692.12
(89.34%) was unsupported.

Cause: OMES did not establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the State is managing the Federal award in compliance with federal statutes, regulations,
and the terms and conditions of the Federal award.

OMES personnel responsible for oversight of the ERA grant do not normally oversee Federal grant programs, and do
not have adequate experience with administering Federal grant funds and understanding the reporting requirements.

OMES fully relied on the subrecipients to administer the program and meet reporting requirements with little guidance.

Effect: OMES did not accurately and correctly report ERA program expenditures on federal reports.




                                                          15
Schedule of Findings
And Questioned Costs
Recommendation: We recommend that the OMES develop and implement internal controls to ensure that program
obligations and expenditures are accurately reported. We also recommend OMES obtain and review reports and
supporting documentation before submitting to the Federal agency.

We recommend that the OMES personnel responsible for oversight of the ERA grant obtain the necessary training
and knowledge to ensure compliance with federal reporting requirements.

Views of Responsible Official(s)
Contact Person: Brandy Manek
Anticipated Completion Date: N/A
Corrective Action Planned: The Office of Management and Enterprise Services does not agree with the finding.
Please see the corrective action plan located in the corrective action plan section of this report.

Auditor Response: All policy changes reflected in the corrective action as well as Treasury no longer requiring
monthly reports, should resolve the issues regarding obligated and expended funds per the date of the guidance by
Treasury. However, we would like to stress that OMES needs to obtain and review reports and supporting
documentation before submitting the information to the Federal agency to ensure the reports are accurate and
complete. We would also like to point out that when Treasury accepts the reports provided to them, they are not tying
the figures to support and therefore aren’t indicating the report is accurate but rather it has been received.

FINDING NO: 2022-030 (Repeat Finding 2021-083)
STATE AGENCY: State of Oklahoma, Office of Management and Enterprise Services (OMES)
FEDERAL AGENCY: US Department of Treasury
ALN: 21.023
FEDERAL PROGRAM NAME: Emergency Rental Assistance (ERA 1 and ERA 2)
FEDERAL AWARD NUMBER: ERA0028 and ERAE0259
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Reporting
QUESTIONED COSTS: $0

Criteria: Per 2 CFR §200.303 states in part, “The non-Federal entity must: (a) Establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the
Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”

2 CFR §200.502 (a) states in part, “Determining Federal awards expended. The determination of when a Federal
award is expended must be based on when the activity related to the Federal award occurs.”

2 CFR §200.510(b), states in part, “Schedule of expenditures of Federal awards. The auditee must also prepare a
schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must
include the total Federal awards expended as determined in accordance with §200.502.
…
(3) Provide total Federal awards expended for each individual Federal program and the Assistance Listings Number
or other identifying number when the Assistance Listings information is not available. For a cluster of programs also
provide the total for the cluster.
(4) Include the total amount provided to subrecipients from each Federal program.”

Condition and Context: The State of Oklahoma’s ERA State Fiscal Year (SFY) 2022 GAAP Package Z – Schedule
of Expenditures of Federal Awards (SEFA) did not correctly report subrecipient expenditures in the “Amounts
Transferred to Non-State Agency Subrecipients and Higher Education” column. The error was not detected during the
State Interim Comptroller’s review process.

Cause: OMES did not perform an adequate review of the SEFA to ensure it was properly completed and expenditures
were properly reported.




                                                         16
Schedule of Findings
And Questioned Costs
Effect: The amount provided to non-state agency subrecipients and higher education column was not accurately
reported on the SEFA, resulting in a $239,529,714 understatement.

Recommendation: We recommend the State of Oklahoma review their current procedures for completing GAAP
Package Z and implement the necessary controls to ensure accurate reporting of subrecipient expenditures on the
SEFA.

Views of Responsible Official(s)
Contact Person: Brandy Manek
Anticipated Completion Date: Next SEFA/Package Z completion
Corrective Action Planned: The Office of Management and Enterprise Services partially agrees with the finding.
Please see the corrective action plan located in the corrective action plan section of this report.

Auditor Response: This is a repeat finding, and it should be noted that the agency’s corrective action plan to the
prior year finding was “We concur with this finding. We will review procedures and implement necessary controls to
insure accurate reporting of subrecipient expenditures.” However, the agency did not accurately report subrecipient
expenditures again in fiscal year 2022.

SAI reiterates that the two non-profit entities in question determined eligibility for the ERA grant and are responsible
for adherence to applicable Federal program requirements specified in the Federal award, therefore both parties are
considered subrecipients not contractors. 2 CFR §200.331states, “The non-Federal entity may concurrently receive
Federal awards as a recipient, a subrecipient, and a contractor, depending on the substance of its agreements with
Federal awarding agencies and pass-through entities. Therefore, a pass-through entity must make case-by-case
determinations whether each agreement it makes for the disbursement of Federal program funds casts the party
receiving the funds in the role of a subrecipient or a contractor. The Federal awarding agency may supply and require
recipients to comply with additional guidance to support these determinations provided such guidance does not
conflict with this section.

(a) Subrecipients. A subaward is for the purpose of carrying out a portion of a Federal award and creates a Federal
assistance relationship with the subrecipient. See definition for Subaward in § 200.1 of this part. Characteristics which
support the classification of the non-Federal entity as a subrecipient include when the non-Federal entity:
(1) Determines who is eligible to receive what Federal assistance.
(2) Has its performance measured in relation to whether objectives of a Federal program were met;
(3) Has responsibility for programmatic decision-making;
(4) Is responsible for adherence to applicable Federal program requirements specified in the Federal award; and
(5) In accordance with its agreement, uses the Federal funds to carry out a program for a public purpose specified in
authorizing statute, as opposed to providing goods or services for the benefit of the pass-through entity.

(b) Contractors. A contract is for the purpose of obtaining goods and services for the non-Federal entity's own use
and creates a procurement relationship with the contractor. See the definition of contract in § 200.1 of this part.
Characteristics indicative of a procurement relationship between the non-Federal entity and a contractor are when the
contractor:
(1) Provides the goods and services within normal business operations;
(2) Provides similar goods or services to many different purchasers;
(3) Normally operates in a competitive environment;
(4) Provides goods or services that are ancillary to the operation of the Federal program; and
(5) Is not subject to compliance requirements of the Federal program as a result of the agreement, though similar
requirements may apply for other reasons.

(c) Use of judgment in making determination. In determining whether an agreement between a pass-through entity
and another non-Federal entity casts the latter as a subrecipient or a contractor, the substance of the relationship is
more important than the form of the agreement. All of the characteristics listed above may not be present in all cases,
and the pass-through entity must use judgment in classifying each agreement as a subaward or a procurement
contract.”




                                                           17
Schedule of Findings
And Questioned Costs

In addition, if the non-profit entities had truly been classified as contractors, the responsibility for determining
eligibility would have fallen on OMES to determine participant eligibility. However, OMES was not involved in the
eligibility determination, or decision-making role at all for ERA program during SFY 2022.

FINDING NO: 2022-032 (Repeat 2021-080)
STATE AGENCY: State of Oklahoma, Office of Management and Enterprise Services
FEDERAL AGENCY: US Department of Treasury
ALN: 21.023
FEDERAL PROGRAM NAME: Emergency Rental Assistance (ERA 1 and ERA 2)
FEDERAL AWARD NUMBER: ERA028 and ERAE0259
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility
QUESTIONED COSTS: $7,044,973

Criteria: U.S Department of the Treasury Emergency Rental Assistance Grantee Award Form (8) (a-b) Compliance
with Applicable Law and Regulations, states in part, “a. Recipient agrees to comply with the requirements of Section
501 and Treasury interpretive guidance regarding such requirements. Recipient also agrees to comply with all other
applicable federal statutes, regulations, and executive orders, and Recipient shall provide for such compliance in any
agreements it enters into with other parties relating to this award. b. Federal regulations applicable to this award
include, without limitation, the following: 1. Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards, 2 C.F.R. Part 200, other than such provisions as Treasury may determine are
inapplicable to this Award and subject to such exceptions as may be otherwise provided by Treasury.”

Per the U.S. Department of the Treasury Emergency Rental Assistance Frequently Asked Questions document revised
August 25, 2021, “The Department of the Treasury (Treasury) is providing these frequently asked questions (FAQs)
as guidance regarding the requirements of the Emergency Rental Assistance program (ERA1) established by section
501 of Division N of the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020) and the
Emergency Rental Assistance program (ERA2) established by section 3201 of the American Rescue Plan Act of 2021,
Pub. L. No. 117-2 (March 11, 2021).Grantees must establish policies and procedures to govern the implementation of
their ERA programs consistent with the statutes and these FAQs. To the extent that these FAQs do not provide specific
guidance on a particular issue, a grantee should establish its own policy or procedure that is consistent with the statutes
and follow it consistently.”

The US Department of Treasury Emergency Rental Assistance (ERA) FAQ #1 states in part “A grantee may only use
the funds provided in the ERA to provide financial assistance and housing stability services to eligible households. To
be eligible, a household must be obligated to pay rent on a residential dwelling [emphasis added] and the grantee
must determine that:
     i. for ERA1:
          a. one or more individuals within the household has qualified for unemployment benefits or experienced a
             reduction in household income, incurred significant costs, or experienced other financial hardship due,
             directly or indirectly, to the COVID-19 outbreak.
          b. one or more individuals within the household can demonstrate a risk of experiencing homelessness or
             housing instability; and
          c. the household has a household income at or below 80 percent of area median income.
     ii. for ERA2:
          a. one or more individuals within the household has qualified for unemployment benefits or experienced a
             reduction in household income, incurred significant costs, or experienced other financial hardship during or
             due, directly or indirectly, to the coronavirus pandemic.
          b. one or more individuals within the household can demonstrate a risk of experiencing homelessness or
             housing instability; and
          c. the household is a low-income family (as such term is defined in section 3(b) of the United States Housing
             Act of 1937 (42 U.S.C. 1437a(b))).2.”




                                                            18
Schedule of Findings
And Questioned Costs
The US Department of Treasury Emergency Rental Assistance (ERA) FAQ #4 states in part “If a written attestation
without further verification is relied on to document the majority of the applicant’s income, the grantee must reassess
the household’s income every three months by obtaining appropriate documentation or a new self-attestation.”

The US Department of Treasury Emergency Rental Assistance (ERA) FAQ #5 states in part “Grantees must obtain,
if available, a current lease, signed by the applicant and the landlord or sublessor, that identifies the unit where the
applicant resides and establishes the rental payment amount.”

The US Department of Treasury Emergency Rental Assistance (ERA) FAQ #6 states in part “All payments for utilities
and home energy costs should be supported by a bill, invoice, or evidence of payment to the provider of the utility or
home energy service.”

The US Department of Treasury Emergency Rental Assistance (ERA) FAQ #10 states in part, “In ERA1, an eligible
household may receive up to twelve (12) months of assistance (plus an additional three (3) months if necessary to
ensure housing stability for the household, subject to the availability of funds). The aggregate amount of financial
assistance an eligible household may receive under ERA2, when combined with financial assistance under ERA1,
must not exceed 18 months.”

2 CFR § 200.303(a) – Internal Controls states in part, “The Non-Federal entity must establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the
Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”

2 CFR § 200.334 – Retention requirements for records state in part, “Financial records, supporting documents,
statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period
of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed
quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as
reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.”

2 CFR § 200.337 Access to records states in part, “(a) Records of non-Federal entities. The Federal awarding agency,
Inspectors General, the Comptroller General of the United States, and the pass-through entity, or any of their
authorized representatives, must have the right of access to any documents, papers, or other records of the non-Federal
entity which are pertinent to the Federal award, in order to make audits, examinations, excerpts, and transcripts. The
right also includes timely and reasonable access to the non-Federal entity's personnel for the purpose of interview and
discussion related to such documents.”

Per Community Cares Partners Emergency Rental Assistance Policies and Procedures “Steps to Quality for
Assistance, Section B, Qualifications - to be approved to receive assistance,
   a.   Live in Oklahoma
   b. Rent [Refers to a household being obligated to pay rent on a dwelling in order to be eligible]
   c.   Qualified for unemployment OR one of the three below due, directly or indirectly, to COVID-19
           i. Reduction in household income
          ii. Incurred significant costs
         iii. Other financial hardship
    d. Risk of housing instability or homelessness
    e. 80% AMI”

The CCP application contains the following regarding “rent”:
*Qualification Checklist
Instructions: Use this form to verify eligibility for each applicant.
USE THE CHECKBOXES BELOW TO CONFIRM THE APPLICANT QUALIFIES FOR CCP
ASSISTANCE.
Check 2
     • Verify Applicant is a Renter
Reason(s) for Denial




                                                          19
Schedule of Findings
And Questioned Costs

     •   Applicant owns home.

Condition and Context: The State of Oklahoma was awarded federal ERA program funds. The Office of Management
Enterprise Services (OMES) passed the funds through to and contracted with two subrecipients to administer the ERA
program: Communities Foundation of Oklahoma (CFO) and Restore Hope Ministries (RHM), which respectively
administered 84% and 16% of ERA program assistance payments for rent and utilities. Community Cares Partners
(CCP), a division of CFO was initially formed to administer the Eviction Mitigation Program and began administering
the ERA program when OMES passed ERA funds through to CFO.

While testing 95 of 49,659 rent and utilities program expenditures, we noted the following:
   • For 20 of 95, or 21.05% of items tested, the amount paid for utilities did not agree to the supporting utility
        bill.
   • For 3 of 95, or 3.16% of items tested, we determined the applicant to potentially be fraudulent.
        o Two cases were flagged as fraudulent by CFO,
        o One case indicated the applicant applied for benefits three months after receiving the maximum number
              of benefits. Additionally, the applicant indicated on the second application they had not previously
              received ERA benefits.
   • For 1 of 95, or 1.05% of items tested, SAI was unable to verify the landlord. The landlord's address on the
        lease from 2018 does not exist. The assistance payment for rent was sent to the tenant when CCP could not
        get ahold of the landlord.
   • For 2 of 95, or 2.11% of items tested, the subrecipient was unable to provide documentation to support the
        applicant's eligibility.
   • For 1 of 95, or 1.05% of items tested, payment was made to a check cashing center for two checks that were
        cashed by applicants but not honored by the financial institution as a stop payment was placed on these
        checks. The subrecipient determined the two payments to be for ineligible applicants and attempted to stop
        the payments but the checks were already cashed.
   • For 1 of 95, or 1.05% of items tested, the payment was for Afghanistan refugees to live in hotels prior to
        applying to the ERA program. Since, at the time of application, they were not obligated to pay rent on a
        residential dwelling per Department of Treasury FAQ 1 and established CCP ERA policy, the cost is
        unallowable. This one item is made up of 498 individual payments made to hotels on behalf of Afghanistan
        refugees.
   • For 1 of 95, or 1.05% of items tested, the subrecipient paid the wrong person and was unable to recoup the
        funds.
   • For 5 of 95, or 5.26% of items tested, the payments were for Afghanistan refugees to move out of hotels and
        into apartments/houses. However, the refugees were not renters in Oklahoma at the time of their application
        and therefore were not eligible to receive ERA funds.
   • For 19 of 95, or 20% of items tested, the amount paid for rental assistance does not agree to the supporting
        documentation and/or was not calculated correctly.
   • For 13of 95, or 13.68% of items tested, the subrecipient was unable to provide sufficient supporting
        documentation for the amount of rental assistance paid.
   • For 11 of 95, or 11.58% of items tested, the subrecipient paid for an unallowable month(s).

While testing 75 of 498 Afghanistan refugee hotel charges, we noted 38 of 75 (50.67%) of the sample items tested, an
additional $381,703.38 in rent assistance was paid after receiving funds to stay in hotels. The applicants were
ineligible; therefore, these payments were unallowable.

We also noted $1,835,000 was paid to two contractors of CCP, Catholic Charities of the Archdiocese Oklahoma City
(Catholic Charities) and OKC Afghanistan Legal Network to provide assistance to Afghanistan refugees prior to the
refugees being obligated to pay rent on a dwelling and applying to the program, which we determined to be
unallowable. Further, we noted $28,627.57 was paid for incidental cleaning fees incurred during the refugee’s stay in
the hotels, which is also an unallowable cost. We also noted the contract between CCP and Catholic Charities was for
$1,340,000, however Catholic Charities was paid $1,810,000 or $470,000 more than the contract amount.




                                                         20
Schedule of Findings
And Questioned Costs
Other sources of assistance were available to refugees. According to the Administration for Children and Families
(ACF) Office of Refugee Resettlement (ORR) some Afghanistan humanitarian parolees are eligible to apply for
federal mainstream benefits in their state, such as cash assistance through Supplemental Security Income (SSI) or
Temporary Assistance for Needy Families (TANF), health insurance through Medicaid, and food assistance through
Supplemental Nutrition Assistance Program (SNAP). If the refugee (parolee) is not eligible to receive these
mainstream benefits, he/she can be screened for eligibility at Catholic Charities of the Archdiocese of Oklahoma City,
the local resettlement agency for Oklahoma, for the following ORR benefits and services:
     Initial ORR Benefits (up to 12 months from ORR eligibility date)
     • Refugee Cash Assistance (RCA) - Counting from their date of eligibility, individuals may receive up to 12
          months of RCA to help meet their most basic needs, such as food, shelter, and transportation.
     • ORR Matching Grant Program - The MG Program provides cash assistance, intensive case management, and
          employment services to help clients immediately find and maintain employment. The goal of the program is
          to assist clients to become economically self-sufficient within the 240-day service period.
     • Refugee Medical Assistance (RMA) - Those not eligible for Medicaid may receive up to 12 months of RMA
          from their date of eligibility. RMA provides the same health insurance coverage as Medicaid.
     • Medical Screening - From their date of eligibility, Afghanistan humanitarian parolees may be eligible for a
          domestic medical screening examination funded by ORR. The screening supports client resettlement by
          identifying health conditions that threaten their well-being, providing vaccinations required for school and
          work, and referring them to primary care providers or specialists for ongoing health care. ORR recommends
          that medical screenings are completed soon after arrival in the U.S.
     Services (up to March 31, 2023, or until the end of the individual’s parole term, whichever is later)
          • Employment Assistance: Refugee Support Services (RSS) - RSS helps provide employability services;
               job training and preparation; assistance with job search, placement, and retention; English language
               training; childcare; transportation; translation and interpreter services; and case management.
          • Immigration-Related Legal Assistance – Afghanistan humanitarian parolees may be eligible for
               immigration-related legal assistance and other related activities to help them on their pathway to
               obtaining a permanent status, such as acquiring asylum, in the United States.
          • Specialized Programs - Some clients may be eligible for specialized programs such as health services,
               technical assistance for small business start-ups, financial savings, youth mentoring, or other targeted
               support programs.

All issues noted above comprise the total questioned costs of $7,044,973. Of the total questioned costs, the total related
to ineligible Afghanistan refugees amounts to $6,594,079.14.

Cause: OMES personnel responsible for oversight of the ERA 1 and ERA 2 grants do not normally oversee Federal
grant programs, and do not have adequate experience with administering Federal grant funds and understanding the
types of activities that may be supported by the ERA 1 and ERA 2 grants.

OMES did not establish and maintain effective internal control over the Federal award that provides reasonable
assurance that OMES is managing the Federal award in compliance with Federal statutes, regulations, and the terms
and conditions of the Federal award.

OMES did not monitor subrecipients to ensure they established and maintained effective internal control over the
Federal award to provide reasonable assurance that the non-Federal entity was managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.

The subrecipients did not maintain effective internal control over payments to applicants for rent and utility expenses
to ensure compliance with allowability requirements and did not obtain all supporting documentation. In addition,
CCP, and therefore the State of Oklahoma, did not follow their established ERA policies and procedures for
determining eligibility.

Effect: Unallowable costs, totaling $7 million were charged to the ERA program.




                                                           21
Schedule of Findings
And Questioned Costs
Recommendation: We recommend that OMES develop and implement internal controls to ensure it administers
current and future ERA grants in accordance with applicable Federal laws and grant requirements, including ensuring
that grant subrecipients are properly informed of Federal requirements related to allowable costs and eligibility.

Further, we recommend OMES ensure subrecipients have established effective internal control over the Federal award
to provide reasonable assurance that the subrecipient is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award.

We recommend that OMES ensure the personnel responsible for oversight of the ERA grant obtain the necessary
training and knowledge to ensure compliance with Federal grant requirements.

Views of Responsible Official(s)
Contact Person: Brandy Manek
Anticipated Completion Date: June 2024
Corrective Action Planned:
The State disagrees with this finding. CCP considered the spreadsheets returned by the utility companies to be
acceptable supporting documentation for the amount that was paid, following Treasury’s best practices.

Auditor Response: SAI would like to stress that OMES has not provided an adequate corrective action to address
the major issues outlined in the finding.

Bullet 1 – Treasury’s best practices include building a relationship with energy providers and establishing information
sharing protocols, which SAI agrees with. However, the utility spreadsheet was internally created by CFO/CCP, which
was provided to the utility companies and returned to CFO/CCP. The utility spreadsheet could be edited after it was
returned; therefore, we cannot confirm those were the amounts owed per the utility company. SAI has informed OMES
that if the utility company could provide a report on their letterhead that the utility spreadsheet could not be edited
after the fact or if screenshots from the utility portal could be provided showing the amounts owed, we would be able
to use that as adequate supporting documentation.

SAI would like to reiterate per Department of Treasury FAQ 1 and established CCP ERA policy, a household must
be obligated to pay rent on a residential dwelling in order to be eligible and none of the Afghanistan refugees were
paying rent prior to receiving assistance from the ERA program.

Remaining Bullets – No additional support was provided; therefore, these findings will stand.

FINDING NO: 2022-033 (Repeat Finding 2021-081)
STATE AGENCY: State of Oklahoma, Office of Management and Enterprise Services (OMES)
FEDERAL AGENCY: US Department of Treasury
ALN: 21.023
FEDERAL PROGRAM NAME: Emergency Rental Assistance (ERA 1 and ERA 2)
FEDERAL AWARD NUMBER: ERA028 and ERAE0259
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Subrecipient Monitoring
QUESTIONED COSTS: $0

 Criteria: U.S Department of the Treasury Emergency Rental Assistance Grantee Award Form (8) (a-b) Compliance
with Applicable Law and Regulations, states in part,
    a. Recipient agrees to comply with the requirements of Section 501 and Treasury interpretive guidance
         regarding such requirements. Recipient also agrees to comply with all other applicable federal statutes,
         regulations, and executive orders, and Recipient shall provide for such compliance in any agreements it enters
         into with other parties relating to this award.
    b. Federal regulations applicable to this award include, without limitation, the following:
            i.    Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal
                  Awards, 2 C.F.R. Part 200, other than such provisions as Treasury may determine are inapplicable
                  to this Award and subject to such exceptions as may be otherwise provided by Treasury. Subpart F




                                                          22
Schedule of Findings
And Questioned Costs
                  -Audit Requirements of the Uniform Guidance, implementing the Single Audit Act, shall apply to
                  this award…
           iii.   Reporting Subaward and Executive Compensation Information, 2 C.F.R. Part 170, pursuant to
                  which the award term set forth in Appendix A to 2 C.F.R. Part 170 is hereby incorporated by
                  reference.

 2 CFR § 200.303(a) – Internal Controls states in part, “The Non-Federal entity must establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the
Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”

2 CFR § 200.332 Requirements for pass-through entities states in part, “All pass-through entities must:
(a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following
information at the time of the subaward and if any of these data elements change, include the changes in subsequent
subaward modification. When some of this information is not available, the pass-through entity must provide the best
information available to describe the Federal award and subaward. Required information includes:
(1) Federal Award Identification.
(i) Subrecipient name (which must match the name associated with its unique entity identifier);
(ii) Subrecipient's unique entity identifier;
(iii) Federal Award Identification Number (FAIN);
(iv) Federal Award Date (see § 200.39 Federal award date) of award to the recipient by the Federal agency;
(v) Subaward Period of Performance Start and End Date;
(vi) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient;
(vii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current
obligation;
(viii) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity;
(ix) Federal award project description, as required to be responsive to the Federal Funding Accountability and
Transparency Act (FFATA);
(x) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-
through entity;
(xi) CFDA Number and Name; the pass-through entity must identify the dollar amount made available under each
Federal award and the CFDA number at time of disbursement;
(xii) Identification of whether the award is R&D; and
(xiii) Indirect cost rate for the Federal award (including if the de minimis rate is charged per § 200.414 Indirect (F&A)
costs).”
(2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in
accordance with Federal statutes, regulations and the terms and conditions of the Federal award;
(3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through
entity to meet its own responsibility to the Federal awarding agency including identification of any required financial
and performance reports; …

(b) evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions
of the subaward for purposes of determining the appropriate subrecipient monitoring, which may include consideration
of such factors as:
(1) The subrecipient's prior experience with the same or similar subawards;
(2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with
Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited
as a major program;
(3) Whether the subrecipient has new personnel or new or substantially changed systems; and
(4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards
directly from a Federal awarding agency). …

(d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes,
in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward
performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: …




                                                           23
Schedule of Findings
And Questioned Costs
(2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining
to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews,
and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single
Audit findings related to the particular subaward. …

(f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that
the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set
forth in § 200.501.”

2 CFR § 200.334 – Retention requirements for records states in part, “Financial records, supporting documents,
statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period
of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed
quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as
reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.”

2 CFR § 200.337 Access to records states in part, “(a) Records of non-Federal entities. The Federal awarding agency,
Inspectors General, the Comptroller General of the United States, and the pass-through entity, or any of their
authorized representatives, must have the right of access to any documents, papers, or other records of the non-Federal
entity which are pertinent to the Federal award, in order to make audits, examinations, excerpts, and transcripts. The
right also includes timely and reasonable access to the non-Federal entity's personnel for the purpose of interview and
discussion related to such documents.”

Condition and Context: The State of Oklahoma entered into agreements with two non-profit entities to administer
the ERA program for the State of Oklahoma. SAI reviewed the agreements for these two entities and determined that
both agreements constituted a subrecipient relationship that would be subject to Part M Subrecipient Monitoring
requirements. Office of Management Enterprise Services (OMES) contracted with Eide Bailly to perform the
subrecipient monitoring for only one of the two subrecipients during SFY 2022; therefore, their monitoring procedures
were not sufficient and could not be relied on.
OMES provided subrecipients advance payments based on expected program rental and utility expenditures for the
month and then paid administrative costs on a set percentage, 9.3% for RHM for ERA 1; and 10 % and 15% for CFO
for ERA 1 and ERA 2 respectively, of program funds advanced. OMES did not review any supporting documentation
related to actual program expenditures for rental and utility assistance, housing stability activities, or administrative
expenditures actually incurred by the subrecipients. While OMES did obtain summary information related to rental
and utility payments and housing stability payments made for reporting purposes, OMES did not review any support
for administrative costs to ensure that the administrative costs were attributable to providing financial assistance and
housing stability services to eligible households.
OMES was unable to provide documentation to support that a risk assessment was performed in which each
subrecipient would have been verified to have maintained an active status in the SAM.gov system and that
subrecipients were not suspended or disbarred.

Cause: OMES did not establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. Adequate subrecipient monitoring policies and
procedures were not established by the State prior to entering into agreements with subrecipients.
The OMES personnel responsible for oversight of the ERA grants do not normally oversee Federal grant programs
and, do not have adequate experience with administering Federal grant funds and understanding the types of activities
that may be supported by the ERA grant.

Effect: The subrecipients may not be in compliance with the award terms and there is an increased risk of
mismanagement and fraud by the subrecipients.

Unallowable administrative costs totaling $8.9 million were paid to subrecipients with ERA funds during SFY 22.
The failure to monitor administrative expenditures on an on-going basis could result in payment of millions of dollars
of additional unallowable administrative charges to the subrecipient.




                                                           24
Schedule of Findings
And Questioned Costs
Recommendation: We recommend that OMES develop and implement internal controls to ensure:

    •    Each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions
         of the subaward is appropriately evaluated for monitoring purposes.
    •    Current and future ERA grants are administered in accordance with applicable Federal laws and grant
         requirements, including ensuring that grant subrecipients are provided the proper award documentation.
    •    Adequate supporting documentation for actual program and administrative expenditures incurred is obtained,
         reviewed, and maintained by the State in order to ensure subrecipients are only expending ERA funds for
         allowable costs.
    •    Subrecipients are reimbursed for administrative costs based on supporting documentation for actual costs
         incurred rather than making advanced payments for a set percentage of program funds advanced.
    •    Subrecipient records are available for inspection for monitoring and other audit purposes as required by
         OMES.

Views of Responsible Official(s)
Contact Person: Brandy Manek
Anticipated Completion Date: June 2021
Corrective Action Planned: The Office of Management and Enterprise Services does not agree with the finding.
Please see the corrective action plan located in the corrective action plan section of this report.

Auditor Response: This is a repeat finding, and it should be noted the agency’s corrective action plan to the prior
year finding was to create the Grants Management Office. However, the creation of the GMO does not specifically
address the State’s lack of internal controls for risk assessment and subrecipient monitoring. Further, the State only
engaged with Eide Bailly for subrecipient monitoring activities over one of the two subrecipients, which is not
sufficient subrecipient monitoring.

We do agree that Uniform Guidance indicates the substance of the relationship determines whether the entity is treated
as a subrecipient or a contractor. The specific guidance is located at 2 CFR 200.331 and states in part,
“(a) Subrecipients. A subaward is for the purpose of carrying out a portion of a Federal award and creates a Federal
assistance relationship with the subrecipient. See definition for Subaward in § 200.1 of this part. Characteristics which
support the classification of the non-Federal entity as a subrecipient include when the non-Federal entity:
(1) Determines who is eligible to receive what Federal assistance.
(2) Has its performance measured in relation to whether objectives of a Federal program were met;
(3) Has responsibility for programmatic decision-making;
(4) Is responsible for adherence to applicable Federal program requirements specified in the Federal award; and
(5) In accordance with its agreement, uses the Federal funds to carry out a program for a public purpose specified in
authorizing statute, as opposed to providing goods or services for the benefit of the pass-through entity.

(b) Contractors. A contract is for the purpose of obtaining goods and services for the non-Federal entity's own use
and creates a procurement relationship with the contractor. See the definition of contract in § 200.1 of this part.
Characteristics indicative of a procurement relationship between the non-Federal entity and a contractor are when the
contractor:
(1) Provides the goods and services within normal business operations;
(2) Provides similar goods or services to many different purchasers;
(3) Normally operates in a competitive environment;
(4) Provides goods or services that are ancillary to the operation of the Federal program; and
(5) Is not subject to compliance requirements of the Federal program as a result of the agreement, though similar
requirements may apply for other reasons.”

The non-profit entities both determined eligibility and made programmatic decisions related to participants for the
ERA program. In addition, if the non-profit entities had truly been classified as contractors, the responsibility for
determining eligibility would have fallen on OMES, who was not involved at all in the subrecipient monitoring
process.




                                                           25
Schedule of Findings
And Questioned Costs
FINDING NO: 2022-034
STATE AGENCY: State of Oklahoma, Office of Management and Enterprise Services (OMES)
FEDERAL AGENCY: US Department of Treasury
ALN: 21.023
FEDERAL PROGRAM NAME: Emergency Rental Assistance (ERA 1)
FEDERAL AWARD NUMBER: ERA0028
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Subrecipient Monitoring
QUESTIONED COSTS: $0

Criteria: U.S Department of the Treasury Emergency Rental Assistance Grantee Award Form (8) (a-b) Compliance
with Applicable Law and Regulations, states in part,

“a. Recipient agrees to comply with the requirements of Section 501 and Treasury interpretive guidance regarding
such requirements. Recipient also agrees to comply with all other applicable federal statutes, regulations, and
executive orders, and Recipient shall provide for such compliance in any agreements it enters into with other parties
relating to this award.
b. Federal regulations applicable to this award include, without limitation, the following:
1. Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 C.F.R. Part
200, other than such provisions as Treasury may determine are inapplicable to this Award and subject to such
exceptions as may be otherwise provided by Treasury.”

2 CFR §200.303 Internal Controls states in part, “The Non-Federal entity must: (a) Establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the
Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”

2 CFR § 200.332 Requirements for pass-through entities states in part, “All pass-through entities must:
(a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following
information at the time of the subaward and if any of these data elements change, include the changes in subsequent
subaward modification. When some of this information is not available, the pass-through entity must provide the best
information available to describe the Federal award and subaward. Required information includes:
(1) Federal Award Identification.
(i) Subrecipient name (which must match the name associated with its unique entity identifier);
(ii) Subrecipient's unique entity identifier;
(iii) Federal Award Identification Number (FAIN);
(iv) Federal Award Date (see § 200.39 Federal award date) of award to the recipient by the Federal agency;
(v) Subaward Period of Performance Start and End Date;
(vi) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient;
(vii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current
obligation;
(viii) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity;
(ix) Federal award project description, as required to be responsive to the Federal Funding Accountability and
Transparency Act (FFATA);
(x) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-
through entity;
(xi) CFDA Number and Name; the pass-through entity must identify the dollar amount made available under each
Federal award and the CFDA number at time of disbursement;
(xii) Identification of whether the award is R&D; and
(xiii) Indirect cost rate for the Federal award (including if the de minimis rate is charged per § 200.414 Indirect (F&A)
costs).”
(2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in
accordance with Federal statutes, regulations and the terms and conditions of the Federal award;
(3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through
entity to meet its own responsibility to the Federal awarding agency including identification of any required financial
and performance reports; …”




                                                           26
Schedule of Findings
And Questioned Costs

Condition and Context: The State of Oklahoma’s agreement with one subrecipient to administer the ERA 1 program
ended on March 31, 2022, and stated funds were “to be used for necessary expenditures/obligations that were or will
be incurred through March 31, 2022.” The State did not obtain a new agreement to cover the remainder of SFY 2022.
While the State did not advance any payments to the subrecipient after January 21, 2022, we noted that from April 1,
2022 through June 30, 2022, the subrecipient expended $5,293,134.71 in ERA 1 funds that were not within the
timeframe of the State’s agreement with the subrecipient.

Cause: The OMES personnel responsible for oversight of the ERA grant do not normally oversee Federal grant
programs, and do not have an adequate understanding or experience with administering Federal grant funds. OMES
thought an amended agreement was not needed because payments to the subrecipient were not made beyond March
of 2022.

Effect: Failure to ensure subrecipient agreements are appropriately updated to cover the Federal grant period could
result in inappropriate use of federal funds past the expiration date of the agreement.

Recommendation: We recommend OMES develop internal controls to ensure subrecipient agreements are reviewed
and updated regularly so the subrecipient is not operating under an expired agreement.

Views of Responsible Official(s)
Contact Person: Brandy Manek
Anticipated Completion Date: June 2024
Corrective Action Planned: The Office of Management and Enterprise Services agrees with the finding. Please
see the corrective action plan located in the corrective action plan section of this report.

FINDING NO: 2022-036
STATE AGENCY: State of Oklahoma, Office of Management and Enterprise Services
FEDERAL AGENCY: US Department of Treasury
ALN: 21.023
FEDERAL PROGRAM NAME: Emergency Rental Assistance (ERA 1 and ERA 2)
FEDERAL AWARD NUMBER: ERA0028 and ERAE0259
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Activities Allowed/Unallowed and Allowable Costs/Cost Principles
QUESTIONED COSTS: $0

Criteria: 2 CFR § 200.303 Internal controls states in part, “The Non-Federal entity must: (a) establish and maintain
effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the
Federal award.”

2 CFR § 200.334 Retention requirements for records states in part, “Financial records, supporting documents,
statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period
of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed
quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as
reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.”

US Department of Treasury FAQ #10 states, “In ERA1 an eligible household may receive up to twelve (12) months
of assistance (plus an additional three (3) months if necessary to ensure housing stability for the household, subject to
the availability of funds). The aggregate amount of financial assistance an eligible household may receive under
ERA2, when combined with financial assistance under ERA1, must not exceed 18 months.”

Condition and Context: While documenting controls over activities allowed or unallowed and allowable costs/cost
principles, we noted that OMES did not obtain any supporting documentation for actual program expenditures.




                                                           27
Schedule of Findings
And Questioned Costs
The subrecipients used Excel to track the number of months of assistance provided to each household. We noted that
one subrecipient did not maintain the Excel tracking sheet consistently throughout the year; thus, it was insufficient
to determine the total number of months paid to each household. The spreadsheet was not designed to allow a user to
see at a glance the number of arrears and prospective months of assistance paid to each household; therefore, the
subrecipient did not ensure all assistance payment to households were in compliance with program assistance limits.

Cause: OMES personnel responsible for oversight of the ERA grant do not normally oversee Federal grant programs,
and do not have adequate experience with administering Federal grant funds and understanding the types and limits
of activities that may be supported by the ERA grant.

The State of Oklahoma did not establish and maintain effective internal control over the Federal award to provide
reasonable assurance that the State and the subrecipients are managed the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award.

Effect: Failure to properly track the number of months of assistance provided to each household could result in
noncompliance with the federal award requirements. In addition, assistance payments to households for more than 15
months for ERA 1 or 18 months for ERA 2 could cause less ERA funds to be available for other eligible households
in need.

Failure to secure adequate supporting records from the subrecipient leads to increased risk that documentation may
not be properly retained and available for monitoring and audit purposes.

Recommendation: We recommend the OMES develop and implement internal controls to ensure
subrecipients establish effective internal controls over Federal awards to provide reasonable assurance that
subrecipients manage Federal awards in compliance with Federal statutes, regulations, and the terms and conditions
of the Federal award. We recommend OMES develop and implement internal controls to ensure subrecipient
records are available for inspection for monitoring and other audit purposes as required. We also recommend that
OMES ensure subrecipients develop and implement an appropriate method to track the number of months of
assistance provided to each household for ERA 1 and ERA 2 to ensure all payments comply with program
requirements and assistance limits per Treasury guidance.

Views of Responsible Official(s)
Contact Person: Brandy Manek
Anticipated Completion Date: February 2024
Corrective Action Planned: The Office of Management and Enterprise Services does not agree with the finding.
Please see the corrective action plan located in the corrective action plan section of this report.

Auditor Response: While the Neighborly system may track the total number of months spent on each applicant, the
subrecipient was unable to provide data that would allow us to perform procedures to verify if the number of months
of assistance provided to each applicant was within the allowable limit. Further, the State did not obtain any such data
and relied entirely on the subrecipient’s Neighborly system. Additionally, the Neighborly system was implemented
on October 18, 2021, and was not the only system used during FY22, and thus could not be relied on for tracking of
the number of months paid to an applicant during the beginning of the fiscal year. SAI reiterates the State should
obtain and review such data from the subrecipients to ensure all grant requirements are met.

FINDING NO: 2022-046
STATE AGENCY: State of Oklahoma, Office of Management and Enterprise Services (OMES)
FEDERAL AGENCY: US Department of Treasury
ALN: 21.023
FEDERAL PROGRAM NAME: Emergency Rental Assistance (ERA 1 and ERA 2)
FEDERAL AWARD NUMBER: ERA0028 and ERAE0259
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Activities Allowed/Unallowed; Allowable Costs/Cost Principles
QUESTIONED COSTS: $4,363,195




                                                          28
Schedule of Findings
And Questioned Costs
Criteria: 2 CFR § 200.303(a) – Internal Controls states in part, “The Non-Federal entity must establish and maintain
effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the
Federal award.”

The US Department of Treasury Emergency Rental Assistance (ERA) FAQ #23 ERA 1 and ERA 2 both allow for up
to 10 percent of the funds received by a grantee to be used for certain housing stability services. What are some
examples of these services? States in part, “Under ERA 1, these funds may be used to provide eligible households
with case management and other services, related to the COVID-19 outbreak.

Under ERA2, these services do not have to be related to the COVID-19 outbreak and the ERA2 statute does not restrict
the provision of housing stability services to “eligible households.”

For purposes of ERA1 and ERA2, housing stability services include those that enable households to maintain or obtain
housing. Such services may include, among other things, eviction prevention and eviction diversion programs;
mediation between landlords and tenants; housing counseling; fair housing counseling; housing navigators or
promotors that help households access ERA programs or find housing; case management related to housing stability;
housing-related services for survivors of domestic abuse or human trafficking; legal services or attorney’s fees related
to eviction proceedings and maintaining housing stability; and specialized services for individuals with disabilities or
seniors that support their ability to access or maintain housing. Grantees using ERA funds for housing stability services
must maintain records regarding such services and the amount of funds provided to them.”

Condition and Context: While documenting controls over housing stability expenditures for the ERA 1 and ERA 2
programs, we noted that OMES did not review any supporting documentation to ensure allowability. Further, we noted
one of the two subrecipients administering the ERA grant did not have proper internal controls for the approval process
of housing stability expenditures.

While testing 32 of 163 housing stability services expenditures for one of the two subrecipients, we noted the
following:

         •   For 2 of 32, or 6.25% of items tested, the expenditure was for an unallowable management fee or moving
             the management fee from ERA 1 to ERA 2, resulting in $984,077.49 in questioned costs that are
             accounted for in finding #2022-087.
         •   For 24 of 32, or 75% of items tested, the subrecipient was unable to provide documentation supporting
             the allowability of the expenditure, resulting in $4,359,422.12 in questioned costs.
         •   For 1 of 32, or 3.13% of items tested, the expenditure was for a payment to a housing stability partner
             that billed CFO for unallowable items, resulting in $3,772.50 in questioned costs.
         •   For 1 of 32, or 3.13% of items tested an administrative expenditure was incorrectly recorded as a housing
             stability services expenditure.

Cause: OMES did not ensure that the subrecipient established and maintained effective internal control over
the Federal award to provide reasonable assurance that the non-Federal entity was managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.

The subrecipient did not maintain effective internal control over housing stability expenditures to ensure compliance
with allowability requirements and did not obtain supporting documentation for the costs actually incurred by the
vendor.

The subrecipients were not properly informed of the Federal requirements regarding allowable costs for the grant.

Effect: Unallowable costs were charged to the ERA program as housing stability expenditures. Administrative costs
were incorrectly charged as housing stability services costs.

Recommendation: We recommend that the OMES develop and implement internal controls to ensure it administers
current and future ERA 1 and ERA 2 awards in accordance with applicable Federal laws and grant requirements,




                                                           29
Schedule of Findings
And Questioned Costs
including ensuring that grant subrecipients are properly informed of federal requirements related to allowable costs
and, that subrecipients have established effective internal control to ensure expenditures are allowable.

Views of Responsible Official(s)
Contact Person: Brandy Manek
Anticipated Completion Date: February 2024
Corrective Action Planned: The Office of Management and Enterprise Services partially agree with the finding.
Please see the corrective action plan located in the corrective action plan section of this report.

Auditor Response: SAI is not questioning any work performed by the CPA firms of the two subrecipients. However,
for the sample items we tested that had exceptions, the agency failed to address most of the bullets noted in the finding.

Bullet 1 – No additional support was provided; therefore, this finding will stand. The management fees were not
supported with actual administrative expenditures applicable to the ERA program.
Bullet 2 - No additional support was provided; therefore, this finding will stand. SAI only received contracts on behalf
of the housing stability partners. We did not receive any invoice or claim support for the amounts paid.
Bullet 3 – OMES concurred with this bullet.
Bullet 4 - No additional support was provided; therefore, this finding will stand. This transaction did not result in
questioned costs as it was an allowable expenditure; however, it was recoded incorrectly.

FINDING NO: 2022-071 (Repeat Finding 2021-084)
STATE AGENCY: State of Oklahoma
FEDERAL AGENCY: US Department of the Treasury
ALN: 21.019
FEDERAL PROGRAM NAME: Coronavirus Relief Fund (CRF)
FEDERAL AWARD NUMBER: N/A
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of
Performance; Subrecipient Monitoring
QUESTIONED COSTS: $3,981,376

Criteria: : 2 CFR §200.303 - Internal controls states in part, “The Non-Federal entity must: (a) Establish and maintain
effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the
Federal award.”

2 CFR §200.332 - Requirements for pass-through entities states in part, “All pass-through entities must:

(a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following
information at the time of the subaward and if any of these data elements change, include the changes in subsequent
subaward modification. When some of this information is not available, the pass-through entity must provide the best
information available to describe the Federal award and subaward. Required information includes:

(1) Federal award identification.
(i) Subrecipient name (which must match the name associated with its unique entity identifier);
(ii) Subrecipient's unique entity identifier;
(iii) Federal Award Identification Number (FAIN);
(iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by
the Federal agency;
(v) Subaward Period of Performance Start and End Date;
(vi) Subaward Budget Period Start and End Date;
(vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient;




                                                          30
Schedule of Findings
And Questioned Costs
(viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current
financial obligation;
(ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity;
(x) Federal award project description, as required to be responsive to the Federal Funding Accountability and
Transparency Act (FFATA);
(xi) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-
through entity;
(xii) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available
under each Federal award and the Assistance Listings Number at time of disbursement;
(xiii) Identification of whether the award is R&D; and
xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414.
…

(d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes,
in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward
performance goals are achieved. Pass-through entity monitoring of the subrecipient must include:
(1) Reviewing financial and performance reports required by the pass-through entity.
(2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining
to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews,
and other means.
(3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from
the pass-through entity as required by §200.521 Management decision.”

The Department of the Treasury Federal Register, Vol. 86, No. 10 from January 15, 2021 states in part, “The CARES
[Coronavirus Aid, Relief, & Economic Security Act] Act provides that payments from the Fund may only be used to
cover costs that— 1. are 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 (the date of enactment of the CARES Act) for the State or government; and 3. were incurred during the
period that begins on March 1, 2020 and ends on December 31, 2021.
…

for a cost to be considered to have been incurred, performance or delivery must occur during the covered period but
payment of funds need not be made during that time.
…

Recipients may not apply their indirect costs rates to payments received from the Fund.”

Condition and Context: Per the GAAP Package Z - Schedule of Expenditures of Federal Awards (SEFA), the State
of Oklahoma reported $6,585,655.31 in CRF cash basis expenditures reimbursed to subrecipients by the CARES
FORWARD 1 team. We tested eleven (11) reimbursement transactions to three (3) subrecipients totaling
$5,775,994.78 and noted the following:

       •     Ten (10), or 91%, of the eleven (11) subrecipient reimbursements were approved by an appropriate authority;
             however, the CARES FORWARD review process to determine whether expenditures qualified for
             reimbursement from CRF consisted of only a summary level cost reimbursement spreadsheet and attestations,
             including that the expenditure had not been accounted for in a prior budget.
       •     One (1), or 9%, of the eleven (11) subrecipient reimbursement requests contained expenditures for
             items/services that were not within the period of performance of March 1, 2020 and prior to June 30, 2022.


1
    Governor Kevin Stitt established CARES FORWARD to administer CRF. This team is made up of various cabinet secretaries and state employees
who have an expertise in state government, finance, and federal awards.




                                                                      31
Schedule of Findings
And Questioned Costs

    •   For eleven (11), or 100%, of the eleven (11) subrecipient reimbursement requests, a Federal funding
        Certification was utilized as the subrecipient agreement; however, it did not outline all applicable award
        information required to be given to the subrecipient.
    •   Ten (10), or 91%, of the eleven (11) subrecipient reimbursements included costs that were not for necessary
        expenditures incurred due to the public health emergency with respect to COVID–19. Of the ten unallowable
        expenditure transactions, seven were for subrecipient 1 totaling $439,743.51; 2 transactions were to
        subrecipient 2 totaling $1,306,316.47; and one transaction was for subrecipient 3 for $2,235,316. The
        detailed questioned costs related to subrecipient 1 was approximately $60k for indirect costs, approximately
        $80k for costs with either no receiving document, only a quote but no invoice ($48k tile flooring), or no
        support at all. The last questioned cost for subrecipient 1 was approximately $300k where the costs did not
        align with the IDEA Project submission form, such as approximately $180k for an outdoor basketball court
        and cover (roof); and approximately $69k for LED lights throughout main building and gym. The majority
        of the questioned costs for subrecipient 2 related to $1,181,539 in non-health service payroll that didn’t align
        with IDEA Project submission form, which stated the expenses would be for clothing, feeding, and resettling
        of individuals and families to avoid congregate housing (shelters). The details behind questioned costs of
        $2,235,316 for subrecipient 3 is covered in bullet 5.
    •   For one (1), or 9%, of the eleven (11) subrecipient reimbursement requests, the subrecipient disclosed that
        the funds requested and expended were in their most recently approved budgeted prior to March 27,2020.
        The costs were for payroll and operating expenses for subrecipient 3 totaling $2,235,316 to help with the
        shortage in their capital campaign fundraiser for a new arts center, as a result of the COVID-19 pandemic.
        Further, since the costs were budgeted prior to March 27, 2020; per IDEA Submission Project Follow-up
        form (question #1), the expenditures were unallowable per U.S. Treasury Federal Register, Vol. 86, No. 10.
        Lastly, per Treasury guidance, funds were not to be expended for Revenue Replacement because of COVID-
        19 shortages. [Questioned costs of $2,235,316 are covered in bullet 4]
    •   Five (5), or 45%, of the eleven (11) subrecipient reimbursements did not contain receiving documentation
        such as, a packing slip, bill of lading, or internally created receiving form/statement; or notations on the
        invoice did not document that all items had been received by the intended recipient. [Questioned costs of
        $231,574.60 are already accounted for in bullet 4]

Cause: The CARES FORWARD team failed to review detailed transactions at the time of reimbursement to ensure
the costs were for a necessary COVID-19 expenditure due to the public health emergency. The CARES FORWARD
review process consisted of only reviewing a summary level cost reimbursement spreadsheet and attestations,
including that the expenditure had not been accounted for in a prior budget, signed by the agencies.

Effect: The CARES FORWARD team reimbursed unallowable costs of $3,981,376 by not performing an adequate
review of the supporting documentation, and instead relying on the attestation & summary level reimbursement
request as their support.    Also, the State of Oklahoma may have utilized CARES FORWARD to pay for
products/services that were not received/performed. Lastly, without a process to ensure that items were received,
services were performed, and costs were allowable and expenditures were made within the period of performance, the
State of Oklahoma is noncompliant with Federal statutes, regulations, and the terms and conditions for the Federal
award.

Recommendation: We recommend CARES FORWARD review all reimbursements from the CRF to ensure that the
relevant supporting documentation is present to support allowability of the expenditure and to prevent potential
recoupment by the Department of the Treasury.

Views of Responsible Official(s)
Contact Person: Brandy Manek
Anticipated Completion Date: On or before June 30, 2024
Corrective Action Planned: The CARES FORWARD team partially agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

Auditor Response: The State Auditor & Inspector’s Office questioned $3,981,376 to three subrecipients based on the
expenditures being for budgeted payroll, indirect costs, purchases with no receiving documents to show proof of
receipt, and costs that did not meet the objective of the program, which was a necessary COVID-19 expenditure to




                                                          32
Schedule of Findings
And Questioned Costs
mitigate the risk due to the public health emergency. Of this total, approximately $3.4 million was for non-health
service-related payroll and operating costs that had been budgeted, which is unallowable per The Department of the
Treasury Federal Register, Vol. 86, No. 10. As a result, the finding will stand.

FINDING NO: 2022-076 (Repeat Finding 2021-094)
STATE AGENCY: State of Oklahoma and Office of Management and Enterprise Services (OMES)
FEDERAL AGENCY: US Department of the Treasury
ALN: 21.019
FEDERAL PROGRAM NAME: Coronavirus Relief Fund (CRF)
FEDERAL AWARD NUMBER: N/A
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of
Performance
QUESTIONED COSTS: $637,653

Criteria: 2 CFR §200.303 - Internal controls states in part, “The Non-Federal entity must: (a) Establish and maintain
effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the
Federal award.”

The Department of the Treasury Federal Register, Vol. 86, No. 10 from January 15, 2021 states in part, “The CARES
[Coronavirus Aid, Relief, & Economic Security] Act provides that payments from the Fund may only be used to cover
costs that— 1. are 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 (the
date of enactment of the CARES Act) for the State or government; and 3. were incurred during the period that begins
on March 1, 2020, and ends on December 31, 2021.”

Treasury Federal Register, Vol. 86, No. 10 also states in part, “for a cost to be considered to have been incurred,
performance or delivery must occur during the covered period but payment of funds need not be made during that
time.”

Coronavirus Relief Fund - Guidance for State, Territorial, Local, and Tribal Governments - Updated September 2,
2020 states “Recipients may not apply their indirect costs rates to payments received from the Fund.”

Treasury Federal Register, Vol. 86, No. 10 also states, “Recipients may not apply their indirect costs rates to payments
received from the Fund.”

Applicable State Rules and Regulations

74 O.S. §85.42 Certain Contracts Prohibited - Contract Limitations - Certain Contracts Allowed states in part,
“A. 1. Except as otherwise provided for in this section or other applicable law, any agency, whether or not such agency
is subject to the Oklahoma Central Purchasing Act, is prohibited from entering into a sole source contract or a contract
for professional services with or for the services of any person, who has terminated employment with or who has been
terminated by that agency for one (1) year after the termination date of the employee from the agency.
…
C. As used in this section, person is defined as any state official or employee of a department, board, bureau,
commission, agency, trusteeship, authority, council, committee, trust, school district, fair board, court, executive
office, advisory group, task force, study group, supported in whole or in part by public funds or entrusted with the
expenditure of public funds or administering or operating public property, and all committees, or subcommittees
thereof, judges, justices and state legislators.”

Condition and Context: Per the GAAP Package Z - Schedule of Expenditures of Federal Awards (SEFA), the State
of Oklahoma reported $43,421,196 in CRF cash basis expenditures transferred to state agencies and consultants during
SFY22. Of this total, $27,777,965 was reimbursed to state agencies and consultants from CRF dollars by the CARES




                                                          33
Schedule of Findings
And Questioned Costs
FORWARD 2 team. In reviewing the consulting contract for the CRF program, the scope of the agreement was to
provide a review of claims, perform subrecipient monitoring, and provide program reporting for the CARES
FORWARD team. Further, we noted CARES FORWARD entered into a non-competitively bid contract with a
former OMES employee prior to the one (1) year limitation period per 74 O.S. §85.42(A)(1). The principal agent of
the consulting firm terminated their employment at OMES as the Budget Director on June 8, 2019; however, the
consulting contract included the period starting May 1, 2020, which is 37 days prior to one year after termination of
regular employment at OMES. In addition, 74 O.S. §85.42(C), states that a person serving in certain positions [i.e.,
board, authority, committee, advisory group] “supported in whole or in part by public funds or entrusted with the
expenditure of public funds…” is also considered an employee of the State. Starting in April of 2020, the principal
agent of the consulting firm began serving on CARES FORWARD team. The CARES FORWARD team is supported
by public funds and is entrusted with the expenditures of public funds and therefore, membership on this team
constitutes employment with the State per 74 O.S. §85.42. This means the principal agent of the consulting firm was
effectively employed by the state before and during the entire agreement periods.

The CARES FORWARD team, including the principal agent of the consulting firm, was tasked with selecting the
individuals/outside firms to award the service contract for administration of the State of Oklahoma CRF funds and
was also tasked with selecting entities that would receive funding. Several of the team members were OMES
employees that had worked closely at OMES with the principal agent of the consulting firm. Instead of obtaining bids
from outside parties with experience in administering federal funds, the CARES FORWARD team awarded the no
bid contract to the newly formed consulting firm owned by the former OMES employee that was currently serving as
the CARES FORWARD Project Director and Team Lead, and thus currently a state employee. Then once the projects
were awarded to CRF recipients, the consulting firm was responsible for reviewing the claims for allowability.

Further, the contract signed by the consultant did not comply with State purchasing laws and regulations. When
reviewing the supporting documentation for the deliverables-based contract, we noted the following:

        •    The invoices contained no detail of the work performed.
        •    The number of hours worked by each consultant was not listed on the invoices.
        •    There were no regular (at least weekly) reporting updating progress and status.
        •    The services to be performed by a specific date was not clearly documented.
        •    The services to be performed or scope of work for the deliverables-based contract was not supported.

As a result, we are questioning the $469,083 in consulting fees paid during SFY 2022 because the State of
Oklahoma/CARES Forward did not have adequate supporting documentation to show that the deliverables-based
contract was met by the consultant. The total consulting fees paid to this consultant by the CRF program as of June
30, 2022, was $719,500.

We tested a sample of 9 reimbursements (including Projects that were scored prior to award and non-Projects) to state
agencies totaling $12,354,213. Each reimbursement can consist of a single line item or multiple line items per each
Journal Entry/Reimbursement. During our testing we noted the following:

       ●     For nine (9) sampled reimbursements tested for controls, the CARES FORWARD review process for
             expenditure allowability consisted of on a summary level cost reimbursement spreadsheet describing what
             the costs were or would be expended for, and attestations signed by the agencies stating the costs were
             allowable. This is the only information provided by OMES as proof of subrecipient monitoring.
       ●     For one (1) reimbursement, we noted line items totaling $24,159 for catering and Department of Tourism
             (venues) for a Public Health Worker Appreciation Day held by Oklahoma State Department of Health
             (OSDH). We are questioning the $24,159 in reimbursements since they do not appear to be necessary
             expenditures due to the public health emergency with respect to COVID–19.


2
    Governor Kevin Stitt established CARES FORWARD to administer CRF. This team is made up of various cabinet secretaries and state employees
who have an expertise in state government, finance, and federal awards. The consulting company charged with reviewing claims for allowability
was considered part of the CRF structure.




                                                                      34
Schedule of Findings
And Questioned Costs
    ●    For one (1) reimbursement, we noted part of the reimbursement was for administrative costs which are not
         allowed to be paid from CRF funds. We are questioning the $121,929 in administrative costs.

In addition to the sampled reimbursements above, we also performed tests for duplicate reimbursements. We noted a
07/19/2021 reimbursement to the Oklahoma Employment Security Commission (OESC) for services that were later
reimbursed again on 8/24/2021, resulting in a duplicate payment of $22,482. We are questioning this amount.

Cause: CARES FORWARD failed to perform a detailed review of transactions at the time of reimbursement to ensure
the costs were for a necessary and allowable COVID-19 expenditure due to the public health emergency.

OMES did not have proper controls in place to ensure State purchasing rules were followed for CRF consulting
contracts.

OMES did not ensure that individuals responsible for procurement of services did not have conflicts of interest with
parties they contracted with.

Effect: CARES FORWARD may have reimbursed unallowable costs by not performing an adequate review of the
supporting documentation and instead relying on the attestation & reimbursement request as their support.

In addition, by not requiring a detailed breakout of consulting services and hours performed related to the CRF
consulting contract, we are unable to determine whether the consultant met the requirements of the contract, and
therefore the requirements of the federal award.

Recommendation: We recommend the CARES FORWARD team design and implement appropriate controls to
ensure expenditures are incurred, per the Department of Treasury guidance, prior to reimbursement approval.
Additionally, we recommend CARES FORWARD review all reimbursements and ensure that relevant documentation
is present to support allowability of the expenditure and to prevent potential recoupment by the Department of the
Treasury. We recommend that OMES ensure all employees responsible for the administration of federal awards
provide adequate oversight of any contracted services applicable to those federal awards. Lastly, we recommend that
OMES provide training to all employees involved in the procurement of consulting service contracts to ensure
compliance with State Statutes.

Views of Responsible Official(s)
Response from the State of Oklahoma CARES FORWARD team:
Contact Person: Brandy Manek
Anticipated Completion Date: On or before June 30, 2024
Corrective Action Planned: The CARES FORWARD team partially agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

Auditor Response: Based on management’s corrective action and review of further supporting documentation, the
finding stands that the consultant invoices contained no detail of the work performed; no listing of the number of hours
worked by each consultant; and no support for the services that needed to be completed to meet the deliverables-based
contract. In addition, the payments were made at a regular monthly fixed-rate invoice amount. As a result, we are
unsure how OMES reviewed the consultant invoices and determined the deliverables-based contract was met
without adequate supporting documentation. Further, since the consultant was responsible for the review of
state agency reimbursements per this finding, and review of subrecipients per finding 2022-071, we do not feel the
consultant met the deliverables-based contract requirements for the CRF program.

FINDING NO: 2022-078
STATE AGENCY: State of Oklahoma
FEDERAL AGENCY: US Department of the Treasury
ALN: 21.019
FEDERAL PROGRAM NAME: Coronavirus Relief Fund (CRF)
FEDERAL AWARD NUMBER: N/A
FEDERAL AWARD YEAR: 2022




                                                          35
Schedule of Findings
And Questioned Costs
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of
Performance
QUESTIONED COSTS: $12,000

Criteria: 2 CFR §200.303 - Internal controls states in part, “The Non-Federal entity must: (a) Establish and maintain
effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the
Federal award.”

The Department of the Treasury Federal Register, Vol. 86, No. 10 from January 15, 2021 states in part, “The CARES
[Coronavirus Aid, Relief, & Economic Security Act] Act provides that payments from the Fund may only be used to
cover costs that— 1. are 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 (the date of enactment of the CARES Act) for the State or government; and 3. were incurred during the
period that begins on March 1, 2020, and ends on December 31, 2021.”

Treasury Federal Register, Vol. 86, No. 10 states in part, “for a cost to be considered to have been incurred,
performance or delivery must occur during the covered period but payment of funds need not be made during that
time.”

Amended Executive Order 2021-15 states in part, “2. In their place, The Oklahoma Back-to-Work Initiative will offer
a one-time $1,200.00 incentive to assist those returning to the workforce. Oklahomans may receive this one-time
incentive upon leaving any unemployment insurance program, including Unemployment Insurance, and providing
pay stubs for six weeks of consecutive employment with the same employer, that pays into the Unemployment
Insurance Trust Fund, or a company with a FEIN number. The duration of the incentive program is from May 17,
2021, through September 4, 2021, or until 20,000 people have received the incentive, whichever is earlier. Applicants
may begin applying June 28, 2021.”

Condition and Context: Per the GAAP Package Z - Schedule of Expenditures of Federal Awards (SEFA), the State
of Oklahoma reported $43,421,196 in CRF cash basis expenditures transferred to state agencies during SFY22. Of
this total, $15,643,139 was advanced to state agencies from CRF dollars by the CARES FORWARD 3 team. Because
the funds were advanced, we tested the CRF payment controls at the agency level. We noted the following for our
sample of 65 CRF transactions at state agencies totaling $6,302,637:

    •   Thirty-four (34) of the transactions we tested were from the Oklahoma Employment Security Commission
        (OESC) – Oklahoma Back-to-Work Initiative. Seven of those payments were to applicants who did not meet
        the 32 hours per week for six consecutive weeks requirement. For one (1) additional payment, we did not
        consider the supporting pay stub valid for proof of employment because the applicant’s name was not present
        on the pay stub. As a result, we are questioning a total of $9,600 in payments made to these applicants.

In addition to the sampled advance transactions above, we also performed tests for duplicate payments. We noted two
payments from the OESC Oklahoma Back-to-Work Initiative to one individual that appear to be based on fraudulent
claims. Based on our discussion with OESC staff, the two payments were referred to their fraud department for further
investigation. As a result, we are questioning the $2,400 in payments made to the applicant.

Cause: Proper eligibility reviews were not performed on OESC Oklahoma Back-to-Work Initiative claims. OESC
used a contractor to review applications for eligibility; however, OESC staff also performed reviews.

Effect: Payments were made to individuals who did not meet the eligibility requirements for the OESC Oklahoma
Back-to-Work Initiative.


3
 Governor Kevin Stitt established CARES FORWARD to administer CRF. This team is made up of various cabinet
secretaries and state employees who have an expertise in state government, finance, and federal awards.




                                                         36
Schedule of Findings
And Questioned Costs

Recommendation: We recommend OESC work to strengthen their eligibility verification process to help prevent
ineligible and/or fraudulent payments.

Views of Responsible Official(s)
Response from the Oklahoma Employment Security Commission:
Contact Person: Michelle Britten, Chief Financial Officer
Anticipated Completion Date: Ongoing
Corrective Action Planned: The agency concurs with the audit finding and agrees with the recommendation. Please
see the corrective action plan located in the corrective action plan section of this report.

FINDING NO: 2022-085
STATE AGENCY: State of Oklahoma, Office of Management and Enterprise Services
FEDERAL AGENCY: US Department of Treasury
ALN: 21.023
FEDERAL PROGRAM NAME: Emergency Rental Assistance (ERA 1 and ERA 2)
FEDERAL AWARD NUMBER: ERA028 and ERAE0259
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Activities Allowed/Unallowed and Allowable Costs/Cost Principles
QUESTIONED COSTS: $834,521

Criteria: U.S. Department of the Treasury Emergency Rental Assistance Grantee Award Form (8) (a-b) Compliance
with Applicable Law and Regulations, states in part, “a. Recipient agrees to comply with the requirements of Section
501 and Treasury interpretive guidance regarding such requirements. Recipient also agrees to comply with all other
applicable federal statutes, regulations, and executive orders, and Recipient shall provide for such compliance in any
agreements it enters into with other parties relating to this award. b. Federal regulations applicable to this award
include, without limitation, the following: 1. Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards, 2 C.F.R. Part 200, other than such provisions as Treasury may determine are
inapplicable to this Award and subject to such exceptions as may be otherwise provided by Treasury.”

2 CFR § 200.303(a) – Internal Controls states in part, “The Non-Federal entity must establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the
Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”

The Consolidated Appropriations Act § Section 501 (c)(5) Use of Funds - Administrative Costs states in part, “A. IN
GENERAL.- Not more than 10 percent of the amount paid to an eligible grantee under this section may be used for
administrative costs attributable to providing financial assistance and housing stability services under paragraphs (2)
and (3), respectively, including for data collection and reporting requirements related to such funds. B. No OTHER
ADMINISTRATIVE COSTS.- Amounts paid under this section shall not be used for any administrative costs other
than to the extent allowed under subparagraph (A)”

 2 CFR § 200.334 – Retention requirements for records state in part, “Financial records, supporting documents,
statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period
of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed
quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as
reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.”

2 CFR § 200.337 Access to records states in part, “(a) Records of non-Federal entities. The Federal awarding agency,
Inspectors General, the Comptroller General of the United States, and the pass-through entity, or any of their
authorized representatives, must have the right of access to any documents, papers, or other records of the non-Federal
entity which are pertinent to the Federal award, in order to make audits, examinations, excerpts, and transcripts. The
right also includes timely and reasonable access to the non-Federal entity's personnel for the purpose of interview and
discussion related to such documents.”




                                                          37
Schedule of Findings
And Questioned Costs
2 CFR § 200.430(f) - Incentive compensation states, “Incentive compensation to employees based on cost reduction,
or efficient performance, suggestion awards, safety awards, etc., is allowable to the extent that the overall
compensation is determined to be reasonable and such costs are paid or accrued pursuant to an agreement entered into
in good faith between the non-Federal entity and the employees before the services were rendered, or pursuant to an
established plan followed by the non-Federal entity so consistently as to imply, in effect, an agreement to make such
payment.”

Condition and Context: While testing 70 of 8,523 payroll administrative expenditures ($285,848.30) we noted the
following:
     • For 7 of 70, or 10% of claims tested, the invoice was not itemized to show the hours worked on each task,
        and the description of work done was not specific enough to determine if the time spent was for an allowable
        activity related to ERA 1 or ERA 2 ($24,482.82). In addition, 3 of the 7 invoices included bonus payments,
        totaling $14,822.77, that are separate from the bonus payments allowed per the contract. (Questioned Costs
        - $39,305.59)
     • For 6 of 70, or 8.57% of claims tested, the subrecipient was unable to provide a contract that covered the
        time period paid; therefore, we are unable to determine whether the amount paid is allowable or accurate.
        (Questioned Costs -$5,959.26).
     • For 6 of 70, or 8.57% of claims tested, the contractor was paid more than their stated hourly rate per the
        contract. (Questioned Costs - $480.07).

A bonus policy was provided by Communities Foundation of Oklahoma to the State Auditor and Inspector office.
This policy did not state how bonuses would be calculated and how contractors could achieve the bonus. We also
determined through email conversation this policy was not in place during SFY 2022 and had not been provided to
contractors prior to them rendering services. (Questioned Costs - $786,989.74)

There is no verbiage in the contract that allowed for vaccination incentive. Therefore, 100% of vaccination incentives
will be questioned. (Questioned Costs $1,786.05)

Cause: OMES personnel responsible for oversight of the ERA 1 and ERA 2 grants do not normally oversee Federal
grant programs, and do not have adequate experience with administering Federal grant funds and understanding the
types of activities that may be supported by the ERA 1 and ERA 2 grants.

OMES did not establish and maintain effective internal control over the Federal award that provides reasonable
assurance that OMES is managing the Federal award in compliance with Federal statutes, regulations, and the terms
and conditions of the Federal award.

OMES did not ensure that the subrecipients established and maintained effective internal control over the Federal
award to provide reasonable assurance that the non-Federal entity was managing the Federal award in compliance
with Federal statutes, regulations, and the terms and conditions of the Federal award.

Effect: Unallowable payroll costs, totaling $834,521, were charged to the ERA program as payroll administrative
expenditures.

Recommendation: We recommend that OMES develop and implement internal controls to ensure it administers
current and future ERA grants in accordance with applicable Federal laws and grant requirements, including ensuring
that grant subrecipients are properly informed of federal requirements related to allowable costs. In addition, we
recommend that OMES ensure the subrecipient has established effective internal controls over the Federal award to
provide reasonable assurance that the subrecipient is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award.

We recommend that OMES ensure adequate supporting documentation for administrative expenditures incurred is
obtained, reviewed, and maintained by OMES to ensure subrecipients only expend ERA funds for allowable activities
and costs.




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Schedule of Findings
And Questioned Costs
We recommend that OMES only reimburse subrecipients for administrative costs based on supporting documentation
of actual costs incurred.

We recommend OMES ensure the personnel responsible for oversight for the ERA grant obtain the necessary training
and knowledge to ensure compliance with the Federal grant requirements.

Views of Responsible Official(s)
Contact Person: Brandy Manek
Anticipated Completion Date: February 2024
Corrective Action Planned: The Office of Management and Enterprise Services partially agrees with the finding.
Please see the corrective action plan located in the corrective action plan section of this report.

Auditor Response: SAI would like to stress that OMES has not provided an adequate corrective action to address the
major issues outlined in the finding.

Bullet 1 – The invoice included items that did not appear to be allowable per the program. Because the invoice was
not itemized to show the number of hours worked for each task, SAI was unable to calculate the individual questioned
costs; therefore, the entire invoice was questioned. In addition, the contracts for both individuals stated that signing
bonuses could be paid; however, the bonuses that were paid, were well after the time the contract was signed. See
additional comment in Bullet 5 below regarding bonus payments.
Bullets 2 and 3 – No additional support was provided; therefore, the finding will stand.
Bullet 4 – The contracts did not contain any verbiage regarding vaccination bonuses. In addition, the bonus policies
provided did not state any verbiage regarding this type of payment. See additional comment in Bullet 5 below
regarding bonus payments.
Bullet 5 – SAI originally requested all CFO/CCP policies and procedures on 2/14/2023. No additional bonus policies
were provided to SAI at that time. When SAI reviewed the contracts as part of our testwork, most contracts stated that
bonuses could be paid within 30 days of the contract date; however, most payments were made outside of the 30 days.
SAI was then provided a document labeled, ‘13.15 Bonus Section of Draft Policies’ on 12/6/2023, and we were
informed that these policies were ‘still being cleaned up.’ SAI was provided another document on 2/13/2024 regarding
bonus determinations and justifications.

SAI determined that the bonus policies could not be relied upon because 1) they were not finalized in SFY 2022, and
2) separate bonus policies were not provided to SAI at any point prior to CFO/CCP receiving the finding.

FINDING NO: 2022-086 (Repeat Finding 2021-080)
STATE AGENCY: State of Oklahoma, Office of Management and Enterprise Services
FEDERAL AGENCY: US Department of Treasury
ALN: 21.023
FEDERAL PROGRAM NAME: Emergency Rental Assistance (ERA 1 and ERA 2)
FEDERAL AWARD NUMBER: ERA028 and ERAE0259
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Activities Allowed or Unallowed; and Allowable Costs/Cost Principles
QUESTIONED COSTS: $33,399

Criteria: U.S Department of the Treasury Emergency Rental Assistance Grantee Award Form (8) (a-b) Compliance
with Applicable Law and Regulations, states in part, “a. Recipient agrees to comply with the requirements of Section
501 and Treasury interpretive guidance regarding such requirements. Recipient also agrees to comply with all other
applicable federal statutes, regulations, and executive orders, and Recipient shall provide for such compliance in any
agreements it enters into with other parties relating to this award. b. Federal regulations applicable to this award
include, without limitation, the following: 1. Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards, 2 C.F.R. Part 200, other than such provisions as Treasury may determine are
inapplicable to this Award and subject to such exceptions as may be otherwise provided by Treasury.”




                                                          39
Schedule of Findings
And Questioned Costs
2 CFR § 200.303(a) – Internal Controls states in part, “The Non-Federal entity must establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the
Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”

The Consolidated Appropriations Act § Section 501 (c)(5) Use of Funds - Administrative Costs states in part, “A. IN
GENERAL.- Not more than 10 percent of the amount paid to an eligible grantee under this section may be used for
administrative costs attributable to providing financial assistance and housing stability services under paragraphs (2)
and (3), respectively, including for data collection and reporting requirements related to such funds. B. No OTHER
ADMINISTRATIVE COSTS.- Amounts paid under this section shall not be used for any administrative costs other
than to the extent allowed under subparagraph (A)”

The American Rescue Plan Act of 2021 § Section 3201 (d)(1)(C) Use of Funds – Administrative Costs states in part,
“Not more than 15 percent of the total amount paid to an eligible grantee under this section may be used for
administrative costs attributable to providing financial assistance, housing stability services, and other affordable
rental housing and eviction prevention activities, including for data collection and reporting requirements related to
such funds.”

2 CFR § 200.334 – Retention requirements for records state in part, “Financial records, supporting documents,
statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period
of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed
quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as
reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.”

2 CFR § 200.337 Access to records states in part, “(a) Records of non-Federal entities. The Federal awarding agency,
Inspectors General, the Comptroller General of the United States, and the pass-through entity, or any of their
authorized representatives, must have the right of access to any documents, papers, or other records of the non-Federal
entity which are pertinent to the Federal award, in order to make audits, examinations, excerpts, and transcripts. The
right also includes timely and reasonable access to the non-Federal entity's personnel for the purpose of interview and
discussion related to such documents.”

Condition and Context: While testing 30 (100%) credit card administrative expenditures totaling $87,871.40 for one
subrecipient, we noted the following:
    • For 24 of 30, or 80% of claims tested, the payment included at least one expenditure for unallowable costs.
         These unallowable costs include gift cards ($12,303.47), flowers ($1,096.29), and entertainment/food
         ($18,285.57) such as Top Golf, bowling, Paint N Cheers, cooking classes, and Chicken N Pickle, which are
         not necessary expenses for the distribution of ERA funds. (Questioned Costs - $31,809,89)
    • For 7 of 30, or 23.33% of claims tested, the subrecipient was unable to provide supporting documentation,
         and we were unable to determine if the cost was allowable. Questioned costs have been included in the first
         bullet.
    • For 1 of 30, or 3.33% of claims tested, the cost did not agree to the supporting documentation, and we were
         unable to determine if the cost was allowable. Questioned costs have been included in the first bullet.
    • For 4 of 30, or 13.33% of claims tested, the claim included duplicate payments. (Questioned Costs -
         $1,349.23)
    • For 5 of 30, or 16.67% of claims tested, the cost appeared allowable based on the vendor’s name and the
         service they provided, however, the subrecipient was unable to provide supporting documentation. These
         vendors include Ink cartridges, Quickbooks, Dial My Calls, E-File, and LAZ Parking. (Questioned Costs -
         $179.60)

We also noted that OMES performed no reviews of the credit card payments to ensure ERA program funds were
expended only for allowable activities. As the pass-through entity, OMES is ultimately responsible for ensuring
program funds are administered in accordance with federal regulations.

Cause: OMES personnel responsible for oversight of the ERA 1 and ERA 2 grants do not normally oversee Federal
grant programs, and do not have adequate experience with administering Federal grant funds and understanding the
types of activities that may be supported by the ERA 1 and ERA 2 grants.




                                                          40
Schedule of Findings
And Questioned Costs

OMES did not establish and maintain effective internal control over the Federal award that provides reasonable
assurance that OMES is managing the Federal award in compliance with Federal statutes, regulations, and the terms
and conditions of the Federal award.

OMES did not ensure that the subrecipients established and maintained effective internal control over the Federal
award to provide reasonable assurance that the non-Federal entity was managing the Federal award in compliance
with Federal statutes, regulations, and the terms and conditions of the Federal award.

OMES advanced the subrecipients a set rate of 10% (ERA 1) and 15% (ERA 2) of program funds for administrative
costs instead of paying administrative costs on a reimbursement basis for costs actually incurred by the subrecipient
and attributable to providing financial assistance and housing stability services under the ERA 1 and ERA 2 programs.

Effect: Unallowable and/or unsupported costs totaling $33,399 or 38% of total credit card administrative expenditures
attributed to the State portion of the ERA grant being administered by one subrecipient, were charged to the ERA
program.

Recommendation: We recommend that OMES develop and implement internal controls to ensure it administers
current and future ERA grants in accordance with applicable Federal laws and grant requirements, including
ensuring that grant subrecipients are properly informed of Federal requirements related to allowable costs
and, that subrecipients have established effective internal control over the Federal award to provide reasonable
assurance that the subrecipient is managing the Federal award in compliance with Federal statutes, regulations,
and the terms and conditions of the Federal award.

We recommend that OMES ensure adequate supporting documentation for actual program and administrative
expenditures incurred is obtained, reviewed, and maintained by OMES to ensure subrecipients only expend ERA
funds for allowable activities and costs.

We recommend that OMES only reimburse subrecipients for administrative costs based on supporting documentation
for actual costs incurred.

We recommend OMES ensure that personnel responsible for oversight of the ERA grant obtain the necessary training
and knowledge to ensure compliance with Federal grant requirements.

Views of Responsible Official(s)
Contact Person: Brandy Manek
Anticipated Completion Date: February 2024
Corrective Action Planned: The Office of Management and Enterprise Services does not agree with the finding.
Please see the corrective action plan located in the corrective action plan section of this report.

Auditor Response: The agency response states, . . . “We disagree with the questioned expenses in the first
bullet. These expenses were appropriate as a contractor and necessary expenses for the distribution of the ERA
funds and fulfillment of the contract.” The expenses in question were for gift cards, flowers, and entertainment/food
such as Top Golf, bowling, Paint N Cheers, cooking classes, and Chicken N Pickle, which are not necessary
expenses for the distribution of ERA funds. SAI would like to stress that the State of Oklahoma/OMES did not
provide an adequate corrective action to address the unallowable costs totaling $42,424.52 in the first bullet point of
the finding. SAI would like to reiterate that the State of Oklahoma/OMES did not review any of the supporting
documentation related to the administrative expenses and our recommendation is for the State of Oklahoma/OMES
to implement internal controls to ensure expenses are only paid on a reimbursement basis after the supporting
documentation has been reviewed and the cost has been determined to be allowable within the grant guidelines.
Although this grant has already been closed, our recommendation should be implemented for any future grants
passed through OMES.

FINDING NO: 2022-087 (Repeat Finding 2021-080)
STATE AGENCY: State of Oklahoma, Office of Management and Enterprise Services
FEDERAL AGENCY: US Department of Treasury




                                                          41
Schedule of Findings
And Questioned Costs
ALN: 21.023
FEDERAL PROGRAM NAME: Emergency Rental Assistance (ERA 1 and ERA 2)
FEDERAL AWARD NUMBER: ERA028 and ERAE0259
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Activities Allowed or Unallowed; and Allowable Costs/Cost Principles
QUESTIONED COSTS: $8,667,947

Criteria: U.S Department of the Treasury Emergency Rental Assistance Grantee Award Form (8) (a-b) Compliance
with Applicable Law and Regulations, states in part, “a. Recipient agrees to comply with the requirements of Section
501 and Treasury interpretive guidance regarding such requirements. Recipient also agrees to comply with all other
applicable federal statutes, regulations, and executive orders, and Recipient shall provide for such compliance in any
agreements it enters into with other parties relating to this award. b. Federal regulations applicable to this award
include, without limitation, the following: 1. Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards, 2 C.F.R. Part 200, other than such provisions as Treasury may determine are
inapplicable to this Award and subject to such exceptions as may be otherwise provided by Treasury.”

2 CFR § 200.303(a) – Internal Controls states in part, “The Non-Federal entity must establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the
Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”

The Consolidated Appropriations Act § Section 501 (c)(5) Use of Funds - Administrative Costs states in part, “A. IN
GENERAL.- Not more than 10 percent of the amount paid to an eligible grantee under this section may be used for
administrative costs attributable to providing financial assistance and housing stability services under paragraphs (2)
and (3), respectively, including for data collection and reporting requirements related to such funds. B. No OTHER
ADMINISTRATIVE COSTS.- Amounts paid under this section shall not be used for any administrative costs other
than to the extent allowed under subparagraph (A)”

The American Rescue Plan Act of 2021 § Section 3201 (d)(1)(C) Use of Funds – Administrative Costs states in part,
“Not more than 15 percent of the total amount paid to an eligible grantee under this section may be used for
administrative costs attributable to providing financial assistance, housing stability services, and other affordable
rental housing and eviction prevention activities, including for data collection and reporting requirements related to
such funds.”

2 CFR § 200.334 – Retention requirements for records states in part, “Financial records, supporting documents,
statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period
of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed
quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as
reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.”

2 CFR § 200.337 Access to records states in part, “(a) Records of non-Federal entities. The Federal awarding agency,
Inspectors General, the Comptroller General of the United States, and the pass-through entity, or any of their
authorized representatives, must have the right of access to any documents, papers, or other records of the non-Federal
entity which are pertinent to the Federal award, in order to make audits, examinations, excerpts, and transcripts. The
right also includes timely and reasonable access to the non-Federal entity's personnel for the purpose of interview and
discussion related to such documents.”

The US Department of Treasury Emergency Rental Assistance (ERA) FAQ #29 states in part “A grantee may permit
a subrecipient to incur more than 10 or 15 percent, as applicable, of the amount of the subaward issued to that
subrecipient as long as the total of all administrative costs incurred by the grantee and all subrecipients, whether as
direct or indirect costs, does not exceed 10 or 15 percent, as applicable, of the total amount of the award provided to
the grantee from Treasury.”

Condition and Context: While documenting controls over subrecipient program and administrative expenditures for
the ERA 1 and ERA 2 grants, we noted that OMES did not require the subrecipients to submit supporting
documentation for administrative expenditures charged to the programs. Further, we determined the subrecipients did




                                                          42
Schedule of Findings
And Questioned Costs
not have sufficient internal controls over program or administrative expenditures to ensure they were for allowable
costs and activities.

While reviewing all administrative management fees, we noted one of the subrecipients charged the ERA 1 and ERA
2 grants $8,625,873.61 in unallowable management fees – costs that were not attributable to providing financial
assistance and housing stability services. These management fees the subrecipient recorded and charged to the grant
are equal to the amount of funds advanced to the subrecipient for the purposes of paying administrative costs in excess
of actual administrative expenditures. (Questioned costs - $8,625,873.61)

In addition, when reviewing the subrecipient’s journal entries and other adjustments we noted the following for one
of the subrecipients:
     • For 12 of 62, or 19.35% transactions tested, the transaction had a description of “Refund for unknown tenant”
         and the subrecipient was unable to provide an explanation or supporting documentation for these transactions.
         We did not question these costs as they were credit transactions.
     • For 2 of 62, or 3.23% transactions tested, the transactions had descriptions of “Reconciled Difference” and
         “Charge back according to bank stmt.” The subrecipient was unable to provide an explanation or supporting
         documentation for these transactions; therefore, we were unable to determine if they were allowable, which
         results in $5,990 in questioned costs.

Lastly, in testing 71 of 366 non-payroll and non-credit card administrative expenditures we noted the following:
    • For 5 of 71, or 7.04% of claims tested, the payment was for management fees to one of the subrecipients that
          were determined to be unallowable. The five exceptions are part of the $8,625,873.61 in questioned costs
          noted above.
    • For 7 of 71, or 9.86% of claims tested, the transaction was to cancel out originally recorded management fees
          and then record “accrued management fees” throughout the year. Because the management fees are
          unallowable, we determined the offsetting transactions are also unallowable. See management fee questioned
          costs noted above.
    • For 7 of 71, or 9.86% of claims tested, one or more of the expenditures in the transaction were not for an
          allowable activity or cost. (Questioned Costs $681.47)
    • For 2 of 71, or 2.82% of claims tested, the contract stated the contractor would be paid $100 per hour;
          however, the timesheet and invoice showed a billing rate of $250 per hour. SAI was provided additional
          support for a project with the contractor. We determined the following: 1) the subrecipient did not need to
          create a new comprehensive change to their management process for a program with which funding expires
          on September 30, 2025 and was expected to be fully disbursed by 2023; 2) this is an organizational issue and
          therefore, should not be paid with ERA 2 funds; and 3) the support provided was not a contract, but rather an
          ‘agreement’ that has no start/end date and was signed after the State Auditor’s Office noted no signatures
          were present. We determined we would question these costs (Questioned Costs - $28,334.58). We also noted
          $13,057.37 in payments under this agreement in addition to our sample items that will result in questioned
          costs. (Total Questioned Costs - $41,391.94)

Cause: OMES personnel responsible for oversight of the ERA 1 and ERA 2 grants do not normally oversee Federal
grant programs, and do not have adequate experience with administering Federal grant funds and understanding the
types of activities that may be supported by the ERA 1 and ERA 2 grants.

OMES did not ensure the personnel responsible for oversight of the ERA 1 And ERA 2 grants received the proper
training to understand and did not ensure they used available resources to help them understand, the grant
requirements.

OMES did not establish and maintain effective internal control over the Federal award that provides reasonable
assurance that OMES manages the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award.

OMES did not ensure that the subrecipients established and maintained effective internal control over the Federal
award to provide reasonable assurance that the non-Federal entity was managing the Federal award in compliance
with Federal statutes, regulations, and the terms and conditions of the Federal award. The State relied entirely on a




                                                          43
Schedule of Findings
And Questioned Costs
public accounting firm to perform subrecipient monitoring procedures during SFY 2022. We noted that this firm only
monitored the eligibility and allowability compliance requirements for the program expenditures for one of the two
subrecipients. The State did not ensure the subrecipient was appropriately monitored by the third party for compliance
with activities allowed and allowable costs.

OMES advanced to one subrecipient a set rate of 10% (ERA 1) and 15% (ERA 2) and to another subrecipient 9.3%
(ERA 1) of program funds for administrative costs instead of reimbursing administrative costs actually incurred by
the subrecipient that were attributable to providing financial assistance and housing stability services under the ERA
1 and ERA 2 programs.

OMES did not obtain, review, approve, or maintain adequate supporting documentation for administrative costs.

Effect: Unallowable costs, totaling $8.7 million, were charged to the ERA program as administrative expenditures.

Recommendation: We recommend that OMES develop and implement internal controls to ensure it has the
knowledge and experience to administer current and future ERA grants in accordance with applicable Federal laws
and grant requirements, including ensuring that grant subrecipients are properly informed of Federal requirements
related to allowable costs. In addition, we recommend that OMES ensure subrecipients have established effective
internal controls over the Federal award to provide reasonable assurance that the subrecipient is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.

We recommend that OMES ensure adequate supporting documentation for administrative costs charged to the
program is obtained, reviewed, approved, and maintained by OMES to ensure subrecipients are only paid or
reimbursed for allowable activities and costs based on that supporting documentation.

Views of Responsible Official(s)
Contact Person: Brandy Manek
Anticipated Completion Date: June 2024
Corrective Action Planned: The Office of Management and Enterprise Services partially agrees with the finding.
Please see the corrective action plan located in the corrective action plan section of this report.

Auditor Response: SAI would like to stress that OMES has not provided an adequate corrective action to
address the major issues outlined in the finding.

Paragraph 1 – No additional support was provided; therefore, the finding will stand.

Paragraph 2 - H.R. 133-888 Section 501 (ERA 1) (c)(5) ‘Administrative Costs’ (A) states “In General – Not more
than 10 percent of the amount paid to an eligible grantee under this section may be used for administrative costs
attributable to providing financial assistance and housing stability services under paragraphs (2) and (3), respectively,
including for data collection and reporting requirements related to such funds”.

Further, H.R. 1319-51(ERA 2) (d)(1)(C) “Administrative Costs” states “Not more than 15% of the total amount paid
to an eligible grantee under this section may be used for administrative costs attributable to providing financial
assistance, housing stability services, and other affordable housing and eviction prevention activities, including for
data collection and reporting requirements related to such funds.”

All administrative costs must be directly related to providing assistance under the ERA program. SAI determined that
CFO is retaining a management fee that is not associated with expenditures directly attributable to providing financial
assistance and housing stability services for this grant. Therefore, the state advanced funds to CFO for management
fees that were not incurred for the ERA program, which is unallowable per 2 CFR § 200.403(g). To be allowed to
charge the maximum 10% for ERA 1, or 15% for ERA 2 for administrative expenditures, CFO must provide proof
they had administrative costs that reached those thresholds.

Paragraph 3 bullet 1 and 2 - No additional support was provided; therefore, the finding will stand.




                                                           44
Schedule of Findings
And Questioned Costs
Paragraph 4 bullets 1 through 3 - No additional support was provided; therefore, the finding will stand.

Paragraph 4 bullet 4 – It was communicated to SAI that once the subrecipient made the change from Foundant to the
Neighborly system, applications were then processed at a spending rate of $4-5 million. While we agree with the PIP
in a system change, SAI reiterates the following in regards to the agreement with the subcontractor: 1) the subrecipient
did not need to create a new comprehensive change to their management process for a program with which funding
expires on September 30, 2025 and was expected to be fully disbursed by 2023; 2) this is an organizational issue and
therefore, should not be paid with ERA 2 funds; and 3) the support provided was not a contract, but rather an
‘agreement’ that has no start/end date and was signed after the State Auditor’s Office noted no signatures were present.
Additionally, the payment for Finding the Key was made to JGC, not the subcontractor, therefore the original contract
amount of $100 per hour would still be applicable.



      State of Oklahoma/ OFFICE OF MANAGEMENT & ENTERPRISE
                            SERVICES
FINDING NO: 2022-081 (Partial Repeat 2021-019 and 2021-109)
STATE AGENCY: Governor's Office and Office of Management and Enterprise Services (OMES)
FEDERAL AGENCY: US Department of Education
ALN: 84.425C
FEDERAL PROGRAM NAME: Education Stabilization Fund – GEER
FEDERAL AWARD NUMBER: S425C200006
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs and Cost Principles; Subrecipient
                        Monitoring
QUESTIONED COSTS: $249,333

Criteria: 2 CFR § 200.303(a) – Internal Controls states in part, “The Non-Federal entity must establish and maintain
effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the
Federal award.”

2 CFR § 200.332 (d) - Requirements for pass-through entities states in part, “All pass-through entities must:
   (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized
   purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that
   subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: …
   (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies
   pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits,
   on-site reviews, and other means.”

The U.S. Department of Education’s Certification and Agreement for Funding under the Education Stabilization Fund
Program Governor’s Emergency Education Relief; Governor’s Emergency Education Relief Fund, Part D: Other
Assurances and Certifications, states “The State and other entities will comply with the provisions of all applicable
acts, regulations, and assurances: …and the Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards in 2 [Code of Federal Regulations (C.F.R.)] part 200, as adopted and amended in
regulations of the Department in C.F.R. part 3474.”

2 CFR § 200.334 – Retention requirements for records state in part, “Financial records, supporting documents,
statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period
of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed
quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as
reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.”




                                                          45
Schedule of Findings
And Questioned Costs
2 CFR § 200.337 Access to records states in part, “(a) Records of non-Federal entities. The Federal awarding agency,
Inspectors General, the Comptroller General of the United States, and the pass-through entity, or any of their
authorized representatives, must have the right of access to any documents, papers, or other records of the non-Federal
entity which are pertinent to the Federal award, in order to make audits, examinations, excerpts, and transcripts. The
right also includes timely and reasonable access to the non-Federal entity's personnel for the purpose of interview and
discussion related to such documents.”

Applicable Federal Rules and Regulations
2 CFR part 200, subpart E § 200.404 Reasonable costs, states in part, “A cost is reasonable if, in its nature and amount,
it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time
the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal
entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given
to … :
   (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal
   entity or the proper and efficient performance of the Federal award.
   (b) The restraints or requirements imposed by such factors as: sound business practices; arm's-length bargaining;
   Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award.
   (c) Market prices for comparable goods or services for the geographic area.
   (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities
   to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the
   Federal Government.
   (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the
   incurrence of costs, which may unjustifiably increase the Federal award's cost.”

2 CFR part 200, subpart E § 200.459 (a) Professional service costs, states,
“(a) Costs of professional and consultant services rendered by persons who are members of a particular profession or
possess a special skill, and who are not officers or employees of the non-Federal entity, are allowable, subject to
paragraphs (b) and (c) of this section when reasonable in relation to the services rendered and when not contingent
upon recovery of the costs from the Federal Government. In addition, legal and related services are limited under §
200.435.
(b) In determining the allowability of costs in a particular case, no single factor or any special combination of factors
is necessarily determinative. However, the following factors are relevant:
          (1) The nature and scope of the service rendered in relation to the service required.
          (2) The necessity of contracting for the service, considering the non-Federal entity's capability in the
          particular area.
          (3) The past pattern of such costs, particularly in the years prior to Federal awards.
          (4) The impact of Federal awards on the non-Federal entity's business (i.e., what new problems have arisen).
          (5) Whether the proportion of Federal work to the non-Federal entity's total business is such as to influence
          the non-Federal entity in favor of incurring the cost, particularly where the services rendered are not of a
          continuing nature and have little relationship to work under Federal awards.
          (6) Whether the service can be performed more economically by direct employment rather than contracting.
          (7) The qualifications of the individual or concern rendering the service and the customary fees charged,
          especially on non-federally funded activities.
          (8) Adequacy of the contractual agreement for the service (e.g., description of the service, estimate of time
          required, rate of compensation, and termination provisions).
(c) In addition to the factors in paragraph (b) of this section, to be allowable, retainer fees must be supported by
evidence of bona fide services available or rendered.”


Applicable State Rules and Regulations
74 O.S. §85.42 Certain Contracts Prohibited - Contract Limitations - Certain Contracts Allowed states in part:
“A. 1. Except as otherwise provided for in this section or other applicable law, any agency, whether or not such agency
is subject to the Oklahoma Central Purchasing Act, is prohibited from entering into a sole source contract or a contract




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Schedule of Findings
And Questioned Costs
for professional services with or for the services of any person, who has terminated employment with or who has been
terminated by that agency for one (1) year after the termination date of the employee from the agency.
…
C. As used in this section, person is defined as any state official or employee of a department, board, bureau,
commission, agency, trusteeship, authority, council, committee, trust, school district, fair board, court, executive
office, advisory group, task force, study group, supported in whole or in part by public funds or entrusted with the
expenditure of public funds or administering or operating public property, and all committees, or subcommittees
thereof, judges, justices and state legislators.”

74 O.S. § 85.7 - Competitive Bid Procedures states in part…”A. Except as otherwise provided by the Oklahoma
Central Purchasing Act, or associated rules: … 6. Competitive bidding requirements of this section shall not be
required for the following: … f. any acquisition of a service which the Office of Management and Enterprise Services
has approved as qualifying for a fixed and uniform rate, subject to the following: (2) fixed and uniform rate contracts
authorized by this subsection shall be limited to contracts for those services furnished to persons directly benefiting
from such services and shall not be used by a state agency to employ consultants or to make other acquisitions”

74 O.S. § 85.44B Payment for Contracted Products or Services – Payment for Acquisition from the Federal
Government or Agency, states in part, “A. Payment for products or services pursuant to a contract executed by a state
agency, whether or not such state agency is subject to the Oklahoma Central Purchasing Act shall be made only after
products or services have been accepted as satisfactory.”

OAS 260:115-7-3 (g)(2)(b)(ii) State agency acquisitions, states in part, “Certifications for services contracts.
Additional documents required to be included in contracts for professional or nonprofessional services include… Each
contract for services shall include a statement certifying that no person who has been involved in any manner in the
development of that contract while employed by the State of Oklahoma shall be employed to fulfill any of the services
provided for under said contract.” [Reference 74 O.S. §85.42]

Procurement Information Memorandum 2 007-01; Fixed and Uniform Rate Contracts - Criteria and Guidelines, states
in part, “2 (7) A state agency shall not use the fixed rates contracting process to employ consultants or purchase
products.”

Condition and Context: The Office of Management and Enterprise Services (OMES) did not obtain, or ensure the
availability of, the books and records of subrecipients [Tri-county Tech and Class Wallet] administering the Skills to
Rebuild, Bridge the Gap Digital Wallet (BTGDW) and Stay in School (SIS) programs during the audit period;
therefore, appropriate subrecipient monitoring was not performed during the audit period.

OMES made payments totaling $249,333 to a consulting firm for consulting services, including subrecipient
monitoring of the GEER I and GEER II programs, that did not conform with the criteria contained in 2 CFR part 200,
Subpart E ‘Basic Guidelines’, or the cost principles set forth in 2 CFR, subpart E § 200.404 Reasonable costs and 2
CFR, subpart E § 200.459 (a) Professional service costs, specifically:

    •    The contracts/agreements with the consulting firm did not comply with State purchasing laws and regulations.
    •    The contracts/agreements were not arm’s-length transactions.
    •    The contracts/agreements constituted unallowable fixed rate agreements.
    •    The consulting firm was paid prior to performing any services and, was paid for some services that were not
         performed.
    •    The consulting firm was newly formed and had no previous contracts for or experience in administering
         federal grants or performing subrecipient monitoring.
    •    The contractual agreement was not adequate for the service required, (e.g., description of the service, estimate
         of time required, rate of compensation).




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    •   The contract/agreement rate did not reflect the market prices for comparable goods or services and was
        significantly excessive in relation to amounts paid to State employees performing the same type of services
        OMES contracted for (i.e., review of federal grant claims, subrecipient monitoring, federal reporting).
    •   The nature and scope of the service rendered were not adequate to ensure compliance with subrecipient
        monitoring and reporting requirements.
    •   The contract costs were not adequately documented. OMES paid for invoiced services that were not
        supported by 1) adequate verification of the actual hours worked per day by specific staff members and, 2)
        documentation of the activities (per the scope of work in the contract agreement) completed for the period.

Noncompliance with State Purchasing Laws and Regulations: The contract/agreements with the consulting firm did
not comply with following State purchasing laws and regulations as required:

o   74 O.S. §85.42 Certain Contracts Prohibited – OMES entered into a contract (that included an addendum for
    GEER I subrecipient monitoring and reporting consulting services) with a former OMES employee prior to the
    one (1) year limitation period. The principal agent of the consulting firm terminated their employment at OMES
    as the Budget Director on June 8, 2019, however, the agreement included the period starting May 1, 2020, which
    is 37 days prior to one year after termination of regular employment at OMES.

    In addition, 74 O.S. §85.42 (3), also states that a person serving in certain positions [i.e., board, authority,
    committee, advisory group] “supported in whole or in part by public funds or entrusted with the expenditure
    of public funds…” is also considered an employee of the State. Starting in April of 2020, the principal agent of
    the consulting firm was serving on CARES FORWARD which is a team of Cabinet Secretaries and public
    employees established by the Governor to provide oversight of Oklahoma’s $1.2 billion in Coronavirus Relief
    Funds (CRF). The CARES FORWARD team is supported by public funds and is entrusted with the
    expenditure of public funds and therefore, membership on this team constitutes employment with the State
    per 74 O.S. §85.42. This means the principal agent of the consulting firm was effectively employed by the state
    before and during the entire agreement periods for both the GEER I and GEER II service agreements.

o   OAS 260:115-7-3 (g.2.b. ii) State agency acquisitions - Certifications for services contracts - The agreements
    did not contain the required certification and, it appears that the agreements were not arms-length transactions.
          GEER I agreement - The CARES FORWARD team was tasked with selecting the individuals/outside
             firms to award the service contract for administration of the State of Oklahoma CRF funds. Several of
             the team members were OMES employees that had worked closely at OMES with the principal agent of
             the consulting firm. Instead of obtaining bids from outside parties with experience in administering
             federal funds, the CARES FORWARD team awarded the no bid contract to the newly formed consulting
             firm owned by the former OMES employee that was currently serving as the CARES FORWARD
             Project Director and Team Lead, and thus currently a state employee.
          GEER II agreement – Individuals facilitating the awarding of this $330,000 contract included OMES
             employees that were also part of the CARES FORWARD team and had worked closely at OMES with
             the principal agent of the consulting firm.

o   74 O.S. § 85.7 - Competitive Bid Procedures and Procurement Information Memorandum 2 007-01; Fixed and
    Uniform Rate Contracts – The GEER I and GEER II agreements were fixed rate contracts which cannot be used
    to employ consultants.

o   74 O.S. § 85.44B (A) - Payment for Goods or Services Pursuant to Contract, payment for services pursuant to a
    contract executed by a state agency shall be made only after services have been accepted as satisfactory.

GEER I - The State Auditor and Inspector’s office (SAI) determined that OMES paid the consulting firm the full
agreement amount of $49,500 ($16,500 per month for October, November and December 2020), for GEER I
subrecipient monitoring and reporting services. SAI reviewed the documentation for the subrecipient monitoring
activities OMES provided us with, and it appears that the consulting firm only performed the following subrecipient
monitoring procedures applicable to GEER I programs:




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Schedule of Findings
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            A review of the partial (as of 12/31/2020) Bridge the Gap expenditure data that identified possible
             unallowable expenditures per a key word search. According to OMES, the consulting firm provided this
             reviewed data to OMES in December of 2022, 12 months after the agreement amount was paid in full.
            A review of the remaining (post 12/31/2020) Bridge the Gap expenditure data that identified possible
             unallowable expenditures per a key word search. According to OMES, the consulting firm provided this
             reviewed data to OMES in July of 2023, 18 months after the agreement amount was paid in full.
            Prepared ‘Project Closeout Reports’ for GEER I programs in August of 2021. These two-page reports
             were sent to the awardees to fill out and only included summary information: specifically, the total
             amount of funds awarded and expended, a brief description of the program objectives and metrics met
             per the awardee, and questions about whether the entity has subrecipients, and if so, whether the awardee
             had a subrecipient monitoring process. These reports do not fulfill any significant federal subrecipient
             monitoring requirements applicable to GEER I funds.

SAI determined that, as of 6/30/2022, OMES had still not obtained, or ensured the availability of, the books and
records of subrecipients [Tri-county Tech and Class Wallet] administering the Skills to Rebuild, Bridge the Gap
Digital Wallet (BTGDW) and Stay in School (SIS) programs which would be necessary to perform adequate
subrecipient monitoring and reporting. Therefore, OMES paid the consulting firm the full agreement amount without
ensuring the following subrecipient monitoring activities were performed for GEER I programs not administered by
OSDE:

                          Skills to Rebuild – Tri-County Tech was paid $1,000,000 up front for scholarships and
                           employee payroll applicable to future periods. Monitoring activities should have included,
                           1) A review of scholarships awarded to determine if the scholarships were awarded
                           appropriately and to determine if students awarded scholarships actually enrolled and
                           completed the programs. 2) A reconciliation between the funds paid up front to Tri-county
                           Tech for estimated employee payroll costs vs. actual employee payroll costs.
                          BTG Program - A review of the supporting documentation applicable to eligibility
                           determinations for family income limits.
                          Stay in School program - A review of the supporting documentation applicable to eligibility
                           determinations for family income limits and school enrollment requirements.

GEER II - SAI determined that OMES paid the consulting firm $254,833.33 in monthly payments starting in
November of 2021, through August of 2022 ($7,333.33 for November 2021, and $27,500 for December 2021 to
August 2022). Of the total paid, $192,500 was applicable to SFY 22 federal expenditures and $55,000 was applicable
for SFY23 federal expenditures). However, no GEER II projects were approved by OMES until September of 2023
and no GEER II funds were expended for projects until 9/28/2023. Based on SAI’s conversations with the OMES
and review of supporting documents, the only services the consulting firm provided were a review and scoring of 19
GEER II project proposals (which was completed by early January 2022) and a revision of OMES ARPA federal grant
policies and procedures in order to align them with GEER requirements. OMES continued to make monthly payments
of $27,500 from January 2022 to August 2022 even though they were aware that no work was being performed related
to review and monitoring of GEER II projects and expenditures as there were no GEER II projects approved during
this time.

Cause: OMES did not gain an understanding of the applicable Federal laws and grant requirements and did not
establish and maintain effective internal control over the Federal award that provides reasonable assurance that the
non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award as required by the criteria contained in 2 CFR part 200, Subpart E ‘Basic Guidelines’,
or the cost principles set forth in 2 CFR, subpart E § 200.404 Reasonable costs and 2 CFR, subpart E § 200.459 (a)
Professional service costs.

OMES did not ensure State purchasing rules were followed appropriately.

OMES did not ensure that individuals responsible for procurement of services did not have a conflict of interest with
parties OMES contracts with.




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Schedule of Findings
And Questioned Costs
OMES did not ensure contract invoices included adequate supporting documentation to verify that services were
performed appropriately prior to payment being made.

With regard to the initial contracting process and oversight of the contract performance, OMES did not act with
prudence in the circumstances considering their responsibilities to the non-Federal entity, the public at large, or the
Federal Government.

Effect: Federal funds were expended for services that are either unallowable or were not actually performed. Also,
per 2 CFR part 200, subpart E § 200.459 (a) Professional Service Costs [esp. #s 1 & 6-8] and 2 CFR part 200, subpart
E § 200.404 Reasonable Costs [ a - e], the costs charged to the program for consulting services is not reasonable.

The required subrecipient monitoring activities were not performed appropriately.

Recommendation: We recommend that OMES gain an understanding of the requirements of federal awards
applicable to activities allowed and allowable costs.

We recommend that OMES ensure all employees responsible for the administration of federal awards provides
adequate oversight of any contracted services applicable to those federal awards.

We recommend that OMES provide training to all employees involved in the procurement of services with regard to
federal requirements and State purchasing rules including ethical considerations.

We recommend that OMES ensure individuals responsible for procurement of services do not have a conflict of
interest with parties OMES contracts with.

We recommend that OMES does not pay for any services until the services are appropriately performed and the
invoiced services are supported by adequate documentation verifying the number of hours actually worked and the
services actually performed.

Views of Responsible Official(s)
Contact Person: Caden Cleveland, OMES Director of Public Affairs and Grants Management, John Laws, Chief
Financial Officer for the State of Oklahoma
Anticipated Completion Date: Complete as of January 2024
Corrective Action Planned: The Office of Management and Enterprise Services (OMES) partially agrees with the
finding. See corrective action plan located in the corrective action plan section of this report.

Auditor Response:

GEER I - OMES failed to provide appropriate corrective action to address the issues noted in the finding related to
the GEER I contract agreement.

GEER II

RE: OMES Response to Rec. 3, 4 & 5 and other finding issues (claim a, b & c):

Fixed Rate Issues and payment for services not performed – For clarification purposes, SAI is not asserting that the
GEER II agreement constituted a fixed rate agreement per the requirements for entering a fixed rate agreement
documented in 74 O.S. § 85.7(A)(6)(f)(2). Rather, SAI is stating that the GEER II agreement was invoiced and paid
on a fixed rate per month regardless of the actual hours worked or services that were performed and, the services
included in the GEER II agreement did not meet the requirements in 74 O.S. § 85.7(A)(6)(f)(2 that would allow a
fixed rate to be charged/paid for these consulting services.




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Schedule of Findings
And Questioned Costs
In the finding response, OMES states that the GEER II contract was a deliverables-based contract. However, there are
only two items identified as ‘deliverables’ listed on the contract’s Scope of Work, and neither were completed. In
addition, the contract does not specify the amount to be paid for each deliverable or type of service. SAI noted the
majority of the services included in the Scope of Work were for project tracking, performance analysis, reconciliation
and review of expenditures, federal reporting, and subrecipient monitoring, and that these consulting services were
not performed (and could not have been because no GEER II project funds were expended until September 2023.
However, OMES continued paying the vendor $27,500 per month through August of 2022, paying in total $254,833
or 77% of the contract amount.

Competitive Bidding Issues and other Contract Support Issues - During the audit, SAI requested that OMES provide
all contracts/agreements with outside entities to review, monitor or administer the GEER II program. In response to
this request, OMES only provided a purchase order for this vendor to SAI and did not inform SAI that they had a
signed contract with this vendor. OMES did not provide the GEER II contract with this vendor until after OMES
received this finding. After reviewing the contract and attachments, it appeared that public solicitation documents
were attached. SAI then requested and obtained the solicitation file associated with the solicitation number from
OMES and reviewed the supporting documents. Based on our review and communications with OMES, we noted the
following issues with the procurement file:

             a.   Issues with Public Posting of Solicitation and Vendor Notifications – OMES claimed that the
                  solicitation was publicly posted on the Oklahoma Central Purchasing Website, however, SAI noted
                  that the solicitation was not listed/posted on the Oklahoma Central Purchasing Website.
             b.   Less than Arm’s Length Transaction - The four OMES employees interviewing and rating the
                  vendor had all worked closely with the vendor either currently or previously.
             c.   Issues with Information Submitted by the Vendor - The vendor provided misleading and incomplete
                  information on the forms used in the evaluation process.
             d.   Evidence of bias in OMES vendor evaluation - The notes entered on the Interview Rating Sheet by
                  one OMES employee stated, “Intend to keep this in house.” SAI notes that this statement is
                  inappropriate for a person involved in rating a competitively bid solicitation.
Continued issues with nonallowable fixed rate contracts for consulting contracts - OMES contracted with another
vendor in June of 2023 ($250,000 contract amount) to perform basically the same GEER II services OMES had
previously paid the vendor referenced in this finding $254,833 (as of August 2022) to perform. The current vendor
contract is also a consulting service contract that is paid by OMES at a flat rate of $25,000 per month.

FINDING NO: 2022-082 (Repeat 2021-060)
STATE AGENCY: The Governor's Office and Office of Management and Enterprise Services (OMES)
FEDERAL AGENCY: US Department of Education
ALN: 84.425C
FEDERAL PROGRAM NAME: Education Stabilization Fund – GEER
FEDERAL AWARD NUMBER: S425C200006
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Reporting

Criteria: 2 CFR Subpart B § 170.200 Federal awarding agency reporting requirements states in part, “(a) Federal
awarding agencies are required to publicly report Federal awards that equal or exceed the micro-purchase threshold
and publish the required information on a public-facing, OMB-designated, governmentwide website and follow OMB
guidance to support Transparency Act implementation.”

2 CFR Subpart B § 170.220 Award term states in part, “(a) To accomplish the purposes described in § 170.100, a
Federal awarding agency must include the award term in appendix A to this part in each Federal award to a recipient
under which the total funding is anticipated to equal or exceed $30,000 in Federal funding.”

2 CFR Subpart B § 170.220 Award term - Appendix A states in part,




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Schedule of Findings
And Questioned Costs
  “I. Reporting Subawards and Executive Compensation

    a. Reporting of first-tier subawards.

    Applicability. Unless you are exempt as provided in paragraph d. of this award term, you must report each action
    that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity or Federal agency (see
    definitions in paragraph e. of this award term).

        2. Where and when to report.

          i. The non-Federal entity or Federal agency must report each obligating action described in paragraph a.1. of
          this award term to http://www.fsrs.gov.

          ii. For subaward information, report no later than the end of the month following the month in which the
          obligation was made. (For example, if the obligation was made on November 7, 2010, the obligation must
          be reported by no later than December 31, 2010.)

        3. What to report. You must report the information about each obligating action that the submission instructions
        posted at http://www.fsrs.gov specify.”

Unites States Department of Education website GEER Annual Reporting states in part, “All grantees are required to
report on GEER funds received under the Coronavirus Aid, Relief, and Economic Security (CARES) Act; and the
Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act. Grantees must submit an annual report
describing how the State and subrecipients used the awarded funds during the performance period. Similar to CARES
Act Year 1 annual reporting, grantees will use the Annual Report Data Collection Tool to submit the State report.”

Condition and Context:

FFATA Reports
   • The State of Oklahoma (Governor’s Office) has not reported the initial subaward information in the FFATA
      Subaward Reporting System (FSRS), for the following:
          o One GEER I (84.425C) subaward totaling $49,500 made on October 1, 2021, with a FFATA
              submission due date of 11/30/2021.
          o One GEER II (84.425C) subaward totaling $330,000 made on November 1, 2020, with a FFATA
              submission due date of 12/31/2021.

    •     OMES did not report the revised subaward information on the FFATA for 2 sub-awards totaling
          $3,322,030.17 until over two years after the due date, specifically.

              o    Incentive/Reallocation award to OSDE revised by $2,902,345.32 on 3/14/2021; however, the
                   FFATA was not revised until 9/28/2023, 881 days after the 4/30/2021 due date.
              o    Learn Anywhere award to the Statewide Virtual Charter School Board (SVCSB) revised by
                   $419,684.85 on 4/28/2021; however, the FFATA was not revised until 9/28/2023, 850 days after
                   the 5/31/2021 due date.

    •     OMES overstated amounts reported for one revised subaward. A total of $76,565.15 was included under the
          subaward amount for Edmentum, however, this amount was never paid to Edmentum and should have been
          reported under SVCSB.

GEER Annual Reports




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Schedule of Findings
And Questioned Costs
GEER 1 Year 1 Annual Report:
   • The amount reported as current year funds expended by two sub awardees does not agree to the supporting
       expenditure records and is overstated by $8,689,866.13.
   • The amount reported as current year funds expended by one sub awardee is not supported by actual
       expenditure records applicable to the reporting period. OMES reported the total award amount of $1,000,000
       as expended as of 9/30/2021; however, the award amount included scholarships that were awarded for both
       current and future periods and estimated payroll costs that were also applicable to current and future periods.
       OMES did not provide support for the expenditures applicable to the report period.
   • The subaward information for one Higher Education related subaward was incorrectly included under the
       ‘Other Education Related Entities’ section of the annual report instead of the Higher Education section.
   • The total award amount for one contract subaward was overstated by $496,750. This amount was not awarded
       to the contractor but was reattained by the State agency for administrative expenditures.
   • OMES did not provide the supporting records for the FTE position data required, therefore, SAI was unable
       to verify that the numbers reported were correct.

GEER 1 Year 2 Annual Report:
   • The GEER 1 Year 2 Annual Report was due June 10, 2022, for the applicable reporting period October 1,
       2020, to September 30, 2021. However, OMES did not submit the annual report for GEER I until March 24,
       2022, 440 days late.
   • A contractor awarded a subaward of $49,500 was not reported on the annual report. In addition, current
       period expenditures of $49,500 for this contractor were not reported under current admin expenditures.
   • The Prime Recipient and sub awardee amounts reported for current period expenditures and prior period
       expenditures do not agree to the supporting records for 4 sub awardees because OMES reported the total for
       both the current year and the prior year under current year expenditures and reported $0 under prior year
       expenditures.
   • The Prime Recipient total GEER I funds expended is incorrect and only includes the total expenditures for
       the Stay in School program.
   • The amount reported as current year funds expended by one sub awardee is not supported by actual
       expenditure records applicable to the reporting period. OMES reported the total award amount of $1,000,000
       as expended as of 9/30/2021; however, the award amount included scholarships that were awarded for both
       current and future periods and estimated payroll costs that were also applicable to current and future periods.
       OMES did not provide support for the expenditures applicable to the report period.
   • The subaward information for one Higher Education related subaward was incorrectly included under the
       ‘LEAs’ section of the annual report and, certain information related to financial aid for students and funds
       used to maintain staff were not reported as required for higher education awards.
   • OMES did not provide the supporting records for the following report fields, therefore, SAI was unable to
       verify that the numbers reported were correct:
       Prime Awardee -
            o Number of Public Schools Funded with GEER I funds.
            o Number of Students Receiving Vouchers
       Other Education Related Entities – Number of Students Receiving Financial Aid
   • Scholarships awarded under the Stay in School program and Skills to Rebuild program were incorrectly
       reported as voucher awards instead of scholarships.

GEER II Year 1 Annual Report:

    •    The GEER II Year I Annual Report was not submitted. While there were no program expenditures in the
         reporting period, OMES made a subaward in the amount of $330,000 (as of 11/1/2021) to a contractor for
         GEER II consulting services, and current period admin expenditures for this subaward were, $34,833 ($7,333
         for Nov 2021 and $27,500 for Dec 2021).




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Schedule of Findings
And Questioned Costs
Cause: The State of Oklahoma did not gain an understanding of the applicable Federal laws and grant requirements
and did not establish and maintain effective internal control over the Federal award that provides reasonable assurance
that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the
terms and conditions of the Federal award as required by 2 CFR 200.303.

OMES does not have adequate policies and procedures to ensure that FFATA reports and GEER annual reports, and
applicable revisions are submitted within the required timeframes, and that information reported is accurate.

OMES failed to obtain all the supporting books and records from sub awardees required for reporting and audit
purposes.

Effect: FFATA reports were not submitted timely and did not include all applicable sub awards.

GEER I Annual reports were not submitted timely, did not include all applicable sub awards, and contained inaccurate
and incomplete information.

GEER II Annual report was not submitted.

Recommendation: We recommend that OMES develop policies and procedures to ensure that FFATA reports, and
applicable revisions are submitted timely, and information is complete.

We recommend that OMES develop policies and procedures to ensure that GEER Annual reports are submitted timely,
and information is accurate and complete.

We recommend that OMES revise the FFATA reports and GEER Annual reports to correct all inaccurate and
incomplete information previously reported.

Views of Responsible Official(s)
Caden Cleveland, OMES Director of Public Affairs and Grants Management, John Laws, Chief Financial Officer for
the State of Oklahoma
Anticipated Completion Date: June 30, 2024
Corrective Action Planned: The Office of Management and Enterprise Services (OMES) partially agrees with the
finding. See corrective action plan located in the corrective action plan section of this report.

Auditor Response:

FFATA –SAI does not agree that corrective action for the FFATA reports is complete.
   1. Specifically regarding the subawards to sub awardees not yet reported on the FFATA for GEER 1 in the
      amount $49,500 and for GEER II in the amount of $330,000, both of these subawards were for subrecipient
      monitoring activities, federal grant reporting, and oversight of the federal program activities and meet the US
      Department of Education (USDOE) requirements for inclusion on the FFATA reports (See excerpts from the
      USDOE FFATA reporting guidance below).

         Source: US Department of Education FFATA Reporting Webinar & Forum Tips & Guidance for Grantees
         provided to SAI by OMES,
         (Slide 9), states in part,
             • “First-tier subawards, regardless of the instrument used to make the award (e.g., a subgrant or
                contract), must be reported when they meet the FFATA criteria for reporting, and when the
                subawards perform programmatic work under the prime recipient's approved grant.
             • Subawards differ from contracts (under FFATA) as sub-awardees maintain day-to-day
                oversight of the activities.”




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       (Slide 10) eCFR :: 2 CFR 200.331 -- Subrecipient and contractor determinations, states in part, “If it is
       determined by the SEA/Pass-through entity that any of the following apply, it would be determined
       to be a subrecipient relationship and the subaward would need to be reported through FFATA:
                              …
                        •     Has its performance measured in relation to whether objectives of a
                              Federal program were met;
                              …
                        •     Is responsible for adherence to applicable Federal program
                              requirements specified in the Federal award; and
                        •     In accordance with its agreement, uses the Federal funds to carry out a program
                              for a public purpose specified in authorizing statute, as opposed to providing
                              goods or services for the benefit of the pass­ through entity.”

       SAI notes that the subrecipient monitoring services the vendor was paid to perform for GEER I and many of
       the services included in the GEER II contract Scope of Work result in a vendor relationship in which the
       vendor is 1) part of the selection committee determining which projects will be awarded GEER II funds and,
       is responsible for determining whether projects are eligible for and in compliance with GEER II
       requirements and/or, 2) responsible for ensuring the objectives of the federal program are met and that
       Federal program requirements are adhered to via claim reviews, federal reporting, subrecipient monitoring
       and contractor oversight. Therefore, the contracted services should be reported on the FFATA.

  2.   OMES is required to report new subawards exceeding $30,000 on the FFATA per FFATA regulations.
       OMES also provided SAI with email correspondence from the US Department of Education (USDOE) to
       OMES regarding the revision of subaward amounts on the FFATA:

                “Generally speaking, the subawards reported on FSRS should reflect the amount that the
                subrecipient had access to through the subaward, even if the subrecipient did not liquidate all funds
                it had been subawarded. However, in the event that a subrecipient returns funds to the grantee and
                those funds are then redistributed (newly subawarded) to another subrecipient, the grantee may
                either decrease the original subaward in order to reallocate them to another subrecipient or may leave
                those funds with the original subrecipient, so long as an overallocation does not occur as a result
                of redistributing the funds (i.e., reported subawards equal/total more than 100% of the grant
                award). OMES should verify that the amounts reported through FSRS and reflected on
                USASpending reflect the subawards provided to each entity and should only decrease the
                subawards where funds that were returned to OMES were then redistributed/newly
                subawarded to another subrecipient.”


       GEER I FFATA: Adding the new subaward for GEER I of $49,500 to the GEER I FFATA would cause the
       GEER I award amounts reported to exceed 100% of the grant award. Therefore, an appropriate revision to
       the existing awards would need to be made in order avoid overallocation.
       GEER II FFATA: SAI is not aware of any USDOE guidance that exempts OMES from reporting this
       $330,000 subaward.

  3.   Although USDOE email communications state that “the grantee may either decrease the original subaward
       in order to reallocate them to another subrecipient or may leave those funds with the original subrecipient,
       so long as an overallocation does not occur as a result of redistributing the funds”, this practice may result in
       difficulties reconciling the FFATA data to the GEER annual reports as required per Uniform Guidance
       Compliance Requirements for Part L, Reporting which state in part, “Depending on the time the audit is
       conducted, auditors should examine the annual report and reconcile that reported data with underlying
       documentation and the public quarterly reporting amounts [FFATA] to ensure accuracy.”




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         SAI notes that, if the FFATA report has not been revised to reflect the actual amount expended/liquidated by
         a subawardee, or the subaward has not even been reported on the FFATA, the amount reported on the FFATA
         will not trace to the annual report per 1) the total amount, 2) the proportion of the reported use of funds or,
         3) the number of FTE’s, students, scholarships or other categories required to be reported that compare to a
         certain amount awarded.

FINDING NO: 2022-090
STATE AGENCY: State of Oklahoma and Office of Management and Enterprise Services
FEDERAL AGENCY: Multiple
ALN: Multiple
FEDERAL PROGRAM NAME: Multiple
FEDERAL AWARD NUMBER: Multiple
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Procurement and Suspension and Debarment
QUESTIONED COSTS: $0

Criteria: 2 CFR § 200.317 Procurements by states, says in part,
“When procuring property and services under a Federal award, a State must follow the same policies and procedures
it uses for procurements from its non-Federal funds. The State will … ensure that every purchase order or
other contract includes any clauses required by § 200.327.

2 CFR § 200.327 Contract provisions, states the following:
“The non-Federal entity's contracts must contain the applicable provisions described in appendix II to this part.” See
appendix II link here: 2 CFR Appendix II to Part 200 - Contract Provisions for Non-Federal Entity Contracts Under
Federal Awards | Electronic Code of Federal Regulations (e-CFR) | US Law | LII / Legal Information Institute
(cornell.edu)
2 CFR § 200.404 Reasonable costs, states in part, “A cost is reasonable if, in its nature and amount, it does not exceed
that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was
made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is
predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to … :
  (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal
  entity or the proper and efficient performance of the Federal award.
  (b) The restraints or requirements imposed by such factors as: sound business practices; arm's-length bargaining;
  Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award.
  (c) Market prices for comparable goods or services for the geographic area.
  (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities
  to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the
  Federal Government.
  (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the
  incurrence of costs, which may unjustifiably increase the Federal award's cost.”

74 O.S. §85.5 Powers and Duties of State Purchasing Director, states in part:
“H. 1. The State Purchasing Director may develop and test new contracting policies, procedures and innovations that
hold potential for making state procurement more effective and efficient and identify, and make recommendations to
the Legislature of, any appropriate changes in law. Such development and testing, proof of concept, pilot project or
other similar test shall not be considered an acquisition subject to the Oklahoma Central Purchasing Act.
2. The State Purchasing Director is authorized to explore and investigate cost savings in energy, resource usage and
maintenance contracts and to identify and negotiate contract solutions including, but not limited to, pilot projects to
achieve cost savings for this state.”




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Condition and Context: While performing federal compliance testing of all major programs for SFY2022 Single
Audit, we were made aware that Office of Management and Enterprise Services (OMES) created a pilot program
(starting in SFY 2019/2020) wherein vendors were put on Statewide Contract, thus no longer requiring them to
competitively bid their services. These pilot programs are known as Rolling Request for Proposal (RFP) or Rolling
Solicitations. In SFY2022, we noted certain non-IT consulting services (SW0133 Statewide Contracts) and
Deliverable Based IT Service (SW1050 Statewide Contracts) vendors were added to Statewide Contract pilot program
and are now receiving federal funds through this process. In SFY2023, OMES added two additional Statewide
Contract pilot programs, SW1025 Information Technology Staff Augmentation Services and SW0132 Non-IT
Temporary Employment Services. Vendors under this contract category will also be receiving federal funding.

Further, there are no written policies and procedures for any of the Statewide Contracting pilot programs (Rolling
RFP’s) to describe how these contracts are to be executed to meet both federal and state law.

Lastly, as of January 2024, no recommendations have been made to the Legislature on how the Statewide Contract
pilot programs has helped state procurement become more effective and efficient for the State of Oklahoma as required
by law. As a result, the longer the pilot programs remain open without recommendations to the Legislature, entities
on Statewide Contract pilot programs are allowed to charge what they feel are appropriate rates per their federal
contracts, without any competitive or vetting process in place.

Cause: The OMES does not have adequate controls in place, including policies and procedures, to ensure federal
grant contracts are properly executed.

Effect: The OMES is not complying with 2 CFR § 200.317 Procurements by states since the agency has no policies
and procedures in place for the Statewide Contracting pilot programs. As a result, federal contracts awarded under the
Statewide Contracting pilot programs, do not appear to meet State of Oklahoma competitive bidding requirements.
Also, contracts with vendors may not contain the applicable provisions required by 2 CFR § 200.327. Lastly, under
the existing Statewide Contract pilot programs, OMES can receive increased federal contract fees because vendors
are not compelled to charge reasonable rates per 2 CFR § 200.404.

Recommendation: We recommend the OMES develop and implement policies and procedures for the
Statewide Contract pilot programs to ensure all federal contracts are properly executed. Further, we recommend
OMES provide justification on how vendors/consultants put on the Statewide Contract pilot programs are exempt
from competitive bidding requirements. Lastly, we recommend the OMES work in a timely manner to either
bring the Statewide Contract pilot programs before the legislature to explain the benefits to the state and what
should be written into law or eliminate the program.

Views of Responsible Official(s)
Contact Person: Amanda Otis
Anticipated Completion Date: Sine Die
Corrective Action Planned: Management does not agree with the finding. Please see the corrective action plan located
in the corrective action plan section of this report.

Auditor Response: Based on the corrective action plan provided by management, the procedures provided were not
adequate policies and procedures to explain how the Statewide Contracting pilot programs (Rolling RFP’s) are
meeting the competitive bidding requirements per Title 74 O.S. § 85.7. As a result, our finding stands that
management does not have adequate policies and procedures to meet 2 CFR § 200.317 Procurements by states for
federal contracting. Further, the Statewide Contracting pilot programs lack support to show that federal grant contracts
are being awarded to the lowest and best, or best value, bidder or bidders per Title 74 O.S. § 85.7.A.7.B.


                          Oklahoma Department of EDUCATION

FINDING NO: 2022-012
STATE AGENCY: Oklahoma State Department of Education (OSDE)




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FEDERAL AGENCY: United States Department of Education (USDE)
ALN: 84.425 – 84.425C; 84.425D; 84.425U
FEDERAL PROGRAM NAME: Governor’s Emergency Education Relief Fund (GEER); Elementary and
                                 Secondary School Emergency Relief Fund (ESSER); American Rescue Plan –
                                 Elementary and Secondary Schools Emergency Relief Fund (ARP ESSER)
FEDERAL AWARD NUMBER: S425C200006; S425D210024; S425U210024
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Special Tests and Provisions – Wage Rate Requirements
QUESTIONED COSTS: $0

Criteria: 2 C.F.R. § 200.303(a) – Internal Controls states in part, “The Non-Federal entity must establish and maintain
effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the
Federal award.”

2 C.F.R. Appendix A to Part 215—Contract Provisions states in part, “All contracts, awarded by a recipient including
small purchases, shall contain the following provisions as applicable:… 3. Davis-Bacon Act, as amended (40 U.S.C.
276a to a–7)—When required by Federal program legislation, all construction contracts awarded by the recipients and
subrecipients of more than $2000 shall include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 276a
to a–7) and as supplemented by Department of Labor regulations (29 CFR part 5, “Labor Standards Provisions
Applicable to Contracts Governing Federally Financed and Assisted Construction”). Under this Act, contractors shall
be required to pay wages to laborers and mechanics at a rate not less than the minimum wages specified in a wage
determination made by the Secretary of Labor.”

40 U.S.§3142. Rate of wages for laborers and mechanics states in part,
“(a) Application. - The advertised specifications for every contract in excess of $2,000, to which the Federal
Government or the District of Columbia is a party, for construction, alteration, or repair, including painting and
decorating, of public buildings and public works of the Government or the District of Columbia that are located in a
State or the District of Columbia and which requires or involves the employment of mechanics or laborers shall contain
a provision stating the minimum wages to be paid various classes of laborers and mechanics.

(b) Based on Prevailing Wage. - The minimum wages shall be based on the wages the Secretary of Labor determines
to be prevailing for the corresponding classes of laborers and mechanics employed on projects of a character similar
to the contract work in the civil subdivision of the State in which the work is to be performed, or in the District of
Columbia if the work is to be performed there.

(c) Stipulations Required in Contract - Every contract based upon the specifications referred to in subsection (a) must
contain stipulations that—
    (1) the contractor or subcontractor shall pay all mechanics and laborers employed directly on the site of the work,
   unconditionally and at least once a week, and without subsequent deduction or rebate on any account, the full
   amounts accrued at time of payment, computed at wage rates not less than those stated in the advertised
   specifications, regardless of any contractual relationship which may be alleged to exist between the contractor or
   subcontractor and the laborers and mechanics;
    (2) the contractor will post the scale of wages to be paid in a prominent and easily accessible place at the site of the
   work; and
    (3) there may be withheld from the contractor so much of accrued payments as the contracting officer considers
   necessary to pay to laborers and mechanics employed by the contractor or any subcontractor on the work the
   difference between the rates of wages required by the contract to be paid laborers and mechanics on the work and
   the rates of wages received by the laborers and mechanics and not refunded to the contractor or subcontractors or
   their agents.”…




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2 C.F.R. § 5.5 (3)(ii) Certified payroll requirements states in part:

“(A) Frequency and method of submission. The contractor or subcontractor must submit weekly, for each week in
which any DBA- or Related Acts-covered work is performed, certified payrolls to the … [applicant, sponsor, owner,
or other entity, as the case may be, that maintains such records, for transmission to the [write in name of agency]. …

(B) Information required. The certified payrolls submitted must set out accurately and completely all of the
information required to be maintained under paragraph (a)(3)(i)(B) of this section, except that full Social Security
numbers and last known addresses, telephone numbers, and email addresses must not be included on weekly
transmittals. Instead, the certified payrolls need only include an individually identifying number for each worker (e.g.,
the last four digits of the worker's Social Security number). …

(C) Statement of Compliance. Each certified payroll submitted must be accompanied by a “Statement of Compliance,”
signed by the contractor or subcontractor, or the contractor's or subcontractor's agent who pays or supervises the
payment of the persons working on the contract, and must certify the following:

  (1) That the certified payroll for the payroll period contains the information required to be provided under paragraph
  (a)(3)(ii) of this section, the appropriate information and basic records are being maintained under paragraph
  (a)(3)(i) of this section, and such information and records are correct and complete;
  (2) That each laborer or mechanic (including each helper and apprentice) working on the contract during the payroll
  period has been paid the full weekly wages earned, without rebate, either directly or indirectly, and that no
  deductions have been made either directly or indirectly from the full wages earned, other than permissible
  deductions as set forth in 29 CFR part 3; and
  (3) That each laborer or mechanic has been paid not less than the applicable wage rates and fringe benefits or cash
  equivalents for the classification(s) of work actually performed, as specified in the applicable wage determination
  incorporated into the contract.”

Condition and Context: While documenting controls over wage rate requirements, we were informed that OSDE’s
Office of Federal Programs did not obtain and review LEA construction contracts or subcontracts in excess of $2,000
in order to verify the required prevailing wage rate clauses were included in the contract or subcontract. In addition,
the Office of Federal Programs did not obtain and review weekly, for each week in which any applicable contract
work is performed, copies of the certified payroll records including the required statement of compliance prior to
reimbursing the LEAs ESF funded construction claims. Also, OSDE failed to include a review of the LEA’s
compliance with Wage Rate Requirements as part of their subrecipient monitoring procedures. Therefore, SAI, was
unable to verify whether the contract or subcontract included the required prevailing wage rate clauses and whether
the certified payroll records were submitted as required.

Cause: It appears that the OSDE Office of Federal Programs did require the LEAs to submit a COVID Relief Funds
Equipment and Construction Approval Application. However, this application did not adequately inform the LEAs of
the Wage Rate requirements included in the Uniform Guidance Compliance Supplement. In addition, it appears that
Office of Federal Programs did not understand that the Uniform Guidance Compliance requirements stipulate that the
actual construction contracts must be reviewed in order to verify that the required prevailing wage rate clauses were
included in the contract and that the required certified payroll records must be submitted to the SEA by the LEAs in
order to verify that the contractor or subcontractor submitted the required certified payrolls.

Effect: ESF funds may have been used to pay for LEA construction projects that do not comply with the required
Wage Rate Requirements.

Recommendation: We recommend that OSDE develop and implement procedures for the following:
   • Prepare and maintain a listing of all ESF funded contact applications (past and future) and document the
      approval status.
   • Immediately obtain from the LEAs the approved construction contracts and subcontracts greater than $2,000
      along with all applicable certified payroll records for all ESF construction projects paid for with ESF funds
      (past and future).




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    •    Perform a review of all ESF funded construction contracts and subcontracts along with all applicable certified
         payroll records (past and future) in order to verify whether the contracts include the required wage rate clauses
         and to ensure the LEAs obtained a copy of the certified payroll records including statement of compliance as
         required.
    •    Ensure ESF funded construction project claims are only reimbursed for LEAs that have an approved
         construction contract on file at OSDE and, the LEA has submitted the certified payroll records including
         statement of compliance as required with the claim.
    •    For any ESF construction project claims OSDE has already paid, ensure all federal funds are returned to
         USDOE for; 1) construction contracts that did not include the required wage rate clauses, and/ or; 2) copies
         of the certified payroll records including the statement of compliance were not obtained.

Views of Responsible Official(s)
Contact Person: Thomas Kirk | Division Director, Federal Programs
Anticipated Completion Date: February 2024
Corrective Action Planned: The Oklahoma State Department of Education partially agrees with the finding. See
corrective action plan located in the corrective action plan section of this report.

Auditor Response: The Corrective Action Plan did not include procedures to maintain a listing of all ESF
funded contact applications (past and future) and documented approval status. Per the Uniform Guidance
Compliance Requirements, SAI is required to test compliance with Wage Rate requirements per the following:

         III. COMPLIANCE REQUIREMENTS

                 Part N - Special Tests and Provisions

                         1.         Wage Rate Requirements

                 Audit Objectives Determine whether the nonfederal entity notified contractors and subcontractors
                 of the requirements to comply with the Wage Rate Requirements and obtained copies of certified
                 payrolls.

                 Suggested Audit Procedures

                 Select a sample of construction contracts and subcontracts greater than $2,000 that are covered by
                 the Wage Rate Requirements and perform the following procedures:

                 a.       Verify that the required prevailing wage rate clauses were included in the contract or
                 subcontract. -

                 b.       For each week in which work was performed under the contract or subcontract, verify that
                          the contractor or subcontractor submitted the required certified payrolls.

In future audit periods, SAI will need a list of all approved construction contracts in order to adequately test whether
the procedures referenced in the OSDE Corrective action Plan (CAP) for Consolidated Monitoring of LEAs with
construction projects funded through federal funds (ESF) include a review of the construction contracts and supporting
certified payroll records.

FINDING NO: 2022-022 (Repeat Finding 2021-032)
STATE AGENCY: Oklahoma State Department of Education (OSDE)
FEDERAL AGENCY: United States Department of Education (USDE)
ALN: 84.425, 84.425C, 84.425D, 84.425U
FEDERAL PROGRAM NAME: Education Stabilization Fund (ESF) - Governor’s Emergency Education Relief
                                 Fund (GEER); Elementary and Secondary School Emergency Relief (ESSER)
                                 Fund; American Rescue Plan (ARP ESSER)
FEDERAL AWARD NUMBER: S425D200024, S425D210024, S425U210024




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FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Subrecipient Monitoring

Criteria: 2 CFR § 200.332(b) – Requirements for Pass-through Entities states in part, “All pass-through entities
must: … (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and
conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in
paragraphs (d) and (e) of this section, which may include consideration of such factors as:

(1) The subrecipient's prior experience with the same or similar subawards;

(2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with
Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program;

(3) Whether the subrecipient has new personnel or new or substantially changed systems; and

(4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards
directly from a Federal awarding agency).”

2 CFR § 200.332(d) – Requirements for Pass-through Entities states in part, “All pass-through entities must: … (d)
Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in
compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward
performance goals are achieved. Pass-through entity monitoring of the subrecipient must include:
…

(2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining
to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews,
and other means.”

2 CFR § 200.303(a) – Internal Controls states in part, “The Non-Federal entity must establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the
Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”

Condition and Context: While testing 40 of 544 LEAs on the Risk Assessment Ranking Tool, we noted the following
issues:

    •    For seven of 40 (17.5%) of LEAs tested, the risk assessment score was not supported by appropriate
         documentation denoting an inadequate review.
    •    For seven of 40 (17.5%) of LEAs tested, the LEA’s risk of noncompliance was inappropriately evaluated.
    •    For one of 40 (2.5%) of LEAs tested, the LEA was not monitored as high risk appropriately.

In addition, while performing testwork on 27 prior year monitored non-compliant sites to see if appropriate follow-up
procedures were performed, we found that two districts were found to be non-compliant on the 2021 Monitoring Log
and did not receive points on the FY22 Risk Assessment.

Cause: OSDE does not have an appropriate review system to ensure subrecipient LEAs are accurately evaluated on
the Risk Assessment Ranking Tool.

Effect: Failure to adequately distribute risk assessment points could result in inadequate monitoring of subrecipient
LEAs.

Recommendation: We recommend OSDE strengthen their policies and procedures related to risk assessment scoring
to ensure all subrecipients are appropriately evaluated and monitored.




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Views of Responsible Official(s)
Contact Person: Tammy Smith, Program Director | Office of Title Services
Anticipated Completion Date: July 1, 2023
Corrective Action Planned: The Oklahoma State Department of Education agrees with the finding. See corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-043
STATE AGENCY: Oklahoma State Department of Education (OSDE)
FEDERAL AGENCY: United States Department of Education (USDE)
ALN: 84.425; 84.425D; 84.425U
FEDERAL PROGRAM NAME: Elementary and Secondary School Emergency Relief Fund (ESSER); American
                              Rescue Plan – Elementary and Secondary Schools Emergency Relief Fund (ARP
                              ESSER)
FEDERAL AWARD NUMBER: S425D210024; S425U210024
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Activities Allowed or Unallowed & Allowable Costs/Cost Principles
QUESTIONED COSTS: $36,466

Criteria: 2 CFR § 200.303(a) – Internal Controls states in part, “The Non-Federal entity must establish and maintain
effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the
Federal award.”

CARES Act – H.R. 748 – ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF FUND – SEC.
18003 (d) USES OF FUNDS states:

“A local educational agency that receives funds under this title may use the funds for any of the following:
(1) Any activity authorized by the ESEA of 1965, including the Native Hawaiian Education Act and the Alaska Native
Educational Equity, Support, and Assistance Act (20 U.S.C. 6301 et seq.), the Individuals with Disabilities Education
Act (20 U.S.C. 1400 et seq.) (‘‘IDEA’’), the Adult Education and Family Literacy Act (20 U.S.C. 1400 et seq.), the
Carl D. Perkins Career and Technical Education Act of 2006 (20 U.S.C. 2301 et seq.) (‘‘the Perkins Act’’), or subtitle
B of title VII of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11431 et seq.).
(2) Coordination of preparedness and response efforts of local educational agencies with State, local, Tribal, and
territorial public health departments, and other relevant agencies, to improve coordinated responses among such
entities to prevent, prepare for, and respond to coronavirus.
(3) Providing principals and others school leaders with the resources necessary to address the needs of their individual
schools. (4) Activities to address the unique needs of low-income children or students, children with disabilities,
English learners, racial and ethnic minorities, students experiencing homelessness, and foster care youth, including
how outreach and service delivery will meet the needs of each population.
(5) Developing and implementing procedures and systems to improve the preparedness and response efforts of local
educational agencies.
(6) Training and professional development for staff of the local educational agency on sanitation and minimizing the
spread of infectious diseases.
(7) Purchasing supplies to sanitize and clean the facilities of a local educational agency, including buildings operated
by such agency.
(8) Planning for and coordinating during long-term closures, including for how to provide meals to eligible students,
how to provide technology for online learning to all students, how to provide guidance for carrying out requirements
under the Individuals with Disabilities Education Act (20 U.S.C. 1401 et seq.) and how to ensure other educational
services can continue to be provided consistent with all Federal, State, and local requirements.
(9) Purchasing educational technology (including hardware, software, and connectivity) for students who are served
by the local educational agency that aids in regular and substantive educational interaction between students and their
classroom instructors, including low-income students and students with disabilities, which may include assistive
technology or adaptive equipment.
(10) Providing mental health services and supports.




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(11) Planning and implementing activities related to summer learning and supplemental afterschool programs,
including providing classroom instruction or online learning during the summer months and addressing the needs of
low- income students, students with disabilities, English learners, migrant students, students experiencing
homelessness, and children in foster care.
(12) Other activities that are necessary to maintain the operation of and continuity of services in local educational
agencies and continuing to employ existing staff of the local educational agency.”

American Rescue Plan Act of 2021 - H.R.2617, 117th Congress - SEC. 2001. ELEMENTARY AND SECONDARY
SCHOOL EMERGENCY RELIEF FUND states in part:

“(2) AVAILABILITY OF FUNDS.— Each State shall make allocations under paragraph (1) to local educational
agencies in an expedited and timely manner and, to the extent practicable, not later than 60 days after the receipt of
such funds.
…

(e) USES OF FUNDS.—A local educational agency that receives funds under this section— (1) shall reserve not less
than 20 percent of such funds to address learning loss through the implementation of evidence-based interventions,
such as summer learning or summer enrichment, extended day, comprehensive afterschool programs, or extended
school year programs, and ensure that such interventions respond to students’ academic, social, and emotional needs
and address the disproportionate impact of the coronavirus on the student subgroups described in section
1111(b)(2)(B)(xi) of the Elementary and Secondary Education Act of 1965 (20 U.S.C. 6311(b)(2)(B)(xi)), students
experiencing homelessness, and children and youth in foster care; and (2) shall use the remaining funds for any of the
following:
(A) Any activity authorized by the Elementary and Secondary Education Act of 1965.
(B) Any activity authorized by the Individuals with Disabilities Education Act.
(C) Any activity authorized by the Adult Education and Family Literacy Act.
(D) Any activity authorized by the Carl D. Perkins Career and Technical Education Act of 2006.
(E) Coordination of preparedness and response efforts of local educational agencies with State, local, Tribal, and
territorial public health departments, and other relevant agencies, to improve coordinated responses among such
entities to prevent, prepare for, and respond to coronavirus.
(F) Activities to address the unique needs of low-income children or students, children with disabilities, English
learners, racial and ethnic minorities, students experiencing homelessness, and foster care youth, including how
outreach and service delivery will meet the needs of each population.
(G) Developing and implementing procedures and systems to improve the preparedness and response efforts of local
educational agencies.
(H) Training and professional development for staff of the local educational agency on sanitation and minimizing the
spread of infectious diseases.
(I) Purchasing supplies to sanitize and clean the facilities of a local educational agency, including buildings operated
by such agency.
(J) Planning for, coordinating, and implementing activities during long-term closures, including providing meals to
eligible students, providing technology for online learning to all students, providing guidance for carrying out
requirements under the Individuals with Disabilities Education Act and ensuring other educational services can
continue to be provided consistent with all Federal, State, and local requirements.
(K) Purchasing educational technology (including hardware, software, and connectivity) for students who are served
by the local educational agency that aids in regular and substantive educational interaction between students and their
classroom instructors, including low-income students and children with disabilities, which may include assistive
technology or adaptive equipment.
(L) Providing mental health services and supports, including through the implementation of evidence-based full-
service community schools.
(M) Planning and implementing activities related to summer learning and supplemental afterschool programs,
including providing classroom instruction or online learning during the summer months and addressing the needs of
low-income students, children with disabilities, English learners, migrant students, students experiencing
homelessness, and children in foster care.
(N) Addressing learning loss among students, including low-income students, children with disabilities, English
learners, racial and ethnic minorities, students experiencing homelessness, and children and youth in foster care, of




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And Questioned Costs
the local educational agency, including by— (i) administering and using high-quality assessments that are valid and
reliable, to accurately assess students’ academic progress and assist educators in meeting students’ academic needs,
including through differentiating instruction; (ii) implementing evidence-based activities to meet the comprehensive
needs of students; (iii) providing information and assistance to parents and families on how they can effectively
support students, including in a distance learning environment; and (iv) tracking student attendance and improving
student engagement in distance education.
(O) School facility repairs and improvements to enable operation of schools to reduce risk of virus transmission and
exposure to environmental health hazards, and to support student health needs.
(P) Inspection, testing, maintenance, repair, replacement, and upgrade projects to improve the indoor air quality in
school facilities, including mechanical and non- mechanical heating, ventilation, and air conditioning systems,
filtering, purification and other air cleaning, fans, control systems, and window and door repair and replacement.
(Q) Developing strategies and implementing public health protocols including, to the greatest extent practicable,
policies in line with guidance from the Centers for Disease Control and Prevention for the reopening and operation of
school facilities to effectively maintain the health and safety of students, educators, and other staff.
(R) Other activities that are necessary to maintain the operation of and continuity of services in local educational
agencies and continuing to employ existing staff of the local educational agency.”

Condition and Context: While testing 67 of 918 accounts payable claims totaling $97,835,613.65, we noted the
following:

    •   For 5 of 67 (7.46%) claims tested, we noted that the electronic LEA expenditure claim included incorrect
        function codes/object codes and/or the claim did not agree with budgeted activities for SFY22. However, the
        claims were for allowable activities under the applicable Education Stabilization Fund (ESF) program and
        were correctly included in accounts payable.
    •   For 1 of 67 (1.49%) claims tested, we noted that no supporting documentation i.e. (invoices, receipts, etc.)
        was submitted for several items listed on the Detailed Expenditure Report totaling $25,812.97 and SAI was
        unable to determine if 1) the items were allowable (per the applicable ESF regulations), 2) the items were
        included in the LEA’s approved budgeted activities and, 3) the transactions were appropriately included in
        accounts payable expenditures. SAI questioned these costs.
    •   For 3 of 67 (4.48%) claims tested, we noted the electronic LEA expenditure claim included unallowable
        items (per the applicable ESF regulations) totaling $10,619 and, the expenditures did not agree with the
        LEA’s approved budgeted activities. SAI questioned these costs.

In addition, while testing 68 of 6,320 claims totaling $737,399,107.82, we noted the following:

    •   For 1 of 68 (1.47%) claims tested, we noted an overclaim of $10 for cleaning services. SAI questioned these
        costs.
    •   For 1 of 68 (1.47%) claims tested, we noted some claim items were coded incorrectly, and one claim,
        totaling $24.63, was not for an allowable use of ESSER II funds. SAI questioned the unallowable cost.

Cause: OSDE did not adequately review claims to ensure all supporting documents were submitted, the claim agreed
with the approved budgeted items and, the claim was only for allowable uses of ESSER II funds and ARP ESSER
funds.

Effect: Failure to adequately review claims could result in reimbursement of unallowable expenses. Claims may have
been incorrectly included in accounts payable.

Recommendation: We recommend OSDE strengthen their policies and procedures related to claim reviews to ensure
that LEAs are not reimbursed for expenditures that are not allowable uses of ESSER II and ARP ESSER funds and to
ensure expenditures are correctly classified.

Views of Responsible Official(s)
Contact Person: Tammy Smith, Program Director| Title Services
Anticipated Completion Date: 06/30/2024




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Corrective Action Planned: The Oklahoma State Department of Education agrees with the finding. See corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-044 (Repeat Finding 2021-036)
STATE AGENCY: Oklahoma State Department of Education (OSDE)
FEDERAL AGENCY: United States Department of Education (USDE)
ALN: 84.425 –84.425D; 84.425U; 84.425V; 84.425W
FEDERAL PROGRAM NAME: Elementary and Secondary School Emergency Relief Fund (ESSER); American
                                Rescue Plan – Elementary and Secondary Schools Emergency Relief Fund (ARP
                                ESSER); ARP Emergency Assistance to Nonpublic Schools (ARP EANS); ARP
                                Homeless Children and Youth I and II (ARP HCY I and II)
FEDERAL AWARD NUMBER: S425D210024; S425U210024; S425V210007; S425W210037 – 21A
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Reporting
QUESTIONED COSTS: $0

Criteria: 2 CFR Subpart B § 170.200 Federal awarding agency reporting requirements states in part, “(a) Federal
awarding agencies are required to publicly report Federal awards that equal or exceed the micro-purchase threshold
and publish the required information on a public-facing, OMB-designated, governmentwide website and follow OMB
guidance to support Transparency Act implementation.”

2 CFR Subpart B § 170.220 Award term states in part “(a) To accomplish the purposes described in § 170.100, a
Federal awarding agency must include the award term in appendix A to this part in each Federal award to a recipient
under which the total funding is anticipated to equal or exceed $30,000 in Federal funding.”

2 CFR Subpart B § 170.220 Award term - Appendix A states in part,

  “I. Reporting Subawards and Executive Compensation
    a. Reporting of first-tier subawards.
    Applicability. Unless you are exempt as provided in paragraph d. of this award term, you must report each action
    that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity or Federal agency (see
    definitions in paragraph e. of this award term).
    …
       2. Where and when to report.
          i. The non-Federal entity or Federal agency must report each obligating action described in paragraph a.1. of
          this award term to http://www.fsrs.gov.
          ii. For subaward information, report no later than the end of the month following the month in which the
          obligation was made. (For example, if the obligation was made on November 7, 2010, the obligation must
          be reported by no later than December 31, 2010.)
       3. What to report. You must report the information about each obligating action that the submission instructions
       posted at http://www.fsrs.gov specify.”

Condition and Context: While documenting controls over FFATA reports, we noted that OSDE did not report the
subaward information timely for the revised ESSER II LEA allocation that was due on January 31, 2022, but not
submitted until February 24, 2022.

In addition, OSDE did not report any of the subaward information for the following revised ESSER allocations:

    •   The FFATA report for the revised ARP ESSER allocations was due on January 31, 2022; however, the report
        was not submitted.
    •   The FFATA report for the ARP EANS allocations was due on October 29, 2021; however, the report was
        not submitted.
    •   The FFATA report for the ARP HCY II allocations was due on April 30, 2022; however, the report was not
        submitted.




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While testing 1 of 5, or 20% of FFATA reports, we noted that one LEA was left off the FFATA report submitted for
the ARP Homeless HCY I allocations.

Cause: OSDE does not have adequate policies and procedures to ensure that FFATA reports, and applicable revisions
are accurate, complete, and submitted within the required timeframes.

Effect: Information being reported in the Federal Subaward Reporting System (FSRS) is not accurate and/or complete.

Recommendation: We recommend that OSDE develop policies and procedures to ensure that FFATA reports, and
applicable revisions are accurate, complete, and submitted within the appropriate timeframes.

Views of Responsible Official(s)
Contact Person: Tammy Smith, Program Director | Office of Title Services
Anticipated Completion Date: September 2022
Corrective Action Planned: The Oklahoma State Department of Education agrees with the finding. See corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-049
STATE AGENCY: Oklahoma State Department of Education (OSDE)
FEDERAL AGENCY: United States Department of Education (USDE)
ALN: 84.425 – 84.425R
FEDERAL PROGRAM NAME: Emergency Assistance for Non-Public Schools
FEDERAL AWARD NUMBER: S425R210007
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Reporting
QUESTIONED COSTS: $0

Criteria: United States Department of Education website ESSER Annual Reporting states in part, “All grantees are
required to report on ESSER funds received under the Coronavirus Aid, Relief, and Economic Security (CARES) Act;
the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act; and the American Rescue Plan
(ARP) Act. Grantees must submit an annual report describing how the State and subrecipients used the awarded funds
during the performance period. Similar to CARES Act Year 1 annual reporting, grantees will use the Annual Report
Data Collection Tool to submit the State report.”

Condition and Context: The expenditures reported for the CRRSA EANS Annual Report were not accurate. The
total amount of the grant expended included expenditures through mid-September 2021 instead of through the end of
the fiscal year, June 30, 2021.

Cause: OSDE does not have adequate policies and procedures to ensure personnel in charge of completing the annual
report have an adequate understanding of the requirements of the report.

Effect: The amount reported for the total CRRSA EANS amount of the grant expended was overstated by
$3,907,693.59.

Recommendation: We recommend OSDE develop and implement policies and procedures to ensure personnel have
an adequate understanding of the requirements for the Annual Report and to ensure the amounts reported are correct.

Views of Responsible Official(s)
Contact Person: Tammy Smith, Program Director | Office of Title Services
Anticipated Completion Date: May 2024
Corrective Action Planned: The Oklahoma State Department of Education agrees with the finding. See corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-070




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STATE AGENCY: Oklahoma State Department of Education (OSDE)
FEDERAL AGENCY: United States Department of Education (USDE)
ALN: 84.425; 84.425V
FEDERAL PROGRAM NAME: American Rescue Plan – Emergency Assistance to Non-Public Schools (ARP
                            EANS)
FEDERAL AWARD NUMBER: S425V210007
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Special Tests and Provisions – Identifying Non-Public Schools under ARP EANS that
                     Enroll a Significant Percentage of Students from Low-income Families and are Most
                     Impacted by the COVID-19 Emergency
QUESTIONED COSTS: $0

Criteria: 2 C.F.R. § 200.303(a) – Internal Controls states in part, “The Non-Federal entity must establish and
maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal
entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions
of the Federal award.”

86 FR 36648 – American Rescue Plan Act Emergency Assistance to Non-Public Schools Program states in part,
“Under the ARP EANS program, consistent with section 312(d)(1) of division M of the CRRSA Act, the Department
will allot funds by formula to each Governor with an approved application based on the State's relative share of
children aged 5 through 17 who are from families at or below 185 percent of the 2020 Federal poverty level and
enrolled in non-public schools, as determined by the Department on the basis of non-public school enrollment data
from the U.S. Census Bureau's American Community Survey (ACS) Public Use Microdata Sample (PUMS) for 2015-
2019.”

U.S. Department of Education Application for Funding – Emergency Assistance to Non-Public Schools (EANS) under
the American Rescue Plan Act of 2021 (ARP Act) states in part, “The final requirements require a Governor, in his or
her application for ARP EANS funds, to identify the significant poverty percentage and the factors demonstrating the
impact of the COVID-19 emergency the State will use, after approval by the Secretary, to determine which non-public
schools are eligible to receive services or assistance. In addition to meeting the definition of a non-public school in
section 316(6) of the CRRSA Act and the eligibility requirement in section 312(d)(9) of the CRRSA Act, a non-public
school must meet or exceed the State’s significant poverty percentage and be most impacted by the COVID-19
emergency.
…

A non-public school enrolls a significant percentage of students from low-income families if the percentage of students
from low-income families enrolled in such school meets or exceeds--
    • 40 percent; or
    • An alternate significant percentage approved by the Secretary in the State’s application that is based on
        circumstances in the State, which may be –
             o The State’s average percentage of students from low-income families in public and non-public
                 schools.
             o The average percentage of students from low-income families in non-public schools in the State
                 that, for example, applied for or participated in the EANS program authorized by the CRRSA Act;
                 or
             o Other factors that the State demonstrates support an alternate significant poverty percentage.

A non-public school is most impacted by the COVID-19 emergency based on one or more of the following factors:
    • The number of COVID-19 infections per capita in the community or communities served by the non-public
        school.
    • The number of COVID-19 related deaths per capita in the community or communities served by the non-
        public school.
    • Data on the academic impact of lost instructional time and the social, emotional, and mental health impacts
        on students attending the non-public school attributable to the disruption of instruction caused by the COVID-
        19 emergency; or




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    •    The economic impact of the COVID-19 emergency on the community or communities served by the non-
         public school.
…

Determining Low-Income Counts - To be counted as a student from a low-income family for purposes of the ARP
EANS program, a student must be aged 5 through 17 from a family whose income does not exceed 185 percent of the
2020 Federal poverty threshold. To obtain a count of students from low-income families enrolled in a non-public
school, an SEA may use one or more of the following sources of data, provided the poverty threshold is consistent
across sources:

    •    Data on student eligibility for free or reduced-price lunch under the Richard B. Russell National School
         Lunch Act (43 U.S.C. 1751 et seq.).
    •    Data from the E-rate program administered by the Federal Communications Commission (47 CFR 54.500,
         54.505(b)).
    •    Data from a different source, such as scholarship or financial assistance data.
    •    Data from a survey developed by the SEA.”

USDE published a webinar dated February 24, 2022, that states in part, “Under the ARP EANS final requirements,
the source of data must be an actual measure of family income. Methodologies, such as proportionality, may not be
used to determine the eligibility of non-public schools for ARP EANS services or assistance.”
USDOE Letter dated July 29, 2022, states in part, “Because proportionality is a methodology to derive an estimate
and is not based on actual income data from the families of students enrolled in a non-public school, it cannot be used
to determine school eligibility for ARP EANS.”

Condition and Context: We reviewed the 31 ARP EANS allocations and noted the following issues:

         1.   For 12 of 31 (38.71%) non-public schools that received an ARP EANS allocation, we noted OSDE
              allowed non-public schools to use of proportionality data to calculate their low-income student counts,
              and OSDE failed to revise the allocations after notification from the USDOE that the use of
              proportionality data was unallowable.
         2.   For 31 of 31 (100%) non-public schools, the ARP EANS allocation is incorrect.
         3.   For 31 of 31 (100%) non-public schools, OSDE did not track the amounts spent to ensure the
              expenditures did not exceed the total allocation.

Also, OSDE did not appropriately determine whether the non-public schools enrolled a significant percentage of
students from low-income families who were most impacted by COVID-19.

SAI noted that many non-public schools elected to use proportionality data (estimate based on the Title IA low income
counts for the public school serving the same area as the private school) even though other reliable low income counts
that were based on actual income data were available. Because OSDE collects actual low income counts from many
of these non-public schools as part of OSDE’s procedures to determine equitable services for non-public schools,
OSDE should have been aware that the use of the proportionality data resulted in the non-public schools receiving an
ARP EANS allocation based on greatly inflated and inaccurate low-income counts. In addition, many non-public
schools would not have met the 40% threshold if their actual low-income counts had been used. Finally, the amount
of ARP EANS funds allocated to other non-public schools that did report actual low-income counts would have been
unfairly reduced by the private schools using the inflated estimates.

SAI notes that, as of the date of our testwork (November 18, 2023), OSDE has not obtained the appropriate low
income counts from the non-public schools that used the proportionality data originally and has not made the required
re-allocation of ARP EANS funds.

Cause: OSDE does not have adequate policies and procedures to ensure:
   • ARP EANS allocations are to non-public schools that enroll a significant percentage of students from low-
       income families who were most impacted by COVID-19




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    •    allocations are based on allowable methodologies for determining non-public school low-income counts.
    •    the amount of ARP EANS funds spent per non-public school to ensure the funds spent do not exceed the
         approved allocation.
     • ARP EANS funds are re-allocated based on USDE published final requirements stating proportionality data
         was not an allowable methodology to determine eligibility for ARP EANS
Effect: ARP EANS funds were allocated and paid to ineligible non-public schools. Eligible non-public schools were
allocated less ARP EANS funding than they should have been awarded.

Recommendation: We recommend that OSDE develop and implement policies and procedures to ensure ARP EANS
funds are correctly allocated only to non-public schools that enroll a significant percentage of students from low-
income families who were most impacted by COVID-19.

We recommend OSDE immediately revise the ARP EANS allocations based on allowable methodologies for
determining non-public school low-income counts.

We recommend OSDE develop and implement procedures to track the amount of ARP EANS funds spent per non-
public school to ensure the funds spent do not exceed the approved allocation.

Views of Responsible Official(s)
Contact Person: Tammy Smith, Program Director| Office of Title Services
Anticipated Completion Date: June 2023
Corrective Action Planned: The Oklahoma State Department of Education partially agrees with the finding. See
corrective action plan located in the corrective action plan section of this report.

Auditor Response: The corrective action provided does not specifically address any of the SAI recommendations.

 The core issue of the finding is that OSDE did not appropriately determine whether the non-public schools enrolled
a significant percentage of students from low-income families who were most impacted by COVID-19. This resulted
in some non-public schools receiving EANS allocations (sometimes very large allocations) when the non-public
school did not meet the low-income threshold and were not eligible to receive EANS funds. This also caused non-
public schools that did meet the low-income threshold to receive an EANS allocation that was less (sometimes
significantly less) than they were actually entitled to receive.

The SAI recommendations include the development and implementation of appropriate policies and procedures to
ensure EANS allocations are correctly allocated, and funds expended are correctly tracked, and the ARP EANS
allocations are appropriately revised based on allowable methodologies for determining non-public school low-income
counts.



                  Oklahoma EMPLOYMENT SECURITY COMMISSION

FINDING NO: 2022-038 (Repeat Finding #2021-011)
STATE AGENCY: Oklahoma Employment Security Commission (OESC)
FEDERAL AGENCY: U.S. Department of Labor
ALN: 17.225
FEDERAL PROGRAM NAME: Unemployment Insurance
FEDERAL AWARD NUMBER: 23A60UI038000-01-03 and UI359652160A40-01-05
FEDERAL AWARD YEAR: 2021 and 2022
CONTROL CATEGORY: Special Tests and Provisions - Reemployment Services and Eligibility Assessments
(RESEA)
QUESTIONED COSTS: $0




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Criteria: Section 306 of the Social Security Act requires all states to operate either a Worker Profiling and
Reemployment Services Program (WPRS) or a Reemployment Services and Eligibility Assessment Program
(RESEA), or both. The State of Oklahoma only operates a RESEA program. The requirements include profiling of
all claimants to determine who will likely exhaust their benefits and need reemployment services to transition to new
employment. If operating only a RESEA program, the Oklahoma Employment Security Commission must include the
basic elements of the WPRS program which includes the required WPRS profiling model and statewide provision of
services.

Social Security Act § 306(a) [42 USC § 506(b)] – Grants to States for reemployment services and eligibility
assessments states in part, “The purposes of this section are to accomplish the following goals:
    (1) To improve employment outcomes of individuals that receive unemployment compensation and to reduce
        the average duration of receipt of such compensation through employment.
    (2) To strengthen program integrity and reduce improper payments of unemployment compensation
        by States through the detection and prevention of such payments to individuals who are not eligible for such
        compensation.
    (3) To promote alignment with the broader vision of the Workforce Innovation and Opportunity Act (29 U.S.C.
        3101 et seq.) of increased program integration and service delivery for job seekers, including claimants for
        unemployment compensation.
    (4) To establish reemployment services and eligibility assessments as an entry point for individuals receiving
        unemployment compensation into other workforce system partner programs.”

U.S. Department of Labor, Unemployment Insurance Program Letter No. 10-22, Number 4. Program Operations, d.
states in part, “i. UI staff must be engaged in the administration of the RESEA program. This includes, but is not
limited to:
     • Participating in the planning, administration, and oversight of the RESEA program;
     • Providing all appropriate staff training on UC eligibility requirements;
     • Ensuring accurate data are provided in the RESEA-required reports; and
     • Conducting eligibility determinations and redeterminations resulting from issues identified through RESEA
          participation.”

Condition and Context: The Department of Labor’s Employment and Training Administration (ETA) 9128 report
provides quarterly information on the Reemployment Services and Eligibility Assessment (RESEA) activities of
claimants who are most likely to exhaust their Unemployment Insurance (UI) benefits and are selected to participate
in the RESEA program. The data on this report allows for evaluation and monitoring of the RESEA program.
Oklahoma Job Match system (OKJM), the management system where the appointments are recorded, provides
appointment information for Sections I and III of the ETA 9128 performance report. OESC’s mainframe generates a
report that is used for Sections II and IV of the report. The data from both systems are then input into the Department
of Labor’s Sun System to create the final ETA 9128 report.

The data generated by OKJM used in the ETA 9128 performance report was not reliable for reporting purposes. In
order to complete the ETA 9128 report, the RESEA program manager had staff manually go back through their
appointments, capture information, and verbally provide the results. Based on the lack of physical documentation for
the ETA 9128 performance report, we are unable to determine if the ETA 9128 performance report accurately
compiled all RESEA performance data.

Cause: During Covid, services were suspended in part due to a directive from the Governor to suspend required work
searches, as well as the inability to meet with RESEA participants in person. As a result, programming changes
prevented enrollments from opening in OKJM and staff were unable to enter data in the RESEA enrollment to be
captured in the report.

Effect: For SFY 2022, OESC staff were unable to use OKJM the system to capture RESEA participant information,
which could result in OESC reporting inaccurate data on the ETA 9128 performance reports.




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Recommendation: We recommend the OESC continue to develop a process in OKJM to ensure that the RESEA
enrollment opens allowing staff to capture appointment information and keep track of the number of RESEA
appointments and that the system generates reliable quarterly data to be reported on the ETA 9128.

Views of Responsible Official(s)
Contact Person: Sharon Smith, RESEA Program Manager
Anticipated Completion Date: Ongoing until modernization of RESEA tools are complete.
Corrective Action Planned: The Oklahoma Employment Security Commission agrees with the finding. See corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-051 (Repeat Finding 2021-057)
STATE AGENCY: Oklahoma Employment Security Commission
FEDERAL AGENCY: U.S. Department of Labor
ALN: 17.225
FEDERAL PROGRAM NAME: Unemployment Insurance (UI)
FEDERAL AWARD NUMBER: UI340792055A40-01-09, UI356692155A40-01-08, and UI372442255A40-01-09
FEDERAL AWARD YEAR: 2020, 2021, and 2022
CONTROL CATEGORY: Special Tests and Provisions – Benefit Accuracy Measurement
QUESTIONED COSTS: $0

Criteria: As documented in the Unemployment Insurance Program Letter (UIPL) No. 02-12, Public Law 112-40
enacted on October 21, 2011, and effective October 21, 2013, amended sections 303(a) and 453A of the Social
Security Act and sections 3303, 3304, and 3309 of FUTA. Section 4. of the UIPL states in part, “Section 251(a) of
the TAAEA [Trade Adjustment Assistance Extension Act of 2011] amends section 303(a), SSA, by adding a new
paragraph (11). As a condition of receiving a Federal grant to administer its UC law, a state that has determined that
an improper payment from its unemployment fund was made to an individual due to fraud committed by such
individual must assess a monetary penalty of not less than 15 percent of the amount of the erroneous payment against
that individual. The 15 percent penalty amount is the minimum amount required; states may impose a greater penalty.”

UIPL No. 02-12, Section 4. States in part, “A. Requirements: Section 303(a)(11), SSA, further requires that the state
immediately deposit receipts of the Federally-mandated penalty amounts into the unemployment fund of the
state….When a recovery with respect to a fraudulent overpayment is made, the state is encouraged to apply any
recovery to the principal amount of the overpayment first, to the Federally-mandated penalty amount second and
finally to any other amounts due (e.g., additional penalties and/or interest). However, the order of the recovery is
determined by state law.” See UIPL No. 02-12 at https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=6707.

40 O.S. §2-613 (1) states, “Fraud overpayment: in which an individual intentionally makes a false statement or
representation or fails to disclose a material fact, and has received any sum as benefits to which the individual was not
entitled. The individual shall be liable to repay this sum, plus a penalty of twenty-five percent (25%) of the amount of
the original overpayment and interest at the rate of one percent (1%) per month on the unpaid balance of the
overpayment, to the Oklahoma Employment Security Commission. Three-fifths (3/5) of the penalty amount collected
shall be deposited in the Unemployment Trust Fund for the State of Oklahoma and the remaining two-fifths (2/5) shall
be deposited in the Oklahoma Employment Security Commission Revolving Fund. The interest shall cease to accrue
when the total accrued interest equals the amount of the overpayment. If an overpayment is modified, the interest shall
cease to accrue when the total accrued interest equals the amount of the modified overpayment. The Commission shall
deduct the principal sum from any future benefits payable to the individual.”

Oklahoma Administrate Code (OAC) 240:10-3-28 (b) states, “All payments or amounts collected in processes other
than offset or recoupment of current unemployment benefit payments – When a payment is made or a collection of
funds is accomplished to repay an indebtedness created by a previous overpayment of unemployment benefits
established pursuant to 40 O.S.§2-613 (1) or (2), the payment or the amount collected shall be applied in the following
manner:
    (1) First, to the fees that have been charged to the debtor in the earliest established overpayment until all fees for
         that overpayment are paid.




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    (2) Second, to accrued penalties in the earliest established overpayment until all penalties for that overpayment
        are paid.
    (3) Third, to the accrued interest in the earliest established overpayment until all interest for that overpayment is
        paid.
    (4) Fourth, to the principal amount in the earliest established overpayment until the principal amount is paid in
        full.
    (5) After the payment or amount collected has been applied in the manner described in paragraphs 1 through 4
        of this subsection and the earliest established overpayment is paid in full, any money left over, and all future
        payments or amounts collected, shall be applied in the same manner to the overpayment established next in
        time, and this procedure shall be repeated until all overpayments are repaid.”

2 CFR §200.1 “Internal controls”, states in part, “Internal controls for non-Federal entities means:
       (1) Processes designed and implemented by non-Federal entities to provide reasonable assurance regarding
            the achievement of objectives in the following categories:

             (i)      Effectiveness and efficiency of operations;
             (ii)     Reliability of reporting for internal and external use; and
             (iii)    Compliance with applicable laws and regulations.”

The Government Accountability Office (GAO) Standards for Internal Control in the Federal Government Design of
the Entity’s Information System, states in part:
     “11.03 Management designs the entity’s information system to obtain and process information to meet each
             operational process’s information requirements and to respond to the entity’s objectives and risks. An
             information system is the people, processes, data, and technology that Federal Internal Control Standards
             management organizes to obtain, communicate, or dispose of information….
       11.04 Management designs the entity’s information system and the use of information technology by considering
             the defined information requirements for each of the entity’s operational processes…. Although
             information technology implies specific types of control activities, information technology is not a “stand-
             alone” control consideration. It is an integral part of most control activities.
      11.05 Management also evaluates information processing objectives to meet the defined information
             requirements. Information processing objectives may include the following:
              • Accuracy - Transactions are recorded at the correct amount in the right account (and on a timely
                  basis) at each stage of processing.
              • Validity - Recorded transactions represent economic events that actually occurred and were executed
                  according to prescribed procedures.”

Condition and Context: When OESC receives a reimbursement (recovery) for a fraudulent overpayment, the OESC
Bull Mainframe is to apply the recovery in the order prescribed in OAC 240:10-3-28(b). While performing testwork
on state fiscal year 2022 recoveries of fraudulent Unemployment Insurance (UI) overpayments totaling $106,663, we
noted 36 of 36 (100%) recoveries did not have penalties applied.

Cause: During SFY 2022, the Bull Mainframe system only allocated fraudulent overpayments to principal and interest
and bypassed the allocation of fees and penalties.

Effect: Penalties totaling $26,666 ($106,663 * 25%) were not applied to recoveries. Further, $16,000 (3/5 of $26,666)
from the omitted penalties was not deposited to the Unemployment Trust fund and $10,666 (2/5 of $26,666) was not
deposited to the Oklahoma Employment Security Commission Revolving Fund.

Recommendation: We recommend OESC IT evaluate the programming relating to recovery allocations and make
the adjustments necessary to ensure recoveries are properly applied in the following order: fees, penalty, interest, and
then principal.

Views of Responsible Official(s)
Contact Person: Christopher O’Brien, Director Integrity Division




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Anticipated Completion Date: Ultimate resolution expected in conjunction with modernization efforts, timing to be
determined.
Corrective Action Planned: The Oklahoma Employment Security Commission agrees with the finding. See corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-053 (Partial Repeat Finding 2021-001)
STATE AGENCY: Oklahoma Employment Security Commission
FEDERAL AGENCY: U.S. Department of Labor
ALN: 17.225
FEDERAL PROGRAM NAME: Unemployment Insurance Programs
FEDERAL AWARD NUMBER: UI340792055A40-01-09, UI356692155A40-01-08, UI372442255A40-01-09
FEDERAL AWARD YEAR: 2021 and 2022
CONTROL CATEGORY: Activities Allowed/Unallowed, Allowable Costs/Cost Principles, Eligibility
QUESTIONED COSTS: $15,979

Criteria: The Government Accountability Office (GAO) Standards for Internal Control in the Federal Government
9.04 states, in part, “As part of risk assessment or a similar process, management analyzes and responds to identified
changes and related risks in order to maintain an effective internal control system. Changes in conditions affecting the
entity and its environment often require changes to the entity’s internal control system, as existing controls may not
be effective for meeting objectives or addressing risks under changed conditions. Management analyzes the effect of
identified changes on the internal control system and responds by revising the internal control system on a timely
basis, when necessary, to maintain its effectiveness.”

The Government Accountability Office (GAO) Standards for Internal Control in the Federal Government 10.03 states,
in part, “Management designs appropriate types of control activities for the entity’s internal control system. Control
activities help management fulfill responsibilities and address identified risk responses in the internal control system.
… Management establishes physical control to secure and safeguard vulnerable assets. Examples include security for
and limited access to assets such as cash, securities, inventories, and equipment that might be vulnerable to risk of
loss or unauthorized use. Management periodically counts and compares such assets to control records.”

The Government Accountability Office (GAO) Standards for Internal Control in the Federal Government 10.06 states,
“Control activities can be implemented in either an automated or a manual manner. Automated control activities are
either wholly or partially automated through the entity’s information technology. … Automated control activities tend
to be more reliable because they are less susceptible to human error and are typically more efficient. If the entity relies
on information technology in its operations, management designs control activities so that the information technology
continues to operate properly.”

The Government Accountability Office (GAO) Standards for Internal Control in the Federal Government 11.13 states,
in part, “Management evaluates security threats to information technology, which can be from both internal and
external sources. External threats are particularly important for entities that depend on telecommunications networks
and the Internet. External threats have become prevalent in today’s highly interconnected business environments, and
continual effort is required to address these risks.”

A component objective of an effective internal control system is to ensure accurate and reliable information through
a proper review and approval process.

Condition: When testing a sample of 62 Unemployment Insurance claim payments totaling $21,413 (identified by
check number per payment data), we noted 2 unallowable payments due to unresolved fraud stops totaling $629 were
paid to 2 claimants, which is a 3.23% error rate of claims tested and a 2.94% error rate of dollars tested. We isolated
these 2 claimants from all state fiscal year 2022 payments per the applicant identifier (SSN per payment data) and
identified 68 benefit payments totaling $15,979 on those 2 claimants.

Cause: The agency’s internal controls were insufficient to detect and/or prevent unallowable unemployment benefit
payments. The lack of controls over the Unemployment Insurance benefit payments that led to the increase in
unallowable payments was a result of the following factors:




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     •   Antiquated system that didn’t have the capacity for proper automated edits or matching of all necessary
         fields at the time a claim was filed.
     •   Large number of stolen identities.
     •   Lack of adequate staffing to handle the volume of claims paid for all Unemployment Insurance programs.
     •   Lack of adequate training for all staff related to the various Unemployment Insurance program requirements.
     •   Delays in the process for employers to dispute claims since the process was largely manual through the
         mailing of notifications.

Effect: Unallowable benefit payments were made, which contributed to the depletion of the Unemployment Insurance
Trust Fund.

With a dollar error rate of 2.94% and benefit payments data total of $275,005,155, we project the amount of
unallowable benefit expenditures were $8,085,152 in state fiscal year 2022. Efforts by OESC to identify and
investigate known and suspected claims, and recover fraudulent and overpayment claims, are ongoing. However, we
do feel that OESC has made big improvements in identifying trends or anomalies in the data that has allowed the
agency to suspend large amounts of potentially fraudulent claims until they can be examined. In addition, OESC
implemented VerifyOK in November of 2022 to further deter and prevent identity theft fraud.

Recommendation: We recommend the OESC perform the following:
    • Continue to work to strengthen internal controls over the automated system to better detect and prevent
      unemployment insurance benefit overpayments related to fraudulent or administrative errors.
    • Continue to refine the analytics process that will help better identify trends or anomalies in the data to catch
      fraudulent claims timely and save taxpayer monies.
    • Work to strengthen their eligibility verification process to help prevent fraudulent claims.
    • Continue to work with the U.S. Department of Labor to recover the remaining fraudulent payments.
    • Continue to work to establish overpayment resolution for unemployment benefit claims.

Views of Responsible Official(s)
Contact Person: Michelle Britten, CFO
Anticipated Completion Date: The efforts required for fraud prevention are not expected to end, as bad actors are
expected to continually pursue new methods to exploit unemployment benefit systems in all states.
Corrective Action Planned: The Oklahoma Employment Security Commission does not completely disagree with the
finding. See corrective action plan located in the corrective action plan section of this report.

FINDING NO: 2022-077 (Repeat Finding 2021-022)
STATE AGENCY: Oklahoma Employment Security Commission
FEDERAL AGENCY: U.S. Department of Labor
ALN: 17.225
FEDERAL PROGRAM NAME: Unemployment Insurance Program
FEDERAL AWARD NUMBER: 23A60UI038000-01-03 and UI359652160A40-01-05
FEDERAL AWARD YEAR: 2021-2022
CONTROL CATEGORY: Special Tests and Provisions – Reemployment Services and Eligibility Assessments
(RESEA)
QUESTIONED COSTS: $0

Criteria: 42 USC § 506(b) – Grants to States for reemployment services and eligibility assessments states in part,
“The purposes of this section are to accomplish the following goals:
         (1) To improve employment outcomes of individuals that receive unemployment compensation and to
             reduce the average duration of receipt of such compensation through employment.
         (2) To strengthen program integrity and reduce improper payments of unemployment compensation
             by States through the detection and prevention of such payments to individuals who are not eligible for
             such compensation.




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        (3) To promote alignment with the broader vision of the Workforce Innovation and Opportunity Act (29
            U.S.C. 3101 et seq.) of increased program integration and service delivery for job seekers, including
            claimants for unemployment compensation.
        (4) To establish reemployment services and eligibility assessments as an entry point for individuals
            receiving unemployment compensation into other workforce system partner programs.”

U.S. Department of Labor, Unemployment Insurance Program Letter No. 10-22, Number 4. Program Operations, d.
states in part, “i. UI staff must be engaged in the administration of the RESEA program. This includes, but is not
limited to:
     • Participating in the planning, administration, and oversight of the RESEA program;
     • Providing all appropriate staff training on UC eligibility requirements;
     • Ensuring accurate data are provided in the RESEA-required reports; and
     • Conducting eligibility determinations and redeterminations resulting from issues identified through RESEA
          participation.”

2 CFR §421 – Failure to Participate in Reemployment Services through Profiling states in part, “The Oklahoma
Employment Security Commission shall establish and utilize a system of profiling for all unemployment benefit
claimants that will identify claimants who will be likely to exhaust unemployment benefits and who will need job-
search assistance services to make a successful transition to new employment. Any claimant who has been referred to
reemployment services pursuant to the profiling system and who fails to participate in the reemployment services
made available to the claimant, shall be disqualified to receive benefits for each week in which the failure occurs;
unless the Commission determines that: 1. The claimant has completed the reemployment services; or 2. There is
justifiable cause for the claimant's failure to participate in reemployment services.”

The RESEA Instructions and Procedures, 7-17-17 revision, Summary of Documentation! states in part, “the RESEA
process will be documented by the following -
    Required services:
           1. Reemployment Services and Eligibility Assessment – RESEA (the placeholder service that stands for
              entire RESEA session)
           2. Reemployment Needs Inventory & Eligibility Review
           3. WOTC Pre-Screening
           4. Job Search Planning
           5. Information on Available Services
           6. Individual Reemployment Plan
           7. Career Guidance
           8. Customized Labor Market Information, and
           9. RESEA – Follow-up
    • Completing the Individual Reemployment Plan according to procedures.
    • Uploading 3 required forms to OKJM:
           1. Reemployment Needs Inventory & Eligibility Review, OES 802
           2. RESEA Follow-Up, OES 251
           3. Unemployment Eligibility Review Questionnaire, OES 173”

The RESEA Instructions and Procedures, 7-17-17 revision, Notifying UI and the Adjudication Process states in part,
“Adjudication Process. Once all notifications have been sent to the OKC Claims Adjudication Unit, the adjudication
process follows these general steps: Local office staff report the claimant as a NO SHOW by emailing the OES 842E
to PRF/JSW/POE@oesc.state.ok.us. A 2-421 code will be placed on the claim.”

2 CFR §200.1 “Internal controls” states in part, “Internal controls for non-Federal entities means:
         (2) Processes designed and implemented by non-Federal entities to provide reasonable assurance regarding
             the achievement of objectives in the following categories:
    (iv)     Effectiveness and efficiency of operations;
    (v)      Reliability of reporting for internal and external use; and
    (vi)     Compliance with applicable laws and regulations.”




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The Government Accountability Office (GAO) Standards for Internal Control in the Federal Government 14.03 states,
“Management communicates quality information down and across reporting lines to enable personnel to perform key
roles in achieving objectives, addressing risks, and supporting the internal control system. In these communications,
management assigns the internal control responsibilities for key roles.”

2 CFR §200.344 Retention requirements for records states in part, “Financial records, supporting documents, statistical
records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three
years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or
annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the
Federal awarding agency or pass-through entity in the case of a subrecipient….”

Condition and Context: The Reemployment Services and Eligibility Assessment (RESEA) provides reemployment
services to unemployment claimants who are unlikely to return to their previous industry or occupation and who are
considered likely to use up benefits. The Department of Labor’s Employment and Training Administration (ETA)
9128 report provides quarterly information on the RESEA activities of claimants selected to participate in the RESEA
program. The data on this report allows for evaluation and monitoring of the RESEA program.

We tested 60 Unemployment Insurance claimants that were profiled for the RESEA program during State Fiscal Year
(SFY) 2022 and noted the following exceptions:

    •    26 (43.3%) had no RESEA Notification Letters in DocuShare.
    •    30 (50.0%) of the required RESEA activities were not completed for at least one of three required follow-up
         forms in OKJobMatch.
    •    13 (21.7%) had industry codes that were not on the list of diminishing industries for the month the claimant
         was enrolled in RESEA.
    •    3 (5.0%) were not associated with an employer record or NAICS number in the OESC mainframe, which
         means there was no industry to use for profiling the claimant.
    •    2 (3.3%) were missing an OES 842E Adjudication Form in OKJobMatch when the claimant did not report
         for follow-up.

Cause: During SFY 2022, the Oklahoma Employment Security Commission did not have adequate controls, along
with timely and/or effective communication of RESEA procedures, including instruction on how to properly retain
documentation. Further, RESEA Quality Control reviews were suspended during SFY 2022 due to system
malfunctions.

Effect: RESEA program evaluation and monitoring may not have been based on correct information and the ETA
9128 performance report may be incomplete and unreliable. RESEA participants may not have received notice
regarding their required participation in the RESEA program and may have received benefits for a longer period than
necessary.

Recommendation: We recommend the Oklahoma Employment Security Commission work to strengthen controls to
include clear and concise RESEA procedures to ensure all documents are properly completed and retained.
Additionally, when the Quality Control program resumes, we recommend follow-up on all Quality Control findings
and training to ensure employees are aware of and understand proper procedures for completing appropriate forms
and retaining records to prevent future errors.

Views of Responsible Official(s)
Contact Person: Sharon Smith, RESEA Program Manager
Anticipated Completion Date: May 31, 2023
Corrective Action Planned: The Oklahoma Employment Security Commission agrees with the finding. See corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-084
STATE AGENCY: Oklahoma Employment Security Commission




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FEDERAL AGENCY: U.S. Department of Labor
ALN: 17.225
FEDERAL PROGRAM NAME: Unemployment Insurance (UI) Program
FEDERAL AWARD NUMBER: UI340792055A40-01-09, UI356692155A40-01-08, UI372442255A40-01-09
FEDERAL AWARD YEAR: 2021 and 2022
CONTROL CATEGORY: Special Tests and Provisions – Employer Experience Rating
QUESTIONED COSTS: $0

Criteria: Oklahoma Statute §40-3-301. Penalty and interest on past-due contributions states,
         “A. If contributions are not paid on the date on which they are due and payable as prescribed by the Oklahoma
         Employment Security Commission, the whole or part thereafter remaining unpaid shall bear interest at the
         rate of one percent (1%) per month for each month or fraction thereof from and after such date until payment
         is received by the Commission. The date on which payment of contributions is deemed to have been received
         may be determined by such rules as the Commission may prescribe.
         B. If any employer fails or refuses to file contribution and wage reports required under the provisions of this
         act within fifteen (15) days after written notice has been mailed to the employer by the Commission or its
         representative regardless whether or not any wages or taxable wages were paid, there shall accrue a penalty
         of One Hundred Dollars ($100.00) and in addition to such penalty, there shall be a penalty of ten percent
         (10%) added to the total contributions due, collected and paid. Such penalties shall be in addition to any
         interest due.”

Oklahoma Administrative Code 240:10-5-10. Payment of contributions, states in part, “(a) Date payment
due. Contributions shall become due and be paid on or before the last day of the month following the calendar
quarter to which they relate….”

2 CFR §200.1 “Internal controls”, states in part, “Internal controls for non-Federal entities means:
       (3) Processes designed and implemented by non-Federal entities to provide reasonable assurance regarding
           the achievement of objectives in the following categories:
           (vii)    Effectiveness and efficiency of operations;
           (viii)   Reliability of reporting for internal and external use; and
           (ix)     Compliance with applicable laws and regulations.”

The Government Accountability Office (GAO) Standards for Internal Control in the Federal Government Design of
the Entity’s Information System, states in part:
     “11.03 Management designs the entity’s information system to obtain and process information to meet each
             operational process’s information requirements and to respond to the entity’s objectives and risks. An
             information system is the people, processes, data, and technology that Federal Internal Control Standards
             management organizes to obtain, communicate, or dispose of information….
       11.04 Management designs the entity’s information system and the use of information technology by considering
             the defined information requirements for each of the entity’s operational processes…. Although
             information technology implies specific types of control activities, information technology is not a “stand-
             alone” control consideration. It is an integral part of most control activities.
      11.05 Management also evaluates information processing objectives to meet the defined information
             requirements. Information processing objectives may include the following:
              • Completeness - Transactions that occur are recorded and not understated.
              • Accuracy - Transactions are recorded at the correct amount in the right account (and on a timely
                  basis) at each stage of processing.
              • Validity - Recorded transactions represent economic events that actually occurred and were executed
                  according to prescribed procedures.”

Condition and Context: Roughly 20 days after the quarter ends, OESC sends delinquent employers a letter with a
second due date. If the employer does not remit payment by the second due date, the system is to automatically charge
penalties and interest to the employer’s account.




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We tested 60 employers who did not pay their UI taxes by the end of the associated quarter and noted 5 (8.3%)
employers who did not remit payment by the second due date and were not charged a penalty.

Cause: During the QE March 30, 2021, an error occurred in the delinquency cycle process where the penalty was
applied on accounts the day after the letters were mailed, instead of the second due date. The correction to this error
caused some delinquent employer accounts to not be charged penalties. Management could not provide an explanation
of how the system chose to apply penalties to some accounts and not to others.

Effect: Penalties totaling $719 were not charged to delinquent employer accounts when tax payments were not
received by the second due date.

Recommendation: We recommend OESC IT evaluate and identify the programming error relating to delinquent
employer penalties and make the adjustments necessary to ensure all penalties are properly applied to employer
accounts in the future.

Views of Responsible Official(s)
Contact Person: Mike Hemphill, Tax Manager
Anticipated Completion Date: Resolution expected in conjunction with modernization efforts, timing to be
determined.
Corrective Action Planned: The Oklahoma Employment Security Commission agrees with the finding. See corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-088
STATE AGENCY: Oklahoma Employment Security Commission (OESC) and Office of Management and
Enterprise Services (OMES)
FEDERAL AGENCY: U.S. Department of Labor
ALN: 17.225
FEDERAL PROGRAM NAME: Unemployment Insurance Program
FEDERAL AWARD NUMBER: N/A – No grant award number exists.
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Agency-Wide
QUESTIONED COSTS: $0

Criteria:
Constitution of the State of Oklahoma
Article 15 § 1 – Officers required to take oath or affirmation -Form, states,

All public officers, before entering upon the duties of their offices, shall take and subscribe to the following oath or
affirmation:

         "I, . . . . . . . , do solemnly swear (or affirm) that I will support, obey, and defend the Constitution of the United
         States, and the Constitution of the State of Oklahoma, and that I will not, knowingly, receive, directly or
         indirectly, any money or other valuable thing, for the performance or nonperformance of any act or duty
         pertaining to my office, other than the compensation allowed by law; I further swear (or affirm) that I will
         faithfully discharge my duties as . . . . . . . . to the best of my ability."

Article 10 § 11 – Revenue and Taxes – Officer receiving interest, profit or perquisites, states,

         “The receiving, directly or indirectly, by any officer of the State, or of any county, city, or town, or member
         or officer of the Legislature, of any interest, profit, or perquisites, arising from the use or loan of public funds
         in his hands, or moneys to be raised through his agency for State, city, town, district, or county purposes shall
         be deemed a felony. Said offense shall be punished as may be prescribed by law, a part of which punishment
         shall be disqualification to hold office.”

Conflict of Interest




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The Government Accountability Office (GAO) Standards for Internal Control in the Federal Government 8.03 states
“In addition to fraud, management considers other forms of misconduct that can occur, such as waste and abuse. Waste
is the act of using or expending resources carelessly, extravagantly, or to no purpose. Abuse involves behavior that is
deficient or improper when compared with behavior that a prudent person would consider reasonable and necessary
operational practice given the facts and circumstances. This includes the misuse of authority or position for personal
gain or for the benefit of another. Waste and abuse do not necessarily involve fraud or illegal acts.”

2 CFR §200.212 – Conflict of Interest states in part, “The non-Federal entity must disclose in writing any potential
conflict of interest to the Federal awarding agency or pass-through entity in accordance with applicable Federal
awarding agency policy.”

2 CFR §200.318 (c)(1) – General Procurement Standards states in part, “The non-Federal entity must maintain written
standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection,
award and administration of contracts. No employee, officer, or agent may participate in the selection, award, or
administration of a contract supported by a Federal award if he or she has a real or apparent conflict of interest. Such
a conflict of interest would arise when the employee, officer, or agent, any member of his or her immediate family,
his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a
financial or other interest in or a tangible personal benefit from a firm considered for a contract.”

Office of Management OMES GAAP Conversion Manual instructions for Package X. Miscellaneous Conversion
Package, the Key Terms define Related Party Transactions as “transactions conducted with other parties with which
an agency or key decision maker has a close association”. Further, question #28 asks, “Did your agency perform
business with any non-state entities that would meet the definition of related party transactions?”

State Rules
260:115-3-5. Procurement ethics - prohibited conduct states, “The Oklahoma Central Purchasing Act, State Ethics
Commission rules and other state laws contain regulations, prohibitions and penalties governing procurement
ethics. Transactions relating to the public expenditure of funds require the highest degree of public trust and
impeccable standards of conduct.”

OESC Procurement Procedures, January 2017 version, 1.0 states, “These procedures are issued pursuant to the
provisions of the Oklahoma Central Purchasing Act, 74 O.S., § 85.1 et seq. and with the Oklahoma Office of
Management and Enterprise Services (OMES) Central Purchasing Division Administrative Rules [Oklahoma
Administrative Code (OAC) 260:115]. These procedures shall become effective upon the date of approval by the
Director Office of Management and Enterprise Services. All agency purchases shall be made pursuant to the Oklahoma
Central Purchasing Act, Oklahoma OMES Central Purchasing Division Administrative Rules, State Use Committee,
State of Oklahoma Purchase Card Procedures, and these internal procurement procedures.”

62 O.S. § 34.62, Oklahoma State Finance Act, paragraph 3 states, “The Director of the Office of Management and
Enterprise Services shall have the power to authorize agencies of the state to make acquisitions without the submission
of competitive bids or compliance with the state purchase card program as otherwise required by the Oklahoma Central
Purchasing Act, for or on behalf of the state whenever the Director determines that it is in the best interests of the
state. The administrative head of any agency shall be personally liable for obligations incurred in excess of the
authorization granted by the Director.”

62 O.S. § 34.11.1, Oklahoma State Finance Act. Paragraph F. “The Information Services Division of the Office of
Management and Enterprise Services shall be responsible for the following duties: 16. For all state agencies, approve
the purchasing of all information technology and telecommunication services and approve the purchase of any
information technology and telecommunication product….”

Condition and Context: As part of the yearly audit, we perform procedures to assess risks that may be present in an
agency. One of the risks assessed is that of related party relationships, transactions, or balances. OESC has two formal
avenues to report related party relationships: a notarized internal Related Party affidavit form completed by employees
and the OMES GAAP Package X-1 Miscellaneous Summary.




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During our risk assessment for State Fiscal Year (SFY) 2022 audit, it came to our attention that the spouse of, OESC’s
Executive Director, was a Vice-President of a vendor (Phase 2) that first contracted with Office of Management and
Enterprise Services (OMES) to perform OESC mainframe work in April 2020, and was later contracted directly by
OESC in November 2020. The direct contracts with OESC were signed by the Executive Director. This relationship
was not disclosed by the Executive Director on the calendar year 2020 OESC Related Party affidavit, which
specifically, asks if the respondent, their spouse, or dependents were involved in any related party transactions with
OESC. The 2020 Related Party affidavit was signed by the Executive Director and notarized on April 8, 2021. We
were unable to obtain the 2021 calendar year Related Party affidavit. According to OESC Legal Counsel, agency
employees were no longer required to complete the form.

During our review of the 2021 and 2022 OMES GAAP Package X-1 Miscellaneous Summary, we noted that no related
party disclosures were identified.

It should also be noted that this vendor had no contracts with the State of Oklahoma prior to April of 2020.

After discovering the relationship and lack of disclosure, we reviewed the vendor contract timelines with both
agencies. Based on contract information reviewed, the initial contract was approved by Director of OMES and was
not competitively bid based on an explanation that the contract was exempt because of COVID-19. Further, none of
the remaining contracts appear to have been competitively bid based on the supporting documentation received.

The timeline of the State employee’s work history and contracts / PO’s with their spouse’s company is as follows:

 Feb-20      The State employee was hired as OMES Chief Innovation Officer.
             OMES contracts with Phase 2:
              4/3/2020       $857,485           PO 0909018942             Product Engagement Development / Project
                                                                          Management
              8/12/2020      $6,100,000        PO 0909019349              Time and materials

 May-20      The State employee was hired as OESC Executive Director.
             OESC contracts with Phase 2:
              11/1/2020         $40,000        PO 2909012664              Mulesoft Architecture
              1/15/2021        $750,000        PO 2909012762              Mulesoft Architecture
               2/1/2022      $6,455,000        PO 2909013045*             Mulesoft / Transformation Team
              3/18/2022       $600,000         PO 2909013045*             Fraud Mitigation
              4/1/2022       $675,740          PO 2909013138              Pega Architecture, Implementation Review,
                                                                          and Guidance

 Oct-22      The State employee left OESC and became the Executive Director of Tourism.

* Portion of PO paid with Unemployment Insurance federal funds.

Lastly, based on the supporting documentation received, we were unable to determine if OMES or OESC received the
deliverables per the stated contracts.

Cause: The OESC Executive Director neglected to report a related party relationship with a vendor for which her
spouse was employed.

Effect: Because the conflict of interest was not disclosed, the procurement process and subsequent contracts related
to the vendor raise substantial doubt as to the legitimacy of the services performed by the vendor. Further, because
the state did not require the new vendor to competitively bid their contracts, there is the potential that the vendor either
overcharged and/or underperformed for the services provided.




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And Questioned Costs

Recommendation: We recommend OESC and OMES ensure all related party transactions are properly reported on
Question #28 of OMES GAAP Package X. Further, we recommend both OMES and OESC work to strengthen the
procurement control process by ensuring initial contracts for new vendors be competitively bid until a determination
can be made as to whether the vendor’s services were a benefit to the State of Oklahoma. Lastly, we recommend that
OMES and OESC not contract with any vendor in the future they become aware of that could result in a conflict of
interest.

Views of Responsible OESC Official(s)
Contact Person: Michelle Britten, Chief Financial Officer
Anticipated Completion Date: July 31, 2024
Corrective Action Planned: The Oklahoma Employment Security Commission agrees with the finding. See corrective
action plan located in the corrective action plan section of this report.

Views of Responsible OMES Official(s)
Contact Person: Megan Meers
Anticipated Completion Date: July 1, 2024
Corrective Action Planned: The Office of Management and Enterprise Services agrees with the finding. See
corrective action plan located in the corrective action plan section of this report.



                             Oklahoma DEPARTMENT OF HEALTH

FINDING NO: 2022-201
STATE AGENCY: Oklahoma State Department of Health
FEDERAL AGENCY: United States Department of Health and Human Services
ALN: 93.268; 93.323
FEDERAL PROGRAM NAME: Immunizations Cooperative Agreements; Epidemiology and Laboratory Capacity
for Infectious Diseases
FEDERAL AWARD NUMBER: NU50CK000535-02-04, NU50CK000535-02-06, NU50CK000535-01-04,
NU50CK000535-01-05, 6 NH23IP922575-02-05, 6 NH23IP922575-02-06, 6 NH23IP922575-03-01, 5
NH23IP922575-03-00
FEDERAL AWARD YEAR: 2020, 2021, 2022
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles

Criteria: 7 CFR § 246.13 - Financial Management System, states in part, “(b) Internal control. The State agency shall
maintain effective control over and accountability for all Program grants and funds.”

The Government Accountability Office (GAO) Standards for Internal Control in the Federal Government 10.03 states,
in part, “Management designs appropriate types of control activities for the entity’s internal control system. Control
activities help management fulfill responsibilities and address identified risk responses in the internal control system.”
Additionally, GAO Standards for Internal Control in the Federal Government 10.03 states, in part, “Transactions are
promptly recorded to maintain their relevance and value to management in controlling operations and making
decisions. This applies to the entire process or life cycle of a transaction or event from its initiation and authorization
through its final classification in summary records. In addition, management designs control activities so that all
transactions are completely and accurately recorded.”

Condition and Context: The Oklahoma State Department of Health’s (the “Department”) internal controls over the
payroll transaction cycle lacked appropriate employee access profiles, allowing all timecodes available for use,
regardless of an employee’s specific job position and function. Thus, the initiation of timecard entry was incorrectly
reported, and supervisors’ approved employee timecards without thoroughly reviewing to detect and correct these
errors.




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Additionally, the Department neglected to perform its existing control activities of timely reviewing time and effort
against the payroll expenses recorded in the general ledger. During FY22, recorded payroll costs did not accurately
reflect the Department’s time and effort.

Cause and Effect: The Department’s conversion from PeopleSoft HR to Workday did not have adequate internal
controls in place to ensure accurate timecodes were selected by employees when completing their timecards. As a
result of converting payroll systems and a lack of employee training prior to going live with Workday, employees’
reported time did not accurately reflect their time and effort.

The impact of the variances was still being investigated at the completion of audit fieldwork. Inadequate internal
control policies and procedures over the payroll cycle could result in an increased risk of noncompliance with federal
requirements, and an inability to comply with audit requirements.

Recommendation: We recommend the Department lockdown employee profiles so that the available timecodes an
employee has access to relate to their specific job function and projects. Supervisors should thoroughly review
timecards prior to approval. Additionally, the Department should timely monitor time and effort against recorded
payroll to ensure grants are not over or under charged.

Views of Responsible Official(s)
Contact Person: Stefan Von Dollen
Anticipated Completion Date: 6/30/24
Corrective Action Planned: The Oklahoma State Department of Health agrees with the finding. Please see the
corrective action plan located in the corrective action plan section of this report.

FINDING NO: 2022-202
STATE AGENCY: Oklahoma State Department of Health
FEDERAL AGENCY: United States Department of Health and Human Services
ALN: 93.268; 93.323
FEDERAL PROGRAM NAME: Immunizations Cooperative Agreements; Epidemiology and Laboratory Capacity
for Infectious Diseases
FEDERAL AWARD NUMBER: NU50CK000535-02-04, NU50CK000535-02-06, NU50CK000535-01-04,
NU50CK000535-01-05, 6 NH23IP922575-02-05, 6 NH23IP922575-02-06, 6 NH23IP922575-03-01, 5
NH23IP922575-03-00
FEDERAL AWARD YEAR: 2020, 2021, 2022
CONTROL CATEGORY: Reporting

Criteria: The Schedule of Expenditures of Federal Awards (SEFA – GAAP Package Z) should be accurately captured,
reconciled, and reviewed by the Oklahoma State Department of Health (the “Department”). Adequate documentation
of procedures performed as well as evidence of thorough reviews should be in place. According to GAAP,
expenditures should be recognized in the period services are performed or goods are received.

Additionally, the Federal Financial Report (FFR), SF-425, is required on an annual basis except for awards where
more frequent reporting is noted in the Notice of Award. The report also must cover any authorized extension during
the reported budget period. Grant recipients submit FFRs to the U.S. Department of Health and Human Services
(HHS) Payment Management System (PMS). Annual FFRs are due 90 days after the end of the budget period and
final FFRs are due 90 days after the end of the period of performance.

Condition and Context: The original SEFA submitted by the Department to the Office of Management and Enterprise
Services (OMES) included the following errors:
    • Approximately $993,000 in expenditures were improperly excluded due to omitting the payroll fund transfer
         file of wages charged against a federal grant.
    • Approximately $4,381,000 of non-cash-based expenditures were improperly excluded as a result of utilizing
         incorrect vaccine consumption report dates, which were not in agreement with the State’s fiscal year.




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    •    Approximately $4,032,000 was improperly advanced to the Department by federal agencies due to utilizing
         incorrect data tables in queries that looked to invoice totals rather than recorded voucher expenditures. Also
         see finding 2022-205.
    •    15 out of 276, or 5.4%, of tested federal expenditure selections were recorded in an incorrect accounting
         period, which totaled approximately $3,360,000.

As of the completion of audit fieldwork, the Department was still working to revise the June 30, 2022, year-end FFR’s
due to the above errors, as well as the payroll errors noted in finding 2022-201.

Cause and Effect: The Department does not have appropriate internal procedures for capturing and reporting the
federal expenditures on the SEFA and FFR’s and has not ensured that staff responsible for preparation and review of
the SEFA and FFR’s have the adequate knowledge and training required. The Department does not have internal
procedures that include adequate processes to review after-the-fact interim charges made to a federal award based on
allocated costs and to ensure all necessary adjustments are made such that the final amount charged to Federal awards
is accurate, allowable, and properly allocated.

As a result, multiple revisions of the SEFA were submitted to OMES and FFR’s relating to FY22 were still being
revised at the completion of fieldwork. Furthermore, all FFR’s tested were not timely filed within 90 days subsequent
to year end, as required per the grantor agency, see finding 2022-205.

Recommendation: We recommend the Department review and document the current procedures and implement the
necessary changes to ensure adequate reporting of program financial information on the SEFA and FFR’s.
Additionally, we recommend retaining evidence that adequate reviews of the SEFA and FFR’s occurred. We also
recommend the Department establish procedures to timely reconcile federal revenues to its federal expenditures.

Views of Responsible Official(s)
Contact Person: Stefan Von Dollen
Anticipated Completion Date: 6/30/24
Corrective Action Planned: The Oklahoma State Department of Health agrees with the finding. Please see the
corrective action plan located in the corrective action plan section of this report.

FINDING NO: 2022-203
STATE AGENCY: Oklahoma State Department of Health
FEDERAL AGENCY: United States Department of Health and Human Services
ALN: 93.268; 93.323
FEDERAL PROGRAM NAME: Immunizations Cooperative Agreements; Epidemiology and Laboratory Capacity
for Infectious Diseases
FEDERAL AWARD NUMBER: NU50CK000535-02-04, NU50CK000535-02-06, NU50CK000535-01-04,
NU50CK000535-01-05, 6 NH23IP922575-02-05, 6 NH23IP922575-02-06, 6 NH23IP922575-03-01, 5
NH23IP922575-03-00
FEDERAL AWARD YEAR: 2020, 2021, 2022
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles

Criteria: AU-C section 260.20 states, “The auditor should evaluate whether the two-way communication between the
auditor and those charged with governance has been adequate for the purpose of the audit. If it has not, the auditor
should evaluate the effect, if any, on the auditor's assessment of the risks of material misstatement and ability to obtain
sufficient appropriate audit evidence and should take appropriate action.” Standards for Internal Control in the Federal
Government, Principle 4 – Demonstrate Commitment to Competence, Attribute 4.02 states, “Management establishes
expectations of competence for key roles, and other roles at management’s discretion, to help the entity achieve its
objectives. Competence is the qualification to carry out assigned responsibilities. It requires relevant knowledge, skills,
and abilities, which are gained largely from professional experience, training, and certifications. It is demonstrated by
the behavior of individuals as they carry out their responsibilities.”

Condition and Context: The Oklahoma State Department of Health (the “Department”) did not communicate or
provide audit documentation to the auditor in a timely manner. In many cases, numerous follow-up requests had to be




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And Questioned Costs
made for the same documentation was never provided. Months-long delays in receiving documentation needed to
perform substantive testwork resulted in the auditor providing a final cutoff date for obtaining support, with
unprovided items, along with follow up attempts, detailed in the below schedule:



  Initial Request            Description                 Follow Up Requested                                         Received/Partially Received

4/11/2023           General ledger details which   4/21/2023; 5/2/2023; 5/5/2023;         Partial support received 5/8/2023; 5/12/2023; 5/23/2023; 6/3/2023 resulted in a
                    reconcile revenue and          5/12/2023; 5/16/2023; 5/17/2023;       second revised Schedule Z received; 6/13/2023 resulted in a third revised
                                                                                          Schedule Z received;
                    expenditures to the SEFA       5/23/2023; 5/31/2023; 6/5/2023;
                                                   6/6/2023
                                                                                          Received final versions of supporting details to agree to expenditures to SEFA
                                                                                          values were received on 6/26/2023, 76 days after initial request.
5/12/2023           Current and prior year         5/23/2023; 6/5/2023; 6/6/2023;         6/26/2023
                    accrual details                6/8/2023; 6/13/2023


5/17/2023           ELC expenditure selections     5/31/2023; 6/5/2023; 6/6/2023;         Partial support received on: 6/13/2023; 6/22/2023; 7/18/2023; 7/19/2023; 8/2/2023;
                    for allowable cost testing     6/8/2023; 7/21/2023; 7/24/2023;        8/21/2023; 8/29/2023; 9/6/2023; 9/19/2023; 9/20/2023
                                                   7/26;2023; 7/31/2023; 8/1/2023;
                                                   8/2/2023; 8/10/2023; 8/15/2023;        Provided the Department with a final cutoff date, 9/21/2023 and received
                                                                                          additional
                                                   8/18/2023; 8/25/2023; 8/29/2023;       partial support on 9/21/2023, 127 days after the initial request, of which at least
                                                                                          one
                                                   9/19/2023; 9/20/2023; 9/21/2023        requested item was not provided for 20 of the 138 selections made, or 15%.
6/5/2023            Immunization allowable cost    6/8/2023; 6/13/2023; 6/27/2023;        Partial support received on: 6/8/2023; 6/12/2023; 6/19/2023; 6/20/2023; 7/6/2023;
                    selections                     7/5/2023; 7/11/2023; 7/21/2023;        7/26/2023; 8/1/2023; 8/14/2023; 9/1/2023; 9/5/2023; 9/9/2023
                                                   7/24/2023; 7/26/2023; 7/31/2023;
                                                   8/1/2023; 8/2/2023; 8/10/2023;         Provided the Department with a final cutoff date, 9/21/2023 and received
                                                                                          additional
                                                   8/15/2023; 8/18/2023 8/25/2023;        partial support on 9/21/2023, 108 days after the initial request, of which at least
                                                                                          one
                                                   8/29/2023 9/19/2023; 9/20/2023;        requested item not provided for 32 of the 138 selections made, or 23%.
                                                   9/21/2023
5/23/2023           Prior Years's schedule Z's     5/31/2023; 6/5/2023; 7/27/2023;        Was never provided by the Department, and was obtained via request directly to
                    [2018, 2019, 2020, 2021]       8/1/2023                               SA&I on 8/2/2023
6/28/2023           Site visit quality assurance   6/28/2023; 7/13/2023; 7/24/2023;       Partially received on: 7/14/2023, 8/7/2023; and 9/20/2023
                    support for VFC and new        8/4/2023; 8/21/2023
                    enrollee support                                                      Provided the Department with a final cutoff date, 9/21/2023 and received
                                                                                          additional partial support regarding quality site visits on 9/20/2023, 84 days
                                                                                          after the initial request, of which at least one requested item not provided for 11
                                                                                          of the 69 selections made, or 16%.

                                                                                          Of the new enrollee support provided, 8 of 70 tested selections were missing at
                                                                                          least one requested item, or 11%.




Cause and Effect: The Department does not have adequate procedures and controls in place to ensure accurate,
reliable, and timely responses to communication and documentation requests by the auditor. Failure to communicate
and provide audit documentations to the auditor in a timely manner resulted in substantial delays in the completion of
the audit.

Recommendation: We recommend that the Department develop adequate procedures and controls to ensure accurate,
reliable, and timely responses to communication and documentation requested by the auditor.

Views of Responsible Official(s)
Contact Person: Stefan Von Dollen
Anticipated Completion Date: 6/30/24
Corrective Action Planned: The Oklahoma State Department of Health agrees with the finding. Please see the
corrective action plan located in the corrective action plan section of this report.

FINDING NO: 2022-204




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STATE AGENCY: Oklahoma State Department of Health
FEDERAL AGENCY: United States Department of Health and Human Services
ALN: 93.268
FEDERAL PROGRAM NAME: Immunizations Cooperative Agreements
FEDERAL AWARD NUMBER: NU50CK000535-02-04, NU50CK000535-01-04, NU50CK000535-01-05
FEDERAL AWARD YEAR: 2020, 2021
CONTROL CATEGORY: Special Tests and Provisions - Control, Accountability, and Safeguarding of Vaccine

Criteria: Document storage and retention was not adequately maintained by the Immunization Program’s field staff
related to assistance listing 93.268.

Condition and Context: Management was unable to provide the below requests for audit testwork, as the items were
not retained by the Department:
     • Authorized site agreement (ASA): 1 of 10, or 10%, of new enrollee’s ASA’s.
     • Enrollment visit form: 2 of 10, or 20% of new enrollee’s completed enrollment visit forms
     • Orientation Packet: 2 of 10, or 20% of new enrollee’s completed orientation packets
     • Certificate of completion: 2 of 10, or 20% of new enrollee’s training certificates
     • Sampled provider patient screening: 5 of 69, or 7%, of quality assurance visits could not provide evidence
          the field staff sampled a providers patient screening for eligibility of vaccination.
     • Inspected provider inventory storage: 5 of 69, or 7%, of quality assurance visits could not provide evidence
          the field staff sampled a inspected the inventory storage and safeguards over vaccine compliance.
     • Signed acknowledgement form: 11 of 69, or 16%, of quality assurance visit could not provide evidence the
          completed acknowledgement form was signed by the respective medical providers.

Cause and Effect: The Department does not have adequate internal controls in place for centrally storing and retaining
documentation as it relates to enrollment and quality assurance visits of providers for the Vaccines for Children (VFC)
Immunizations program. As a result, there is an increased risk of non-compliance with federal requirements, and an
inability to comply with audit requirements.

Recommendation: We recommend the Department evaluate the documentation preparation and retention process and
make the appropriate adjustments to ensure that future documents are properly prepared and retained.

Views of Responsible Official(s)
Contact Person: Stefan Von Dollen
Anticipated Completion Date: 6/30/24
Corrective Action Planned: The Oklahoma State Department of Health agrees with the finding. Please see the
corrective action plan located in the corrective action plan section of this report.

FINDING NO: 2022-205
STATE AGENCY: Oklahoma State Department of Health
FEDERAL AGENCY: United States Department of Health and Human Services
ALN: 93.268; 93.323
FEDERAL PROGRAM NAME: Immunizations Cooperative Agreements; Epidemiology and Laboratory Capacity
for Infectious Diseases
FEDERAL AWARD NUMBER: NU50CK000535-02-04, NU50CK000535-02-06, NU50CK000535-01-04,
NU50CK000535-01-05, 6 NH23IP922575-02-05, 6 NH23IP922575-02-06, 6 NH23IP922575-03-01, 5
NH23IP922575-03-00
FEDERAL AWARD YEAR: 2020, 2021, 2022
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles, Cash Management,
Reporting
QUESTIONED COSTS: 93.268 – $4,032,000
                        93.323 – Unknown

Criteria: See finding 2022-201 and 2022-202




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Schedule of Findings
And Questioned Costs

Condition and Context: See finding 2022-201.

Additionally, as indicated in finding 2022-202, approximately $4,032,000 was identified as improperly advanced to
the Department due to utilizing incorrect data tables in queries that looked to invoice totals rather than posted voucher
expenditures claimed against assistance listing 93.268.

Furthermore, all FFR’s tested for assistance listing 93.268 were not timely filed within 90 days subsequent to year
end, as required per the Center for Disease Control and Prevention (CDC).

Cause and Effect: See finding 2022-201 and 2022-202.

As a result, Federal program funds were advanced to the Department and expenditures claimed for reimbursement
were overstated.

In many cases sufficient time and effort existed to meet or exceed a federal program’s claimed payroll. Since the
Department will only claim reimbursements up to a specific grant award’s budgeted amount, payroll costs did not
appear to overcharge the federal programs in total. However, timely monitoring did not occur, as indicated in finding
2022-201, and the Department was unaware individual grants time and effort had not been reconciled to payroll costs
recorded in the general ledger.

The impact of the variances was still being investigated at the completion of audit fieldwork, and the amounts in
question are unknown. Expenditures overcharged are required to be reimbursed to the Federal Agency. Additionally,
due to a lack of internal controls as indicated in findings 2022-201 and 2022-202, timely submissions of FRR’s did
not occur, and CDC’s required reporting deadline of 90 days subsequent to year end were missed.

Recommendation: See finding 2022-201 and 2022-202.

Additionally, we recommend retaining evidence that adequate reviews of the Payment Management Services (PMS)
claimed costs occurred. We recommend the Department perform reconciliations of 100% of the FY22 time and effort
to the amounts included in the FY22 SEFA and related FFR’s for assistance listings 93.268 and 93.323 and return any
identified overcharges to the respective Federal Agency.

Views of Responsible Official(s)
Contact Person: Stefan Von Dollen
Anticipated Completion Date: 6/30/24
Corrective Action Planned: The Oklahoma State Department of Health agrees with the finding. Please see the
corrective action plan located in the corrective action plan section of this report.

FINDING NO: 2022-206
STATE AGENCY: Oklahoma State Department of Health
FEDERAL AGENCY: United States Department of Health and Human Services
ALN: 93.268; 93.323
FEDERAL PROGRAM NAME: Immunizations Cooperative Agreements; Epidemiology and Laboratory Capacity
for Infectious Diseases
FEDERAL AWARD NUMBER: NU50CK000535-02-06, 6 NH23IP922575-02-06, 6 NH23IP922575-02-05, 6
NH23IP922575-03-01
FEDERAL AWARD YEAR: 2021, 2022
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles
QUESTIONED COSTS: 93.268 – $1,540
                        93.323 – $8,109

Criteria: 7 CFR § 246.3 Administration. Delegation to the State agency states in part, “The State agency is responsible
for the effective and efficient administration of the Program in accordance with the requirements of this part; the




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And Questioned Costs
Department's regulations governing nondiscrimination (7 CFR parts 15, 15a, and 15b); governing administration of
grants (2 CFR part 200, subparts A through F…).”

2 CFR §200.403 (a) Factors affecting allowability of costs states, “Except where otherwise authorized by statute, costs
must meet the following general criteria in order to be allowable under Federal awards: Be necessary and reasonable
for the performance of the Federal award and be allocable thereto under these principles.”

Condition and Context: The Oklahoma State Department of Health (the “Department”) entered into a contract with
a vendor, which included the following clause in its statement of work for the Department: “… development and
implementation of a communications strategy around OSDH legislative priorities leading up to and during the 2022
session.” In accordance with applicable law, direct lobbying communications by award recipients are prohibited.
Direct lobbying includes any attempt to influence legislative or other similar deliberations at all levels of government
through communications that directly express a view on proposed or pending legislation and other orders and which
are directed to members, staff, or other employees of a legislative body or to government officials or employees who
participate in the formulation of legislation or other orders. The amount indicated in the statement of work provided
for payment of up to $100,000 in lobbying activity.

Additionally, an expenditure charged against Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
assistance listing 93.323, for a vaccine freezers, as well as transport and storage containers, should have been charged
to another program. The amount in question totaled $7,180.

Cause and Effect: As a result of the unallowable activities being included in the statement of work, the Department
charged lobbying costs against federal funds. Through inspection of the invoices provided by the Department relating
to this vendor, the below schedule indicates the identified expenditures which were associated to legislative priorities
and lobbying activities:

Immunizations Cooperative assistance listing 93.268:

Invoice Date Voucher Amount             Project      Op Unit    Program Code Charfield 2
   10/7/2021    450487       $4,933 340ST248WUXDU    DU0        A0200             WUX        Not subject to program audit
   12/7/2021    456458         $332 340ST210HEXSR0   SRO        A0100             HEX        Not subject to program audit
    2/8/2022    456649       $1,030 340ST210HEXSR0   SRO        A0100             HEX        Not subject to program audit
   1/14/2022    458962        $307 340GR400CD12F0    2F0        A0100             CD1        Immunizations
    3/7/2022    458964        $929 340GR400CD1P40    P40        A0100             CD1        Immunizations
    5/7/2022    459812         $54 340GR400CD1P40    P40        A0100             CD1        Immunizations
    5/5/2022    467183        $250 340GR400CD1P40    P40        A0100             CD1        Immunizations


$1,540 were identified as lobbying costs charged against assistance listing number 93.268, (CD1). The Department’s
support for the below invoices charged against the grant did not contain an itemized detail of specific services provided
by the vendor, thus we are unable to determine how much, if any, of these charges related to possible lobbying activity.


 Amount          Invoice #        Voucher #
 $ 24,891        19137            451543
 $ 34,123        19138            450075



Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) assistance listing 93.323:

 Invoice Date   Voucher       Amount     Project           Op Unit      Program Code    Charfield 2
 3/7/2022       458965        $ 929      340GR400BQ1OC     OC0          A0104           BQ1             ELC




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The above $929 invoice was charged for legislative strategies against assistance listing number 93.323 (BQ1). The
Department’s support for the below invoices did not include an itemized detail of specific services provided, thus we
are unable to determine how much, if any, of these charges related to possible lobbying activity.




As a result of an improper input of the ChartField 2 for voucher 455059, the expenditure was claimed against assistance
listing 93.268, whereas, it should not have been reimbursed by the ELC program. A reconciliation of project code and
operating unit to ChartField 2 did not occur prior to drawing down funds via the Payment Management System (PMS).
An overcharging of the ELC program occurred and a correction request was made by management upon completion
of audit testwork.

Recommendation: We recommend a more thorough review of the statements of work occurs to prevent unallowable
activities when authorizing a purchase order funded by federal sources. Program Director’s should thoroughly review
invoices for approval of payment based on the specific funding source the payment should be derived from, as
indicated by specific line items of purchase order.

Additionally, we recommend a more thorough reconciliation of expenditures, and a second level review occurs for
each federal program before drawing down funds through the PMS.

We recommend the Department repays the respective Federal Agency for the unallowable costs identified above.

Views of Responsible Official(s)
Contact Person: Stefan Von Dollen
Anticipated Completion Date: 6/30/24
Corrective Action Planned: The Oklahoma State Department of Health agrees with the finding. Please see the
corrective action plan located in the corrective action plan section of this report.



                            Oklahoma Health Care Authority
FINDING NO: 2022-002 (Repeat Finding 2021-010)
STATE AGENCY: Oklahoma Health Care Authority
FEDERAL AGENCY: United States Department of Health and Human Services
CFDA NO: 93.778
FEDERAL PROGRAM NAME: Medicaid Cluster
FEDERAL AWARD NUMBER: 2105OK5MAP and 2205OK5MAP
FEDERAL AWARD YEAR: 2021 and 2022
CONTROL CATEGORY: Activities Allowed or Unallowed and Allowable Costs/Cost Principles; Matching
QUESTIONED COSTS: $157

Criteria: 45 CFR § 75.403 Factors affecting allowability of costs states in part, “Costs must…(a) Be necessary and
reasonable for the performance of the Federal award and be allocable thereto under these principles, and (b) Conform
to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items,
and (g) Be adequately documented.”




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And Questioned Costs
Condition and Context: Medical payments are direct medical costs that are initiated by the provider based on services
rendered through the Medicaid Management Information System (MMIS). Based on a medical professional’s review
of 114 medical claims initiated by the provider for Medical Assistance Program (MAP) recipients, we noted the
following:

    •    One claim had a payment error totaling $197, of which $157 ($197 x the applicable Federal Medical
         Assistance Percentage (FMAP) rate (79.51% for QE 12/31/21)) is the federal questioned costs. The claim
         was billed using an incorrect place of service (POS), resulting in an overpayment. This claim will result in
         questioned costs.
    •    Additionally, two claims had documentation errors. One claim was missing a progress note for one of the
         dates of service billed, and the other claim was for a tooth extraction that billed the wrong tooth. Neither
         claim resulted in an underpayment or overpayment. The cost of these items will not be questioned.

Cause: Providers submitted claims through the MMIS that did not meet MAP program requirements. In addition,
since all provider claims are not scanned in the system, the only way these exceptions are detected are through audits
or reviews.

Effect: The Oklahoma Health Care Authority (OHCA) may be paying for services that were not properly supported
by medical records.

Recommendation: We recommend OHCA investigate the MAP medical exceptions noted and make any processing
changes possible to ensure MAP claims are meeting program requirements.

Views of Responsible Official(s)
Contact Person: Kristine West, Senior Director of Program Integrity and Accountability
Anticipated Completion Date: February 2024
Corrective Action Planned: The Oklahoma Health Care Authority agrees with the finding. See corrective action plan
located in the corrective action plan section of this report.

FINDING NO: 2022-004 (Repeat 2021-009)
STATE AGENCY: Oklahoma Health Care Authority
FEDERAL AGENCY: United States Department of Health and Human Services
CFDA NO: 93.767
FEDERAL PROGRAM NAME: Children’s Health Insurance Program
FEDERAL AWARD NUMBER: 2105OK5021 and 2205OK5021
FEDERAL AWARD YEAR: 2021 and 2022
CONTROL CATEGORY: Activities Allowed or Unallowed and Allowable Costs/Cost Principles; Matching
QUESTIONED COSTS: $10

Criteria: 45 CFR § 75.403 Factors affecting allowability of costs states in part, “Costs must…(a) Be necessary and
reasonable for the performance of the Federal award and be allocable thereto under these principles, and (b) Conform
to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items,
and (g) Be adequately documented.”

Condition and Context: Medical payments are direct medical costs that are initiated by the provider based on services
rendered through the Medicaid Management Information System (MMIS). Based on a medical professional’s review
of 112 medical claims initiated by the provider for Children’s Health Insurance Program (CHIP) recipients, we noted
the following:

    •    One claim had a payment error totaling $12, of which $10 ($12 x the applicable Federal Medical Assistance
         Percentage (FMAP) rate (82.16% for QE 3/31/22)) is the federal questioned costs. The claim was billed using
         an improper procedure code, resulting in an overpayment.




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Schedule of Findings
And Questioned Costs
Cause: Providers submitted claims through the MMIS that did not meet CHIP program requirements. In addition,
since all provider claims are not scanned in the system, the only way these exceptions are detected are through audits
or reviews.

Effect: The Oklahoma Health Care Authority (OHCA) may be paying for services that were not properly supported
by medical records.

Recommendation: We recommend OHCA investigate the CHIP medical exceptions noted and make any processing
changes possible to ensure CHIP claims are meeting program requirements.

Views of Responsible Official(s)
Contact Person: Kristine West, Senior Director of Program Integrity and Accountability
Anticipated Completion Date: February 2024
Corrective Action Planned: The Oklahoma Health Care Authority agrees with the finding. See corrective action plan
located in the corrective action plan section of this report.

FINDING NO: 2022-006
STATE AGENCY: Oklahoma Health Care Authority
FEDERAL AGENCY: United States Department of Health and Human Services
ALN: 93.778
FEDERAL PROGRAM NAME: Medicaid Cluster (MAP)
FEDERAL AWARD NUMBER: 2105OK5MAP and 2205OK5MAP
FEDERAL AWARD YEAR: 2021 and 2022
CONTROL CATEGORY: Utilization and Program Integrity

Criteria: 45 CFR §75.303 states, “The non-Federal entity must:(a) Establish and maintain effective internal control
over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award
in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued
by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO).”

Condition and Context: Of the 88 Service Quality Reviews performed totaling $105,130.02 in recoupment requests
during SFY 2022, we sampled 15 totaling $62,703.10 and noted the following:

    •    For 8 (53%) Service Quality Reviews, the Inspection of Care (IOC) Internal Audit Form from Provider
         Services were not completed
    •    For 5 (33%) Service Quality Reviews, the number of days from when the notice of audit completion was sent
         to Provider Services to when the accounts receivable was set up was not timely.
               One accounts receivable was not set up until 251 days after the date of audit completion was sent to
                  provider services. The recoupment requested totaled $2,950.00.
               Two accounts receivables were not set up until 272 days after the date of audit completion was sent
                  to provider services. The recoupments requested totaled $9,037.64.
               One accounts receivable was not set up until 273 days after the date of audit completion was sent to
                  provider services. The recoupment requested totaled $7,043.29.
               One accounts receivable was not set up until 504 days after the date of audit completion was sent to
                  provider services. The recoupment requested totaled $150.00.

Cause: The duties performed by Personnel Services were not adequately communicated to those who took over the
role of ensuring Service Quality Reviews were being reviewed properly.

Effect: The Inspection of Care (IOC) Internal Audit Form from Provider Services were not consistently being
completed. Finance was not being notified in a timely manner to set up accounts receivables. Untimely setting up
accounts receivable may increase the risk of not being able to recoup funds.




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Recommendation: We recommend OHCA design and implement appropriate controls to review Service Quality
Reviews and ensure finance is being notified of any recoupment accounts receivables in a timely manner.

Views of Responsible Official(s)
Contact Person: Tanesha Hooks, Director of Behavioral Health
Anticipated Completion Date: January 2023
Corrective Action Planned: The Oklahoma Health Care Authority agrees with the finding. See corrective action plan
located in the corrective action plan section of this report.

FINDING NO: 2022-020
STATE AGENCY: Oklahoma Health Care Authority (OHCA)
FEDERAL AGENCY: United States Department of Health and Human Services
ALN: 93.767; 93.778
FEDERAL PROGRAM NAME: Children’s Health Insurance Program; Medicaid Cluster
FEDERAL AWARD NUMBER: 2105OK5021 and 2205OK5021; 2105OK5MAP and 2205OK5MAP
FEDERAL AWARD YEAR: 2021 & 2022
CONTROL CATEGORY: Reporting

Criteria: The Government Accountability Office (GAO) Standards for Internal Control in the Federal Government
10.03 states, in part, “Transactions are promptly recorded to maintain their relevance and value to management in
controlling operations and making decisions. This applies to the entire process or life cycle of a transaction or event
from its initiation and authorization through its final classification in summary records. In addition, management
designs control activities so that all transactions are completely and accurately recorded.”

A basic objective of Generally Accepted Accounting Principles is to provide accurate and reliable information.

A component objective of an effective internal control system is to ensure accurate and reliable information through
a proper review and approval process.

Condition and Context:
   1. Based upon testwork performed on GAAP Package Q - Medicaid Payable and Receivable, we noted
        Medicaid Accounts Payable was recorded at $866,894,715 and Medicaid Federal Receivable was recorded
        at $584,001,412. However, based on errors in the calculations for both accounts, the Medicaid Accounts
        Payable amount should have been $781,270,299 and the Medicaid Federal Receivable amount should have
        been $514,300,444.
   2. We performed procedures to reconcile the total Federal draws made during SFY 2022 according to the
        Payment Management System (PMS) against the total of Federal Grants Revenue reported on CTB per
        Statewide Accounting System. We noted a variance of $7,718,144.65. This amount represents a payment
        made by OHCA using enhanced federal funding received for Home and Community Based Services (HCBS)
        programs.

Cause:
   1. We noted that amounts were incorrectly transferred from the “Service Date Reimbursement Analysis” Report
       (MAR-2300-M reports) to the “Encumbered Funds by Date of Service” excel spreadsheet. The variances
       occurred when amounts were manually entered incorrectly onto the Encumbered Funds by Date of Service
       spreadsheet. In addition, it does not appear the Encumbered Funds by Date of Service spreadsheet amounts
       were being reviewed to ensure they were being recorded correctly.
   2. OHCA misinterpreted the intended use of these federal funds and improperly classified them as state funds.

Effect:
    1. The errors on the Encumbered Funds by Date of Service spreadsheet resulted in Medicaid Accounts Payable
        being overstated by $85,624,416 and Medicaid Federal Receivable being overstated by $69,700,968 for
        GAAP Package Q.




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         In addition, the overstatements carried through to GAAP Package Z for ALN # 93.778 Medical Assistance
         Program & ALN # 93.767 Children’s Health Insurance Program Current Year Federal Accounts Payable and
         Accounts Receivable.
    2.   The classification error resulted in a $7,718,144.65 understatement of Federal Revenue in the Statewide
         Accounting System. In addition, the understatements carried through to GAAP Package Z for ALN # 93.778
         Medical Assistance Program & ALN # 93.767 Children’s Health Insurance Program Federal Revenue and
         Federal Expenditures.

Recommendation:
   1. We recommend OHCA continue to work to strengthen their review and reconciliation controls related to the
      accuracy of data reported for Medicaid Accounts Payable and Medicaid Federal Receivable.
   2. We recommend the Authority ensures that federal funds are properly classified in order to report total federal
      funds correctly in all systems.

Views of Responsible Official(s)
Contact Person: Susan Crooke, Director of Financial Services
Anticipated Completion Date: November 2023
Corrective Action Planned: The Oklahoma Health Care Authority agrees with the finding. See corrective action plan
located in the corrective action plan section of this report.

FINDING NO: 2022-025 (Repeat Finding 2021-069)
STATE AGENCY: Oklahoma Health Care Authority (the Authority)
FEDERAL AGENCY: United States Department of Health and Human Services
CFDA NO: 93.767; 93.778
FEDERAL PROGRAM NAME: Children’s Health Insurance Program; Medicaid Cluster
FEDERAL AWARD NUMBER: 2105OK5021 and 2205OK5021; 2105OK5MAP and 2205OK5MAP
FEDERAL AWARD YEAR: 2021 and 2022
CONTROL CATEGORY: Activities Allowed or Unallowed and Allowable Costs/Cost Principles; Eligibility
QUESTIONED COSTS: $0

Criteria: 45 CFR §75.303 states, “The non-Federal entity must:(a) Establish and maintain effective internal control
over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award
in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued
by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO).”

42 CFR §435.900 through .965 (Subpart J) describes the federal regulations applicable to Medicaid eligibility. The
specific federal regulations applicable to this finding are listed below.
    • 42 CFR §435.916 (a)(2)
    • 42 CFR §435.916 (c)
    • 42 CFR §435.916 (d)(1) and (2)
    • 42 CFR §435.916 (e)
    • 42 CFR §435.945 (b)
    • 42 CFR §435.948 (a) and (b) (c)
    • 42 CFR §435.952 (a) and (c)(2)

Oklahoma Administrative Code (OAC) 317:35 contains the State’s administrative code applicable to Medicaid
eligibility. The specific OAC sections applicable to this finding are listed below.
     • OAC 317:35-6-60.1 (c)
     • OAC 317:35-10-26

Additionally, a component objective of generally accepted accounting principles is to provide accurate and reliable
information.




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Condition and Context: MAGI-based Medicaid and CHIP eligibility are determined using the same methodology.

We tested a non-statistical sample of 73 Medicaid MAGI based recipients for Medicaid eligibility requirements using
the documentation in the Authority’s eligibility case records. The universe included 1,045,646 Medicaid MAGI-based
recipients with 17,283,558 medical claims and 12,189,952 capitation payments totaling $3,503,548,974.37. We
sampled one medical claim or capitation payment tied to a specific date of service per recipient tested. Tested medical
claims and capitation payments for sampled recipients totaled $9,649.61.

    •    For 1 (1.37%) of 73 cases tested, the member was present on multiple PARIS reports, indicating potential
         non residency. In addition, no further evidence was obtained for verifying residency.

    •    For 2 (2.74%) of 73 cases tested, OHCA failed to perform post enrollment verification of income. The
         applicant and/or their spouse lacked a SSN or other personal identifier to compare self-reported income to a
         data exchange. In addition, no further evidence was obtained for verifying the income.

    •    For 2 (2.74%) of 73 cases tested, OHCA failed to perform post enrollment verification of income. The
         applicant and/or their spouse self-attested income that did not match with any data exchange. In addition, no
         further evidence was obtained for verifying the income.

We tested a non-statistical sample of 73 Medicaid Non MAGI based recipients for Medicaid eligibility requirements
using the documentation in the Authority’s eligibility case records. The universe included 230,232 Medicaid Non
MAGI-based recipients with 11,431,015 medical claims and 2,955,398 capitation payments totaling
$2,887,468,243.90. We sampled one medical claim or capitation payment tied to a specific date of service per recipient
tested. Tested medical claims and capitation payments for sampled recipients totaled $10,217.74.

     •    For 5 (6.85%) of 73 cases tested, DHS did not perform the required 5 year lookback for bank statement
          transfers.
     •    For 41 (56.16%) of 73 cases tested, DHS failed to notify the member of their most recent eligibility
          determination.

We tested a non-statistical sample of 73 CHIP MAGI based recipients for Medicaid eligibility requirements using the
documentation in the Authority’s eligibility case records. The universe included 247,999 Medicaid MAGI-based
recipients with 2,153,637 medical claims and 2,049,196 capitation payments totaling $380,100,000.97. We sampled
one medical claim or capitation payment tied to a specific date of service per recipient tested. Tested medical claims
and capitation payments for sampled recipients totaled $12,974.16.

    •    For 1 (1.37%) of 73 cases tested, the wage data exchange received was not compared against the household
         income each time quarterly wage data was received to determine if the recipient remained eligible throughout
         the year.

    •    For 3 (4.11%) of 73 cases tested, OHCA failed to perform post enrollment verification of income. The
         applicant and/or their spouse lacked a SSN or other personal identifier to compare self-reported income to a
         data exchange. In addition, no further evidence was obtained for verifying the income.

    •    For 1 (1.37%) of 73 cases tested, OHCA failed to perform post enrollment verification of income. The
         applicant and/or their spouse self-attested income that did not match with any data exchange. In addition, no
         further evidence was obtained for verifying the income.

    •    For 8 (10.96%) of 73 cases tested, OHCA failed to perform post enrollment verification of income. The
         applicant and/or their spouse reported self-employment income that could not match with any data exchange.
         In addition, no further evidence was obtained for verifying the income.




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We tested a non-statistical sample of 40 CHIP Non-MAGI (TEFRA) based recipients for Medicaid eligibility
requirements using the documentation in the Authority’s eligibility case records. The universe included 198 CHIP
Non-MAGI -based recipients with 15,684 medical claims and 337 capitation payments totaling $5,460,170.76. We
sampled one medical claim or capitation payment tied to a specific date of service per recipient tested. Tested medical
claims and capitation payments for sampled recipients totaled $6,732.95.

     •    For 1 (2.5%) of 40 cases tested, DHS failed to perform a redetermination within 12 months.
     •    For 27 (67.5%) of 40 cases tested, DHS failed to notify the member of their most recent eligibility
          determination.

Cause: The Authority lacked internal controls over the MAGI (Modified Adjusted Gross Income) eligibility
determinations. The Authority accepted self-attested income without a wage match or requesting further
documentation from the recipient. They also failed to compare data exchanges to the case files each time quarterly
wage data was received; therefore, the methodology they used did not provide appropriate oversight over the eligibility
determinations to ensure adequate controls are in place to properly determine eligibility.

Effect: The Authority’s methodology does not comply with the state and federal regulations and the Authority may
be paying for services for which the recipient is not entitled.

Recommendation: We recommend the Authority review the current system of eligibility controls and update its
methodology to ensure the required conditions of eligibility are met and comply with state and federal regulations
when making eligibility determinations. This should include, but not be limited to, taking steps to enhance the
eligibility determination process and controls to ensure income is adequately verified.

Views of Responsible Official(s)
Contact Person: April Anonsen (OKHCA) Carla McCarrell-Williams (OKDHS) Ginger Clayton (OKHCA Member
Audit)
Anticipated Completion Date: June 2024 unless indicated as complete.
Corrective Action Planned: The Oklahoma Health Care Authority agrees with the finding. See corrective action plan
located in the corrective action plan section of this report.

FINDING NO: 2022-029 (All Clusters/Programs Repeat 2021-014)
STATE AGENCY: Oklahoma Department of Human Services (DHS) and Oklahoma Health Care Authority
FEDERAL AGENCY: United States Department of Agriculture and Department of Health and Human Services
ALN: 10.551, 93.558, 93.575, 93.596, and 93.778
FEDERAL PROGRAM NAME: SNAP Cluster, TANF Program, CCDF Cluster, and Medicaid Cluster
FEDERAL AWARD NUMBER: G2101OKTANF, G2201OKTANF, G2101OKCCDF, G2201OKCCDF,
2105OK5MAP, and 2205OK5MAP
FEDERAL AWARD YEAR: 2021 and 2022
CONTROL CATEGORY: Special Tests and Provisions – ADP System for SNAP (SNAP); Special Tests and
Provisions – Income Eligibility and Verification System (TANF Program); Eligibility (CCDF Cluster and Medicaid
Cluster)
QUESTIONED COSTS: $0

Criteria: According to 2 CFR Part 200, Appendix XI, Part 4 applicable to the Temporary Assistance for Needy
Families program, each State shall participate in the Income Eligibility and Verification System (IEVS) required by
section 1137 of the Social Security Act as amended. Under the state plan the state is required to coordinate data
exchanges with other federally assisted benefit programs, request and use income and benefit information when
making eligibility determinations and adhere to standardized formats and procedures in exchanging information with
other programs and agencies.

45 CFR 205.56(a)(1)(iv) states in part “For individuals who are recipients when the information is received or for
whom a decision could not be made prior to authorization of benefits, the State agency shall within forty-five (45)
days of its receipt, initiate a notice of case action or an entry in the case record that no case action is necessary… .”




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Condition and Context: We reviewed the SFY 2022 (July 1, 2021 – June 30, 2022) G1DX Exception and Clearance
Reports to determine whether data exchange discrepancy (exception) messages were resolved within the required 45
calendar days of the date the message was posted on the data exchange inquiry screen. Because the method used to
compile the discrepancy messages did not differentiate by program, the messages were reviewed at the error type
level. Therefore, the discrepancies listed below are a culmination of multiple programs and may not apply to each
program individually. We noted 133,321 of a total of 367,047 exceptions, or 36.32%, were not resolved within the
required 45 calendar day period as noted in the following schedule.


                                                                TOTAL OPEN &                 % OF
                 ERROR          OPEN & RESOLVED
                                                               RESOLVED G1DX              EXCEPTIONS
                  TYPE          G1DX EXCEPTIONS
                                                                 EXCEPTIONS               OVER 45 DAYS
                                  OVER 45 DAYS

              BEN                        11,741                       47,739                   24.59%
              CSE                         6,577                        9,290                   70.80%
              DOD                          312                          371                    84.10%
              ENU                        11,514                       17,021                   67.65%
              IEV                         6,129                       13,555                   45.22%
              NNH                        22,427                       74,065                   30.28%
              OWG                        15,495                       48,381                   32.03%
              PRS                          626                         2,499                   25.05%
              SDX                        15,590                       65,125                   23.94%
              SNH                        40,944                       81,946                   49.96%
              UIB                         1,966                        7,055                   27.87%
              TOTAL                     133,321                      367,047                   36.32%

The G1DX System is a OKDHS application that compares client information entered by a OKDHS employee and
OKDHS IEVS information sources as they are periodically updated. These sources include:
    • Wage information for the State Wage Information Collection Agency (SWICA).
    • Unemployment Compensation
    • All available information from the Social Security Administration (SSA)
    • Information from the U.S. Citizenship and Immigration Services
    • Unearned Income from the Internal Revenue Services (IRS)

Cause: The discrepancies were not cleared within the allowable 45 days per federal regulation due to an inadequate
number of personnel assigned to these duties. Additionally, management is not closely monitoring the clearance of
G1DX discrepancies.

Effect: The Department was not in compliance with the above stated requirement, which may result in ineligible
individuals receiving program benefits.

Recommendation: We recommend the Department utilize the monitoring reports created for the G1DX discrepancies
that summarize these discrepancies by worker, supervisor, county, and area. These reports allow management to
monitor not only the type of discrepancy and length of days outstanding, but also to distinguish who is responsible for
clearing the discrepancy within the 45 days allowed under current federal regulation and DHS policy.

Views of Responsible Official(s)
Contact Person: Paulette Kendrick, Jeff Rosebeary (OKDHS), Ginger Clayton (OHCA)
Anticipated Completion Date: July 2024




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Corrective Action Planned: The Oklahoma Health Care Authority agrees with the finding. See corrective action plan
located in the corrective action plan section of this report.

FINDING NO: 2022-039 (Repeat Finding 2021-048)
STATE AGENCY: Oklahoma Health Care Authority (OHCA)
FEDERAL AGENCY: United States Department of Health and Human Services
ALN: 93.778
FEDERAL PROGRAM NAME: Medicaid Cluster
FEDERAL AWARD NUMBER: 2105OK5MAP; 2205OK5MAP
FEDERAL AWARD YEAR: 2021 and 2022
CONTROL CATEGORY: Special Tests and Provisions – Refunding of Federal Share of Medicaid Overpayments
to Providers
QUESTIONED COSTS: $0

Criteria: 42 CFR § 433.304 Definitions states, “Discovery (or discovered) means identification by any State Medicaid
agency official or other State official, the Federal Government, or the provider of an overpayment, and the
communication of that overpayment finding or the initiation of a formal recoupment action without notice as described
in § 433.316.”

42 CFR § 433.304 Definitions states, “Final written notice means that written communication, immediately preceding
the first level of formal administrative or judicial proceedings, from a Medicaid agency official or other State official
that notifies the provider of the State's overpayment determination and allows the provider to contest that
determination, or that notifies the State Medicaid agency of the filing of a civil or criminal action.”

42 CFR § 433.312 Basic Requirements for Refunds states in part, “(a) Basic rules.
(1) … the State Medicaid agency has 1 year from the date of discovery of an overpayment to a provider to recover or
seek to recover the overpayment before the Federal share must be refunded to CMS.
(2) The State Medicaid agency must refund the Federal share of overpayments at the end of the 1-year period following
discovery in accordance with the requirements of this subpart, whether or not the State has recovered the overpayment
from the provider.

42 CFR § 433.316(a) General rule states, “The date on which an overpayment is discovered is the beginning date of
the 1-year period allowed for a State to recover or seek to recover an overpayment before a refund of the Federal share
of an overpayment must be made to CMS.”

42 CFR § 433.316(b) Requirements for notification states, “Unless a State official or fiscal agent of the State chooses
to initiate a formal recoupment action against a provider without first giving written notification of its intent, a State
Medicaid agency official or other State official must notify the provider in writing of any overpayment it discovers in
accordance with State agency policies and procedures and must take reasonable actions to attempt to recover the
overpayment in accordance with State law and procedures.”

42 CFR § 433.316(c) Overpayments resulting from situations other than fraud states, “An overpayment resulting from
a situation other than fraud is discovered on the earliest of - -
(1) The date on which any Medicaid agency official or other State official first notifies a provider in writing of
an overpayment and specifies a dollar amount that is subject to recovery;
(2) The date on which a provider initially acknowledges a specific overpaid amount in writing to the Medicaid agency;
or
(3) The date on which any State official or fiscal agent of the State initiates a formal action to recoup a specific
overpaid amount from a provider without having first notified the provider in writing.”

42 CFR § 433.316(d) Overpayments resulting from fraud states:
(1) An overpayment that results from fraud is discovered on the date of the final written notice (as defined in § 433.304
of this subchapter) of the State's overpayment determination.”




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42 CFR § 433.316(h) Effect of administrative or judicial appeals states, “Any appeal rights extended to a provider do
not extend the date of discovery.”

42 CFR § 433.320 Procedures for Refunds to CMS states, “(a) Basic Requirements.
(1) The agency must refund the Federal share of overpayments that are subject to recovery to CMS through a credit
on its Quarterly Statement of Expenditures (Form CMS-64).
(2) The agency must credit CMS with the Federal share of overpayments subject to recovery on the earlier of -
       (i) The Form CMS-64 submission due to CMS for the quarter in which the State recovers the overpayment from
       the provider; or
       (ii) The Form CMS-64 due to CMS for the quarter in which the 1-year period following discovery, established
       in accordance with § 433.316, ends.
(3) A credit on the Form CMS-64 must be made whether or not the overpayment has been recovered by the State from
the provider.
(4) If the State does not refund the Federal share of such overpayment as indicated in paragraph (a)(2) of this section,
the State will be liable for interest on the amount equal to the Federal share of the non-recovered, non-
refunded overpayment amount. Interest during this period will be at the Current Value of Funds Rate (CVFR), and
will accrue beginning on the day after the end of the 1-year period following discovery until the last day of the quarter
for which the State submits a CMS-64 report refunding the Federal share of the overpayment.”

Condition and Context: Based on review of the overpayment discovery records, it appears the overpayment letters
were mailed to providers, which started the 1-year period before an overpayment must be reported on the CMS-64.
However, when reviewing the MAP overpayments reported on Form CMS-64, we noted that for 1 of 64 (1.56%)
overpayments totaling $108,000, the overpayment was not properly recorded on the CMS -64.9C1 and refunded to
CMS within one year of the discovery date (final written notice per 42 CFR § 433.320, and the overpayment was not
reported on the correct line of the CMS 64.9C1.

Additionally, we noted that for 4 of 64 (6.25%) overpayments totaling $1,485,373, the overpayment was not properly
recorded on the CMS -64.9C1 within one year of the discovery date as required per 42 CFR § 433.316 (d) and, the
overpayment was not refunded to CMS within one year of the discovery date as required per 42 CFR § 433.320.

Cause: The Authority’s staff did not submit MAP overpayments for inclusion on the CMS-64 until an appeal case
had been resolved, which is contradictory to the requirement in 42 CFR § 433.316(h).

Effect: MAP overpayments related to appeals were not reported in compliance with 42 CFR § 433.316. Also, when
refunding overpayments past the allowable period as indicated in 42 CFR § 433.320(a)(2), the Authority could be
liable for interest as outlined at 42 CFR § 433.320(a)(4).

Recommendation: We recommend the Authority develop policies and procedures to ensure correspondence related
to overpayments are relayed timely, in accordance with 42 CFR § 433.316, to all staff involved in the overpayment
process.

The Authority should also develop a process to identify how and when MCHIP overpayments will be reported on the
CMS-64.

Views of Responsible Official(s)
Contact Person: Kristine West, Senior Director of Program Integrity and Accountability
Anticipated Completion Date: Fraud overpayment: May 2024; Non-fraud Overpayment: November 2022
Non-fraud: November 2022
Corrective Action Planned: The Oklahoma Health Care Authority agrees with the finding. See corrective action
plan located in the corrective action plan section of this report.


FINDING NO: 2022-040 (Repeat Finding 2021-008)
STATE AGENCY: Oklahoma Health Care Authority
FEDERAL AGENCY: United States Department of Health and Human Services




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ALN: 93.778
FEDERAL PROGRAM NAME: Medicaid Cluster
FEDERAL AWARD NUMBER: 2105OK5MAP; 2205OK5MAP
FEDERAL AWARD YEAR: 2021 and 2022
CONTROL CATEGORY: Special Tests and Provisions - Medicaid National Correct Coding Initiative (NCCI)
QUESTIONED COSTS: $0

Criteria: 42 USC §1396b(r)(1) Mechanized claims processing and information retrieval systems; operational, etc.,
requirements states “In order to receive payments under subsection (a) for use of automated data systems
in administration of the State plan under this subchapter, a State must, in addition to meeting the requirements of
paragraph (3), have in operation mechanized claims processing and information retrieval systems that meet the
requirements of this subsection and that the Secretary has found— … (B) are compatible with the claims processing
and information retrieval systems used in the administration of subchapter XVIII, and for this purpose— … (iv)
effective for claims filed on or after October 1, 2010, incorporate compatible methodologies of the National Correct
Coding Initiative administered by the Secretary (or any successor initiative to promote correct coding and
to control improper coding leading to inappropriate payment) and such other methodologies of that Initiative (or such
other national correct coding methodologies) as the Secretary identifies in accordance with paragraph (4) … .”

Condition and Context: The purpose of the NCCI Program is to promote correct coding, prevent coding errors,
prevent code manipulation, reduce improper payments and reduce the paid claims improper payment rate.

In paying applicable Medicaid claims, States’ Medicaid Enterprise Systems (MES) are required to completely and
correctly implement the following six Medicaid NCCI methodologies to ensure that only proper payments of
procedures are reimbursed. OHCA has yet to fully implement the six NCCI methodologies listed below:

(1) NCCI Procedure-to-Procedure (PTP) edits for practitioner and ambulatory surgical center (ASC) claims.
(2) NCCI PTP edits for outpatient hospital services including emergency department, observation care, and outpatient
hospital laboratory services.
(3) Medically Unlikely Edit (MUE) units of service (UOS) edits for practitioner and ASC services.
(4) MUE UOS edits for outpatient hospital services including emergency department, observation care, and outpatient
hospital laboratory services.
(5) MUE UOS edits for durable medical equipment (DME) billed by providers.
(6) NCCI PTP edits for durable medical equipment (added in October 2012).

Since the NCCI methodologies have been partially implemented, the OHCA has also been unable to use the following
as intended:
         • all four components of each Medicaid NCCI methodology;
         • the most recent quarterly Medicaid NCCI edit files for States;
         • the Medicaid NCCI edits in effect for the date of service on the claim line or claim;
         • the claim-adjudication rules in the Medicaid NCCI methodologies; and
         • all modifiers for Healthcare Common Procedure Coding System (HCPCS) codes and Current Procedural
         Terminology (CPT) codes needed for the correct adjudication of applicable Medicaid claims.

Cause: The OHCA initially tried to implement the NCCI edits as part of their state edit system, or the Medicaid
Management Information System (MMIS). However, after having trouble implementing the NCCI and state specific
edits when needed per the Medicaid Technical Guidance Manual, the agency began working on a separate NCCI
claims review system.

Effect: OHCA may be paying for services that were billed containing improper coding, coding errors, or code
manipulation. As a result, significant Medicaid savings could be seen by fully implementing the required NCCI
medical claims review edits.

Recommendation: We recommend OHCA continue to work on development of the NCCI edits to ensure full
implementation of the NCCI methodologies into the agency’s claim’s review process.




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Views of Responsible Official(s)
Contact Person: Karen Beam, Director, Medical Administrative Support Services and Thi Nguyen, Senior System
Analyst Manager
Anticipated Completion Date: May 2022
Corrective Action Planned: The Oklahoma Health Care Authority agrees with the finding. See corrective action
plan located in the corrective action plan section of this report.

FINDING NO: 2022-054 (Repeat Finding 2021-026)
STATE AGENCY: Oklahoma Health Care Authority (the Authority)/Oklahoma Department of Human Services
(OKDHS)
FEDERAL AGENCY: United States Department of Health and Human Services
ALN: 93.778
FEDERAL PROGRAM NAME: Medicaid Cluster
FEDERAL AWARD NUMBER: 2105OK5021 and 2205OK5021
FEDERAL AWARD YEAR: 2021 and 2022
CONTROL CATEGORY: Eligibility
QUESTIONED COSTS: $0

Criteria: 45 CFR §75.303 states, “The non-Federal entity must:(a) Establish and maintain effective internal controls
over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award
in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued
by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO).”

42 CFR §431.10(c)(2) states, “The Medicaid agency may delegate authority to make eligibility determinations or to
conduct fair hearings under this section only to a government agency which maintains personnel standards on a merit
basis.”

42 CFR §431.10(c)(3)(ii) states in part, “The Medicaid agency must exercise appropriate oversight over the eligibility
determinations and appeals decisions made by such agencies ….”

OKDHS Policy OAC 340:65-3-4 (4) states in part, “Automated data exchange with other agencies provides DHS with
information regarding household members' benefits, wages, taxes, Social Security numbers, and current addresses.
The system compares information obtained electronically with data stored within DHS electronic records to determine
if there are discrepancies to be addressed.”

OAC 317:35-5-42(b)(5)(A) states in part, “A lump sum payment may be considered as earned or unearned income,
depending on the source of the lump sum payment. Lump sum payments may include, but are not limited to:
          (vi) Lottery or gambling winnings,….”

Condition and Context: The Authority delegates OKDHS to determine eligibility for non-MAGI (modified adjusted
gross income) recipients. OKDHS utilizes automated data exchange information obtained from other agencies to
verify the information provided by recipients.

Office of Management and Enterprise Services – Information Services Division (OMES-ISD) runs scheduled data
exchange jobs to gather the information from the various agencies for the Automated Caseload Evaluation System
(ACES). The ACES system is a web-based application that gathers all available OKDHS data exchange information
on a case, which is used by the Social Services Specialist to assist in determining Medicaid eligibility. The data
exchange jobs are assigned to a coordinator who is responsible for seeing that the jobs are placed in the TWS
(scheduling system) on the correct calendar with the date and time jobs are to run.

We determined that OKDHS did not run any data exchange jobs with the Oklahoma Lottery Commission to determine
eligibility during SFY2022.




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Cause: The Authority lacked appropriate oversight over the data exchange jobs completed by OKDHS resulting in
inadequate controls over the data exchange process to ensure jobs are ran at the frequency required.

Effect: Non-compliance with the Code of Federal Regulations (CFRs) and The Authority’s Policy OAC 317:35-5-42
and OKDHS Policy OAC 340:65-3-4 (4), which could result in payment of Medicaid benefits to ineligible recipients.

Recommendation: To comply with the CFRs and The Authority’s Policy OAC 317:35-5-42 and OKDHS Policy
OAC 340:65-3-4 (4), we recommend the Authority review internal control policy and procedures over data exchange
jobs and update as necessary to ensure they are operating effectively so that data exchange jobs are run at the frequently
required and issues noted are addressed in a timely manner.

Views of Responsible Official(s)
Contact Person: Ginger Clayton, Director of Member Audits
Anticipated Completion Date: Lottery Commission data exchange was implemented on 8/14/2023; OHCA
monitoring – March 2024
Corrective Action Planned: The Oklahoma Health Care Authority agrees with the finding. See corrective action plan
located in the corrective action plan section of this report.

FINDING NO: 2022-074 (Repeat Finding 2021-028)
STATE AGENCY: Oklahoma Health Care Authority (the Authority)/Oklahoma Department of Human Services
(OKDHS)
FEDERAL AGENCY: United States Department of Health and Human Services
ALN: 93.778
FEDERAL PROGRAM NAME: Medicaid Cluster
FEDERAL AWARD NUMBER: 2105OK5MAP and 2205OK5MAP
FEDERAL AWARD YEAR: 2021 and 2022
CONTROL CATEGORY: Eligibility
QUESTIONED COSTS: $0

Criteria: 42 CFR §431.211 states in part “The State or local agency must send a notice at least 10 days before the date
of action…”

42 CFR §433.400(c)(2)(iii) states, “For beneficiaries not described in paragraph (c)(2)(i) or (ii) of this section, the
state must continue to provide at least the same level of medical assistance as was provided as of or after March 18,
2020.”

CMS-9912 Interim Final Rule with Comment Factsheet on Updated Policy for Maintaining Medicaid Enrollment
during the Public Health Emergency for COVID-19 states “In states claiming the temporary FMAP increase, a
beneficiary’s Medicaid enrollment may be terminated prior to the first day of the month after the PHE for COVID-19
ends if:

    1.   The beneficiary requests a voluntary termination of eligibility;
    2.   The beneficiary dies;
    3.   The beneficiary ceases to be a resident of the state; or
    4.   The beneficiary was not validly enrolled.”

Additionally, a component objective of generally accepted accounting principles is to provide accurate and reliable
information.

Condition and Context: We tested a non-statistical sample of 72 cases that were closed during the year and reviewed
the case record documentation maintained at OHCA and DHS for Medicaid eligibility.

         OKDHS Medicaid

         •    For 2 (14.29 %) of 14 cases tested the case was closed for circumstances during the PHE other than:




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                  o    The beneficiary requests a voluntary termination of eligibility;
                  o    The beneficiary dies;
                  o    The beneficiary ceases to be a resident of the state;
                  o    The beneficiary was not validly enrolled on or after March 18, 2020

Cause: OHCA lacked adequate internal controls and appropriate processes to ensure services were only reduced on
cases outlined at 42 CFR §433.400 paragraph (c)(2)(i) or (ii).

OKDHS lacked adequate internal controls and appropriate processes to ensure cases were only closed as outlined in
CMS-9912.

Effect: Non-compliance with the Code of Federal Regulations (CFRs) and CMS guidance (CMS-9912) on
maintaining Medicaid Enrollment during the Public Health Emergency for COVID-19, which could result in the
termination of the temporary FMAP increase.

Recommendation: To comply with the CFRs and CMS guidance (CMS-9912) we recommend OKDHS review
internal control policy and procedures over decisions affecting an applicant or beneficiaries’ eligibility, including the
termination of benefits to align with CMS-9912.

Views of Responsible Official(s)
Contact Person: April Anonsen (OKHCA) Carla McCarrell-Williams (OKDHS) Ginger Clayton (OKHCA Member
Audit)
Anticipated Completion Date: September 2024
Corrective Action Planned: The Oklahoma Health Care Authority agrees with the finding. See corrective action plan
located in the corrective action plan section of this report.



                      Oklahoma Department of Human services

FINDING NO: 2022-007 (Repeat Finding 2021-059)
STATE AGENCY: Oklahoma Department of Human Services
FEDERAL AGENCY: United States Department of Agriculture
ALN: 10.551 / 10.561
FEDERAL PROGRAM NAME: SNAP Cluster
FEDERAL AWARD NUMBER: N/A
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Special Tests & Provisions – EBT Card Security
QUESTIONED COSTS: $0

Criteria: The Government Accountability Office (GAO) Standards for Internal Control in the Federal Government
10.10 states “Transaction control activities are actions built directly into operational processes to support the entity in
achieving its objectives and addressing related risks. “Transactions” tends to be associated with financial processes
(e.g., payables transactions), while “activities” is more generally applied to operational or compliance processes. For
the purposes of this standard, “transactions” covers both definitions. Management may design a variety of transaction
control activities for operational processes, which may include verifications, reconciliations, authorizations and
approvals, physical control activities, and supervisory control activities.”

7 CFR § 274.8 Functional and Technical EBT system requirements states in part “(a) Functional requirements. The
State agency shall ensure that the EBT system is capable of performing the following functional requirements prior to
implementation: … (2) Providing food benefits to households. (i) Verifying the identity of authorized households or
authorized household representatives at issuance terminals or POS;”

According to OKDHS’ Electronic Payments Handbook,




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    •    “EBT cards are counted and recorded each and every time the EBT card inventory is accessed. For example,
         designated staff count and record the EBT card inventory in each of the following circumstances:
              o Upon receipt of new cards (from another office, or the vendor),
              o When removing cards from the bulk inventory in secure storage, and
              o When returning unused cards to secure storage at the end of the day.”
    •    “Documenting card inventory is completed on the EBT Daily Card Issuance Report …”
    •    “At the completion of each day, both the designated EBT staff and their supervisor review and sign the report
         (the EBT Daily Card Issuance Report) …”
    •    “Retain a copy of the email order and the confirmation reply for verification purposes...”
    •    “Cards returned by mail or dropped off at the county office must be properly logged and shredded under the
         following procedures … 3) The card log and the cards will be provided to the supervisor for audit. The
         supervisor will ensure the cards have been logged and deactivated.”

Best practice includes the security of Electronic Benefit Transaction (EBT) cards, which includes the daily
reconciliation of EBT cards, and deactivation of an EBT card prior to destruction.

Condition and Context: Based on communications with Tess Murlin, Financial Programs Assistant Administrator,
and a walkthrough of the Oklahoma City DHS County Office (55C) we noted that, while OKDHS EBT specialists
check the ID of the client to confirm their identity within Conduent, the Daily Issuance form was not used. Thus, tests
of this control cannot be performed.

DHS procedures are that EBT card stock will be counted and recorded each and every time the card stock inventory
is accessed, and the documenting of the card inventory is performed on the EBT Daily Card Issuance Report. At the
end of each day the designated EBT staff and their supervisor review and sign the report. Procedures also have that
email orders for new card stock to be retained for verification purposes.

Based on procedures performed on 72 of 7,881 EBT cards on DHS destruction logs from SFY 2022 we noted:
    • Five (6.94%) of the EBT cards were still active after the destruction process.

Based on procedures performed at 9 of 42 county office locations, we noted:
    • Eight (88.89%) offices’ inventory logs did not support that the inventory count was performed by two
        individuals at the end of each day.
    • Two (22.22%) offices where the EBT inventory did not tie to the email request.

Cause: Internal controls are not in place to ensure OKDHS policies and procedures related to the inventory
accounting, unauthorized transfer/issuance, and destruction process of EBT cards are consistently followed by field
employees

Effect: EBT cards are at risk of improper use and possible misappropriation of Supplement Nutrition Assistance
Program (SNAP) benefits.

Recommendation: We recommend DHS implement internal controls to ensure policies and procedures related to
inventory accounting, security, transfer/issuance, and the destruction process of the cards are consistently followed
and updated. Additionally, we recommend DHS provide training to staff regarding these policies and procedures. We
further recommend management implement procedures to monitor the county office locations for compliance with
these policies and procedures throughout the year.

Views of Responsible Official(s)
Contact Person: Thomas Pennington
Anticipated Completion Date: January 2024
Corrective Action Planned: The Department of Human Services partially agrees with the finding. Please see the
corrective action plan located in the corrective action plan section of this report.




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FINDING NO: 2022-010
STATE AGENCY: Oklahoma Department of Human Services
FEDERAL AGENCY: United States Department of Agriculture
ALN: 10.561
FEDERAL PROGRAM NAME: Supplemental Nutrition Assistance Program Cluster
FEDERAL AWARD NUMBER: N/A
FEDERAL AWARD YEAR: 2021 & 2022
CONTROL CATEGORY: Reporting
QUESTIONED COSTS: $0

Criteria: A basic objective of Generally Accepted Accounting Principles is to provide accurate, reliable, and timely
information.

A component objective of an effective internal control system is to ensure accurate and reliable information through
a proper review and approval process.

OMES GAAP Package Z Schedule of Expenditures of Federal Awards Instruction 4.1 states in part, “If funds related
to COVID-19 programs are administered through other non-COVID ALN programs, those amounts should be
segregated and reported separately from the non-COVID ALN.”

Condition and Context: During our review of the GAAP Package Z Schedule of Expenditures of Federal Awards
and supporting documentation for the State Matching Grant for SNAP, AL #10.561, we noted the expenditures amount
was incorrect.

Cause: The agency reported Covid-19 expenditures twice on their GAAP Package Z Schedule of Expenditures of
Federal Awards. Covid-19 expenditures were reported for State Matching Grant for SNAP, AL #10.561, and also
included in the amount reported for non-Covid State Matching Grant for SNAP, AL #10.561.

Effect: Expenditures reported for non-Covid State Matching Grant for SNAP, AL #10.561, on the agency’s GAAP
Package Z Schedule of Expenditures of Federal Awards were overstated by $3,194,116.

Recommendation: We recommend that OKDHS evaluate its control process related to the reporting accuracy and
review of its Schedule of Expenditures of Federal Awards to ensure the reported amounts are correct.

Views of Responsible Official(s)
Contact Person: Kevin Haddock
Anticipated Completion Date: December 2023
Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-014 (Repeat Finding 2021-089)
STATE AGENCY: Department of Human Services
FEDERAL AGENCY: United States Department of Health and Human Services
ALN: 93.575, 93.596
FEDERAL PROGRAM NAME: CCDF Cluster
FEDERAL AWARD NUMBER: 2101OKCCDF and 2201OKCCDF
FEDERAL AWARD YEAR: 2021 and 2022
CONTROL CATEGORY: Special Tests and Provisions - Health and Safety Requirements
QUESTIONED COSTS: $0

Criteria: CFR 45 §98.41 Health and safety requirements states, in part, “(a) Each Lead Agency shall certify that there
are in effect, within the State (or other area served by the Lead Agency), under State, local or tribal law, requirements
(appropriate to provider setting and age of children served) that are designed, implemented, and enforced to protect
the health and safety of children. Such requirements must be applicable to child care providers of services for which
assistance is provided under this part. Such requirements, which are subject to monitoring pursuant to §98.42, shall:




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(1) Include health and safety topics consisting of, at a minimum:
(i) The prevention and control of infectious diseases (including immunizations); with respect to immunizations, the
following provisions apply:
(A) As part of their health and safety provisions in this area, Lead Agencies shall assure that children receiving services
under the CCDF are age-appropriately immunized. Those health and safety provisions shall incorporate (by reference
or otherwise) the latest recommendation for childhood immunizations of the respective State, territorial, or tribal
public health agency.
(B) Notwithstanding this paragraph (a)(1)(i), Lead Agencies may exempt:
(1) Children who are cared for by relatives (defined as grandparents, great grandparents, siblings (if living in a separate
residence), aunts, and uncles), provided there are no other unrelated children who are cared for in the same setting.
(2) Children who receive care in their own homes, provided there are no other unrelated children who are cared for in
the home.
(3) Children whose parents object to immunization on religious grounds.
(4) Children whose medical condition contraindicates immunization.
(C) Lead Agencies shall establish a grace period that allows children experiencing homelessness and children in foster
care to receive services under this part while providing their families (including foster families) a reasonable time to
take any necessary action to comply with immunization and other health and safety requirements.
(1) The length of such grace period shall be established in consultation with the State, Territorial or Tribal health
agency.
(2) Any payment for such child during the grace period shall not be considered an error or improper payment under
subpart K of this part.
(3) The Lead Agency may also, at its option, establish grace periods for other children who are not experiencing
homelessness or in foster care.
(4) Lead Agencies must coordinate with licensing agencies and other relevant State, Territorial, Tribal, and local
agencies to provide referrals and support to help families of children receiving services during a grace period comply
with immunization and other health and safety requirements;
(ii) Prevention of sudden infant death syndrome and use of safe sleeping practices;
(iii) Administration of medication, consistent with standards for parental consent;
(iv) Prevention and response to emergencies due to food and allergic reactions;
(v) Building and physical premises safety, including identification of and protection from hazards, bodies of water,
and vehicular traffic;
(vi) Prevention of shaken baby syndrome, abusive head trauma, and child maltreatment;
(vii) Emergency preparedness and response planning for emergencies resulting from a natural disaster, or a man-
caused event (such as violence at a child care facility), within the meaning of those terms under section 602(a)(1) of
the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. 5195a(a)(1)) that shall include
procedures for evacuation, relocation, shelter-in-place and lock down, staff and volunteer emergency preparedness
training and practice drills, communication and reunification with families, continuity of operations, and
accommodation of infants and toddlers, children with disabilities, and children with chronic medical conditions;
(viii) Handling and storage of hazardous materials and the appropriate disposal of bio contaminants;
(ix) Appropriate precautions in transporting children, if applicable;
(x) Pediatric first aid and cardiopulmonary resuscitation;
(xi) Recognition and reporting of child abuse and neglect, in accordance with the requirement in paragraph (e) of this
section; and…”

OAC 340:110-3-11(a)(8) states in part, “Ongoing approvals by fire and health are required every two years.”

OAC 340:110-1-9 (b) states, “Ongoing monitoring: During monitoring visits, the licensing staff observes the entire
facility, including outdoor play space and vehicles used for transportation, if available. At or subsequent to each
visit, licensing staff checks:
     • (1) compliance with licensing regulations;
     • (2) records for new staff including personnel sheets and compliance with background investigations per
           OAC 340:110-1-8.1;
     • (3) personnel professional development records;
     • (4) Oklahoma Department of Human Services (OKDHS) computer checks on applicable persons per OAC
           340:110-1-8.1;




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    •    (5) fire and health inspections within the last 24 months, (when) applicable;
    •    (6) Form 07LC092E, Insurance Verification, within the last 12 months, or posting of Form 07LC093E,
         Insurance Exception Notification; and
    •    (7) other documentation requiring renewal.”

Instructions to Staff OAC 340:110-1-9(3) states, “Licensing staff: (1) documents observations and discussions on the
appropriate monitoring checklists, enters the information from the monitoring checklists onto the licensing database,
provides copies of the monitoring summary to the program’s owner/operator and files the original in the program’s
file in the local Oklahoma Department of Human Services (OKDHS) office.”

2 CFR 200.333 states, “Financial records, supporting documents, statistical records, and all other non-Federal entity
records pertinent to a Federal award must be retained for a period of three years from the date of submission of the
final expenditures report, or for Federal awards that are renewed quarterly or annually, from the date of the submission
of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through
entity in the case of a subrecipient.”

Condition and Context: We noted the following for a sample of 72 of 1,766 daycare centers and homes:

    •    72 centers/homes (100%) where we could not determine that monitoring checklists were adequately
         documented in relation to compliance with the health and safety requirements.
    •    6 centers/homes (8.33%) where the fire extinguisher was expired, but was not noted as non-compliant on the
         review.
    •    1 center/home (1.39%) where the annual insurance was expired, but was not noted as non-compliant on the
         review.
    •    1 center/home (1.39%) where the annual Equipment Inventory and Physical Environment checklists were
         not completed and was not noted as non-compliant on the review.
    •    14 centers/homes (19.44%) where the number of visits were not performed according to the Monitoring
         Frequency Plan (MFP). In addition, we were unable to verify if there would have been non-compliance that
         was followed up on.

During walk-through of the monitoring checklist software application in the prior audits, we observed a drop-down
box containing the requirements applicable to each header. When non-compliance was noted during monitoring, the
monitoring specialist would mark the corresponding requirement in the drop-down box as well as “NC” beside the
header. However, we noted that if ‘NC’ is not marked in the header, the non-compliance will not be carried forward
to the monitoring summary report that is reviewed and signed by the center/home administrator and the monitoring
specialist.

In addition, we could not determine that the tracking mechanism for monitoring visits is consistently used to ensure
that all daycare facilities and homes are monitored in accordance with their applicable Monitoring Frequency Plan
(MFP) or that follow-up takes place when non-compliance is noted. Work plan reports are generated in the Child Care
Monitoring, Administration and Safety System (CCMASS) to assist with tracking monitoring visits, pending
complaints, and Star review visits to be conducted; however, these are not retained by the licensing specialist, so we
were unable to verify their use.

Cause: Monitoring checklists and summary reports are not sufficiently designed to allow a reviewer to see what has
been observed. Additionally, a uniform system to track monitoring visits and non-compliance follow-up has been
designed, but the Agency does not require monitors to use it.

Effect: The agency is not in compliance with the above stated requirements. If health and safety requirements are
not met at each home/center, children in these facilities are at risk for illness and injury. Further, the lack of a required
comparison back to the work plan reports could potentially result in a facility not being monitored appropriately.

Recommendation: We recommend the agency implement procedures to ensure all monitoring visits are documented
in a manner that clearly conveys all health and safety requirements were reviewed for the facility. In addition, we




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recommend training be provided to all monitoring staff to ensure all monitoring visits are performed in a consistent
manner and are adequately documented. Further, we recommend the importance of the use of the work plan report
and the retention of these real time documents be emphasized to all staff.

Views of Responsible Official(s)
Contact Person: Dione Smith
Anticipated Completion Date: January 30, 2023
Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-017 (Repeat Finding 2021-100)
STATE AGENCY: Oklahoma Department of Human Services
FEDERAL AGENCY: Department of Health and Human Services
ALN: 93.659
FEDERAL PROGRAM NAME: Adoption Assistance Program
FEDERAL AWARD NUMBER: 2101OKADPT & 2201OKADPT
FEDERAL AWARD YEAR: 2021 & 2022
CONTROL CATEGORY: Eligibility
QUESTIONED COSTS: $0

Criteria: 45 CFR §75.303(a) states, “The non-Federal entity must: Establish and maintain effective internal control
over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award
in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued
by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO).”

42 USC §671(a)(20) states in part, “In order for a State to be eligible for payments under this part, it shall have a plan
approved by the Secretary which (A) provides procedures for criminal records checks, including fingerprint-based
checks of national crime information databases, for any prospective foster or adoptive parent … (B) provides that the
State shall (i) check any child abuse and neglect registry maintained by the State for information on any prospective
foster or adoptive parent and on any other adult living in the home … .”

Condition and Context: Based on procedures performed on 60 of 18,540 adoption assistance case files we noted:

         •    1 case file (1.64%) in which the required eligibility determination and documentation of a criminal
              background check and Oklahoma’s child abuse and neglect registry were not retained.

Cause: The agency’s internal controls were not effective to ensure all required actions occurred and required
documentation is retained within the files.

Effect: If criminal records and child abuse registries are not checked, children could be placed in a home with an
imminent safety threat Additionally, recipients of adoption assistance may not be eligible for assistance.

Recommendation: We recommend that DHS strengthen internal controls to ensure required documentation is
retained within the case files. In addition, we recommend training be provided to staff to ensure they are aware of and
understand the applicable policies and procedures for adoption assistance.

Views of Responsible Official(s)
Contact Person: Kevin Haddock
Anticipated Completion Date: January 2024
Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-018 (Repeat 2021-099)




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STATE AGENCY: Oklahoma Department of Human Services
FEDERAL AGENCY: Department of Health and Human Services
ALN: 93.658
FEDERAL PROGRAM NAME: Foster Care – Title IV-E
FEDERAL AWARD NUMBER: 2101OKFOST and 2201OKFOST
FEDERAL AWARD YEAR: 2021 and 2022
CONTROL CATEGORY: Subrecipient Monitoring
QUESTIONED COSTS: $0

Criteria: 45 CFR §75.303(a) states in part “The Non-Federal entity must: Establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These
internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government”
issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO).”

Per 2 CFR §200.1 Definitions, “Subaward means an award provided by a pass-through entity to a subrecipient for the
subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to
a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided
through any form of legal agreement, including an agreement that the pass-through entity considers a contract
[emphasis added].”

2 CFR §200.332 Requirements for pass-through entities states in part “All pass-through entities must:
(a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following
information at the time of the subaward and if any of these data elements change, include the changes in subsequent
subaward modification. When some of this information is not available, the pass-through entity must provide the best
information available to describe the Federal award and subaward. Required information includes:
(1) Federal award identification.
(i) Subrecipient name (which must match the name associated with its unique entity identifier);
(ii) Subrecipient's unique entity identifier;
(iii) Federal Award Identification Number (FAIN);
(iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by
the Federal agency;
(v) Subaward Period of Performance Start and End Date;
(vi) Subaward Budget Period Start and End Date;
(vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient;
(viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current
financial obligation;
(ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity;
(x) Federal award project description, as required to be responsive to the Federal Funding Accountability and
Transparency Act (FFATA);
(xi) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-
through entity;
(xii) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available
under each Federal award and the Assistance Listings Number at time of disbursement;
(xiii) Identification of whether the award is R&D; and
(xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414.
(2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in
accordance with Federal statutes, regulations and the terms and conditions of the Federal award;
…

(b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and
conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in
paragraphs (d) and (e) of this section, which may include consideration of such factors as:
(1) The subrecipient's prior experience with the same or similar subawards;




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(2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance
with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major
program;
(3) Whether the subrecipient has new personnel or new or substantially changed systems; and
(4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal
awards directly from a federal awarding agency).”

Condition and Context: For our sample of two of the eight SFY 22 Foster Care subrecipients, we noted the following
exceptions related to award identification requirements:

     •   Two of two (100%) subawards did not contain the subrecipient’s unique entity identifier, federal award
         identification number, federal award date, and identification as to whether the award is for research and
         development.
     •   Two of two (100%) subawards did not include all requirements imposed by the pass-through entity on the
         subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms
         and conditions of the Federal award.
     •   For one of two (50%) subrecipients, OKDHS did not include the subaward budget period in the subaward.
     •   For one of two (50%) subrecipients, OKDHS did not include the subaward project description in the
         subaward.
     •   For one of two (50%) subrecipients did not include the AL# on the subaward.

In our audit review of the eight SFY22 Foster Care subrecipients, management was unable to provide accurate
information regarding whether or when risk assessments were completed during the year.

When evaluating the design and implementation of internal controls we noted OKDHS has no documentation of their
review of claims for the SFY22 Foster Care subrecipients. Additionally, no other during award monitoring was noted.

Cause: This is a prior audit finding dating back to SFY2017; DHS Management showed no corrective action has
been implemented to address identifying the award and applicable requirements or monitoring as required in 2 CFR
200.332. Management does not properly understand the program requirements.

Effect: OKDHS is not in compliance with the monitoring requirements for this program. Therefore, subrecipients may
not be spending federal funds in accordance with program requirements.

Recommendation: We recommend OKDHS further modify its subrecipient agreements and related documentation
to ensure all required award identification is provided. Additionally, we recommend OKDHS perform risk assessments
on all subrecipients to determine the level of monitoring necessary at the start of the fiscal year. Lastly, we recommend
OKDHS perform and document a review of subrecipients financial and performance reports to ensure OKDHS can
assess subrecipient compliance with program requirements and achievement of performance goals.

Views of Responsible Official(s)
Contact Person: Kevin Haddock
Anticipated Completion Date: June 2024
Corrective Action Planned: The Department of Human Services partially agrees with the finding. Please see the
corrective action plan located in the corrective action plan section of this report.

FINDING NO: 2022-023
STATE AGENCY: Department of Human Services
FEDERAL AGENCY: Department of Health and Human Services
ALN: 93.658, 93.659, 93.778, 93.558, 93.596, 10.561
FEDERAL PROGRAM NAME: Foster Care – Title IV-E, Adoption Assistance, Medicaid Cluster, TANF, Child
Care Development Cluster, & SNAP Cluster
FEDERAL AWARD NUMBER: 2201OKFOST, 2201OKADPT, 2105OK5MAP, G1901OKTANF,
2201OKADPT
FEDERAL AWARD YEAR: 2022




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CONTROL CATEGORY: Allowable Costs/Cost Principles - Random Moment Time Study (RMTS)
QUESTIONED COSTS: $0

Criteria: 45CFR95.507(b)(8)(ii) states, “The cost allocation plan shall contain a certification by a duly authorized
official of the State stating that the costs are accorded consistent treatment through the application of generally
accepted accounting principles appropriate to the circumstances.”

OKDHS:2-11-60(1)(B) states, “The Finance Division oversees the collection of data necessary for allocations and
distribution.”

OKDHS:2-11-60(1)(B) states, “The Finance Division uses generally accepted accounting procedures of costs as
described in the cost allocation plan.

A basic objective of generally accepted accounting principles is to provide accurate and reliable information.

Condition and Context: For the quarter ending 12/31/21, the number of children used to calculate the allocation
percentage for Cost Pool 655, Child Welfare Services County Offices (RMTS) was overstated according to the
supporting Quarterly Kids and Days Report, causing:

    •    Cost Pool 335, Child Welfare Medicaid Targeted Case Management, to be understated by $1,120.38
    •    Cost Pool 306, Title IV-E Foster Care Administration, to be overstated by $103,868.23
    •    Cost Pool 313, Child Welfare Services (IV-B, Subpart 1), to be understated by $101,628.97
    •    Cost Pool 379, Title IV-E Adoption Assistance Administration, to be understated by $1,120.38

For the quarter ending 3/31/22, due to an Excel formula error, the number of children used to calculate the allocation
percentages for Cost Pool 655was inaccurate, causing

    •    Cost Pool 306, Title IV-E Foster Care Administration, to be understated by $76,281.70.

For the quarter ending 6/30/22, the IVA (a cost allocation and random moment software company) system used
March’s responses for Cost Pool 656 – Adult Family Services County Offices (AFS) (RMTS) by default for June
causing a $16,303.79 miss-allocation of funds to Cost Pool 656. The miss-allocation caused incorrect allocations to
the following cost pools:

                    Cost Pool       Over/(Under) Allocated             Cost Pool       Over/(Under) Allocated
                        282                                $174.16        378                            $(291.84)
                         301                             $(189.93)        570                             $(368.47)
                         302                             $(313.52)        571                            $ (110.87)
                         303                               $185.37        572                             $(26.09)
                         306                                   $8.43      574                             $(26.09)
                         308                             $1,154.02        575                             $(68.48)
                         329                             $1,351.72        577                          $(1,201.59)
                         338                                $42.13        578                            $(154.89)
                         342                                   $7.34      579                            $(489.11)
                         371                               $335.63        655                             $(17.93)

Responses for Social Services Block Grant (307) were not updated from the March allocation causing:
    • Cost Pool 308 Medicaid to be under allocated by $45,162.55
    • Cost Pool 329 Supplemental Nutrition Assistance Program to be under allocated $143.37




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Cause: The Allocation Schedules were not properly reviewed and compared to supporting documentation. Excel
formulas were not protected and were overwritten causing mathematical errors and allocation percentages to be
incorrect. Old RMTS uploads were left in the new IVA system causing the system to default to the old RMTS upload
rather than the new.

Effect: Costs charged to the Child Welfare Medicaid Targeted Case Management, Title IV-E Foster Care
Administration, Child Welfare Services (IV-B, Subpart 1) programs were inaccurate for the quarter ending 12/31/21.
Title IV-E Foster Care Administration program allocation was inaccurate for the quarter end 3/31/22. Programs that
received funding through the Adult Family Services Cost Pool 656, Medicaid, and SNAP programs for the quarter
ending 6/30/22 were inaccurate.

Recommendation: We recommend the Department follow established procedures to ensure allocation data is entered
accurately in the cost allocation system and implement procedures to ensure accurate allocation percentages within
the new IVA system. Additionally, we recommend a correction be made as soon as possible to correct the allocation
amounts recorded for the relevant programs.

Views of Responsible Official(s)
Contact Person: Kevin Haddock
Anticipated Completion Date: June 2023
Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-029 (All Clusters/Programs Repeat Finding 2021-014)
STATE AGENCY: Oklahoma Department of Human Services (DHS) and Oklahoma Health Care Authority
FEDERAL AGENCY: United States Department of Agriculture and Department of Health and Human Services
ALN: 10.551, 93.558, 93.575, 93.596, and 93.778
FEDERAL PROGRAM NAME: SNAP Cluster, TANF, CCDF Cluster, and Medicaid Cluster
FEDERAL AWARD NUMBER: G2101OKTANF, G2201OKTANF, G2101OKCCDF, G2201OKCCDF,
2105OK5MAP, and 2205OK5MAP
FEDERAL AWARD YEAR: 2021 and 2022
CONTROL CATEGORY: Special Tests and Provisions – ADP System for SNAP (SNAP); Special Tests and
Provisions – Income Eligibility and Verification System (TANF Program); Eligibility (CCDF Cluster and Medicaid
Cluster)
QUESTIONED COSTS: $0

Criteria: According to 2 CFR Part 200, Appendix XI, Part 4 applicable to the Temporary Assistance for Needy
Families program, each State shall participate in the Income Eligibility and Verification System (IEVS) required by
section 1137 of the Social Security Act as amended. Under the state plan the state is required to coordinate data
exchanges with other federally assisted benefit programs, request and use income and benefit information when
making eligibility determinations and adhere to standardized formats and procedures in exchanging information with
other programs and agencies.

45 CFR 205.56(a)(1)(iv) states in part “For individuals who are recipients when the information is received or for
whom a decision could not be made prior to authorization of benefits, the State agency shall within forty-five (45)
days of its receipt, initiate a notice of case action or an entry in the case record that no case action is necessary…”

Condition and Context: We reviewed the SFY 2022 (July 1, 2021 – June 30, 2022) G1DX Exception and Clearance
Reports to determine whether data exchange discrepancy (exception) messages were resolved within the required 45
calendar days of the date the message was posted on the data exchange inquiry screen. Because the method used to
compile the discrepancy messages did not differentiate by program, the messages were reviewed at the error type
level. Therefore, the discrepancies listed below are a culmination of multiple programs and may not apply to each
program individually. We noted 133,321 of a total of 367,047 exceptions, or 36.32%, were not resolved within the
required 45 calendar day period as noted in the following schedule.




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                                                                TOTAL OPEN &
                  ERROR          OPEN & RESOLVED                                        % OF EXCEPTIONS
                                                               RESOLVED G1DX
                   TYPE          G1DX EXCEPTIONS                                          OVER 45 DAYS
                                                                 EXCEPTIONS
                                   OVER 45 DAYS

              BEN                        11,741                         47,739                  24.59%
              CSE                         6,577                          9,290                  70.80%
              DOD                          312                           371                    84.10%
              ENU                        11,514                         17,021                  67.65%
              IEV                         6,129                         13,555                  45.22%
              NNH                        22,427                         74,065                  30.28%
              OWG                        15,495                         48,381                  32.03%
              PRS                          626                           2,499                  25.05%
              SDX                        15,590                         65,125                  23.94%
              SNH                        40,944                         81,946                  49.96%
              UIB                         1,966                          7,055                  27.87%
              TOTAL                      133,321                        367,047                 36.32%

The G1DX System is a OKDHS application that compares client information entered by a OKDHS employee and
OKDHS IEVS information sources as they are periodically updated. These sources include:

    •    Wage information for the State Wage Information Collection Agency (SWICA)
    •    Unemployment Compensation
    •    All available information from the Social Security Administration (SSA)
    •    Information from the U.S. Citizenship and Immigration Services
    •    Unearned Income from the Internal Revenue Services (IRS)

Cause: The discrepancies were not cleared within the allowable 45 days per federal regulation due to an inadequate
number of personnel assigned to these duties. Additionally, management did not closely monitor the clearance of
G1DX discrepancies.

Effect: Program benefits could be provided to ineligible individuals.

Recommendation: We recommend the Department utilize the monitoring reports created for the G1DX discrepancies
that summarize these discrepancies by worker, supervisor, county, and area. These reports allow management to
monitor not only the type of discrepancy and length of days outstanding, but also to distinguish who is responsible for
clearing the discrepancy within the 45 days allowed under current federal regulation and DHS policy.

Views of Responsible Official(s)
Contact Person: Paulette Kendrick, Jeff Rosebeary (OKDHS), Ginger Clayton (OHCA)
Anticipated Completion Date: Spring, 2024
Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-031 (Repeat Finding 2021-101)
STATE AGENCY: Oklahoma Department of Human Services
FEDERAL AGENCY: Department of Health and Human Services
ALN: 93.658
FEDERAL PROGRAM NAME: Foster Care – Title IV-E
FEDERAL AWARD NUMBER: 2101OKFOST & 2201OKFOST




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FEDERAL AWARD YEAR: 2021 & 2022
CONTROL CATEGORY: Eligibility
QUESTIONED COSTS: $11,342

Criteria: 45 CFR §75.303: states, “The Non-Federal entity must:(a) Establish and maintain effective internal control
over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award
in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued
by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO).” (b) comply with federal statutes,
regulations, and the terms and conditions of federal awards; (c) evaluate and monitor the non-federal entity’s
compliance with statutes, regulations and the terms and conditions of federal awards; (d) take prompt action when
instances of noncompliance are identified including noncompliance identified in audit findings.

OAC 340:75-7-53(b): states in part, “DOC rates and descriptions. DOC reimbursements are provided for the eligible
child in addition to the foster care maintenance or adoption assistance payment, per DHS Appendix C-20, Child
Welfare Service Rates Schedule.”

OAC 340:75-7-53(3): “DOC rates I through V. The district director approves or denies the request in KIDS
based on the documentation provided within 10-business days from the request date.”

OAC 340: 75-7-53(5): “The district director reviews the child's placement type and when a child in
coordinated foster care (CFC) is approved for any level of DOC on an original approval or continuing
approval,    the    district   director  granting      approval   sends  an      email     notification to
therapeuticfostercare@okdhs.org with the child's name and KK number. TFC program staff provides the CFC
contractor with the necessary documentation to file claims for DOC payment.” (b) in part says “DOC review.
KIDS generates an email notification for the DOC rate payment review date one month before the DOC
approval end date.”

OAC 340:75-13-17(a): states, “Title IV-E eligibility is re-determined: (1) no less than 12 months from the date
of the most recent court order used to establish or maintain Title IV-E eligibility; ….”

OAC 340:75-7-94(a): Annual Update states, “The resource family assessment is updated annually from the
resource home’s approval date in KIDS.” (1) is completed yearly by the assigned resource specialist following
the home's approval on Form 04AF038E, Annual Update.

Condition and Context: We noted the following for a sample of 72 of 5,984 foster care case files:

    •   1 case files (1.39%) where The DOC used to determine the benefit amount in our data does not agree to the
        supporting documentation in the file.

    •   13 case files (18.06%) where the required eligibility redetermination of the foster home was not performed
        within twelve months after the license effective date and the home receiving benefits was determined eligible.

Cause: The agency’s internal controls were not effective to ensure adequate supervision or review of case files to
ensure all required actions occurred and required documentation is retained within the files.

Effect: The agency is not in compliance with the above stated requirements. The case worker could reduce assistance
payments if the age and DOC are not properly documented in the case file. The annual reviews are not consistently
performed within 12 months and assistance payments could be paid to a home that is not eligible.

Recommendation: We recommend DHS strengthen internal controls to ensure all required actions occur and
required documentation is retained withing the case files. In addition, we recommend training be provided to staff to
ensure they are aware of and understand the applicable policies, timeliness required and procedures for foster care
assistance.




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Views of Responsible Official(s)
Contact Person: Kevin Haddock
Anticipated Completion Date: June 2024
Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-037 (Repeat Finding 2021-015)
STATE AGENCY: Oklahoma Department of Human Services
FEDERAL AGENCY: United States Department of Health and Human Services
ALN: 93.558
FEDERAL PROGRAM NAME: Temporary Assistance for Needy Families
FEDERAL AWARD NUMBER: G2201OKTANF
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Reporting
QUESTIONED COSTS: $0

Criteria: 45 CFR §75.303 states, “The Non-Federal entity must:(a) Establish and maintain effective internal control
over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award
in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued
by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO).”

ACF-199 Reporting Instructions state in part: “The State agency or Tribal grantee should collect and report data for
each data element. The data must be complete (unless explicitly instructed to leave the field blank) and accurate (i.e.,
correct).”

Additionally, a component objective of generally accepted accounting principles is to provide accurate and reliable
information.

Condition and Context: “Critical line-item data for one line item reported on the ACF-199 report for the quarter
ending 3/31/22 did not trace and agree to supporting documentation for 1 of the 45 cases tested from a population of
4,184 cases: Data reported for the “number of months countable toward federal time limit” critical line item did not
trace and agree to supporting documentation for 1 case.”

Cause: The case was not compared to the Department’s Information Management System (IMS) to ensure the
accuracy of the report data.

Effect: The ACF-199 report for the TANF program may have inaccurate data for SFY 2022.

Recommendation: We recommend the Department implement established procedures to ensure the data recorded
on the ACF-199 report is accurate.

Views of Responsible Official(s)
Contact Person: Rhonda Archer and Jeff Rosebeary
Anticipated Completion Date: 12/19/2023
Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-041
STATE AGENCY: Oklahoma Department of Human Services (DHS) & State Department of Education (SDE)
FEDERAL AGENCY: United States Department of Agriculture
ALN: 10.542
FEDERAL PROGRAM NAME: Pandemic EBT – Food Benefits




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FEDERAL AWARD NUMBER: N/A
FEDERAL AWARD YEAR: 2022
CONTROL CATEGORY: Activities Allowed & Eligibility
QUESTIONED COSTS: $3,154

Criteria: 45 CFR §75.303(a) states, “The non-Federal entity must: Establish and maintain effective internal control
over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award
in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued
by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO).”

2 CFR § 200.400(b) states, “The non-Federal entity assumes responsibility for administering Federal funds in a manner
consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award.”

Per the SFY 2022 School Year 2020-2021 State Year Plan for students:
1. The child would be eligible for free or reduced-price meals if the National School Lunch Program and School
Breakfast Program were operating normally and therefore an allowable activity. This includes children who are:
           a. Directly certified or determined “other source categorically eligible” for SY 2020-2021, or
           b. Certified through submission of a household application processed by the child’s school district for SY
2020-2021, or
           c. Enrolled in a community eligibility provisions school or a school operating under provisions 2 or 3, or
           d. Directly certified, determined other source categorically eligible, or certified by application in SY 2019-
2020 and the school district has not made a new school meal eligibility determination for the child in SY 2020-2021.
DHS will issue benefits based upon the actual days each month that each student attends school virtually at the rate of
$6.82 per day.

Per the SFY 2022 School Year 2020-2021 State Year Plan for Child Care: “DHS will compare this list of children to
those that received school aged PEBT to ensure that any children that are receiving PEBT as they were in kindergarten
do not receive duplicate benefits.”

Condition and Context:
Based on procedures performed on 72 of 2,646,118 benefit payments to students during the school year we noted:

    •    6 of 72 instances (8.33%) in which the benefit amount issues were calculated incorrectly ($12.78).
    •    3 of 72 instances (4.17%) in which the child was not eligible for free or reduced lunches if the National
         School Lunch Program and School Breakfast Program were operating normally but was paid anyways
         ($34.00).
    •    5 of 72 instances (6.94%) in which the benefit amount was calculated correctly, however the days supplied
         by State Department of Education were incorrect ($389.08).
    •    7 of 72 instances (9.72%) in which a student was not listed as eligible in the Accountability database but was
         sent to DHS Eligible. However, the student’s benefit was later expunged as the funds were never accessed
         by the family ($0).

Based on procedures performed on 72 of 496,589 benefit payments for childcare children during the school year we
noted:

         •   6 of 72 children (8.33%) received benefits under the school-aged plan as well as the childcare plan.
             ($468.00).

Based on procedures performed on 72 of 69,534 benefit payments for childcare children during the summer we noted:

         •   6 of 72 children (8.33%) received benefits under the school-aged plan as well as the childcare plan
             ($2,250.00).




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Cause: Based on discussion with the State Department of Education (SDE) there is nothing on the Reporting Platform
to indicate the student data was validated by the school, therefore, no control is present.

For the school-age plan benefits, SDE internal controls did not effectively ensure accurate and reliable information
was provided to DHS. DHS internal controls did not effectively ensure accurate benefit amounts were provided to
eligible students.

For the childcare plan, DHS lacks adequate internal controls to ensure a child under the age of 6 did not also receive
benefits under the school-age plan.

Effect: The SDE and DHS are not administering the P-EBT program in accordance with the School Year 2020-2021
State Plans.

Recommendation: We recommend both SDE and DHS establish and implement internal controls to ensure only
eligible students/childcare children receive benefits and the benefits are accurately calculated. Further, DHS should
review and update its procedures to ensure childcare children under the age of 6 do not receive benefits from both the
School Age Plan and Childcare Plan.

Views of Responsible DHS Official(s)
Contact Person: Sondra Shelby
Anticipated Completion Date: March 30, 2024
Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

Views of Responsible OSDE Official(s)
Contact Person: Jennifer Weber
Anticipated Completion Date: March 30, 2024
Corrective Action Planned: The Oklahoma State Department of Education agrees with the finding. Please see the
DHS corrective action plan located in the corrective action plan section of this report.

FINDING NO: 2022-042 (Repeat Finding 2021-062)
STATE AGENCY: Oklahoma Department of Human Services
FEDERAL AGENCY: United States Department of Agriculture
ALN: 10.542
FEDERAL PROGRAM NAME: Pandemic EBT
FEDERAL AWARD NUMBER: N/A
FEDERAL AWARD YEAR: 2021 and 2022
CONTROL CATEGORY: Reporting
QUESTIONED COSTS: $0

Criteria: GAO Standards for Internal Control in the Federal Government (Green Book), Principle 13 – Use of Quality
Information states in part, “13.05 Management processes the obtained data into quality information that supports the
internal control system. This involves processing data into information and then evaluating the processed information
so that it is quality information. Quality information meets the identified information requirements when relevant data
from reliable sources are used. Quality information is appropriate, current, complete, accurate, accessible, and
provided on a timely basis. Management considers these characteristics as well as the information processing
objectives in evaluating processed information and makes revisions when necessary, so that the information is quality
information…”

45 CFR §75.303(a) states in part, “The Non-Federal entity must a) Establish and maintain effective internal control
over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award
in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued
by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO).”




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2 CFR §200.334 states in part, “Financial records, supporting documents, statistical records, and all other non-Federal
entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of
the final expenditure report or…”

Additionally, a component objective of generally accepted accounting principles is to provide accurate and reliable
information.

Condition and Context: When testing 12 of 12 monthly FNS-46, FNS-388 and FNS-292B reports, we noted the
following:
     • 4 of 12 FNS-46 and FNS-388 reports (33.3%) do not trace to supporting documentation. We also noted these
        reports were only updated after the State Auditor requested the support. The FNS-46 & FNS-388 reports
        were each overstated by $33,898,976.
     • 4 of 12 FNS-282B reports (33.3%) do not trace to supporting documentation and 1 of 12 reports (8.3%) could
        not be located for testing. The FNS-292B was understated by $233,843,173 and cases were under reported
        by 1,724,146.

Cause: OKDHS management does not have a process in place to ensure a documented review of the reports by
someone other than the preparer occurs in order to check for accuracy prior to submission.

Effect: The amount of P-EBT benefits issued and the number cases that received benefits were not correctly reported.

Recommendation: We recommend the Department develop and implement policies and procedures to ensure the
PEBT Issuance reports are properly reviewed and approved, by someone other than the preparer prior to submission.
We further recommend the department retain copies of all reports.

Views of Responsible Official(s)
Contact Person: Matthew Conley and Damian Lim
Anticipated Completion Date: March 30, 2024
Corrective Action Planned: The Department of Human Services partially agrees with the finding. Please see the
corrective action plan located in the corrective action plan section of this report.

FINDING NO: 2022-048
STATE AGENCY: Department of Human Services
FEDERAL AGENCY: Department of Health and Human Services
ALN: 93.558
FEDERAL PROGRAM NAME: Temporary Assistance for Needy Families
FEDERAL AWARD NUMBER: G1801OKTANF, G1901OKTANF, G2201OKTANF,
FEDERAL AWARD YEAR: 2018, 2019, 2022
CONTROL CATEGORY: Special Tests and Provisions – Penalty for Failure to Comply with Work Verification
Plan
QUESTIONED COSTS: $0

Criteria: 45 CFR 261.62(a)(2) states: “To ensure accuracy in the reporting of work activities by work-eligible
individuals on the TANF Data Report and, if applicable, the SSP–MOE Data Report, each State must establish and
employ procedures for determining how to count and verify reported hours of work.”

45 CFR 261.62(b)(1)(iii) states: “A State's Work Verification Plan must include for each countable work activity a
description of the documentation it uses to monitor participation and ensure that the actual hours of participation are
reported.”

OAC 340:10-2-6.1 Instructions to Staff 1.(b) states in part: “These participants are required to work on a high school
diploma or high school equivalency certificate. The participant documents on Form 08TW013E, Time and Progress
Report, the hours spent in class. The worker records homework or study time hours only on days the participant




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attended class on Form 08TW013E and in the system after ensuring that documentation required to count these hours
is in the case record.”

Additionally, a component objective of generally accepted accounting principles is to provide accurate and reliable
information.

Condition and Context: Based on procedures performed on 45 of 11,780 reporting months, we noted one (2.22%)
reporting month for which the work participation hours reported to HHS were not documented, verified, or reported
in accordance with the State’s Work Verification Plan. Form 08TW013E was not present in the case file documenting
educational services work participation hours for one reporting month and the ETPAI screen on the OKDHS
Mainframe documents less educational services work participation hours than were reported on the ACF-199 report
for one reporting month.

Cause: Controls were not implemented to ensure accuracy of the data used in calculating work participation rates.

Effect: Inaccurate data may have been used to calculate work participation rates.

Recommendation: We recommend the Department implement internal controls to ensure accuracy in the reporting
of work activities by work-eligible individuals on the TANF Data Report. Also, we recommend the Department ensure
that documentation of the work participation hours is maintained in the case records.

Views of Responsible Official(s)
Contact Person: Rhonda Archer
Anticipated Completion Date: 9/30/2022
Corrective Action Planned: The Department of Human Services partially agrees with the finding. Please see the
corrective action plan located in the corrective action plan section of this report.

FINDING NO: 2022-054 (Repeat Finding 2021-026)
STATE AGENCY: Oklahoma Health Care Authority (the Authority)/Oklahoma Department of Human Services
(OKDHS)
FEDERAL AGENCY: United States Department of Health and Human Services
ALN: 93.778
FEDERAL PROGRAM NAME: Medicaid Cluster
FEDERAL AWARD NUMBER: 2105OK5021 and 2205OK5021
FEDERAL AWARD YEAR: 2021 and 2022
CONTROL CATEGORY: Eligibility
QUESTIONED COSTS: $0

Criteria: 45 CFR §75.303 states, “The non-Federal entity must:(a) Establish and maintain effective internal controls
over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award
in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued
by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO).”

42 CFR §431.10(c)(2) states, “The Medicaid agency may delegate authority to make eligibility determinations or to
conduct fair hearings under this section only to a government agency which maintains personnel standards on a merit
basis.”

42 CFR §431.10(c)(3)(ii) states in part, “The Medicaid agency must exercise appropriate oversight over the eligibility
determinations and appeals decisions made by such agencies ….”

OKDHS Policy OAC 340:65-3-4 (4) states in part, “Automated data exchange with other agencies provides DHS with
information regarding household members' benefits, wages, taxes, Social Security numbers, and current addresses.




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The system compares information obtained electronically with data stored within DHS electronic records to determine
if there are discrepancies to be addressed.”

OAC 317:35-5-42(b)(5)(A) states in part, “A lump sum payment may be considered as earned or unearned income,
depending on the source of the lump sum payment. Lump sum payments may include, but are not limited to:
          (vi) Lottery or gambling winnings,….”

Condition and Context: The Authority delegates OKDHS to determine eligibility for non-MAGI (modified adjusted
gross income) recipients. OKDHS utilizes automated data exchange information obtained from other agencies to
verify the information provided by recipients.

Office of Management and Enterprise Services – Information Services Division (OMES-ISD) runs scheduled data
exchange jobs to gather the information from the various agencies for the Automated Caseload Evaluation System
(ACES). The ACES system is a web-based application that gathers all available OKDHS data exchange information
on a case, which is used by the Social Services Specialist to assist in determining Medicaid eligibility. The data
exchange jobs are assigned to a coordinator who is responsible for seeing that the jobs are placed in the TWS
(scheduling system) on the correct calendar with the date and time jobs are to run.

We determined that OKDHS did not run any data exchange jobs with the Oklahoma Lottery Commission to determine
eligibility during SFY2022.

Cause: The Authority lacked appropriate oversight over the data exchange jobs completed by OKDHS resulting in
inadequate controls over the data exchange process to ensure jobs are ran at the frequency required.

Effect: Non-compliance with the Code of Federal Regulations (CFRs) and The Authority’s Policy OAC 317:35-5-42
and OKDHS Policy OAC 340:65-3-4 (4), which could result in payment of Medicaid benefits to ineligible recipients.

Recommendation: To comply with the CFRs and The Authority’s Policy OAC 317:35-5-42 and OKDHS Policy
OAC 340:65-3-4 (4), we recommend the Authority review internal control policy and procedures over data exchange
jobs and update as necessary to ensure they are operating effectively so that data exchange jobs are run at the frequently
required and issues noted are addressed in a timely manner.

Views of Responsible Official(s)
Contact Person: Ginger Clayton, Director of Member Audits and Jeff Rosebeary, Information Security Officer, Adult
and Family Services Division DHS
Anticipated Completion Date: Lottery Commission data exchange was implemented on 8/14/2023; OHCA
monitoring – March 2024
Corrective Action Planned: The Department of Human Services agrees with the finding. See corrective action plan
located in the corrective action plan section of this report.

FINDING NO: 2022-057 (Repeat Finding 2021-064)
STATE AGENCY: Department of Human Services
FEDERAL AGENCY: Department of Health and Human Services
ALN: 93.558
FEDERAL PROGRAM NAME: Temporary Assistance for Needy Families
FEDERAL AWARD NUMBER: G1801OKTANF
FEDERAL AWARD YEAR: 2018
CONTROL CATEGORY: Special Tests and Provisions – Child Support Non-Cooperation
QUESTIONED COSTS: $0

Criteria: 45 CFR Sec. 264.30 states “(a)(1) The State agency must refer all appropriate individuals in the family of
a child, for whom paternity has not been established or for whom a child support order needs to be established,
modified or enforced, to the child support enforcement agency (i.e., the IV-D agency). (2) Referred individuals must
cooperate in establishing paternity and in establishing, modifying, or enforcing a support order with respect to the
child. (b) If the IV-D agency determines that an individual is not cooperating, and the individual does not qualify for




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a good cause or other exception established by the State agency responsible for making good cause determinations in
accordance with section 454(29) of the Act or for a good cause domestic violence waiver granted in accordance with
§ 260.52 of this chapter, then the IV-D agency must notify the IV-A agency promptly. (c) The IV-A agency (OKDHS)
must then take appropriate action by: (1) Deducting from the assistance that would otherwise be provided to the family
of the individual an amount equal to not less than 25 percent of the amount of such assistance; or (2) Denying the
family any assistance under the program.”

OAC 340:10-10-5(d) states “When the applicant or recipient is the natural or adoptive parent and fails or refuses
to cooperate with OKDHS without good cause, the TANF benefit is reduced by 25 percent of the payment
standard shown on OKDHS Appendix C-1, Maximum Income, Resource and Payment Standards, Schedule
IX, per 42 U.S.C. § 608(a)(2), for the next advance notice effective date.”

OAC 340:10-10-5 2.(a) Instructions to Staff states in part “Child Support Services (CSS) staff makes the
determination of non-cooperation, CSS staff updates the child support computer system to show an "O' in the
"cooperation" field, the reason code in the "reason code" field, and the date non-cooperation is determined in
the "non-cooperation date" field. The worker views cooperation status by entering CCPI space and the client's
family group number (FGN). When the CCPI screen shows non-cooperation, the system: (1) automatically
applies the 25 percent penalty.”

Condition and Context: SAI staff made inquiry to OKDHS Adult and Family Services Information Services Division
(AFS-ISD) regarding the TANF Child Support Non-Cooperation data. SAI was unable to obtain complete data for
SFY 2022. It was disclosed to SAI staff that the TANF Child Support Non-Cooperation files are incomplete and only
ran for the period of 9/15/2021 – 6/30/2022 during SFY 2022. The job that generated the reports was also tied to the
process that closed medical cases for Child Support Non-Cooperation, since the CARES act prevented closure of
Medicaid for any reason, the job was suspended due to COVID-19 and was not restored until 9/15/21.

Cause: Department management were unaware of TANF Child Support Non-Cooperation requirements were linked
to Medicaid in the Oklahoma Child Support Services OSIS system and temporarily discontinued determining child
support non-cooperation and therefore the 25% penalty for child support noncooperation was not applied.

Effect: The Department was not in compliance with the above stated requirement, which resulted in individuals
receiving TANF benefits while not cooperating with Child Support Enforcement. According to the 2 CFR Part 200
Child Support Non-Cooperation Compliance Requirement HHS may penalize a State for up to 5% of the State Family
Assistance Grant for failure to substantially comply with the required State child support program.

Recommendation: We recommend the Department ensure the determination of child support non-cooperation and
the penalty for non-cooperation is suspended only when directed to do so by the federal awarding agency.

Views of Responsible Official(s)
Contact Person: Rhonda Archer
Anticipated Completion Date: July 2022
Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-058
STATE AGENCY: Department of Human Services
FEDERAL AGENCY: Department of Health and Human Services
ALN: 93.558
FEDERAL PROGRAM NAME: Temporary Assistance for Needy Families
FEDERAL AWARD NUMBER: G1801OKTANF & G2101OKTANF
FEDERAL AWARD YEAR: 2018 & 2021
CONTROL CATEGORY: Allowable Cost Principals
QUESTIONED COSTS: $ 145,273




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Criteria: 45 CFR §75.303 states, “The non-Federal entity must:(a) Establish and maintain effective internal control
over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award
in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued
by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO).”

OKDHS:2-11-60(1)(A) states, “The Finance Division coordinates the preparation, revision, and accumulation of all
administrative costs of the cost allocation plan.

OKDHS:2-11-60(1)(C) states, “The Finance Division uses generally accepted accounting procedures of costs as
described in the cost allocation plan.”

A basic objective of Generally Accepted Accounting Principles is to provide accurate and reliable information.

Condition and Context: For our sample of eight of 23 TANF adjustments in SFY 2022, one adjustment (12.50%) did
not agree with supporting documentation.

Cause: An error was made on a TANF adjustment worksheet used to calculate the adjustment for cost pool 303
(TANF Work) for the quarter ending 9/30/21 and the error was not detected during review, or an adequate review was
not performed.

Effect: Cost Pool 303 (TANF Work) costs for the quarter ending 9/30/21 were overstated by $145,273.

Recommendation: We recommend the Department follow established procedures to ensure adjustments are
calculated using accurate and reliable information and that adjustments are adequately reviewed. Additionally, we
recommend a correction be made as soon as possible to correct the adjustment amount recorded for the TANF Work
cost.

Views of Responsible Official(s)
Contact Person: Kevin Haddock
Anticipated Completion Date: June 2023
Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-059 (Repeat Finding 2021-088)
STATE AGENCY: Department of Human Services
FEDERAL AGENCY: Department of Health and Human Services
ALN: 93.558
FEDERAL PROGRAM NAME: Temporary Assistance for Needy Families
FEDERAL AWARD NUMBER: G1801OKTANF, G1901OKTANF and G2201OKTANF
FEDERAL AWARD YEAR: 2018, 2019, and 2022
CONTROL CATEGORY: Special Tests and Provisions – Penalty for Refusal to Work
QUESTIONED COSTS: $0

Criteria: 45 CFR Sec. 261.14(a) states in part “If an individual refuses to engage in work required under section 407
of the Act, the State must reduce or terminate the amount of assistance payable to the family, subject to any good
cause or other exceptions the State may establish...”

OAC 340:10-2-2(c) states in part “The worker must contact the individual to determine good cause…”

INSTRUCTIONS TO STAFF OAC 340:10-2-2 2.(c) states “When the worker is unable to reach the client by phone
to schedule an interview, the worker may use Form 08AD092E, Client Contact and Information Request, to request
contact.”




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INSTRUCTIONS TO STAFF OAC 340:10-2-2 2.(d) states “Family Assistance/Client Services (FACS) case notes
must clearly document the worker's efforts to contact the client and, when contact is made, the client’s reasons for
failure to participate.”

Condition and Context: For a sample of 60 of 637 case sanction or closure occurrences, we noted eight occurrences
(13.33% of the sample) where effort to contact the individual and their refusal/failure to participate without good cause
was not made or was not documented in the case file or the Family Assistance/Client Services (FACS) case notes.

Cause: Controls in place are not adequate to ensure OKDHS policies and procedures that require the worker contact
individuals to determine good cause and document their efforts are consistently followed by staff.

Effect: The Department is not in compliance with the above stated internal policies and federal program requirements,
which may result in individuals not meeting TANF work participation requirement with good cause to be denied
TANF benefits.

Recommendation: We recommend the Department strengthen internal controls designed to ensure staff follow
established policy to 1) make every effort to contact individuals to determine good cause and document their efforts
as required, and 2) ensure that documentation of their effort to contact individuals to determine good cause is
maintained in the case records.

Views of Responsible Official(s)
Contact Person: Rhonda Archer
Anticipated Completion Date: 06/09/2022
Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-060 (Repeat Finding 2021-065)
STATE AGENCY: Department of Human Services
FEDERAL AGENCY: Department of Health and Human Services
ALN: 93.558
FEDERAL PROGRAM NAME: Temporary Assistance for Needy Families
FEDERAL AWARD NUMBER: G1801OKTANF, G2101OKTANF and G2201OKTANF
FEDERAL AWARD YEAR: 2018, 2021, and 2022
CONTROL CATEGORY: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Eligibility, and
Level of Effort
QUESTIONED COSTS: $15,969

Criteria: 45 CFR § 206.10(a)(1)(ii) states in part, “The agency shall require a written application, signed under a
penalty of perjury, on a form prescribed by the State agency, from the applicant himself, or his authorized
representative, or, where the applicant is incompetent or incapacitated, someone acting responsibly for him…”

OAC 340:65-3-1(a) states in part, “The eligibility determination process includes the applicant filing a signed
application, the worker certifying or denying benefits, and all subsequent activities required to receive continuous
benefits… “

OAC 340:65-1-3 states in part, “…The case record is the means used by OKDHS to document the factual basis for
decisions.”

OAC 340:65-1-3 Instructions to Staff states in part, “(a) Definition of Adult and Family Services (AFS) case
records. The AFS electronic case record is an accumulation of imaged documents organized into packets based on
case actions that document a client's eligibility for and receipt of benefits. The case record also includes all
electronically maintained data associated with the same case number. For legal requirements and audit purposes, the
Oklahoma Department of Human Services (DHS) retains case records for at least three years after all benefits included
in the case close…”




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OAC 340:65-3-8(e)(1) states in part, “Benefit renewal interview requirements vary depending on the program. The
TANF program requires a face-to-face interview. The face-to-face interview may be conducted in the OKDHS
office, at a home visit, or through a virtual video conference. When none of these options are feasible due to
a hospitalization or other extenuating circumstance and the worker obtains prior approval from Adult and
Family Services (AFS) TANF Unit staff, a phone interview may be conducted at application or renewal.”

OAC 340:65-3-8(b)(2)(A) states in part, “A benefit renewal is completed at 12-month intervals, unless an earlier
renewal date is warranted, with a TANF recipient.”

OAC 340:10-13-1(b)(1) states, “An otherwise eligible child who is 18 years of age is included in the assistance
unit if he or she is a full time secondary school student, attending HSE classes, an alternative high school, or
a virtual school and expects to graduate before or during the month he or she turns 19 years of age.”

An effective internal control system provides for proper record retention to ensure that all information and transactions
are accurately recorded and retained.

Condition and Context: In a sample of 60 of 6,056 TANF cases, we noted the following:
   • Seven case files did not contain documentation of an eligibility re-determination for benefits paid during SFY
        2022 and benefits were not discontinued when the period of eligibility expired (Questioned Costs $14,212).
   • One case file did not contain documentation of an eligibility determination for benefits paid during SFY 2022
        and benefits were not discontinued when the period of eligibility expired (Questioned Costs $613).
   • Three case files that included children 18 years old did not contain documentation the child was enrolled as
        a full-time student in a secondary school (or the equivalent level of vocational or technical training)
        (Questioned Costs $1,144).

Cause: Adequate internal controls are not in place to ensure initial determinations and redeterminations are properly
performed and documented.

Effect: The Department is not in compliance with the above stated internal policies and federal program requirements,
which may result in ineligible individuals receiving TANF benefits and cause the maintenance of effort expenditures
to be overstated.
Recommendation: We recommend the Department follow policy and complete eligibility determinations and
redeterminations for all TANF recipients as required and ensure benefits are discontinued when the period of eligibility
expires. Also, we recommend the Department design and implement controls to ensure the determination and
redetermination documentation is maintained in the case records.

Views of Responsible Official(s)
Contact Person: Rhonda Archer
Anticipated Completion Date: 06/09/2022
Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-061 (Repeat Finding 2021-066)
STATE AGENCY: Department of Human Services
FEDERAL AGENCY: Department of Health and Human Services
ALN: 93.558
FEDERAL PROGRAM NAME: Temporary Assistance for Needy Families
FEDERAL AWARD NUMBER: G1801OKTANF, G2101OKTANF and G2201OKTANF
FEDERAL AWARD YEAR: 2018, 2021, and 2022
CONTROL CATEGORY: Special Tests and Provisions – Child Support Non-Cooperation
QUESTIONED COSTS: $0

Criteria: 45 CFR Sec. 264.30 states “(a)(1) The State agency must refer all appropriate individuals in the family of
a child, for whom paternity has not been established or for whom a child support order needs to be established,
modified or enforced, to the child support enforcement agency (i.e., the IV-D agency). (2) Referred individuals must




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And Questioned Costs
cooperate in establishing paternity and in establishing, modifying, or enforcing a support order with respect to the
child. (b) If the IV-D agency determines that an individual is not cooperating, and the individual does not qualify for
a good cause or other exception established by the State agency responsible for making good cause determinations in
accordance with section 454(29) of the Act or for a good cause domestic violence waiver granted in accordance with
§ 260.52 of this chapter, then the IV-D agency must notify the IV-A agency promptly. (c) The IV-A agency must
then take appropriate action by: (1) Deducting from the assistance that would otherwise be provided to the family of
the individual an amount equal to not less than 25 percent of the amount of such assistance; or (2) Denying the family
any assistance under the program.”

OAC 340:65-1-3 states in part “…The case record is the means used by the Agency to document the factual basis for
decisions.”

OAC 340:65-1-3 Instructions to Staff states in part “(a) Definition of Adult and Family Services (AFS) case
records. The AFS electronic case record is an accumulation of imaged documents organized into packets based on
case actions that document a client's eligibility for and receipt of benefits. The case record also includes all
electronically maintained data associated with the same case number. For legal requirements and audit purposes, the
Oklahoma Department of Human Services (DHS) retains case records for at least three years after all benefits included
in the case close…”

OAC 340:10-10-5(a) states in part “When the reason for deprivation is absence, each applicant or recipient of
Temporary Assistance for Needy Families (TANF) must assign to Oklahoma Human Services (OKDHS) any
support rights, including cash medical, that is pending or continuing for any family member included in the
assistance unit as a condition of eligibility. This assignment excludes amounts ordered for past due or
judgment amounts for persons who never received TANF prior to this application. For persons who previously
received TANF, the assignment includes past due or judgment amounts previously assigned to OKDHS for
the time period the applicant received TANF. Failure to assign support rights makes the assistance unit
ineligible for TANF.”

OAC 340:10-10-5(b) states in part “As a condition of TANF eligibility, each applicant or recipient, who is the
natural or adoptive parent of the child(ren) included in the assistance unit, must cooperate with OKDHS in
obtaining support for each child, per Section 608 of Title 42 of the United States Code (42 U.S.C. §
608). Failure of the applicant or recipient to cooperate without good cause may be indicated during the
application interview or at any time further action by the recipient is necessary.”

Condition and Context: Based on procedures performed on 60 of 6,056 cases, we noted four cases (6.67%) where
no documentation could be found in the case file indicating the applicant was required to cooperate with the State in
obtaining child support or requiring the applicant to assign the support rights to the State for benefits paid during SFY
2022.

Cause: Controls in place are not adequate to ensure the Oklahoma Department of Human Services (OKDHS) policies
and procedures that require TANF applicants to assign to the OKDHS any support rights are consistently followed by
staff.

Effect: The Department may not be following the above stated internal policies or adequate documentation was not
retained in the file. This may result in ineligible individuals receiving TANF benefits or eligible individual’s benefits
not being reduced.

Recommendation: We recommend the Department strengthen internal controls designed to ensure staff follow
policy and procedures to ensure TANF applicants assign to the Oklahoma Department of Human Services (OKDHS)
any support rights or determine the assistance unit ineligible. Also, we recommend the Department ensure that
documentation of the assignment of child support rights is maintained in the case records.

Views of Responsible Official(s)
Contact Person: Rhonda Archer
Anticipated Completion Date: 06/07-09/2022




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Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-062 (Repeat Finding 2021-067)
STATE AGENCY: Department of Human Services
FEDERAL AGENCY: Department of Health and Human Services
ALN: 93.558
FEDERAL PROGRAM NAME: Temporary Assistance for Needy Families
FEDERAL AWARD NUMBER: G1801OKTANF, G2101OKTANF and G2201OKTANF
FEDERAL AWARD YEAR: 2018, 2021, and 2022
CONTROL CATEGORY: Special Tests and Provisions – Income Eligibility and Verification System
QUESTIONED COSTS: $0

Criteria: 2 CFR Part 200 Compliance Supplement Part 4 TANF Part N2 Compliance Requirement states in part,
“Each state shall participate in the Income Eligibility and Verification System (IEVS) required by section 1137 of the
Social Security Act as amended. Under the state plan the state is required to coordinate data exchanges with other
federally assisted benefit programs, request and use income and benefit information when making eligibility
determinations and adhere to standardized formats and procedures in exchanging information with other programs
and agencies.”

DHS Policy 340:65-3-1 (e)(2)(B)&(C) states in part, “The worker is responsible for collecting information
necessary for determining the applicant's initial and continuing eligibility. Information is considered verified
when not questionable or inconsistent with known facts, and the information provider is the primary source
of the information. Unless questionable, the worker accepts, without further verification, the unearned income
information obtained through the Beneficiary and Earnings Data Exchange System, from the Social Security
Administration; Supplemental Security Income /State Data Exchange System, from SSA; Unemployment
Insurance Benefits (UIB), from the Oklahoma Employment Security Commission; and workers' compensation
documents from the Workers' Compensation Commission; and alien status information obtained through
Systematic Alien Verification for Entitlements (SAVE), from the United States Citizenship and Immigration
Services (USCIS).”

DHS Policy 340:65-1-3 INSTRUCTIONS TO STAFF 1. (a) states in part, “Definition of Adult and Family Services
(AFS) case records. The AFS electronic case record is an accumulation of imaged documents organized into packets
based on case actions that document a client's eligibility for and receipt of benefits.”

DHS Policy 340:65-1-3 INSTRUCTIONS TO STAFF 1. (b)(2) states, “The FACS system includes an Interview
Notebook, an Eligibility Notebook, and FACS case notes. The worker uses FACS to process applications, renewals,
and change actions, and FACS case notes for case documentation.”

DHS Policy 340:65-1-3 INSTRUCTIONS TO STAFF 1. (b)(4)(D)(i) states in part, “Case notes must describe how
initial eligibility, continuing eligibility, or ineligibility was determined, the verification used, and how income was
calculated.”

Condition and Context: In a sample of 60 of 6,056 TANF cases, we noted five cases (8.33%) where no income
eligibility and verification system documentation was present in the electronic case record or FACS case notes for the
period tested.

Cause: Controls in place are not adequate to ensure staff consistently follow OKDHS policies and procedures that
require the worker to review data exchange information at application and eligibility renewal. The initial verification
of income is a manual process performed by the social worker. This process was either omitted or not documented
when determining eligibility.

Effect: The income used to determine a TANF applicant’s eligibility may not be accurate which could allow for an
ineligible recipient to receive benefits.




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Recommendation: We recommend the Department strengthen internal controls designed to ensure staff follow
established policy and procedures regarding the review of data exchange information at application and eligibility
renewal. Also, we recommend the Department ensure that documentation is maintained to support income verification
through data exchange was utilized in eligibility determination or re-determination.

Views of Responsible Official(s).
Contact Person: Rhonda Archer
Anticipated Completion Date: 09/30/2022
Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-063
STATE AGENCY: Department of Human Services
FEDERAL AGENCY: Department of Health and Human Services
ALN: 93.558
FEDERAL PROGRAM NAME: Temporary Assistance for Needy Families
FEDERAL AWARD NUMBER: G1801OKTANF, G2101OKTANF and G2201OKTANF
FEDERAL AWARD YEAR: 2018, 2021, and 2022
CONTROL CATEGORY: Special Tests and Provisions – Child Support Non-Cooperation
QUESTIONED COSTS: $0

Criteria: 45 CFR Sec. 261.14 states “(a) If an individual refuses to engage in work required under section 407 of
the Act, the State must reduce or terminate the amount of assistance payable to the family, subject to any good cause
or other exceptions the State may establish.”

OAC 340:65-1-3 states in part “…The case record is the means used by the Agency to document the factual basis for
decisions.”

OAC 340:65-1-3 Instructions to Staff states in part “(a) Definition of Adult and Family Services (AFS) case
records. The AFS electronic case record is an accumulation of imaged documents organized into packets based on
case actions that document a client's eligibility for and receipt of benefits. The case record also includes all
electronically maintained data associated with the same case number. For legal requirements and audit purposes, the
Oklahoma Department of Human Services (DHS) retains case records for at least three years after all benefits included
in the case close…”

OAC 340:10-2-1 states in part “All parents or needy caretakers who apply for or receive Temporary Assistance
for Needy Families (TANF) cash assistance from Oklahoma are required to be engaged in a work activity. The
parent(s) or needy caretaker must participate in work activities for at least the minimum number of hours
necessary to move that person into employment and self-sufficiency.”

OAC 340:10-2-1 INSTRUCTIONS TO STAFF states in part “During the application process, the worker and
applicant complete Form 08TW002E, TANF Work/Personal Responsibility Agreement, and the worker
reviews the responsibilities listed on the form with the applicant before he or she signs the agreement.”

Condition and Context: Based on procedures performed on 60 of 6,056 cases, we noted two cases (3.33%) where no
documentation was present in the case file indicating the applicant agreed to cooperate with TANF work requirements,
was not exempt under State rules or met the State good cause criteria and was determined eligible for benefits paid
during SFY 2022.

Cause: Controls in place are not adequate to ensure the Oklahoma Department of Human Services (OKDHS) policies
and procedures that require TANF applicants agree to cooperate with TANF work requirements during eligibility
determination and redetermination are consistently followed by staff.




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Effect: The Department may not be following the above stated internal policies or adequate documentation was not
retained in the file. This may result in ineligible individuals receiving TANF benefits, or eligible individual’s benefits
not being reduced.

Recommendation: We recommend the Department strengthen internal controls designed to ensure staff follow
policy and procedures to ensure TANF applicants agree to cooperate with TANF work requirements if the applicant
is not exempt under State rules or meets the State good cause criteria or determine the assistance unit ineligible. Also,
we recommend the Department ensure that documentation of the TANF work requirement agreement is maintained
in the case records.

Views of Responsible Official(s)
Contact Person: Rhonda Archer
Anticipated Completion Date: 03/01/24
Corrective Action Planned: The Department of Human Services partially agrees with the finding. Please see the
corrective action plan located in the corrective action plan section of this report.

FINDING NO: 2022-064 (Repeat Finding 2021-046)
STATE AGENCY: Department of Human Services
FEDERAL AGENCY: Department of Health and Human Services
ALN: 93.558
FEDERAL PROGRAM NAME: Temporary Assistance for Needy Families
FEDERAL AWARD NUMBER: G1801OKTANF, G2101OKTANF, & G2201OKTANF
FEDERAL AWARD YEAR: 2018, 2021, & 2022
CONTROL CATEGORY: Eligibility
QUESTIONED COSTS: $7,318

Criteria: 45 CFR 264.1(a)(1) states: “Subject to the exceptions in this section, no State may use any of its Federal
TANF funds to provide assistance (as defined in §260.31 of this chapter) to a family that includes an adult head-of-
household or a spouse of the head-of-household who has received Federal assistance for a total of five years (i.e., 60
cumulative months, whether or not consecutive).”

45 CFR 264.1(c) states: “States have the option to extend assistance paid for by Federal TANF funds beyond the five-
year limit for up to 20 percent of the average monthly number of families receiving assistance during the fiscal year
or the immediately preceding fiscal year, whichever the State elects. States are permitted to extend assistance to
families only on the basis of:
(1) Hardship, as defined by the State; or (2) The fact that the family includes someone who has been battered, or
subject to extreme cruelty based on the fact that the individual has been subjected to: (i) Physical acts that resulted in,
or threatened to result in, physical injury to the individual; (ii) Sexual abuse; (iii) Sexual activity involving a dependent
child; (iv) Being forced as the caretaker relative of a dependent child to engage in nonconsensual sexual acts or
activities; (v) Threats of, or attempts at, physical or sexual abuse; (vi) Mental abuse; or (vii) Neglect or deprivation of
medical care.”

OAC 340:10-1-4 states: “Both federal and state laws specify that assistance is available to those persons who meet
certain conditions of eligibility. Receipt of Temporary Assistance for Needy Families has been restricted to a lifetime
limit of 60 months, whether consecutive or not, effective October 1, 1996. The time limit can be extended when a
hardship extension has been approved.”

OAC INSTRUCTIONS TO STAFF 340:10-3-56 5.(c)(1) states: “When the client meets all other eligibility factors
and requests a hardship extension, the worker and applicant complete and sign Part I of Form 08TW024E, Extension
Request for Temporary Assistance for Needy Families (TANF), during the face-to-face interview.”

OAC INSTRUCTIONS TO STAFF 340:10-3-56 5.(d)(2)(B) states: “The client’s signature date on Form 08TW024E
is used as the hardship extension request application date. Action is not taken on the hardship extension request until
AFS TANF staff reaches a decision.”




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And Questioned Costs
OAC INSTRUCTIONS TO STAFF 340:10-3-56 5.(f)(1) & (2) states: (1) “When the client requests an additional
extension, the worker and client complete and sign Part 1 of Form 08TW025E, Extension Review/Disposition. The
worker gives Form 08AD092E to the client when additional supporting documentation is needed.” (2) “The worker
emails TANF@okdhs.org to request a hardship extension, attaches Form 08TW025E, and images any supporting
documentation to the case record. AFS TANF staff reviews the request, completes Part II of Form 08TW025E
approving or disapproving the request, and sends Form 08TW025E and all submitted information to the worker.”

Condition and Context: When testing 7 of the 64 TANF cases receiving benefits for more than sixty months, we
noted the following:
    • Form 08TW024E was not present in the case file documenting approval of a hardship for extension of
         benefits prior to benefits being awarded for four cases (57.14%).
    • Form 08TW025E was not present in the case file documenting approval of a hardship for extension of
         benefits prior to benefits being awarded for one case (14.29%).

Cause: Controls in place are not adequate to ensure OKDHS policies and procedures that require the worker and
applicant to complete and sign Part I and Part II of Form 08TW024E, Extension Request for Temporary Assistance
for Needy Families or Part I and Part II of Form 08TW025E, Extension Review/Disposition are consistently followed
by staff.

Effect: The Department is not in compliance with the above stated internal policies, which may allow ineligible
individuals to receive TANF benefits.

Recommendation: We recommend the Department strengthen internal controls designed to ensure staff follow
established policy and procedures addressing the completion, approval, adequate documentation, and retention of
request for TANF hardship extensions.

Views of Responsible Official(s)
Contact Person: Rhonda Archer
Anticipated Completion Date: 09/30/2022
Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-065
STATE AGENCY: Department of Human Services
FEDERAL AGENCY: Department of Health and Human Services
ALN: 93.558
FEDERAL PROGRAM NAME: Temporary Assistance for Needy Families
FEDERAL AWARD NUMBER: G1801OKTANF, G2101OKTANF, G2201OKTANF
FEDERAL AWARD YEAR: 2018, 2021, 2022
CONTROL CATEGORY: Eligibility
QUESTIONED COSTS: $0

Criteria: 2 CFR Part 200 Compliance Supplement Part 4 TANF Part E Compliance Requirement states in part,
“Qualified aliens, as defined in 8 USC 1641(b), are the only non-citizens who may receive a TANF public benefit, as
defined in 8 USC 1611(c)), using federal TANF or commingled funds. Qualified aliens are lawful permanent residents,
asylees, refugees, aliens paroled into the United States for at least one year, aliens whose deportations are being
withheld, aliens granted conditional entry, Cuban/Haitian entrants, and certain battered aliens. Victims of severe forms
of trafficking and certain family members are also eligible for federally funded or administered public benefits and
services to the same extent as refugees.”

OAC 340:10-15-1(e) states: “Persons declaring qualified alien status must provide documentation of their alien
status and have their status verified through the Systematic Alien Verification for Entitlements (SAVE)
program's Alien Status Verification Index. When secondary verification must be pursued through USCIS, the
worker must not delay, deny, close, or reduce benefits to an alien pending a response from USCIS.”




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OAC 340:65-3-4(5) states: “All applicants and recipients of the TANF, SoonerCare (Medicaid), Supplemental
Nutrition Assistance Program (SNAP), Low Income Home Energy Assistance Program (LIHEAP), State
Supplemental Payment (SSP), and Child Care Subsidy Program benefits are required to declare their
citizenship status. Persons who declare themselves or their minor child non-citizens must present
documentation of their legal alien status from the United States Citizenship and Immigration Services (USCIS)
or other acceptable source. The status, as determined from the documentation, must be verified through the
Alien Status Verification Index (ASVI) maintained by USCIS.”

OAC INSTRUCTIONS TO STAFF 340:65-3-4 #18 states: “The worker accesses the Alien Status Verification Index
(ASVI) through a web-based online system at https://save.uscis.gov/Web/vislogin.aspx?JS=YES. Online responses
are returned for the initial and additional verification inquiries. The worker images and files the online verification
number or entire verification record in the case record or copies and pastes the information into FACS case notes.”

Condition and Context: When testing 5 of the 49 TANF cases receiving benefits with a Citizen Status code of “2”
(Qualified alien) or code “9” (Unknown) from the ACF-199 T2 data, we noted one case (20%) where the non-citizen
documentation of legal alien status was not verified through the Alien Status Verification Index (ASVI)/SAVE system
to verify applicant data and determine eligibility in accordance with the state plan.

Cause: Controls in place are not adequate to ensure OKDHS policies and procedures that require the worker verify
and document a non-citizen’s alien status through the Alien Status Verification Index are consistently followed
by staff.

Effect: The Department is not in compliance with the above stated internal policies, which may allow ineligible
individuals to receive TANF benefits.

Recommendation: We recommend the Department strengthen internal controls designed to ensure staff follow
established policy and procedures for verifying and documenting a non-citizen’s alien status through the Alien
Status Verification Index.

Views of Responsible Official(s)
Contact Person: Rhonda Archer
Anticipated Completion Date: 9/30/2022
Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-066 (Repeat Finding 2021-053)
STATE AGENCY: Oklahoma Department of Human Services (OKDHS)
FEDERAL AGENCY: Department of Health and Human Services
CFDA NO: 93.558
FEDERAL PROGRAM NAME: Temporary Assistance for Needy Families
FEDERAL AWARD NUMBER: G1801OKTANF; G1901OKTANF; G2101OKTANF; G2201OKTANF
FEDERAL AWARD YEAR: 2018, 2019, 2021, 2022
CONTROL CATEGORY: Maintenance of Effort
QUESTIONED COSTS: $0

Criteria: 45 CFR §75.303 states, “The non-Federal entity must a) Establish and maintain effective internal control
over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award
in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued
by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO).”

According to Title 45 CFR §263.2, “What kinds of State expenditures count toward meeting a State's basic MOE
expenditure requirement? (a) Expenditures of State funds in TANF or separate State programs may count if they are
made for the following types of benefits or services: … (3) Education activities designed to increase self-sufficiency,




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job training, and work (see §263.4); … (b) With the exception of paragraph (a)(4)(ii) of this section, the benefits or
services listed under paragraph (a) of this section count only if they have been provided to or on behalf of eligible
families.”

Title 45 CFR §263.4 states, “When do educational expenditures count? (a) Expenditures for educational activities or
services count if: (1) They are provided to eligible families (as defined in §263.2(b)) to increase self-sufficiency, job
training, and work; and (2) They are not generally available to other residents of the State without cost and without
regard to their income. (b) Expenditures on behalf of eligible families for educational services or activities provided
through the public education system do not count unless they meet the requirements under paragraph (a) of this
section.”

According to the intergovernmental agreement between DHS and the Oklahoma State Regents for Higher Education
(OSRHE), “In accordance with this agreement, a 20% match to the Block Grant funding expended by DHS for post-
secondary/vocational training programs at local colleges will be provided through OSRHE or local college funds
and/or in-kind contributions. In lieu of transfer of matching funds from OSRHE or Local Col1eges to DHS, OSRHE
will identify the specific amount of matching funds ascertained and that are available for DHS to use as the non-
federal share of Block Grant expenditures.” Additionally, “the purpose of this agreement is to set forth a process
designed to provide post-secondary/vocational education skills (and/or other necessary skills) needed to gain
employment for eligible recipients in the DHS TANF WORK program.

Condition and Context: For a sample of 12 of 116 cases, we noted three cases (25.00%) where the case was not
recorded as being placed in a TANF Work activity on the DSD Mainframe ETE screen and/or no documentation was
found in the case file for the student's attendance of education activities at one of the OSRHE colleges during SFY
2022.

Cause: Adequate review of the recipients receiving post-secondary/vocational education needed to gain employment
through the OKDHS TANF Work program was not performed to ensure qualified expenditures used to meet MOE
requirements were made on behalf of TANF eligible families that received the educational and training activities
during SFY 2022.

Effect: OSRHE education and training expenditures reported as TANF MOE may not have been made to, or on
behalf of, TANF eligible families during SFY 2022.

Recommendation: We recommend the agency design and implement internal controls and develop written policies
and procedures to ensure any OSRHE education and training expenditures utilized as TANF MOE have been made
to, or on behalf of, TANF eligible families during the period the expenditures were reported.

Views of Responsible Official(s):
Contact Person: Rhonda Archer
Anticipated Completion Date: 9/30/2022
Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-067 (Repeat Finding 2021-068)
STATE AGENCY: Oklahoma Department of Human Services
FEDERAL AGENCY: United States Department of Health and Human Services
ALN: 93.558
FEDERAL PROGRAM NAME: Temporary Assistance for Needy Families
FEDERAL AWARD NUMBER: G1801OKTANF, G1901OKTANF, G2101OKTANF, and G2201OKTANF
FEDERAL AWARD YEAR: 2018, 2019, 2021, and 2022
CONTROL CATEGORY: Activities Allowed or Unallowed and Level of Effort
QUESTIONED COSTS: $0

Criteria: Title 45 CFR §263.2(b) states, “With the exception of paragraph (a)(4)(ii) of this section, the benefits or
services listed under paragraph (a) of this section count only if they have been provided to or on behalf of eligible




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families. An ‘‘eligible family’’ as defined by the State, must: (1) Be comprised of citizens or noncitizens who: (i) Are
eligible for TANF assistance; (ii) Would be eligible for TANF assistance, but for the time limit on the receipt of
federally funded assistance; or (iii) Are lawfully present in the United States and would be eligible for assistance, but
for the application of title IV of PRWORA; (2) Include a child living with a custodial parent or other adult caretaker
relative (or consist of a pregnant individual); and (3) Be financially eligible according to the appropriate income and
resource (when applicable) standards established by the State and contained in its TANF plan.”

The State of Oklahoma State Plan for Title IV-A of the Social Security Act Temporary Assistance for Needy Families
(TANF) in the TANF Funded Programs section under Other TANF-Funded Services states in part, “Oklahoma utilizes
the TANF block grant to fund several services and programs that meet one of the four TANF goals and which may be
provided to families with incomes above the threshold for TANF cash assistance. Income eligibility for these services
and programs is limited to families at or below 300% of the Federal Poverty Level (FPL) unless otherwise noted and
Programs and Services that address Goals 3 and/or 4 of TANF do not have income limits unless otherwise noted.”
Noted for Child Welfare Services Non IV-E TANF goal 1 the description states “Services that are designed to promote
and allow children to be cared for in their own home or the homes of relatives; as well as provide emergency assistance.
Children receiving TANF, SNAP, Childcare or Sooner Care benefits at the time of service enrollment are
automatically deemed eligible for this category.”

OAC 340:75-13-61 Medical services to children in placement states in part, “Children in Oklahoma Department of
Human Services (DHS) custody and out-of-home placements have fee-for service medical cases. The Oklahoma
Health Care Authority pays for each medical service provided at the Medicaid allowable rate. The child welfare
specialist: … (3) applies for Medicaid for a child within five-business days of the child's removal from the home by
entering the child's removal information into the Child Abuse and Neglect Information System (KIDS) Removal
screen. (A) When the child's removal information is entered into the KIDS Removal screen, a KIDS assignment is
generated to the custody specialist. (B) The KIDS assignment to the custody specialist is considered the referral for:
(i) Title XIX medical benefits; and (ii) Title IV-E eligibility determination.”

45 CFR §75.303 states, “The non-Federal entity must:(a) Establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued
by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO).”

Condition and Context: We requested the detailed data supporting the $12,668,130 reported on line 20.a of the ACF-
196R reports for SFY22. Based on conversation with OKDHS management, the detailed data represents CWS clients
that are Medicaid eligible and automatically deemed eligible for TANF and is used in the calculation of the applicable
percentage rate to be applied to CWS contracts expenditures to determine the amount funded by TANF. We performed
procedures on a sample of 55 of 1,599 CWS recipients in the detailed data to determine if they were Medicaid eligible
by reviewing OKDHS KIDS removal screens documenting the period the child was removed from the home. We
noted forty-one (74.55%) CWS clients for which the Child Abuse and Neglect Information System (KIDS) Removal
screen did not contain information the child had been removed from the home during SFY 2022; these CWS clients
do not appear to be Medicaid eligible, therefore they are not eligible for TANF funding and are considered a
unallowable activity for the TANF program.

    •    For thirty-seven children, the date the child was removed from the home was not documented.
    •    Two children were removed from the home after the end of SFY 2022.
    •    One child’s removal date and removal end date was prior to SFY 2022.
    •    One child’s last name was not in the OKDHS KIDS system.

Cause: Adequate internal controls are not in place or were not implemented to ensure that only allowable activities
were charged to the TANF program.

Effect: An incorrect percentage rate may have been applied to CWS contracts expenditures to determine the amount
funded by TANF.




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Recommendation: We recommend the Department design and implement controls to ensure information used in the
calculation of the applicable percentage rate applied to CWS contracts expenditures to determine the amount charged
to the TANF program is accurate and that only allowable activities are charged to the TANF program.

Views of Responsible Official(s)
Contact Person: Kevin Haddock
Anticipated Completion Date: N/A
Corrective Action Planned: The Department of Human Services did not agree with the finding.

FINDING NO: 2022-068
STATE AGENCY: Oklahoma Department of Human Services
FEDERAL AGENCY: United States Department of Health and Human Services
ALN: 93.558
FEDERAL PROGRAM NAME: Temporary Assistance for Needy Families
FEDERAL AWARD NUMBER: G1801OKTANF, G1901OKTANF, G2101OKTANF, and G2201OKTANF
FEDERAL AWARD YEAR: 2018, 2019, 2021, and 2022
CONTROL CATEGORY: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
QUESTIONED COSTS: $0

Criteria: 2 CFR § 200.303(a) – Internal Controls states in part, “The Non-Federal entity must establish and maintain
effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the
Federal award.”

A component objective of an effective internal control system is to ensure accurate and reliable information through
a proper review and approval process.

Condition and Context: In a sample of 63 of 1,598 TANF direct cost pools non-payroll claims, we noted 3 claims
(4.76%) where the claim supporting documentation was not appropriately approved or the approval was not
documented. The approval of one invoice was not documented, one purchase order was approved by an individual
that was not listed in the authorized signature file, and one flex fund voucher was approved by an individual that was
not listed on the authorized system listing.

Cause: A lack of internal controls to ensure claims are properly reviewed and approved for allowability.

Effect: Failure to properly review and approve expenditure claims could result in payment of unallowable claims.

Recommendation: We recommend that DHS develop and implement appropriate policies and procedures to ensure
claims are properly reviewed and approved prior to payment.

Views of Responsible Official(s)
Contact Person: Kayla Urtz
Anticipated Completion Date: August 2022
Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-074 (Repeat Finding 2021-028)
STATE AGENCY: Oklahoma Health Care Authority (the Authority)/Oklahoma Department of Human Services
FEDERAL AGENCY: United States Department of Health and Human Services
ALN: 93.778
FEDERAL PROGRAM NAME: Medicaid Cluster
FEDERAL AWARD NUMBER: 2105OK5MAP and 2205OK5MAP
FEDERAL AWARD YEAR: 2021 and 2022
CONTROL CATEGORY: Eligibility




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QUESTIONED COSTS: $0

Criteria: 42 CFR §431.211 states in part “The State or local agency must send a notice at least 10 days before the date
of action…”

42 CFR §433.400(c)(2)(iii) states, “For beneficiaries not described in paragraph (c)(2)(i) or (ii) of this section, the
state must continue to provide at least the same level of medical assistance as was provided as of or after March 18,
2020.”

CMS-9912 Interim Final Rule with Comment Factsheet on Updated Policy for Maintaining Medicaid Enrollment
during the Public Health Emergency for COVID-19 states “In states claiming the temporary FMAP increase, a
beneficiary’s Medicaid enrollment may be terminated prior to the first day of the month after the PHE for COVID-19
ends if:

    1.   The beneficiary requests a voluntary termination of eligibility;
    2.   The beneficiary dies;
    3.   The beneficiary ceases to be a resident of the state; or
    4.   The beneficiary was not validly enrolled.”

Additionally, a component objective of generally accepted accounting principles is to provide accurate and reliable
information.

Condition and Context: We tested a non-statistical sample of 72 cases that were closed during the year and reviewed
the case record documentation maintained at OHCA and DHS for Medicaid eligibility.

         OKDHS Medicaid

         •   For 2 (14.29 %) of 14 cases tested the case was closed for circumstances during the PHE other than:
                 o The beneficiary requests a voluntary termination of eligibility;
                 o The beneficiary dies;
                 o The beneficiary ceases to be a resident of the state;
                 o The beneficiary was not validly enrolled on or after March 18, 2020

Cause: OHCA lacked adequate internal controls and appropriate processes to ensure services were only reduced on
cases outlined at 42 CFR §433.400 paragraph (c)(2)(i) or (ii).

OKDHS lacked adequate internal controls and appropriate processes to ensure cases were only closed as outlined in
CMS-9912.

Effect: Non-compliance with the Code of Federal Regulations (CFRs) and CMS guidance (CMS-9912) on
maintaining Medicaid Enrollment during the Public Health Emergency for COVID-19, which could result in the
termination of the temporary FMAP increase.

Recommendation: To comply with the CFRs and CMS guidance (CMS-9912) we recommend OKDHS review
internal control policy and procedures over decisions affecting an applicant or beneficiaries’ eligibility, including the
termination of benefits to align with CMS-9912.

Views of Responsible Official(s)
Contact Person: April Anonsen (OKHCA) Carla McCarrell-Williams (OKDHS) Ginger Clayton (OKHCA Member
Audit)
Anticipated Completion Date: September 2024
Corrective Action Planned: The Department of Human Services agrees with the finding. See corrective action plan
located in the corrective action plan section of this report.




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            Oklahoma Department of rehabilitation services

FINDING NO: 2022-101
STATE AGENCY: Oklahoma Department of Rehabilitation Services (OkDRS)
FEDERAL AGENCY: United States Department of Education
ALN: 84.126
FEDERAL PROGRAM NAME: Vocational Rehabilitation Services Program
FEDERAL AWARD NUMBER: H126A200053, H126A210053, H126A220053
FEDERAL AWARD YEAR: 2020, 2021, and 2022
CONTROL CATEGORY: Other

Criteria: OkDRS maintains the RSA-11 data elements and submits the data elements to the Department of Education.
The data elements document the application for and/or provision of vocational rehabilitation services to individuals
with disabilities, including program outcomes and demographic information. OkDRS is to ensure the accuracy and
validity of the data elements.

Condition and Context: During the audit, we reviewed 40 participants’ key line data elements and compared with the
supporting documentation. We noted 9 deficiencies in the key line data elements for 9 participants’ files. We noted
that 3 participants did not have Exit letters on file. Two participants’ Individualized Plan for Employment (IPE) date
did not agree to the supporting document. Two participants’ hourly wage rate did not agree to the supporting
document. One participant did not have the signed IPE on file. One participant did not have the eligibility
determination document on file.

Cause: OkDRS case management team overlooked certain documentation and did not review or verify the accuracy
of the data elements for certain cases.

Effect: Not all of the RSA-11 data elements submitted by OkDRS to the Department of Education were accurate.

Recommendation: We recommend that OkDRS enforce its review and approval procedures and provide additional
training as needed to its employees to ensure the accuracy and validity of the participants’ data elements for reporting.

Views of Responsible Official(s)
Contact Person: Mark Kinnison, VR Division Administrator
Anticipated Completion Date: October 31, 2022
Corrective Action Planned: The Department of Rehabilitation Services agrees with the finding. Please see the
corrective action plan located in the corrective action plan section of this report.



                    Oklahoma Department of TRANSPORTATION

FINDING NO: 2022-024 (Repeat Finding 2021-017)
STATE AGENCY: Oklahoma Department of Transportation
FEDERAL AGENCY: U.S. Department of Transportation
ALN: 20.509
FEDERAL PROGRAM NAME: Formula Grants for Rural Areas
FEDERAL AWARD NUMBER: OK-2017-023-05, OK-2018-023-03, OK-2019-025-03, OK-2020-021-02, OK-
2021-018-00, OK-2022-016-00, OK-2022-025-00, OK-2022-027-00
FEDERAL AWARD YEAR: 2017, 2018, 2019, 2020, 2021, 2022
CONTROL CATEGORY: Subrecipient Monitoring




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QUESTIONED COSTS: $0

Criteria: 2 CFR 1201.1 states, “Except as otherwise provided in this part, the Department of Transportation adopts
the Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards (2 CFR part 200). This part supersedes and repeals the requirements of the
Department of Transportation Common Rules (49 CFR part 18 - Uniform Administrative Requirements for Grants
and Cooperative Agreements to State and Local Governments and 49 CFR part 19 - Uniform Administrative
Requirements - Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher
Education, Hospitals, and other Non-Profit Organizations), except that grants and cooperative agreements executed
prior to December 26, 2014 shall continue to be subject to 49 CFR parts 18 and 19 as in effect on the date of such
grants or agreements. New parts with terminology specific to the Department of Transportation follow.”
2 CFR 200.332 states in part, “All pass-through entities must: … (b) Evaluate each subrecipient's risk of
noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of
determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section.…”

2 CFR 200.332 states in part, “All pass-through entities must: … (b) Evaluate each subrecipient's risk of
noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of
determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section.…”

2 CFR 200.332 states in part, “All pass-through entities must: … (d) Monitor the activities of the subrecipient as
necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations,
and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity
monitoring of the subrecipient must include:
(1) Reviewing financial and performance reports required by the pass-through entity.
(2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining
to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews,
and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single
Audit findings related to the particular subaward.
(3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the
subrecipient from the pass-through entity as required by § 200.521. …”

2 CFR 200.332 states in part, “All pass-through entities must: … (f) Verify that every subrecipient is audited as
required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the
respective fiscal year equaled or exceeded the threshold set forth in § 200.501.”

Condition and Context: The Office of Mobility and Public Transit (OMPT) at the Oklahoma Department of
Transportation (Department) is responsible for monitoring of subrecipients. Project managers at OMPT monitor
specific subrecipients assigned to them. As part of this process, the project managers obtain subrecipients’ audit reports
and forward them to the Department’s Cabinet-wide audit Office (CWO) for review. OMPT relies on responses
received from CWO subsequent to review for identification of findings to monitor and assess the risk related to
subrecipients’ compliance with Federal statutes, regulations, and the terms and conditions of the subaward.

Based on review of the audit tracking spreadsheet for 20 subrecipients for 2021 Single Audits, we noted that
subrecipients’ audit status was not properly tracked, was not updated timely, or monitored regularly to ensure all audits
are received and followed up on. We noted various discrepancies such as improper identification of required financial
versus single audit reports, missing audit status, incomplete information, and lack of updates regarding findings
reported in the subrecipients’ audit report. Furthermore, we noted that the Department does not have an adequate
process in place to determine whether subrecipients expended $750,000 or more in Federal awards for the year and
are, therefore, subject to a single audit.

Lastly, based on inquiry with CWO, we noted that documentation supporting the review of subrecipients’ audit reports
was not maintained.

Cause: Internal controls have not been designed and implemented to ensure compliance with all subrecipient
monitoring requirements. The Department does not have a process in place to determine the type of audit required for




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each subrecipient. Each program manager is responsible for updating the information for their assigned subrecipients
without proper oversight to ensure that all subrecipients’ are accurately tracked.

Effect: The Department is not in compliance with the requirements of 2 CFR 200.332. Because the OMPT is not
performing adequate risk assessments, monitoring of subrecipients is not designed to account for the level of
noncompliance risk the subrecipient poses. If audits are not adequately tracked, the Department cannot meet the
imposed deadlines for follow-up. In addition, because information regarding Federal expenditures is not sought,
subrecipients may not obtain a required Single Audit.

Lastly, because documentation supporting the review of subrecipients’ audit reports was not maintained by CWO, we
were unable to determine that a review of these audits took place.

Recommendation: We recommend that the OMPT develop and implement procedures to ensure subrecipient risk
assessments are performed annually and follow-up by incorporating the assessed risk in the design and intensity of its
monitoring activities. We recommend the OMPT inquire after the subrecipients’ year-end as to the total Federal
expenditures spent during the preceding fiscal year and update the Single Audit Tracking Sheet with the type of audit
required. Further, we recommend the Single Audit Tracking Sheet be updated monthly to ensure all review/follow-up
deadlines are met. Lastly, we recommend CWO implement a process to ensure that the review of subrecipients’ audit
reports is adequately documented, and results are communicated to OMPT in a timely manner.

Views of Responsible Official(s)
Contact Person: Holly Lowe / CWO /Eric Rose / Jared Schwennesen / OMPT
Anticipated Completion Date: January 31, 2024 - CWO findings; 03/2024 – OMPT findings
Corrective Action Planned: The Oklahoma Department of Transportation agrees with the finding. See corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-056
STATE AGENCY: Oklahoma Department of Transportation
FEDERAL AGENCY: U.S. Department of Transportation
ALN: 20.509
FEDERAL PROGRAM NAME: Formula Grants for Rural Areas
FEDERAL AWARD NUMBER: OK-2017-023-05, OK-2018-023-03, OK-2019-025-03, OK-2020-021-02, OK-
2021-018-00, OK-2022-016-00, OK-2022-025-00, OK-2022-027-00
FEDERAL AWARD YEAR: 2017, 2018, 2019, 2020, 2021, 2022
CONTROL CATEGORY: Activities Allowed or Unallowed, Allowable Costs/Cost Principles; Subrecipient
Monitoring
QUESTIONED COSTS: $0

Criteria: 2 CFR 1201.1 states, “Except as otherwise provided in this part, the Department of Transportation adopts
the Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards (2 CFR part 200). This part supersedes and repeals the requirements of the
Department of Transportation Common Rules (49 CFR part 18 - Uniform Administrative Requirements for Grants
and Cooperative Agreements to State and Local Governments and 49 CFR part 19 - Uniform Administrative
Requirements - Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher
Education, Hospitals, and other Non-Profit Organizations), except that grants and cooperative agreements executed
prior to December 26, 2014 shall continue to be subject to 49 CFR parts 18 and 19 as in effect on the date of such
grants or agreements. New parts with terminology specific to the Department of Transportation follow.”

45 CFR §75.303 states in part, “The non-Federal entity must:(a) Establish and maintain effective internal control over
the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued
by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO).”




                                                         135
Schedule of Findings
And Questioned Costs
2 CFR § 200.334 – Retention requirements for records state in part, “Financial records, supporting documents,
statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period
of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed
quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as
reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.”

Condition and Context: The Oklahoma Department of Transportation (Department) requires subrecipients to submit
reimbursement claims via the electronic dispatch software system “MYLEOnet”. The system will select ten random
line items in addition to any line items that exceed the minimum threshold of $30,000. Upon approval of the randomly
selected line items by the Project Manager, subrecipients are required to upload the supporting invoices into
MYLEOnet for further review and approval by the Project Manager prior to submission of the claim for
reimbursement.

In testing a non-statistical random sample of 105 of 330 reimbursed claims, we noted individual line items totaling
only $2,934,558.81 of $7,048,332.85 (41.63%) paid to subrecipients in SFY 2022 were selected for review and
required an upload of supporting documentation. We also noted that payroll expenses were not selected for review.

Furthermore, based on review of 105 of 330 claims, we noted:

       •    For 1 (0.95%) of 105 claims tested, ODOT form 324 was not signed by an authorized representative of
            the Department’s Office of Mobility and Public Transit (OMPT).
       •    For 1 (0.95%) of 105 claims tested, the claim was approved for an amount previously claimed for
            reimbursement.
       •    For 15 (14.29%) of 105 claims tested, less than 10-line items were selected for review.

Cause: The Department lacks adequate internal controls to ensure that 100% of subrecipient expenditure claims are
supported and reviewed prior to reimbursement to the subrecipient.

Effect: The Department’s monitoring methodology does not ensure compliance with federal regulations. The
Department may reimburse subrecipients for expenditures that are not allowable or may not have been incurred.

Because $4,113,774.04 in expenditures claimed were unsupported (not selected for review and therefore,
no supporting documentation was required to be uploaded for further review), we were unable to obtain
sufficient appropriate evidence to test for Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and
Subrecipient Monitoring.

Recommendation: We recommend the Department review the current system of controls and update its methodology
to ensure all expenditures are supported and reviewed for allowability prior to reimbursement to the subrecipient.

Views of Responsible Official(s)
Contact Person: Eric Rose/Jared Schwennesen
Anticipated Completion Date: Completed
Corrective Action Planned: The Oklahoma Department of Transportation agrees with the finding. See corrective
action plan located in the corrective action plan section of this report.

FINDING NO: 2022-079
STATE AGENCY: Oklahoma Department of Transportation
FEDERAL AGENCY: U.S. Department of Transportation
ALN: 20.509
FEDERAL PROGRAM NAME: Formula Grants for Rural Areas
FEDERAL AWARD NUMBER: OK-2017-023-05, OK-2018-023-03, OK-2019-025-03, OK-2020-021-02, OK-
2021-018-00, OK-2022-016-00, OK-2022-025-00, OK-2022-027-00
FEDERAL AWARD YEAR: 2017, 2018, 2019, 2020, 2021, 2022
CONTROL CATEGORY: Cash Management




                                                          136
Schedule of Findings
And Questioned Costs
Criteria: 2 CFR 1201.1 states, “Except as otherwise provided in this part, the Department of Transportation adopts
the Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards (2 CFR part 200). This part supersedes and repeals the requirements of the
Department of Transportation Common Rules (49 CFR part 18 - Uniform Administrative Requirements for Grants
and Cooperative Agreements to State and Local Governments and 49 CFR part 19 - Uniform Administrative
Requirements - Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher
Education, Hospitals, and other Non-Profit Organizations), except that grants and cooperative agreements executed
prior to December 26, 2014 shall continue to be subject to 49 CFR parts 18 and 19 as in effect on the date of such
grants or agreements. New parts with terminology specific to the Department of Transportation follow.”

45 CFR §75.303 states, “The non-Federal entity must:(a) Establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued
by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO).”

Condition and Context: Federal Transit Authority (FTA) billing procedures are to be performed weekly in accordance
with the Procedures for FTA Billing outlined by the Comptroller Division. As part of these procedures, the Oklahoma
Department of Transportation (DOT) utilizes the “FTA billing excel spreadsheet” to record and track expenditures
processed for reimbursement.

Based on review of a sample of 13 of 26 draws performed in SFY 2022, we noted the following:

    •   5 (38.46%) of 13 draws contained discrepancies between the draw support and the information documented
        in the FTA billing spreadsheet (e.g. billing numbers, dates, and amounts).
    •   1 (7.69%) of 13 draws did not contain the required Office of Mobility and Public Transit (OMPT) approval.
    •   13 (100%) of 13 draws were not prepared and approved within a reasonable timeframe. The time elapsed
        between the billing week and the approval of the draw request range between 31 and 44 weeks.

Cause: The FTA billing procedures were not properly followed and were not performed in a timely manner due to
changes within the Comptroller Division - DOT.

Effect: Weekly FTA draws were not performed timely, consistently, and accurately which can lead to improper draw
down of Federal funds.

Recommendation: We recommend the Department of Transportation (DOT) strengthen internal controls to ensure
weekly billing procedures are properly followed. In addition, we recommend training be provided to staff to ensure
draws are properly reviewed and approved, and adequately supported.

Views of Responsible Official(s)
Contact Person: Sam Ddamba/Robert Hackney
Anticipated Completion Date: February 29, 2024
Corrective Action Planned: The Oklahoma Department of Transportation agrees with the finding. See corrective
action plan located in the corrective action plan section of this report.




                                                       137
Schedule of Expenditures of Federal Awards
            By Federal Grantor
                                                                                                                Pass Through
                                                                                                                   Entity                                                                                                         Expenditures
                                                                                                        AL       Identifying                                                                                                           to
Federal Grantor/Pass-Through Grantor/Program Title                                                     Number     Number             Agency                                                                Expenditures           Subrecipients

U.S. Department of Agriculture
    Direct and Pass Through Programs:
        Plant and Animal Disease, Pest Control, and Animal Care                                        10.025                  Department of Agriculture                                               $           866,096
        Voluntary Public Access and Habitat Incentive Program                                          10.093                  Department of Wildlife Conservation                                                 925,739 
        Inspection Grading and Standardization                                                         10.162                  Department of Agriculture                                                           703,467
        Market Protection and Promotion                                                                10.163                  Department of Agriculture                                                            16,800
        Specialty Crop Block Grant Program - Farm Bill                                                 10.170                  Department of Agriculture                                                           466,699
        Cooperative Agreements with States for Intrastate Meat and Poultry Inspection                  10.475                  Department of Agriculture                                                         1,630,024
         COVID-19 Pandemic EBT Food Benefits                                                           10.542                  Department of Human Services                                                    380,476,298 

         Supplemental Nutrition Assistance Program                                                     10.551                  Department of Human Services                                                   1,797,691,589 

         State Administrative Matching Grants for the Supplemental Nutrition Assistance Program        10.561                  Department of Human Services                                                      51,547,760            5,647,336
         COVID-19 State Administrative Matching Grants for the Supplemental Nutrition Assistance
         Program                                                                                       10.561                  Department of Human Services                                                       3,376,116 
                                                                                                                                                                                SNAP Cluster Total            1,852,615,465           5,647,336

         School Breakfast Program                                                                      10.553                  Department of Education                                                          87,703,109           87,703,109
         National School Lunch Program                                                                 10.555                  Department of Education                                                         301,973,684          301,697,381
         National School Lunch Program                                                                10.555                  Department of Human Services                                                     29,200,778              (63,555)
         COVID-19 National School Lunch Program                                                       10.555                  Department of Human Services                                                      3,721,104            3,322,094
                                                                                                                                                                                     Program Total             334,895,566          304,955,920
         Special Milk Program for Children                                                             10.556                  Department of Education                                                               2,392                2,392
         Summer Food Service Program for Children                                                      10.559                  Department of Education                                                          10,908,941           10,376,289
         Summer Food Service Program for Children                                                     10.559                  Department of Human Services                                                        573,672    
                                                                                                                                                                                     Program Total              11,482,613           10,376,289
         Fresh Fruit and Vegetable Program                                                             10.582                  Department of Education                                                           2,891,425            2,861,426
                                                                                                                                                                       Child Nutrition Cluster Total           436,975,105          405,899,136

         Child Nutrition Discretionary Grants Limited Availability                                     10.579                  Department of Education                                                              277,241               277,241

         WIC Special Supplemental Nutrition Program for Women, Infants and Children                    10.557                  State Department of Health                                                        33,098,094             6,727,818

         COVID-19 WIC Special Supplemental Nutrition Program for Women, Infants and Children           10.557                  State Department of Health                                                           691,312
                                                                                                                                                                                     Program Total               33,789,406             6,727,818

         Child and Adult Care Food Program                                                             10.558                  Department of Education                                                           68,201,243            67,932,282

         State Administrative Expenses for Child Nutrition                                             10.560                  Department of Education                                                            3,207,063               475,544
         State Administrative Expenses for Child Nutrition                                             10.560                  Department of Human Services                                                         561,673
                                                                                                                                                                                     Program Total                3,768,736               475,544

         Commodity Supplemental Food Program                                                           10.565                  Department of Human Services                                                       2,151,904              300,854
         Emergency Food Assistance Program (Administrative Costs)                                      10.568                  Department of Human Services                                                         866,761              784,611
         COVID-19 Emergency Food Assistance Program (Administrative Costs)                             10.568                  Department of Human Services                                                       1,378,168            1,378,168
                                                                                                                                                                                     Program Total                2,244,929            2,162,779
         Emergency Food Assistance Program (Food Commodities)                                         10.569                  Department of Human Services                                                      18,425,546   
         COVID-19 Emergency Food Assistance Program (Food Commodities)                                10.569                  Department of Human Services                                                       5,386,783   
                                                                                                                                                                                     Program Total               23,812,329                    -
                                                                                                                                                                     Food Distribution Cluster Total             28,209,162            2,463,633

         Farm to School Grant Program                                                                  10.575                  Department of Education                                                               45,558                45,558
         Senior Farmers Market Nutrition Program                                                       10.576                  Department of Human Services                                                          49,582

         Pandemic EBT Administrative Costs                                                             10.649                  Department of Education                                                              532,925               532,925
         Pandemic EBT Administrative Costs                                                             10.649                  Office of Juvenile Affairs                                                               614
         COVID-19 Pandemic EBT Administrative Costs                                                    10.649                  Department of Human Services                                                       6,699,221
                                                                                                                                                                                     Program Total                7,232,760               532,925




                                                                                                                               138
                                                                                                      Pass Through
                                                                                                         Entity                                                                                                                                  Expenditures
                                                                                             AL        Identifying                                                                                                                                    to
Federal Grantor/Pass-Through Grantor/Program Title                                          Number      Number             Agency                                                                                       Expenditures             Subrecipients

        Forestry Research                                                                   10.652                   Department of Agriculture                                                                                   425,254
        Cooperative Forestry Assistance                                                     10.664                   Department of Agriculture                                                                                 1,785,712
        Forest Health Protection                                                            10.680                   Department of Agriculture                                                                                     4,000
        State & Private Forestry Hazardous Fuel Reduction Program                           10.697                   Department of Agriculture                                                                                    70,581
        Partnership Agreements                                                              10.699                   Department of Agriculture                                                                                     1,566

        Soil and Water Conservation                                                         10.902                   Department of Agriculture                                                                                    29,932
        Soil and Water Conservation                                                         10.902                   Conservation Commission                                                                                   1,521,273
                                                                                                                                                                                                   Program Total               1,551,205                         -

        Watershed Protection and Flood Prevention                                            10.904                  Conservation Commission                                                                                   1,589,730
        Watershed Rehabilitation Program                                                     10.916                  Conservation Commission                                                                                   3,376,976
        Conservation Stewardship Program                                                     10.924                  Conservation Commission                                                                                      60,323
        Agricultural Conservation Easement Program                                           10.931                  Department of Wildlife Conservation                                                                          23,098
        Feral Swine Eradication and Control Pilot Program                                    10.934                  Conservation Commission                                                                                      (6,190)
        Cost Reimbursement Contract - McGee Creek Project                                   10 UNK                   Department of Wildlife Conservation                                                                          98,292
    U.S. Department of Agriculture-Subtotal                                                                                                                                                                         $      2,825,229,928     $      490,001,473

U.S. Department of Commerce
    Direct and Pass Through Programs:
        Cost Reimbursement Contract: Economic Adjustment Assistance                         11.307                   Department of Commerce                                                                                      282,000                        -
                                                                                                                                                                              Economic Development Cluster Total                 282,000                        -

        State and Local Implementation Grant Program                                        11.549                   Office of Management and Enterprise Services                                                                129,353
    U.S. Department of Commerce-Subtotal                                                                                                                                                                            $            411,353     $                   -

U.S. Department of Defense
    Direct and Pass Through Programs:
        Procurement Technical Assistance For Business Firms                                 12.002                   Department of Career & Technology Education                                                                 756,041                 362,834
        Cost Reimbursement Contract: State Memorandum of Agreement Program for the
        Reimbursement of Technical Services                                                 12.113                   Department of Environmental Quality                                                                          68,968
        Cost Reimbursement Contract - Military Construction, National Guard                 12.400                   Oklahoma Military Department                                                                              3,883,855
        Cost Reimbursement Contract - National Guard Military Operations and Maintenance
        (O&M) Projects                                                                      12.401                   Oklahoma Military Department                                                                             33,909,505
        Cost Reimbursement Contract - National Guard ChalleNGe Program                      12.404                   Oklahoma Military Department                                                                              6,594,600
        Troops to Teachers grant Program                                                    12.620                   Department of Education                                                                                     131,287
    U.S. Department of Defense-Subtotal                                                                                                                                                                             $         45,344,256     $           362,834

U.S. Department of Housing and Urban Development
    Direct and Pass Through Programs:
        Community Development Block Grants/State's Program and Non-Entitlement Grants in
        Hawaii                                                                              14.228                   Department of Commerce                                                                                   15,623,475             15,095,874
        Community Development Block Grants/State's Program and Non-Entitlement Grants in
        Hawaii                                                                              14.228                   Mental Health and Substance Abuse Services                                                                  177,075                 153,306
                                                                                                                                                                                                   Program Total              15,800,550              15,249,180

        Emergency Solutions Grant Program                                                   14.231                   Department of Commerce                                                                                   10,373,369             10,050,880
        Shelter Plus Care                                                                   14.238                   Mental Health and Substance Abuse Services                                                                  275,601                 200,490
        Continuum of Care Program                                                           14.267                   Mental Health and Substance Abuse Services                                                                      779

        Hurricane Sandy Community Development Block Grant Disaster Recovery Grants (CDBG-
        DR)                                                                                 14.269                   Department of Commerce                                                                                      190,974                 30,384
                                                                                                                                                  CDBG-Disaster Recovery Grants - Pub. L. No. 113-2 Cluster Total                190,974                30,384
    U.S. Department of Housing and Urban Development-Subtotal                                                                                                                                                       $         26,641,273     $        25,530,934

U.S. Department of the Interior
    Direct and Pass Through Programs:

        Regulation of Surface Coal Mining and Surface Effects of Underground Coal Mining    15.250                   Department of Mines                                                                                         161,680




                                                                                                                     139
                                                                                         Pass Through
                                                                                            Entity                                                                                                                                     Expenditures
                                                                                 AL       Identifying                                                                                                                                       to
Federal Grantor/Pass-Through Grantor/Program Title                              Number     Number              Agency                                                                                    Expenditures                  Subrecipients
         Abandoned Mine Land Reclamation (AMLR)                                 15.252                  Conservation Commission                                                                                   173,356
         Federal Oil and Gas Royalty Management State and Tribal Coordination   15.427                  State Auditor and Inspector                                                                               506,489
         Recreation Resources Management                                        15.524                  Department of Agriculture                                                                                 111,367
         Fish and Wildlife Management Assistance                                15.608                  Department of Wildlife Conservation                                                                       113,524

        Sport Fish Restoration Program                                          15.605                  Department of Wildlife Conservation                                                                    7,378,659                      180,719
        Wildlife Restoration and Basic Hunter Education                         15.611                  Department of Wildlife Conservation                                                                   17,053,404                      960,785
        Enhanced Hunter Education and Safety                                    15.626                  Department of Wildlife Conservation                                                                      142,777     
                                                                                                                                                                   Fish and Wildlife Cluster Total            24,574,840                   1,141,504

        Cooperative Endangered Species Conservation Fund                        15.615                  Department of Wildlife Conservation                                                                       77,980                        40,369
        Clean Vessels                                                           15.616                  Department of Environmental Quality                                                                      260,257

        Partners for Fish and Wildlife                                          15.631                  Department of Wildlife Conservation                                                                      323,323
        Partners for Fish and Wildlife                                          15.631                  Conservation Commission                                                                                  100,000
                                                                                                                                                                                   Program Total                 423,323                               -

        State Wildlife Grants                                                   15.634                  Department of Wildlife Conservation                                                                      895,908                      698,521
        Historic Preservation Fund Grants-In-Aid                                15.904                  Historical Society                                                                                       985,225                       260,997
        Outdoor Recreation - Acquisition, Development and Planning              15.916                  Department of Tourism and Recreation                                                                   1,091,512
        National Ground-Water Monitoring Network                                15.980                  Water Resources Board                                                                                     71,943
    U.S. Department of the Interior-Subtotal                                                                                                                                                         $        29,447,404           $         2,141,391

U.S. Department of Justice
    Direct and Pass Through Programs:
        Sexual Assault Services Formula Program                                 16.017                  District Attorneys Council and District Attorney Offices                                                 529,885                       268,609

        COVID-19 Coronavirus Emergency Supplemental Funding Program             16.034                  Attorney General                                                                                            8,591
        COVID-19 Coronavirus Emergency Supplemental Funding Program             16.034                  District Attorneys Council and District Attorney Offices                                                2,249,844                    1,430,899
        COVID-19 Coronavirus Emergency Supplemental Funding Program             16.034                  State Bureau of Investigation                                                                             216,701
                                                                                                                                                                                   Program Total                2,475,136                    1,430,899

        Services for Trafficking Victims                                        16.320                  Mental Health and Substance Abuse Services                                                                28,765                         6,200

        Juvenile Justice and Delinquency Prevention                             16.540                  District Attorneys Council and District Attorney Offices                                                   42,203                       38,657
        Juvenile Justice and Delinquency Prevention                             16.540                  Office of Juvenile Affairs                                                                                (99,192)
                                                                                                                                                                                   Program Total                  (56,989)                      38,657

        Missing Children's Assistance                                           16.543                  State Bureau of Investigation                                                                            509,419
        State Justice Statistics Program for Statistical Analysis Centers       16.550                  State Bureau of Investigation                                                                             32,407

        National Criminal History Improvement Program (NCHIP)                   16.554                  Department of Corrections                                                                                 104,598
        National Criminal History Improvement Program (NCHIP)                   16.554                  District Attorneys Council and District Attorney Offices                                                  945,002                      373,630
        National Criminal History Improvement Program (NCHIP)                   16.554                  State Bureau of Investigation                                                                             153,916
                                                                                                                                                                                   Program Total                1,203,516                      373,630

        Crime Victim Assistance                                                 16.575                  Attorney General                                                                                         106,634
        Crime Victim Assistance                                                 16.575                  District Attorneys Council and District Attorney Offices                                              28,930,510                    19,626,090
        Crime Victim Assistance                                                 16.575                  State Bureau of Investigation                                                                             65,086
        Crime Victim Assistance                                                 16.575                  Medicolegal Investigation Board                                                                           35,625
                                                                                                                                                                                   Program Total              29,137,855                    19,626,090

        Crime Victim Compensation                                               16.576                  District Attorneys Council and District Attorney Offices                                                5,081,233                    2,578,728

        Crime Victim Assistance/Discretionary Grants                            16.582                  District Attorneys Council and District Attorney Offices                                                 191,724                       154,921
        Crime Victim Assistance/Discretionary Grants                            16.582                  Mental Health and Substance Abuse Services                                                                19,000
                                                                                                                                                                                   Program Total                 210,724                       154,921

        Drug Court Discretionary Grant Program                                  16.585                  Mental Health and Substance Abuse Services                                                              1,464,482                    1,092,842




                                                                                                        140
                                                                                                             Pass Through
                                                                                                                Entity                                                                                                              Expenditures
                                                                                                     AL       Identifying                                                                                                                to
Federal Grantor/Pass-Through Grantor/Program Title                                                  Number     Number               Agency                                                                 Expenditures             Subrecipients
         Violence Against Women Formula Grants                                                      16.588                  Attorney General                                                                        173,893
         Violence Against Women Formula Grants                                                      16.588                  District Attorneys Council and District Attorney Offices                              2,767,943               1,844,865
                                                                                                                                                                                       Program Total              2,941,836               1,844,865


        Rural Domestic Violence, Dating Violence, Sexual Assault, and Stalking Assistance Program   16.589                  District Attorneys Council and District Attorney Offices                               239,115                  233,803

        Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program            16.590                  District Attorneys Council and District Attorney Offices                               126,513                   93,233

        Residential Substance Abuse Treatment for State Prisoners                                   16.593                  Department of Corrections                                                              261,488
        Residential Substance Abuse Treatment for State Prisoners                                   16.593                  District Attorneys Council and District Attorney Offices                               435,238                   98,640
        Residential Substance Abuse Treatment for State Prisoners                                   16.593                  Office of Juvenile Affairs                                                              89,629
        Residential Substance Abuse Treatment for State Prisoners                                   16.593                  Mental Health and Substance Abuse Services                                              85,208
                                                                                                                                                                                       Program Total               871,563                   98,640

        Bulletproof Vest Partnership Program                                                        16.607                  Department of Corrections                                                                  823
        Project Safe Neighborhood                                                                   16.609                  District Attorneys Council and District Attorney Offices                               406,019                  305,503
        Public Safety Partnership and Community Policing Grants                                     16.710                  Bureau of Narcotics & Dangerous Drugs Control                                          534,090

        Edward Byrne Memorial Justice Assistance Grant Program                                      16.738                  Department of Corrections                                                                68,012
        Edward Byrne Memorial Justice Assistance Grant Program                                      16.738                  District Attorneys Council and District Attorney Offices                              2,817,038               2,452,486
                                                                                                                                                                                       Program Total              2,885,050               2,452,486

        DNA Backlog Reduction Program                                                               16.741                  State Bureau of Investigation                                                          587,196

        Paul Coverdell Forensic Sciences Improvement Grant Program                                  16.742                  District Attorneys Council and District Attorney Offices                               272,189                   83,453
        Paul Coverdell Forensic Sciences Improvement Grant Program                                  16.742                  State Bureau of Investigation                                                          146,191
        Paul Coverdell Forensic Sciences Improvement Grant Program                                  16.742                  Medicolegal Investigation Board                                                         25,612
                                                                                                                                                                                       Program Total               443,992                   83,453

        Support for Adam Walsh Act Implementation Grant Program                                     16.750                  Department of Corrections                                                              125,687
        Harold Rogers Prescription Drug Monitoring Program                                          16.754                  Bureau of Narcotics & Dangerous Drugs Control                                          852,257

        NICS Act Record Improvement Program (NARIP)                                                 16.813                  Department of Corrections                                                                42,700
        NICS Act Record Improvement Program (NARIP)                                                 16.813                  District Attorneys Council and District Attorney Offices                              1,730,038                  78,005
        NICS Act Record Improvement Program (NARIP)                                                 16.813                  State Bureau of Investigation                                                         1,558,300
                                                                                                                                                                                       Program Total              3,331,038                  78,005

        John R. Justice Prosecutors and Defenders Incentive Act                                     16.816                  District Attorneys Council and District Attorney Offices                                85,780                   42,890
        Postconviction Testing of DNA Evidence                                                      16.820                  State Bureau of Investigation                                                          109,401
        Justice Reinvestment Initiative                                                             16.827                  Mental Health and Substance Abuse Services                                             212,388                   33,750
        Swift, Certain, and Fair Supervision Program: Applying the Principles Behind Project
        HOPE                                                                                        16.828                  Department of Corrections                                                              149,009

        National Sexual Assault Kit Initiative (SAKI)                                               16.833                  Attorney General                                                                      (629,643)
        National Sexual Assault Kit Initiative (SAKI)                                               16.833                  State Bureau of Investigation                                                          203,074
                                                                                                                                                                                       Program Total              (426,569)                         -

        Comprehensive Opioid, Stimulant, and Substance Abuse Program                                16.838                  Bureau of Narcotics & Dangerous Drugs Control                                           97,381
        STOP School Violence                                                                        16.839                  Department of Education                                                                646,004
        Combatting Contraband Cell Phone Use in Prisons                                             16.844                  Department of Corrections                                                              135,582
    U.S. Department of Justice-Subtotal                                                                                                                                                                $        54,970,588      $        30,837,204

U.S. Department of Labor
    Direct and Pass Through Programs:
        Labor Force Statistics                                                                      17.002                  Employment Security Commission                                                         884,156
        Compensation and Working Conditions                                                         17.005                  Department of Labor                                                                    153,045

        Employment Service/Wagner-Peyser Funded Activities                                          17.207                  Office of Management and Enterprise Services                                            100,870 
        Employment Service/Wagner-Peyser Funded Activities                                          17.207                  Employment Security Commission                                                        6,062,764 




                                                                                                                            141
                                                                                                              Pass Through
                                                                                                                 Entity                                                                                                                                       Expenditures
                                                                                                      AL       Identifying                                                                                                                                         to
Federal Grantor/Pass-Through Grantor/Program Title                                                   Number     Number             Agency                                                                                         Expenditures                Subrecipients
                                                                                                                                                                                                          Program Total                  6,163,634                           -
                                                                                                                                                                                        Employment Service Cluster Total                 6,163,634                           -

        WIOA Adult Program                                                                           17.258                  Department of Commerce                                                                                     6,477,200                  5,907,063
        WIOA Youth Activities                                                                        17.259                  Department of Commerce                                                                                     6,802,010                  5,886,256
        WIOA Dislocated Worker Formula Grants                                                        17.278                  Department of Commerce                                                                                     6,078,215                  5,133,267
                                                                                                                                                                                                      WIOA Cluster Total               19,357,425                16,926,586

        Unemployment Insurance                                                                       17.225                  Employment Security Commission                                                                           233,832,104
        COVID-19 Unemployment Insurance                                                              17.225                  Employment Security Commission                                                                            38,186,550
                                                                                                                                                                                                            Program Total             272,018,654                            -

        Senior Community Service Employment Program                                                  17.235                  Department of Human Services                                                                                 630,712                     621,952
        Trade Adjustment Assistance                                                                  17.245                  Employment Security Commission                                                                             1,912,252
        Work Opportunity Tax Credit Program (WOTC)                                                   17.271                  Employment Security Commission                                                                               164,075
        Temporary Labor Certification for Foreign Workers                                            17.273                  Employment Security Commission                                                                                69,328

        WIOA National Dislocated Worker Grants / WIA National Emergency Grants                       17.277                  Department of Commerce                                                                                      846,397                      806,840
        WIOA National Dislocated Worker Grants / WIA National Emergency Grants                       17.277                  Employment Security Commission                                                                               19,152
                                                                                                                                                                                                            Program Total                865,549                      806,840

        Apprenticeship USA Grants                                                                    17.285                  Department of Commerce                                                                                       448,702
        Consultation Agreements                                                                      17.504                  Department of Labor                                                                                        1,403,225
        Mine Health and Safety Grants                                                                17.600                  Department of Mines                                                                                          274,950
        Jobs for Veterans Stat Grants                                                                17.801                  Employment Security Commission                                                                             1,422,281
        Local Veterans' Employment Representative Program                                            17.804                  Employment Security Commission                                                                               463,508
    U.S. Department of Labor-Subtotal                                                                                                                                                                                         $       306,231,496         $        18,355,378

U.S. Department of Transportation
    Direct and Pass Through Programs:
        Airport Improvement Program and COVID-19 Airports Programs                                   20.106                  Aeronautics Commission                                                                                      996,238
        Highway Research and Development Program                                                     20.200                  Department of Transportation                                                                                 93,371                        7,101

        Highway Planning and Construction                                                            20.205                  Department of Transportation                                                                             756,432,085                  6,573,875
                                                                                                              9000006077;
                                                                                                              9000017185;
        Highway Planning and Construction                                                            20.205   9000014190     Pass-Through from Texas Department of Transportation to Department of Transportation                       5,390,219   
                                                                                                                                                                                                            Program Total             761,822,304                  6,573,875
        Recreational Trails Program                                                                  20.219                  Department of Tourism and Recreation                                                                         818,292   
                                                                                                                                                                          Highway Planning and Construction Cluster Total             762,640,596                  6,573,875

        Highway Training and Education                                                               20.215                  Department of Transportation                                                                                112,706

        Motor Carrier Safety Assistance                                                              20.218                  Department of Public Safety                                                                                1,568,757 
        Motor Carrier Safety Assistance High Priority Activities Grants and Cooperative Agreements
        (Commercial Vehicle Info Systems and Networks)                                               20.237                  Department of Transportation                                                                                 703,473 
                                                                                                                                                                      Federal Motor Carrier Safety Assistance Cluster Total             2,272,230                            -

        Bus and Bus Facilities Formula, Competitive, and Low or No Emissions Programs                20.526                  Department of Transportation                                                                               1,761,905                  1,761,905
                                                                                                                                                                                             Federal Transit Cluster Total              1,761,905                  1,761,905

        Metropolitan Transportation Planning and State and Non-Metropolitan Planning and
        Research                                                                                     20.505                  Department of Transportation                                                                                593,008                      574,720

        Formula Grants for Rural Areas                                                               20.509                  Department of Transportation                                                                               9,185,301                   9,185,301
        COVID-19 Formula Grants for Rural Areas                                                      20.509                  Department of Transportation                                                                               3,453,299                   3,453,299
                                                                                                                                                                                                            Program Total              12,638,600                 12,638,600

        Enhanced Mobility of Seniors and Individuals with Disabilities                               20.513                  Department of Transportation                                                                                981,097                     981,097
        Enhanced Mobility of Seniors and Individuals with Disabilities                               20.513                  Department of Human Services                                                                                   (643) 




                                                                                                                             142
                                                                                                      Pass Through
                                                                                                         Entity                                                                                                                                         Expenditures
                                                                                              AL       Identifying                                                                                                                                           to
Federal Grantor/Pass-Through Grantor/Program Title                                           Number     Number              Agency                                                                                            Expenditures              Subrecipients
                                                                                                                                                                                Transit Services Programs Cluster Total                980,454                 981,097

        Program                                                                              20.528                  Department of Transportation                                                                                      8,394                     8,394
        Minimum Penalties for Repeat Offenders for Driving While Intoxicated                 20.608                  Department of Public Safety                                                                                     113,597
        National Highway Traffic Safety Administration Discretionary Safety Grants and
        Cooperative Agreements                                                               20.614                  Department of Public Safety                                                                                         518

        E-911 Grant Program                                                                  20.615                  Department of Emergency Management                                                                             1,581,429                1,439,376
        E-911 Grant Program                                                                  20.615                  Conservation Commission                                                                                          154,716
                                                                                                                                                                                                         Program Total              1,736,145                1,439,376

        State and Community Highway Safety                                                   20.600                  Mental Health and Substance Abuse Services                                                                        16,000   
        State and Community Highway Safety                                                   20.600                  Department of Public Safety                                                                                    3,914,386   
                                                                                                                                                                                                         Program Total              3,930,386                        -
        National Priority Safety Programs                                                    20.616                  District Attorneys Council and District Attorney Offices                                                          42,999   
        National Priority Safety Programs                                                    20.616                  State Bureau of Investigation                                                                                    268,447   
        National Priority Safety Programs                                                    20.616                  Mental Health and Substance Abuse Services                                                                        42,000   
        National Priority Safety Programs                                                    20.616                  Department of Public Safety                                                                                      897,194   
                                                                                                                                                                                                       Program Total                1,250,640                        -
                                                                                                                                                                                          Highway Safety Cluster Total              5,181,026                        -

        Cost Reimbursement Contract - Pipeline Safety Program State Based Grant              20.700                  Corporation Commission                                                                                         1,766,715
        Interagency Hazardous Materials Public Sector Training and Planning Grants           20.703                  Department of Emergency Management                                                                               469,807                  469,807
        National Infrastructure Investments                                                  20.933                  Department of Transportation                                                                                   3,711,303
    U.S. Department of Transportation- Subtotal                                                                                                                                                                           $       795,076,613       $       24,454,875

U.S. Department of the Treasury
    Direct and Pass Through Programs:
        COVID-19 Coronavirus Relief Fund                                                     21.019                  State of Oklahoma                                                                                    $         9,649,051       $        6,585,563
        COVID-19 Coronavirus Relief Fund                                                     21.019                  Office of Management and Enterprise Services                                                                  12,383,796
        COVID-19 Coronavirus Relief Fund                                                     21.019                  Department of Corrections                                                                                        131,793
        COVID-19 Coronavirus Relief Fund                                                     21.019                  Employment Security Commission                                                                                 6,035,552
        COVID-19 Coronavirus Relief Fund                                                     21.019                  State Department of Health                                                                                     2,981,914
        COVID-19 Coronavirus Relief Fund                                                     21.019                  Department of Transportation                                                                                     703,633
        COVID-19 Coronavirus Relief Fund                                                     21.019                  Department of Public Safety                                                                                    1,074,990
        COVID-19 Coronavirus Relief Fund                                                     21.019                  Center for Advancement of Science and Technology                                                                 149,892
        COVID-19 Coronavirus Relief Fund                                                     21.019                  Department of Human Services                                                                                   1,855,055
                                                                                                                                                                                                         Program Total             34,965,676               6,585,563

        COVID-19 Emergency Rental Assistance Program                                         21.023                  State of Oklahoma                                                                                            239,529,714                         -
        COVID-19 Emergency Rental Assistance Program                                         21.023                  Office of Management and Enterprise Services                                                                      37,826
                                                                                                                                                                                                         Program Total            239,567,540                        -

        COVID-19 Coronavirus State and Local Fiscal Recovery                                 21.027                  Office of Management and Enterprise Services                                                                   2,595,232
        COVID-19 Coronavirus State and Local Fiscal Recovery                                 21.027                  Legislative Service Bureau                                                                                       130,000
                                                                                                                                                                                                         Program Total              2,725,232                        -
    U.S. Department of the Treasury-Subtotal                                                                                                                                                                              $       277,258,448       $        6,585,563

Federal Communications Commission
    Direct and Pass Through Programs:
        COVID-19 Telehealth Program                                                          32.006                  Department of Corrections                                                                                        65,802
    Federal Communications Commission-Subtotal                                                                                                                                                                            $           65,802        $                 -

General Services Administration
   Direct and Pass Through Programs:
        Donation of Federal Surplus Personal Property                                       39.003                  Office of Management and Enterprise Services-DCAM                                                              1,777,469
   General Services Administration-Subtotal                                                                                                                                                                               $         1,777,469       $                 -

National Foundation on the Arts and the Humanities
    Direct and Pass Through Programs:




                                                                                                                     143
                                                                                                                 Pass Through
                                                                                                                    Entity                                                                                                                                        Expenditures
                                                                                                      AL          Identifying                                                                                                                                          to
Federal Grantor/Pass-Through Grantor/Program Title                                                   Number        Number                 Agency                                                                                        Expenditures              Subrecipients
         Promotion of the Arts Partnership Agreements                                                45.025                        State Arts Council                                                                                          1,949,744

         Grants to States                                                                            45.310                        Historical Society                                                                                             10,000
         Grants to States                                                                            45.310                        Department of Libraries                                                                                     1,858,052                  501,244
         COVID-19 Grants to States                                                                   45.310                        Department of Libraries                                                                                     2,116,031                1,907,789
                                                                                                                                                                                                                   Program Total               3,984,083                2,409,033
    National Foundation on the Arts and the Humanities-Subtotal                                                                                                                                                                     $          5,933,827      $         2,409,033

U.S. Small Business Administration
    Direct and Pass Through Programs:
        State Trade Expansion Program                                                                59.061                        Department of Commerce                                                                                       561,771
    U.S. Small Business Administration-Subtotal                                                                                                                                                                                     $           561,771       $                   -

U.S. Department of Veterans Affairs
    Direct and Pass Through Programs:
        Grants to States for Construction of State Home Facilities                                   64.005                        Department of Veterans Affairs                                                                             6,635,600
        Veterans State Nursing Home Care                                                             64.015                        Department of Veterans Affairs                                                                            99,842,681
        All-Volunteer Force Educational Assistance                                                   64.124                        Department of Veterans Affairs                                                                               405,457
    U.S. Department of Veterans Affairs-Subtotal                                                                                                                                                                                    $       106,883,738       $                   -

U.S. Environmental Protection Agency
    Direct and Pass Through Programs:
        Surveys, Studies, Research, Investigations, Demonstrations, and Special Purpose Activities
        Relating to the Clean Air Act                                                                66.034                        Department of Environmental Quality                                                                          394,811
        State Clean Diesel Grant Program                                                             66.040                        Department of Environmental Quality                                                                          288,414

         Multipurpose Grants to States and Tribes                                                    66.204                        Corporation Commission                                                                                         1,217
         Multipurpose Grants to States and Tribes                                                    66.204      AA02F01601        Pass-Through from Sec. of Energy & Enviro. to Dept. of Enviro. Quality                                        31,870
                                                                                                                                                                                                                   Program Total                 33,087                           -

         Water Pollution Control State, Interstate and Tribal Program Support                        66.419                        Conservation Commission                                                                                         (302)
                                                                                                              OK292PT2928126320;
                                                                                                              OK292PT2928131618;
                                                                                                              OK292PT2928131620;
         Water Pollution Control State, Interstate and Tribal Program Support                        66.419   OK292PT2928131718    Pass-Through from Sec. of Energy & Enviro. to Water Resources Board                                           226,443
         Water Pollution Control State, Interstate and Tribal Program Support                        66.419       I-02F03301       Pass-Through from Sec. of Energy & Enviro. to Dept. of Enviro. Quality                                      1,911,410
                                                                                                                                                                                                                   Program Total               2,137,551                          -

         State Underground Water Source Protection                                                   66.433                        Corporation Commission                                                                                       170,526
         Assistance for Small and Disadvantaged Communities Drinking Water Grant Program
         (SDWA 1459A)                                                                                66.442                        Department of Environmental Quality                                                                          182,846
         Lead Testing in School and Child Care Program Drinking Water (SDWA 1464(d))                 66.444                        Department of Environmental Quality                                                                          139,224
                                                                                                              OK292PT2928133417;
         Water Quality Management Planning                                                           66.454   OK292PT2928139520    Pass-Through from Sec. of Energy & Enviro. to Water Resources Board                                           54,663

         Capitalization Grants for Clean Water State Revolving Funds                                 66.458                        Water Resources Board                                                                                     10,076,067               10,076,067
                                                                                                                                                                                   Clean Water State Revolving Fund Cluster Total            10,076,067              10,076,067


                                                                                                              OK292PT2928130017;
                                                                                                              OK292PT2928130019;
                                                                                                              OK292PT2928131319;
                                                                                                              OK292PT2928131320;
                                                                                                              OK292PT2928131321;
                                                                                                              OK292PT2928131420;
                                                                                                              OK292PT2928131421;
                                                                                                              OK292PT2928131520;
                                                                                                              OK292PT2928131521;
         Nonpoint Source Implementation Grants                                                       66.460   OK292PT2928134018    Pass-Through from Sec. of Energy & Environment to Conservation Commission                                   2,538,619

                                                                                                              OK292PT2928133817;
         Regional Wetland Program Development Grants                                                 66.461   OK292PT2928139319    Pass-Through from Sec. of Energy & Environment to Water Resources Board                                      212,844
                                                                                                              OK292PT2928137919;
         Regional Wetland Program Development Grants                                                 66.461   OK292PT2928139820    Pass-Through from Sec. of Energy & Environment to Conservation Commission                                      (1,302)




                                                                                                                                   144
                                                                                                             Pass Through
                                                                                                                Entity                                                                                                                                  Expenditures
                                                                                                     AL       Identifying                                                                                                                                    to
Federal Grantor/Pass-Through Grantor/Program Title                                                  Number     Number              Agency                                                                                     Expenditures              Subrecipients
                                                                                                                                                                                                         Program Total                 211,542                          -

        Capitalization Grants for Drinking Water State Revolving Funds                              66.468                  Department of Environmental Quality                                                                    23,336,032               18,327,808
                                                                                                                                                                      Drinking Water State Revolving Fund Cluster Total            23,336,032              18,327,808

        Performance Partnership Grants                                                              66.605                  Department of Environmental Quality                                                                      5,470,342


        Environmental Information Exchange Network Grant Program and Related Assistance             66.608                  Department of Environmental Quality                                                                        67,818

        Environmental Information Exchange Network Grant Program and Related Assistance             66.608                  Water Resources Board                                                                                      54,145
                                                                                                                                                                                                         Program Total                121,963                           -

        Consolidated Pesticide Enforcement Cooperative Agreements                                   66.700                  Department of Agriculture                                                                                  12,267
        Toxic Substances Compliance Monitoring Cooperative Agreements                               66.701                  Department of Labor                                                                                        80,000
        Toxic Substances Control Act Title IV State Lead Grants Certification of Lead-Based Paint
        Professionals                                                                               66.707                  Department of Environmental Quality                                                                       233,158

        Superfund State, Political Subdivision, and Indian Tribe Site-Specific Cooperative
        Agreements                                                                                  66.802                  Department of Environmental Quality                                                                    15,595,449
        Superfund State, Political Subdivision, and Indian Tribe Site-Specific Cooperative
        Agreements                                                                                  66.802                  State Department of Health                                                                                 46,065
                                                                                                                                                                                                         Program Total             15,641,514                           -

        Underground Storage Tank (UST) Prevention, Detection and Compliance Program                 66.804                  Corporation Commission                                                                                    514,015
        Leaking Underground Storage Tank Trust Fund Corrective Action Program                       66.805                  Corporation Commission                                                                                    970,089

        State and Tribal Response Program Grants                                                    66.817                  Corporation Commission                                                                                    210,226
        State and Tribal Response Program Grants                                                    66.817                  Department of Environmental Quality                                                                       485,281
                                                                                                                                                                                                         Program Total                695,507                           -

        Brownfields Multipurpose, Assessment, Revolving Loan Funds, and Cleanup Cooperative
        Agreements                                                                                  66.818                  Corporation Commission                                                                                     41,859
        Brownfields Multipurpose, Assessment, Revolving Loan Funds, and Cleanup Cooperative
        Agreements                                                                                  66.818                  Department of Environmental Quality                                                                       394,225
                                                                                                                                                                                                         Program Total                436,084                           -

        Superfund State and Indian Tribe Combined Cooperative Agreements (Site-Specific and
        Core)                                                                                       66.961                  Department of Environmental Quality                                                                       357,986
    U.S. Environmental Protection Agency-Subtotal                                                                                                                                                                         $        64,096,307       $        28,403,875

U.S. Department of Energy
    Direct and Pass Through Programs:
        State Energy Program                                                                        81.041                  Department of Commerce                                                                                     651,749                  482,127
        Weatherization Assistance for Low-Income Persons                                            81.042                  Department of Commerce                                                                                   1,866,384                1,556,098
    U.S. Department of Energy-Subtotal                                                                                                                                                                                    $          2,518,133      $         2,038,225

U.S. Department of Education
    Direct and Pass Through Programs:
        Adult Education - Basic Grants to States                                                    84.002                  Department of Corrections                                                                                  316,773
        Adult Education - Basic Grants to States                                                    84.002                  Department of Career & Technology Education                                                              7,897,827                5,863,734
                                                                                                                                                                                                         Program Total               8,214,600                5,863,734

        Title I Grants to Local Educational Agencies                                                84.010                  Department of Education                                                                               204,956,896              202,842,350
        Title I Grants to Local Educational Agencies                                                84.010                  Office of Juvenile Affairs                                                                                 13,276
                                                                                                                                                                                                         Program Total            204,970,172              202,842,350

        Migrant Education State Grant Program                                                       84.011                  Department of Education                                                                                   620,431                   314,353

        Title I State Agency Program for Neglected and Delinquent Children and Youth                84.013                  Department of Corrections                                                                                 525,555
        Title I State Agency Program for Neglected and Delinquent Children and Youth                84.013                  Department of Education                                                                                   (78,110)                          -




                                                                                                                            145
                                                                                                             Pass Through
                                                                                                                Entity                                                                                                                             Expenditures
                                                                                                    AL        Identifying                                                                                                                               to
Federal Grantor/Pass-Through Grantor/Program Title                                                 Number      Number              Agency                                                                               Expenditures               Subrecipients
         Title I State Agency Program for Neglected and Delinquent Children and Youth              84.013                   Office of Juvenile Affairs                                                                           219,603
                                                                                                                                                                                                   Program Total                 667,048                           -

        Special Education Grants to States                                                         84.027                   Department of Corrections                                                                             2,018    
        Special Education Grants to States                                                         84.027                   Department of Education                                                                         154,984,766              139,251,713
        Special Education Grants to States                                                         84.027                   Office of Juvenile Affairs                                                                           16,180    
        COVID-19 Special Education Grants to States                                                84.027                   Department of Education                                                                          15,833,413               15,833,413
                                                                                                                                                                                                   Program Total            170,836,377              155,085,126
        Special Education Preschool Grant                                                          84.173                   Department of Education                                                                           3,343,113                3,224,803
        COVID-19 Special Education Preschool Grant                                                 84.173                   Department of Education                                                                             833,193                  833,193
                                                                                                                                                                                                    Program Total             4,176,306                4,057,996
                                                                                                                                                                           Special Education Cluster (IDEA) Total           175,012,683              159,143,122

        Career and Technical Education - Basic Grants to States                                    84.048                   Department of Career & Technology Education                                                      17,848,743                 12,675,855
        Rehabilitation Services Vocational Rehabilitation Grants to States                         84.126                   Department of Rehabilitation Services                                                            38,116,225 
        Rehabilitation Services Client Assistance Program                                          84.161                   Office of Disability Concerns                                                                       122,630


        Rehabilitation Services Independent Living Services for Older Individuals Who are Blind    84.177                   Department of Rehabilitation Services                                                               291,443

        Special Education - Grants for Infants and Families                                        84.181                   Department of Education                                                                             214,711
        Special Education - Grants for Infants and Families                                        84.181                   State Department of Health                                                                        9,499,085
        COVID-19 Special Education - Grants for Infants and Families                               84.181                   Department of Education                                                                             208,074
        COVID-19 Special Education - Grants for Infants and Families                               84.181                   State Department of Health                                                                          116,984
                                                                                                                                                                                                   Program Total             10,038,854                            -

        School Safety National Activities (formerly, Safe and Drug-Free Schools and Communities-
        National Programs)                                                                         84.184                   Department of Education                                                                            1,610,250                    67,632

        Supported Employment Services for Individuals with the Most Significant Disabilities       84.187                   Department of Rehabilitation Services                                                               300,000
        Education for Homeless Children and Youth                                                  84.196                   Department of Education                                                                           1,165,406                  1,138,523
        Javits Gifted and Talented Students Education                                              84.206                   Department of Education                                                                             294,422
        Twenty-First Century Community Learning Centers                                            84.287                   Department of Education                                                                          13,027,122                 12,173,893
        Indian Education - Special Programs for Indian Children                                    84.299                   Department of Education                                                                             558,762
        Special Education - State Personnel Development                                            84.323                   Department of Education                                                                           1,339,188
        Rural Education                                                                            84.358                   Department of Education                                                                           4,769,058                  4,498,230
        English Language Acquisition State Grants                                                  84.365                   Department of Education                                                                           5,725,220                  5,414,134
        Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State
        Grants)                                                                                    84.367                   Department of Education                                                                          20,258,569                 18,098,798
        Grants for State Assessments and Related Activities                                        84.369                   Department of Education                                                                           7,734,182
        Comprehensive Literacy Development                                                         84.371                   Department of Education                                                                             810,188                    745,874
        School Improvement Grants                                                                  84.377                   Department of Education                                                                           1,592,353                    824,916
        Performance Partnership Pilots for Disconnected Youth                                      84.420                   Department of Human Services                                                                            (29)

        Student Support and Academic Enrichment Program                                            84.424                   Department of Education                                                                            8,746,092                 7,020,684
        Student Support and Academic Enrichment Program                                            84.424                   Office of Juvenile Affairs                                                                             2,704
                                                                                                                                                                                                   Program Total               8,748,796                 7,020,684

        COVID-19 Education Stabilization Fund                                                      84.425C                  Office of Management and Enterprise Services                                                        286,098
        COVID-19 Education Stabilization Fund                                                      84.425C                  Department of Education                                                                           3,408,031
        COVID-19 Education Stabilization Fund                                                      84.425C                  Governor's Office                                                                                    49,500
        COVID-19 Education Stabilization Fund                                                      84.425D                  Department of Education                                                                         392,412,078               386,360,496
        COVID-19 Education Stabilization Fund                                                      84.425R                  Department of Education                                                                          13,007,855                10,861,251
        COVID-19 Education Stabilization Fund                                                      84.425U                  Department of Education                                                                         395,610,277               381,053,819
        COVID-19 Education Stabilization Fund                                                      84.425W                  Department of Education                                                                             664,970                   664,970
                                                                                                                                                                                                   Program Total            805,438,809              778,940,536

        Randolph-Sheppard - Financial Relief and Restoration Payments                              84.426                   Department of Rehabilitation Services                                                                  2,294
    U.S. Department of Education-Subtotal                                                                                                                                                                           $      1,329,277,419       $     1,209,762,634




                                                                                                                            146
                                                                                                                 Pass Through
                                                                                                                    Entity                                                                                                        Expenditures
                                                                                                         AL       Identifying                                                                                                          to
Federal Grantor/Pass-Through Grantor/Program Title                                                      Number     Number              Agency                                                          Expenditures               Subrecipients
National Archives and Records Administration
    Direct and Pass Through Programs:
         National Historical Publications and Records Grants                                            89.003                  Department of Libraries                                                           4,219                     2,563
    National Archives and Records Administration - Subtotal                                                                                                                                        $              4,219       $             2,563

U.S. Election Assistance Commission
    Direct and Pass Through Programs:
         Help America Vote Act Requirements Payments                                                    90.401                  State Election Board                                                            899,388
         2018 HAVA Election Security Grants                                                             90.404                  State Election Board                                                            244,865
    U.S. Election Assistance Commission - Subtotal                                                                                                                                                 $          1,144,253       $                   -

U.S. Department of Health and Human Services
    Direct and Pass Through Programs:
        Special Programs for the Aging, Title VII, Chapter 3, Programs for Prevention of Elder
        Abuse, Neglect, and Exploitation                                                                93.041                  Department of Human Services                                                     49,461                    49,461
        COVID-19 Special Programs for the Aging, Title VII, Chapter 2, Long Term Care
        Ombudsman Services for Older Individuals                                                        93.042                  Department of Human Services                                                    223,001
        Special Programs for the Aging, Title III, Part D, Disease Prevention and Health Promotion
        Services                                                                                        93.043                  Department of Human Services                                                    287,082                   249,991

         Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior
         Centers                                                                                        93.044                  Department of Human Services                                                  4,396,548                4,396,548

         Special Programs for the Aging, Title III, Part C, Nutrition Services                          93.045                  Department of Human Services                                                  7,193,303                7,193,303
         COVID-19 - Special Programs for the Aging, Title III, Part C, Nutrition Services               93.045                  Department of Human Services                                                      9,000                        -
                                                                                                                                                                                  Program Total               7,202,303                7,193,303
         Nutrition Services Incentive Program                                                           93.053                  Department of Human Services                                                    778,199                  778,199
                                                                                                                                                                             Aging Cluster Total             12,377,050               12,368,050

         Special Programs for the Aging, Title IV, and Title II, Discretionary Projects                 93.048                  Insurance Department                                                            240,556
         COVID-19 Special Programs for the Aging, Title IV, and Title II, Discretionary Projects        93.048                  Department of Human Services                                                    744,479                    94,200
                                                                                                                                                                                  Program Total                 985,035                    94,200

         National Family Caregiver Support, Title III, Part E                                           93.052                  Department of Human Services                                                  1,863,037                 1,808,733

         Public Health Emergency Preparedness                                                           93.069                  State Department of Health                                                    4,914,599                 2,135,879
         COVID-19 Public Health Emergency Preparedness                                                  93.069                  State Department of Health                                                      251,659
                                                                                                                                                                                  Program Total               5,166,258                 2,135,879

         Medicare Enrollment Assistance Program                                                         93.071                  Insurance Department                                                            222,248
         Medicare Enrollment Assistance Program                                                         93.071                  Department of Human Services                                                    201,171                           -
                                                                                                                                                                                  Program Total                 423,419                           -

         Lifespan Respite Care Program                                                                  93.072                  Department of Human Services                                                    210,870

         Cooperative Agreements to Promote Adolescent Health through School-Based HIV/STD
         Prevention and School-Based Surveillance                                                       93.079                  State Department of Health                                                      471,837                   417,776
         COVID-19 Cooperative Agreements to Promote Adolescent Health through School-Based
         HIV/STD Prevention and School-Based Surveillance                                               93.079                  State Department of Health                                                       36,542
                                                                                                                                                                                  Program Total                 508,379                   417,776

         Enhance Safety of Children Affected by Substance Abuse                                         93.087                  Mental Health and Substance Abuse Services                                    1,045,929                   785,344

         Affordable Care Act (ACA) Personal Responsibility Education Program                            93.092                  State Department of Health                                                      596,794                   511,943

         Food and Drug Administration - Research                                                        93.103                  Department of Agriculture                                                       474,629
         COVID-19 Food and Drug Administration - Research                                               93.103                  State Department of Health                                                       84,627
                                                                                                                                                                                  Program Total                 559,256                           -

         Comprehensive Community Mental Health Services for Children with Serious Emotional
         Disturbances (SED)                                                                             93.104                  Mental Health and Substance Abuse Services                                        3,313




                                                                                                                                147
                                                                                                                 Pass Through
                                                                                                                    Entity                                                                                           Expenditures
                                                                                                         AL       Identifying                                                                                             to
Federal Grantor/Pass-Through Grantor/Program Title                                                      Number     Number             Agency                                                    Expenditures         Subrecipients

        Maternal and Child Health Federal Consolidated Programs                                         93.110                  State Department of Health                                               847,394             545,515
        Maternal and Child Health Federal Consolidated Programs                                         93.110                  Mental Health and Substance Abuse Services                                74,541              31,123
        COVID-19 Maternal and Child Health Federal Consolidated Programs                                93.110                  State Department of Health                                                 4,530
                                                                                                                                                                                Program Total            926,465             576,638



        Project Grants and Cooperative Agreements for Tuberculosis Control Programs                     93.116                  State Department of Health                                               466,075              78,108

        COVID-19 Project Grants and Cooperative Agreements for Tuberculosis Control Programs            93.116                  State Department of Health                                                   796
                                                                                                                                                                                Program Total            466,871              78,108

        Cooperative Agreements to States/Territories for the Coordination and Development of
        Primary Care Offices                                                                            93.130                  State Department of Health                                               102,677                 404

        Injury Prevention and Control Research and State and Community Based Programs                   93.136                  State Department of Health                                             1,731,865             292,879
        Injury Prevention and Control Research and State and Community Based Programs                   93.136                  Bureau of Narcotics & Dangerous Drugs Control                             43,200
        COVID-19 Injury Prevention and Control Research and State and Community Based
        Programs                                                                                        93.136                  State Department of Health                                                 8,944
                                                                                                                                                                                Program Total          1,784,009             292,879

        Projects for Assistance in Transition from Homelessness (PATH)                                  93.150                  Mental Health and Substance Abuse Services                               346,342             195,516

        Childhood Lead Poisoning Prevention Projects, State and Local Childhood Lead Poisoning
        Prevention and Surveillance of Blood Lead Levels in Children                                    93.197                  State Department of Health                                               229,067

        COVID-19 Childhood Lead Poisoning Prevention Projects, State and Local Childhood Lead
        Poisoning Prevention and Surveillance of Blood Lead Levels in Children                          93.197                  State Department of Health                                                 2,701
                                                                                                                                                                                Program Total            231,768                     -

        Family Planning Services                                                                        93.217                  State Department of Health                                             3,501,229           1,884,589
        COVID-19 Family Planning Services                                                               93.217                  State Department of Health                                                13,847
                                                                                                                                                                                Program Total          3,515,076           1,884,589

        Title V State Sexual Risk Avoidance Education (Title V State SRAE) Program                      93.235                  State Department of Health                                               449,476             311,379


        Substance Abuse and Mental Health Services Projects of Regional and National Significance       93.243                  Department of Education                                                3,398,461           1,433,858

        Substance Abuse and Mental Health Services Projects of Regional and National Significance       93.243                  State Department of Health                                                 6,820

        Substance Abuse and Mental Health Services Projects of Regional and National Significance       93.243                  Mental Health and Substance Abuse Services                             9,614,468           7,020,004

        Substance Abuse and Mental Health Services Projects of Regional and National Significance       93.243                  Department of Human Services                                                (240)
                                                                                                                                                                                Program Total         13,019,509           8,453,862

        Early Hearing Detection and Intervention                                                        93.251                  State Department of Health                                               161,380              68,364

        Immunization Cooperative Agreements                                                            93.268                  State Department of Health                                            71,003,447           1,652,859
        COVID-19 Immunization Cooperative Agreements                                                   93.268                  State Department of Health                                             1,832,614
                                                                                                                                                                                Program Total         72,836,061          1,652,859

        Viral Hepatitis Prevention and Control                                                          93.270                  State Department of Health                                               133,216                 441
        Centers for Disease Control and Prevention Investigations and Technical Assistance              93.283                  State Department of Health                                                 1,536
        PPHF 2018: Office of Smoking and Health-National State-Based Tobacco Control Programs-
        Financed in part by 2018 Prevention and Public Health funds (PPHF)                              93.305                  State Department of Health                                                (3,514)

        Early Hearing Detection and Intervention Information System (EHDI-IS) Surveillance
        Program                                                                                         93.314                  State Department of Health                                               245,240              24,581
        COVID-19 Early Hearing Detection and Intervention Information System (EHDI-IS)
        Surveillance Program                                                                            93.314                  State Department of Health                                                 2,607




                                                                                                                                148
                                                                                                              Pass Through
                                                                                                                 Entity                                                                                                     Expenditures
                                                                                                      AL       Identifying                                                                                                       to
Federal Grantor/Pass-Through Grantor/Program Title                                                   Number     Number              Agency                                                              Expenditures        Subrecipients
                                                                                                                                                                                        Program Total            247,847             24,581

        Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)                           93.323                  State Department of Health                                                      22,399,834         22,399,834
        COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)                  93.323                  Department of Education                                                         15,064,922
        COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)                  93.323                  State Department of Health                                                      27,784,478
                                                                                                                                                                                        Program Total        65,249,234        22,399,834

        State Health Insurance Assistance Program                                                    93.324                  Insurance Department                                                               613,936

        The Healthy Brain Initiative: Technical Assistance to Implement Public Health Actions
        related to Cognitive Health, Cognitive Impairment, and Caregiving at the State and Local
        Levels                                                                                       93.334                  State Department of Health                                                          99,544              2,485
        COVID-19 The Healthy Brain Initiative: Technical Assistance to Implement Public Health
        Actions related to Cognitive Health, Cognitive Impairment, and Caregiving at the State and
        Local Levels                                                                                 93.334                  State Department of Health                                                           3,618
                                                                                                                                                                                        Program Total           103,162              2,485

        Behavioral Risk Factor Surveillance System                                                   93.336                  State Department of Health                                                          (57,586)
        COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health
        Department Response to Public Health or Healthcare Crises                                    93.354                  State Department of Health                                                        5,361,727         2,192,179
        ACL Independent Living State Grants                                                          93.369                  Department of Rehabilitation Services                                               394,582

        National and State Tobacco Control Program                                                   93.387                  State Department of Health                                                         763,646            228,788
        COVID-19 National and State Tobacco Control Program                                          93.387                  State Department of Health                                                             581
                                                                                                                                                                                        Program Total           764,227            228,788

        Activities to Support State, Tribal, Local and Territorial (STLT) Health Department
        Response to Public Health or Healthcare Crisis                                               93.391                  State Department of Health                                                        2,848,467           662,111
        COVID-19 Activities to Support State, Tribal, Local and Territorial (STLT) Health
        Department Response to Public Health or Healthcare Crisis                                    93.391                  State Department of Health                                                           70,552
                                                                                                                                                                                        Program Total          2,919,019           662,111

        Improving the Health of Americans through Prevention and Management of Diabetes and
        Heart Disease and Stroke                                                                     93.426                  State Department of Health                                                        1,066,263           125,266
        Improving the Health of Americans through Prevention and Management of Diabetes and
        Heart Disease and Stroke                                                                     93.426                  Mental Health and Substance Abuse                                                   83,434
        COVID-19 Improving the Health of Americans through Prevention and Management of
        Diabetes and Heart Disease and Stroke                                                        93.426                  State Department of Health                                                           15,205
                                                                                                                                                                                        Program Total          1,164,902           125,266

        Title IV-E Kinship Navigator Program                                                         93.471                  Department of Human Services                                                      1,655,000
        Community Health Workers for Public Health Response and Resilient                            93.495                  State Department of Health                                                           71,769            38,811
        Pregnancy Assistance Fund Program                                                            93.500                  State Department of Health                                                          120,950
                                                                                                                                                                                        Program Total            120,950                  -

        Promoting Safe and Stable Families                                                           93.556                  Office of Juvenile Affairs                                                          122,000
        Promoting Safe and Stable Families                                                           93.556                  Department of Human Services                                                      3,693,253           335,779
                                                                                                                                                                                        Program Total          3,815,253           335,779

        Temporary Assistance for Needy Families                                                      93.558                  Department of Libraries                                                             15,091
        Temporary Assistance for Needy Families                                                      93.558                  Mental Health and Substance Abuse Services                                         443,634
        Temporary Assistance for Needy Families                                                      93.558                  Department of Career & Technology Education                                      2,682,517
        Temporary Assistance for Needy Families                                                      93.558                  Department of Human Services                                                    38,714,874            425,214
                                                                                                                                                                                        Program Total        41,856,116           425,214

        Child Support Enforcement                                                                    93.563                  District Attorneys Council and District Attorney Offices                         2,899,247
        Child Support Enforcement                                                                    93.563                  Department of Human Services                                                    33,487,184            847,688
                                                                                                                                                                                        Program Total        36,386,431            847,688

        Child Support Enforcement Research                                                           93.564                  Department of Human Services                                                          1,470
        Refugee and Entrant Assistance State/Replacement Designee Administered Programs              93.566                  Department of Human Services                                                      2,805,345         1,907,731




                                                                                                                             149
                                                                                                      Pass Through
                                                                                                         Entity                                                                                                    Expenditures
                                                                                              AL       Identifying                                                                                                      to
Federal Grantor/Pass-Through Grantor/Program Title                                           Number     Number             Agency                                                            Expenditures          Subrecipients

        Low-Income Home Energy Assistance                                                    93.568                  Department of Commerce                                                         1,242,668            1,182,270
        Low-Income Home Energy Assistance                                                    93.568                  Department of Human Services                                                  38,346,394
        COVID-19 Low-Income Home Energy Assistance                                           93.568                  Department of Human Services                                                  10,909,654
                                                                                                                                                                           Program Total           50,498,716            1,182,270

        Community Services Block Grant                                                       93.569                  Department of Commerce                                                        14,471,133          14,043,674

        Child Care and Development Block Grant                                               93.575                  Department of Human Services                                                 129,174,319           2,700,168
        COVID-19 Child Care and Development Block Grant                                      93.575                  Department of Human Services                                                 159,152,727 
                                                                                                                                                                           Program Total          288,327,046           2,700,168

        Child Care Mandatory and Matching Funds of the Child Care and Development Fund       93.596                  Department of Human Services                                                  54,425,328 
        COVID-19 Child Care Mandatory and Matching Funds of the Child Care and Development
        Fund                                                                                 93.596                  Department of Human Services                                                  2,524,374 
                                                                                                                                                                          Program Total           56,949,702                    -
                                                                                                                                                                      CCDF Cluster Total         345,276,748           2,700,168

        State Court Improvement Program                                                      93.586                  Supreme Court                                                                    526,876
        COVID-19 State Court Improvement Program                                             93.586                  Supreme Court                                                                     11,916
                                                                                                                                                                           Program Total              538,792                      -

        Community-Based Child Abuse Prevention Grants                                        93.590                  Commission on Children and Youth                                                  82,397
        Community-Based Child Abuse Prevention Grants                                        93.590                  State Department of Health                                                       421,616              180,115
                                                                                                                                                                           Program Total              504,013              180,115

        Grants to States for Access and Visitation Programs                                  93.597                  Department of Human Services                                                      78,843

        Chafee Education and Training Vouchers Program (ETV)                                 93.599                  Department of Human Services                                                   1,062,496
        COVID-19 Chafee Education and Training Vouchers Program (ETV)                        93.599                  Department of Human Services                                                     859,408
                                                                                                                                                                           Program Total            1,921,904                      -

        Head Start                                                                           93.600                  Department of Commerce                                                           139,110             133,256
                                                                                                                                                                  Head Start Cluster Total            139,110             133,256

        Adoption and Legal Guardianship Incentive Payments                                   93.603                  Department of Human Services                                                   5,479,475
        Basic Center Grant                                                                   93.623                  Mental Health and Substance Abuse Services                                       156,816              151,947

        Developmental Disabilities Basic Support and Advocacy Grants                         93.630                  Department of Human Services                                                     816,276
        COVID-19 Developmental Disabilities Basic Support and Advocacy Grants                93.630                  Department of Human Services                                                         978
                                                                                                                                                                           Program Total              817,254                      -
        Section 9813: State Planning Grants for Qualifying Community-Based Mobile Crisis
        Intervention Services                                                                93.639                  Health Care Authority                                                             72,964
        Children's Justice Grants to States                                                  93.643                  Department of Human Services                                                     246,688
        Stephanie Tubbs Jones Child Welfare Services Program                                 93.645                  Department of Human Services                                                   1,422,803
        Child Welfare Research Training or Demonstration                                     93.648                  Department of Human Services                                                     270,086
        Adoption Opportunities                                                               93.652                  Department of Human Services                                                        (125)

        Foster Care Title IV-E                                                               93.658                  Office of Juvenile Affairs                                                        96,459
        Foster Care Title IV-E                                                               93.658                  Department of Human Services                                                  69,422,330            3,159,147
        COVID-19 Foster Care Title IV-E                                                      93.658                  Department of Human Services                                                   1,301,190
                                                                                                                                                                           Program Total           70,819,979           3,159,147

        Adoption Assistance                                                                  93.659                  Department of Human Services                                                  99,581,753
        COVID-19 Adoption Assistance                                                         93.659                  Department of Human Services                                                   7,862,650
                                                                                                                                                                           Program Total          107,444,403                     -

        COVID-19 Emergency Grants to Address Mental and Substance Use Disorders During
        COVID-19                                                                             93.665                  Mental Health and Substance Abuse Services                                     2,225,969            1,820,223
        Social Services Block Grant                                                          93.667                  Department of Human Services                                                  32,636,690




                                                                                                                     150
                                                                                                             Pass Through
                                                                                                                Entity                                                                                                                               Expenditures
                                                                                                     AL       Identifying                                                                                                                                 to
Federal Grantor/Pass-Through Grantor/Program Title                                                  Number     Number              Agency                                                                                  Expenditures              Subrecipients
         Child Abuse and Neglect State Grants                                                       93.669                  Department of Human Services                                                                            906,518
                                                                                                                            Pass-Through from National Quality Improvement Center to Mental Health and Substance Abuse
        Child Abuse and Neglect Discretionary Activities                                            93.670    90CA1854      Services                                                                                                18,995

        Family Violence Prevention and Services/Domestic Violence Shelter and Supportive Services   93.671                  Attorney General                                                                                      3,449,006                1,891,578

        John H. Chafee Foster Care Program for Successful Transition to Adulthood                   93.674                  Department of Human Services                                                                          3,584,877

        COVID-19 John H. Chafee Foster Care Program for Successful Transition to Adulthood          93.674                  Department of Human Services                                                                          3,250,531
                                                                                                                                                                                                          Program Total           6,835,408                          -

        Elder Abuse Prevention Interventions Program                                                93.747                  Department of Human Services                                                                           389,637
        COVID-19 Elder Abuse Prevention Interventions Program                                       93.747                  Department of Human Services                                                                           393,627
                                                                                                                                                                                                          Program Total            783,264                           -

        Child Lead Poisoning Prevention Surveillance financed in part by Prevention and Public
        Health (PPHF) Program                                                                       93.753                  State Department of Health                                                                               (1,316)

        Children's Health Insurance Program                                                         93.767                  State Department of Health                                                                              59,839
        Children's Health Insurance Program                                                         93.767                  Health Care Authority                                                                              223,918,285
        COVID-19 Children's Health Insurance Program                                                93.767                  Health Care Authority                                                                               11,732,972
                                                                                                                                                                                                          Program Total        235,711,096                          -

        State Medicaid Fraud Control Units                                                          93.775                  Attorney General                                                                                      1,604,766 
        State Survey and Certification of Health Care Providers and Suppliers (Title XVIII)
        Medicare                                                                                    93.777                  State Department of Health                                                                            4,121,102                  87,106
        COVID-19 State Survey and Certification of Health Care Providers and Suppliers (Title
        XVIII) Medicare                                                                             93.777                  State Department of Health                                                                               24,413    
                                                                                                                                                                                                          Program Total           4,145,515                  87,106
        Medical Assistance Program                                                                  93.778                  State Department of Health                                                                            2,445,631    
        Medical Assistance Program                                                                  93.778                  Health Care Authority                                                                             5,789,111,240    
        Medical Assistance Program                                                                  93.778                  Department of Human Services                                                                         62,978,036    
        COVID-19 Medical Assistance Program                                                         93.778                  Health Care Authority                                                                               291,696,055    
                                                                                                                                                                                                         Program Total        6,146,230,962                       -
                                                                                                                                                                                                  Medicaid Cluster Total      6,151,981,243                 87,106

        Opioid STR                                                                                  93.788                  Mental Health and Substance Abuse Services                                                          14,039,579                 7,543,036

        Money Follows the Person Rebalancing Demonstration                                          93.791                  Health Care Authority                                                                                 1,666,671
        Money Follows the Person Rebalancing Demonstration                                          93.791                  Department of Human Services                                                                                525
        COVID-19 Money Follows the Person Rebalancing Demonstration                                 93.791                  Health Care Authority                                                                                    55,450
                                                                                                                                                                                                          Program Total           1,722,646                          -

        State Survey Certification of Health Care Providers and Suppliers (Title XIX) Medicaid      93.796                  State Department of Health                                                                            1,820,838
        State Survey Certification of Health Care Providers and Suppliers (Title XIX) Medicaid      93.796                  Health Care Authority                                                                                 3,182,543
                                                                                                                                                                                                          Program Total           5,003,381                          -

        Section 223 Demonstration Programs to Improve Community Mental Health Services              93.829                  Mental Health and Substance Abuse Services                                                             806,453

        Maternal, Infant, and Early Childhood Home Visiting Grant                                   93.870                  State Department of Health                                                                            5,161,495                  336,642
        COVID-19 Maternal, Infant and Early Childhood Home Visiting Grant                           93.870                  State Department of Health                                                                                1,369
                                                                                                                                                                                                          Program Total           5,162,864                  336,642

        National Bioterrorism Hospital Preparedness Program                                         93.889                  State Department of Health                                                                            2,262,015                1,766,642
        COVID-19 National Bioterrorism Hospital Preparedness Program                                93.889                  State Department of Health                                                                               56,374
                                                                                                                                                                                                          Program Total           2,318,389                1,766,642

        Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations      93.898                  State Department of Health                                                                             948,444                    41,887
        COVID-19 Cancer Prevention and Control Programs for State, Territorial and Tribal
        Organizations                                                                               93.898                  State Department of Health                                                                               3,065




                                                                                                                            151
                                                                                                           Pass Through
                                                                                                              Entity                                                                                                                             Expenditures
                                                                                                   AL       Identifying                                                                                                                               to
Federal Grantor/Pass-Through Grantor/Program Title                                                Number     Number              Agency                                                                                Expenditures              Subrecipients
                                                                                                                                                                                                 Program Total                  951,509                   41,887

         HIV Care Formula Grants                                                                  93.917                  State Department of Health                                                                           (881,676)                       -
         HIV Care Formula Grants                                                                  93.917                  Department of Human Services                                                                          155,783
                                                                                                                                                                                                 Program Total                 (725,893)                      -

         HIV Prevention Activities Health Department Based                                        93.940                  State Department of Health                                                                          1,558,304                 390,377
         COVID-19 HIV Prevention Activities Health Department Based                               93.940                  State Department of Health                                                                              3,265
                                                                                                                                                                                                 Program Total                1,561,569                 390,377

         Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health
         Initiative Programs                                                                      93.946                  State Department of Health                                                                            90,355                   10,300
         Block Grants for Community Mental Health Services                                        93.958                  Mental Health and Substance Abuse Services                                                        13,988,871                6,680,385
         Block Grants for Prevention and Treatment of Substance Abuse                             93.959                  Mental Health and Substance Abuse Services                                                        26,986,755                7,525,340

         Sexually Transmitted Diseases (STD) Prevention and Control Grants                        93.977                  State Department of Health                                                                           912,604                   14,149
         COVID-19 Sexually Transmitted Diseases (STD) Prevention and Control Grants               93.977                  State Department of Health                                                                             6,839
                                                                                                                                                                                                 Program Total                 919,443                   14,149

         Improving Student Health and Academic Achievement through Nutrition, Physical Activity
         and the Management of Chronic Conditions in Schools                                      93.981                  Department of Education                                                                              460,554
         Improving Student Health and Academic Achievement through Nutrition, Physical Activity
         and the Management of Chronic Conditions in Schools                                      93.981                  State Department of Health                                                                            86,422                    7,730
                                                                                                                                                                                                 Program Total                 546,976                    7,730



         Mental Health Disaster Assistance and Emergency Mental Health                            93.982                  Mental Health and Substance Abuse Services                                                          3,112,508               2,541,435

         Preventive Health and Health Services Block Grant                                        93.991                  State Department of Health                                                                           682,515                  143,164
         Preventive Health and Health Services Block Grant                                        93.991                  Bureau of Narcotics & Dangerous Drugs Control                                                          6,398
                                                                                                                                                                                                 Program Total                 688,913                  143,164

         Maternal and Child Health Services Block Grant to the States                             93.994                  State Department of Health                                                                          3,946,715               1,087,062
         Maternal and Child Health Services Block Grant to the States                             93.994                  Department of Human Services                                                                        2,551,097
         COVID-19 Maternal and Child Health Services Block Grant to the States                    93.994                  State Department of Health                                                                             25,542
                                                                                                                                                                                                 Program Total                6,523,354               1,087,062

         Assisted Outpatient Treatment                                                            93.997                  Mental Health and Substance Abuse Services                                                           846,033                  844,296

        Cost Reimbursement Contracts:
        Client Level Projects                                                                     93.UNK                  Mental Health and Substance Abuse Services                                                             45,514
    U.S. Department of Health and Human Services-Subtotal                                                                                                                                                          $      7,401,038,834      $      115,408,812

Executive Office of the President
        Cost Reimbursement Contract: High Intensity Drug Trafficking Areas Program                95.001                  Bureau of Narcotics & Dangerous Drugs Control                                                         72,296
    Executive Office of the President-Subtotal                                                                                                                                                                     $            72,296       $                 -

Social Security Administration
    Direct and Pass Through Programs:
         Social Security Disability Insurance                                                     96.001                  Department of Rehabilitation Services                                                             45,370,682 
                                                                                                                                                                          Disability Insurance/SSI Cluster Total            45,370,682                        -

    Social Security Administration-Subtotal                                                                                                                                                                        $        45,370,682       $                 -

U.S. Department of Homeland Security
    Direct and Pass Through Programs:
        Non-Profit Security Program                                                               97.008                  Department of Emergency Management                                                                   419,744                  419,744
        Boating Safety Financial Assistance                                                       97.012                  Department of Public Safety                                                                          863,123
        Community Assistance Program State Support Services Element (CAP-SSSE)                    97.023                  Water Resource Board                                                                                 227,354
        Flood Mitigation Assistance                                                               97.029                  Department of Emergency Management                                                                   164,014                  164,014




                                                                                                                          152
                                                                                                         Pass Through
                                                                                                            Entity                                                                                                 Expenditures
                                                                                                 AL       Identifying                                                                                                   to
Federal Grantor/Pass-Through Grantor/Program Title                                              Number     Number              Agency                                                       Expenditures           Subrecipients

        Disaster Grants - Public Assistance (Presidentially Declared Disasters)                 97.036                  Department of Emergency Management                                      127,989,397           126,131,933
        Disaster Grants - Public Assistance (Presidentially Declared Disasters)                 97.036                  State Department of Health                                                4,948,303
        Disaster Grants - Public Assistance (Presidentially Declared Disasters)                 97.036                  Department of Transportation                                                 50,631
                                                                                                                                                                        Program Total           132,988,331           126,131,933

        Hazard Mitigation Grant                                                                 97.039                  Department of Emergency Management                                         8,580,460             8,241,483
        National Dam Safety Program                                                             97.041                  Water Resources Board                                                        285,281
        Emergency Management Performance Grants                                                 97.042                  Department of Emergency Management                                         6,844,192             1,991,077
        Cooperating Technical Partners                                                          97.045                  Water Resources Board                                                        235,624
        Fire Management Assistance Grant                                                        97.046                  Department of Emergency Management                                         1,818,830             1,797,324
        BRIC: Building Resilient Infrastructure and Communities                                 97.047                  Department of Emergency Management                                           225,049               195,590

        Presidential Declared Disaster Assistance to Individuals and Households - Other Needs   97.050                  Employment Security Commission                                               623,084

        Homeland Security Grant Program                                                         97.067                  Office of Management and Enterprise Services                                  14,852
        Homeland Security Grant Program                                                         97.067                  Department of Education                                                       56,167
        Homeland Security Grant Program                                                         97.067                  State Election Board                                                          65,250
        Homeland Security Grant Program                                                         97.067                  State Bureau of Investigation                                                133,664
        Homeland Security Grant Program                                                         97.067                  Department of Emergency Management                                         2,674,880             1,485,307
        Homeland Security Grant Program                                                         97.067                  Department of Public Safety                                                   15,132
                                                                                                                                                                        Program Total              2,959,945             1,485,307

        State Homeland Security Program (SHSP)                                                  97.073                  State Bureau of Investigation                                                681,537
        State Homeland Security Program (SHSP)                                                  97.073                  Department of Emergency Management                                         2,931,307             1,597,733
        State Homeland Security Program (SHSP)                                                  97.073                  Department of Public Safety                                                  171,812
        State Homeland Security Program (SHSP)                                                  97.073                  Conservation Commission                                                       21,733
                                                                                                                                                                        Program Total              3,806,389             1,597,733

        Earthquake Consortium                                                                   97.082                  Department of Emergency Management                                            39,357                39,357
        Disaster Assistance Projects                                                            97.088                  Department of Emergency Management                                           550,530               550,529
        Regional Catastrophic Preparedness Grant Program                                        97.111                  Department of Emergency Management                                           174,648
    U.S. Department of Homeland Security-Subtotal                                                                                                                                       $        160,805,955   $      142,614,091

U.S. Drug Enforcement Administration
    Direct and Pass Through Programs:
        Other Federal Assistance - Marijuana Eradication Suppression Program                    99.UNK                  Bureau of Narcotics & Dangerous Drugs Control                                 96,896
    U.S. Drug Enforcement Administration-Subtotal                                                                                                                                       $             96,896   $                   -

Total Federal Assistance                                                                                                                                                                $     13,480,258,960   $     2,098,908,885

    Noncash Assistance
    Partially Noncash Assistance
    Tested as a major program as defined by 2 CFR §200.518
    Program audited as a major program by independent auditor
    Programs defined as a cluster by OMB Compliance Supplement
    See SEFA footnote #7
  UNK Unknown




                                                                                                                        153
Notes to the Schedule of Expenditures
          of Federal Awards
        NOTES TO THE SCHEDULE OF EXPENDITURES OF
                    FEDERAL AWARDS
                                 For the Fiscal Year Ended June 30, 2022


Note 1. Summary of Significant Accounting Policies
The accompanying Schedule of Expenditures of Federal Awards (schedule) includes the federal award
activity of the State of Oklahoma for the year ended June 30, 2022. The information in this schedule is
presented in conformity with the requirements set forth in Title 2 U.S. Code of Federal Regulations (CFR)
Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal
Awards (Uniform Guidance).

A.       Reporting Entity

The Governmental Accounting Standards Board (GASB) has set forth criteria to be considered in determining
financial accountability. The reporting entity includes the primary government of the State of Oklahoma as
presented in the Annual Comprehensive Financial Report (ACFR). Component units included in the ACFR
prepare individual financial statements that meet the requirements of Uniform Guidance and have not been
included in the schedule. Uniform Guidance allows non-Federal entities to meet the audit requirements of
the compliance supplement through a series of audits that cover the reporting entity.

B.       Basis of Presentation

The schedule presents expenditures and expenses for the fiscal year ended June 30, 2022. The schedule
reports total federal award expenditures and expenses for each federal program as identified by the Assistance
Listing (AL) number in the Catalog of Federal Domestic Assistance. Federal awards without identified AL
numbers have been identified as “Unknown” (UNK).

Federal financial awards include federal financial assistance and federal cost-reimbursement contracts.
Federal financial assistance may be defined as assistance provided by a federal agency, either directly or
indirectly, in the form of grants, contracts, cooperative agreements, loans, loan guarantees, property, food
commodities, interest subsidies, insurance or direct appropriations, but does not include direct federal cash
assistance to individuals. Non-monetary federal assistance including surplus property, supplemental nutrition
benefits and food commodities is reported in the schedule. Solicited contracts between the state and the
federal government for which the federal government procures tangible goods or services are not considered
to be federal financial assistance.

Food and commodity distributions on the accompanying schedule are valued using a weighted average cost
based on the U.S. Department of Agriculture commodity price list at the inventory receipt date. The
supplemental nutrition benefits issuance amount included in the accompanying schedule is stated at the value
of supplemental nutrition benefits redeemed. Donated federal surplus property is included in the schedule at
a percentage of the federal government acquisition cost.

The scope of the schedule includes expenditures made by state primary recipients. The determination of when
a federal award is expended is based on when the activity related to the federal award occurs. Generally, the
activity pertains to events that require the state agency to comply with federal statutes, regulations, and the
terms and conditions of federal awards. With reference to the primary government, the primary recipient
expenditures are not adjusted for sub-recipient expenditures.




                                                     154
Notes to the Schedule of
Expenditures of Federal Awards
Certain federal expenditure transactions may appear in the records of more than one state agency. To avoid
duplication and overstatement of the aggregate level of federal expenditures by the State of Oklahoma, the
following policies have been adopted:

    •    When monies are received by one state agency and distributed to another state agency, the federal
         expenditures are attributed to the state agency that actually expends the funds.

    •    When purchases of provider services between two state agencies occurs, the federal funds are
         normally recorded as expenditures on the purchasing state agency’s records and provider service
         revenues on the records of the state agency rendering the services. Therefore, the receipt of federal
         funds related to provider services will be attributed to the purchasing agency which is the primary
         receiving/expending state agency.

Major programs are defined by levels of expenditures and expenses and risk assessments established in the
Uniform Guidance.

C. Basis of Accounting

The accompanying schedule, in general, reports expenditures of the primary government in accordance
with Generally Accepted Accounting Principles (GAAP). GAAP requires that governmental funds report
revenue and expenditures using the modified accrual basis of accounting as described in the ACFR. The
modified accrual basis of accounting recognizes expenditures and expenses when liquidated with current
resources. The Oklahoma Department of Wildlife Conservation, Oklahoma Department of Environmental
Quality and Oklahoma Water Resources Board use the accrual basis of accounting that recognizes
expenditures when incurred.


Note 2. Indirect Cost Rate

Per Uniform Guidance 2 CFR § 200.510(b)(6), agencies are required to disclose whether or not they elect to
use the 10 percent de minimis cost rate that 2 CFR§ 200.414(f) allows for nonfederal entities that have never
received a negotiated indirect cost rate. Below is a table indicating whether the agency has elected to use the
10 percent de minimis cost rate or not:

                  Yes                                      No

   Office of Management and Enterprise             State of Oklahoma
     Services                                      Military Department
   Department of Mines                             Attorney General
   Office of Disability Concerns                   Oklahoma Arts Council
   State Auditor & Inspector                       Oklahoma Aeronautics Commission
                                                   Oklahoma Commission on Children and Youth
                                                   Department of Corrections
                                                   Oklahoma Department of Commerce
                                                   District Attorney’s Council
                                                   Election Board
                                                   Oklahoma Employment Security Commission
                                                   Governor’s Office
                                                   Oklahoma State Bureau of Investigation Oklahoma
                                                   Department of Emergency Management
                                                      and Homeland Security
                                                   Oklahoma Department of Wildlife Conservation
                                                   Medicolegal Investigation Board
                                                   Transportation Department




                                                     155
Notes to the Schedule of
Expenditures of Federal Awards

                                                   Oklahoma Historical Society
                                                   Office of Juvenile Affairs
                                                   Department of Libraries
                                                   Narcotics/Dangerous Drugs Control
                                                   Oklahoma Center for Science and Technology
                                                   Oklahoma Tax Commission
                                                   J. D. McCarty Center
                                                   Supreme Court
                                                   Veterans Affairs Department
                                                   Oklahoma Health Care Authority
                                                   Department of Human Services



Note 3. State Unemployment Insurance Fund
Expenditures for unemployment insurance (UI), AL #17.225, include state UI funds as well as federal UI
funds. The state portion of UI funds amounted to $191,095,072. The federal portion of UI funds amounted
to $42,737,032. Federal UI funds expended specifically in response to the coronavirus pandemic amounted
to $38,186,550.

Note 4. Cost Recovery of Federal Program Expenditures
During fiscal year 2022, the Oklahoma Department of Health received cash rebates from infant formula
manufacturers in the amount of $19,200,415 on sales of formula to participants in the Special Supplemental
Nutrition Program for Women, Infants, and Children, AL #10.557. The rebate contracts are authorized by 7
CFR 246.16a as a cost containment measure. The cash rebates are treated as a credit against prior food
expenditures.

The Oklahoma Department of Transportation incurred significant expenditures on construction projects that
exceeded the contract amounts approved by the federal grantor. These project expenditures are held in
suspense until modified contracts are approved by the federal grantor and the expenditures subsequently
reimbursed. Project expenditures totaling $5,262,200 were in suspense at June 30, 2022, and once the
modified contracts are approved by the U.S. Department of Transportation an estimated 100% will be
considered available.

Note 5. Audits Provided by Auditors Other Than Principal Auditor
Audits provided by auditors other than the principal auditor include:

         Oklahoma Department of Commerce
         Oklahoma Department of Wildlife Conservation
         Oklahoma Department of Environment Quality
         Oklahoma Water Resources Board

Several programs were identified as major and audited as such in the separate single audits of these entities.
The schedule separately identifies programs that were audited as major programs by independent auditors of
entities.

Note 6. Department of Transportation Federal Soft Match Provision

Beginning in the year 1992, the Oklahoma Department of Transportation began using the “soft match”
provision of the Inter-modal Surface Transportation Efficiency Act, which allows the maintenance and




                                                     156
Notes to the Schedule of
Expenditures of Federal Awards
construction cost of toll facilities that serve interstate commerce to be used in lieu of state matching funds.
Annually, dollars spent for major maintenance (reconstruction) of turnpikes or new construction may be
added to the amount of soft match credit available for use as state match. The state’s share of expenditures is
deducted from the available soft match amount. Federal money would then fund 100 percent of the project
from the amount that had previously been apportioned for Oklahoma’s highway projects.

The Department utilized $30,339,549 of the soft match provision for projects billed during fiscal year 2022.
These soft match dollars are applied to the approved construction projects when expenditures are incurred,
based on the soft match percentage. It should be noted that the amount of soft match credit utilized on the
progressive estimate billings submitted to the Federal Highway Administration for each project is an estimate
during the course of the project. The actual amount of soft match utilized for a particular project is not
determinable until the project is final and the final reconciliation and billing has been submitted to the Federal
Highway Administration.

Note 7. Department of Health HIV Care Rebates
Although federal expenditures for HIV Care Formula Grants, AL #93.917, are minimal, this program also
receives drug rebates to help administer the program. These rebates are not considered federal expenditures,
however, they must be restricted and spent in accordance with applicable federal grant requirements. After
considering these drug rebates of $16,689,928, the Oklahoma State Department of Health expended
$16,779,470 during 2022 for this program.

Note 8. Child Care and Development Fund Expenditures
The Child Care and Development Fund (CCDF) provides funds to increase the availability, affordability, and
quality of child care services. Funds are used to subsidize child care for low-income families when the parents
are working or attending training or educational programs, as well as for activities to promote overall child
care quality for all children. As a response to several naturally occurring disasters during 2019 and the
coronavirus pandemic in 2020, 2021, and 2022, additional federal funds were appropriated to CCDF.
The Oklahoma Department of Human Services, the primary receiving agency, expended the following
amounts for each CCDF program during fiscal year 2022:

                                                                                              Total Federal
                                  Program                                        AL #         Expenditures
 CCDF Block Grant                                                               93.575         $161,826,637
 CCDF Disaster Relief                                                           93.575                    -
 CCDF Coronavirus Aid, Relief, and Economic Security                            93.575                    -
 CCDF Coronavirus Response and Relief Supplemental Appropriation                93.575          $56,278,963
 CCDF America Rescue Plan Supplemental                                          93.575                    -
 CCDF America Rescue Plan Child Care Stabilization Funds                        93.575         $326,364,883
 CCDF Mandatory and Matching                                                    93.596          $53,133,056
 CCDF Coronavirus Mandatory and Matching                                        93.596           $2,519,172
 CCDF Coronavirus Aid, Relief, and Economic Security                            93.596                    -




                                                      157
Corrective Action Plan
                          STATE OF OKLAHOMA/OFFICE OF MANAGEMENT AND ENTERPRISE SERVICES
                                         STATE OF OKLAHOMA – SINGLE AUDIT
                                             CORRECTIVE ACTION PLAN
                                                   2 CFR § 200.511(c)
                                                       SFY 2022

            Subject Heading
             (Financial) or                                                                                                           Responsible
Finding                                                                                                             Anticipated
           Assistance Listing                           Planned Corrective Action                                                       Contact
Number                                                                                                            Completion Date
           and program name                                                                                                             Person
                (Federal)
                                    The State disagrees with this finding. Funds were reported as obligated
                                    and expended when the State issued payment to the partners carrying out
                                    the program on behalf of the State. This is how the State interpreted the
                                    guidance at the time. Treasury has accepted the State of Oklahoma’s
                                    reports provided to them to date. Treasury has since updated guidance, and
                                    the State is updating how obligated and expended are reported – however,
                                    that’s a recent (end of calendar 2023) change. Monthly and quarterly
             21.023 Emergency       reports were snapshots in time. Towards the end of ERA-1, Treasury
2022-028   Rental Assistance (ERA   acknowledged this reality by recommending that no corrections should be              N/A         Brandy Manek
               1 and ERA 2)         made to past reports, that the final report would take care of any
                                    corrections that needed to be made (per NCSHA Meeting with Treasury on
                                    October 14th, 2022). As of Q1 2023, all reports submitted to Treasury are
                                    cumulative over the life of the program, due on a quarterly basis – monthly
                                    and quarterly reports are no longer required. The State believes that there
                                    is no corrective action plan needed since the cumulative reports should
                                    accurately reflect the reality of spend vs refunds.

                                    The State of Oklahoma entered into contracts with two non-profit entities
             21.023 Emergency       to administer the ERA program for the State of Oklahoma. The State
                                    viewed the relationship as contractual and proceeded accordingly on the       Next SEFA/Package Z
2022-030   Rental Assistance (ERA                                                                                                     Brandy Manek
                                    SEFA. SAI reviewed the contracts for these two entities and determined             Completion
               1 and ERA 2)
                                    that both agreements constituted a subrecipient relationship. However,
                                    according to Uniform Guidance the substance of the relationship




                                                                        158
                                    determines whether the entity is treated as a subrecipient or contractor. We
                                    are awaiting guidance from Treasury. This is the reason for the discrepancy
                                    on the SEFA not a process issue. Going forward and until there is a
                                    determination from Treasury, OMES will classify any ERA expenditures
                                    as payments to subrecipients.

                                    The State disagrees with this finding. CCP considered the spreadsheets
             21.023 Emergency       returned by the utility companies to be acceptable supporting
2022-032   Rental Assistance (ERA   documentation for the amount that was paid, following Treasury’s best          February 2024   Brandy Manek
               1 and ERA 2)         practices.


                                    The State disagrees with this finding. The State of Oklahoma entered into
                                    contracts with two non-profit entities to administer the ERA program for
                                    the State of Oklahoma. SAI reviewed the contracts for these two entities
                                    and determined that both agreements constituted a subrecipient
                                    relationship, however according to Uniform Guidance the substance of the
                                    relationship determines whether the entity is treated as a subrecipient or
                                    contractor. As we await a Treasury determination on the nature of the
             21.023 Emergency       contracted relationship between OMES and its ERA partners, OMES
2022-033   Rental Assistance (ERA   sought to establish a Grants Management Office (GMO) that would be               June 2021     Brandy Manek
               1 and ERA 2)         responsible for any future centralized state grants that come to the state.
                                    The GMO has drafted policies and procedures for administration of federal
                                    grants including a Grant Agreement and Grant Award Notification, as well
                                    as other documents on Policies and Procedures, Risk Assessment,
                                    Subrecipient Monitoring, Maintenance of Effort and Close Out Procedures.
                                    The State has previously engaged Eide Baily for subrecipient monitoring
                                    activities in FY22.

                                    The State concurs with this finding. OMES established a Grants
             21.023 Emergency       Management Office that will be responsible for any future centralized state
                                    grants that come to the state.
2022-034   Rental Assistance (ERA                                                                                   June 2024      Brandy Manek
               1 and ERA 2)

                                    The State disagrees with this finding. We agree that the spreadsheet
                                    discussed was not designed to see “at a glance” the number of arrears and
                                    prospective payments as that was not the purpose of the spreadsheet. This
             21.023 Emergency       information was tracked in a robust system specifically designed for ERA       February 2024
2022-036   Rental Assistance (ERA   reporting, called Neighborly. The spreadsheet was designed to provide                          Brandy Manek
               1 and ERA 2)         clarity of the flow of money across the different categories of ERA funds.
                                    The Neighborly system includes all the information mentioned in the audit
                                    finding. This includes the total number of months spent on each applicant
                                    and which months fell into the arrear’s vs prospective category.




                                                                        159
                                     Inquiries throughout the audit were answered using documentation from
                                     this system. The documentation provided to answer multiple audit inquiries
                                     included the very information that is said to not be maintained in Finding
                                     #2022-036.
                                     Although the rental assistance program has ended and there will not be a
                                     need for tracking months of rental assistance going forward, the state will
                                     ensure that it has adequate supporting documentation for review of ongoing
                                     grant assistance.
                                     The State partially concurs with this finding. The State partially disagrees
                                     with the ‘Condition and Context’ statement. Both contracted
                                     administrators of the ERA program underwent Single Audit reviews by
                                     independent, qualified CPA firms and neither had any findings. Review of
                                     internal controls was a significant portion of those audit(s). Both
                                     administrators regularly reported the status of ERA programs to the State.
             21.023 Emergency
2022-046   Rental Assistance (ERA                                                                                       February 2024     Brandy Manek
                                     In addition, while the State disagrees with the findings overall context that
               1 and ERA 2)
                                     supporting documents were inadequate, we do acknowledge that in those
                                     supporting documents provided to the auditor an error in billing was noted
                                     resulting in questioned costs of $3,772.50. The subcontractor was notified
                                     and a credit issued so that funds could be returned to Treasury.
                                     Going forward, the State will review all documents provided by the
                                     administrator of ERA funds for accuracy and allowability.
                                     Management partially agrees with this finding. As the Coronavirus Relief
                                     Fund grant has expired, CARES FORWARD no longer exists. OMES will               Additional review will
                                     review the reimbursements contained in the bulleted samples and will             be conducted, and
                   21.019            present its determinations once the review is complete.                         OMES determinations
2022-071   Coronavirus Relief Fund                                                                                   will be communicated Brandy Manek
                   (CRF)             Additionally, completed third party audits performed on the 2 of the 3          on or before June 30,
                                     subrecipients for fiscal year 2022 noted no questioned or unallowable costs              2024
                                     related to federal expenditures. OMES is not yet in receipt of a third-party
                                     audit for the remaining subrecipient.
                                     Management partially agrees with these findings. These recommendations           Partially Complete.
                                     are considered partially complete. As the Coronavirus Relief Fund grant         Additional review will
                                     has expired, CARES FORWARD no longer exists. The CARES Forward                   be conducted, and
                   21.019            team developed procedures during rapid deployment of $1.2 billion of
                                                                                                                     OMES determinations
2022-076   Coronavirus Relief Fund   pandemic relief funding and, later in the process, in response to certain                              Brandy Manek
                                                                                                                     will be communicated
                   (CRF)             previous single audit findings. Specifically, In June of 2021, OMES
                                                                                                                     on or before June 30,
                                     established a Grants Management Office (GMO) as a central agency
                                     resource to oversee and ensure compliance for specific grant programs.                   2024
                                     The GMO previously designed and implemented, and currently continues




                                                                          160
to improve, its controls to ensure that expenditures are properly incurred
pursuant to the federal award and associated guidance. OMES will review
the bulleted samples, the reimbursement to OESC, and OMES will present
its determinations after it has conducted its review.

In relation to the context and cause section of this finding, management
would suggest the following:

   •      that the auditor considers Title 62, Section 34.62 which is
   referenced in the contract and allows the OMES Director to waive
   competitive bidding when it is in the best interest of the state.
   Certainly, it was in the best interest of the state to support the
   deployment of over $1.2 billion in less than one year that was intended
   to save lives and support state agencies as they battled the pandemic
   falls under this category.

   •     that the contractor referenced in the condition and context section
   did not approve their own contract nor did they approve invoices for
   payment to them. The selection of the contractor and approval of the
   contract was done by state employees. Invoice approvals were done in
   PeopleSoft by OMES employees. The contractor only approved those
   payments as eligible for reimbursement from the Coronavirus Relief
   Fund.

   •      The auditor states that the invoices contained no detail of the work
   performed. Subsequent to this audit period, the contractor has improved
   their invoicing procedures and includes detail such as number of hours
   worked and associated contract. Management will review the process
   with the contract for invoices submitted going forward.

   •     The auditor states that the number of hours worked by each
   consultant was not listed on the invoices. Subsequent to this audit
   period, the contractor has improved their invoicing procedures and
   includes detail such as number of hours worked and associated contract.

   •     The auditor states that there were no regular (at least weekly)
   reporting updating progress and status. The contractor did participate in
   weekly and bi-weekly meetings to report progress. The contractor did
   also provide email updates of progress. The auditor’s office has been
   provided with emails and meeting notices to support this. The contract
   did not require written updates.




                                     161
                                      •      The auditor states that the services to be performed by a specific
                                      date was not clearly documented. The services to be performed are tied
                                      to the federal covid relief funding. This essentially ended up being the
                                      Coronavirus Relief Fund grant which is a responsibility that the
                                      contractor will support until the last state audit and/or federal reviews
                                      are complete.

                                      •     The auditor states that the services to be performed or scope of
                                      work for the deliverables-based contract was not supported.
                                      Management has supplied the auditor with several agendas and progress
                                      reports over the course of the contracts that represent the written
                                      documentation of scope of work of this project.

                                    Finally, the Central Purchasing division of OMES will review the current
                                    training offered to OMES Certified Procurement Officers and consider
                                    updates to such training responsive to this recommendation regarding
                                    conflicts of interest and other requirements when awarding consulting
                                    contracts.


                                    The State partially concurs with this finding. The ERA contractors
                                    recorded their daily time worked through time sheets, subject to weekly
                                    review and approval. The entire scope of their work was ERA dedicated
                                    tasks, unlike an individual who might be working on multiple projects at
                                    once. Because of this singular focus, it was not necessary to itemize
                                    individual tasks.
                                    Within the contractual agreements and bonus policies, provisions were
                                    made for bonuses tied to various completion goals, strategically designed
             21.023 Emergency
                                    to enhance retention. The nature of the contractors' responsibilities was
2022-085   Rental Assistance (ERA                                                                                 February 2024   Brandy Manek
                                    profound, involving tasks which subjected them to level two trauma such
               1 and ERA 2)
                                    as engaging in daily conversations with individuals facing homelessness or
                                    contemplating suicide. Acknowledging the challenging nature of this work,
                                    the administrator intentionally incorporated opportunities for retention
                                    bonuses, understanding the significance of recognizing and incentivizing
                                    their continued work to assist as many Oklahomans as possible. It is
                                    imperative to note that both the structure of the bonuses and the overall
                                    approach were not only reasonable but also fully compliant with federal
                                    program regulations.




                                                                        162
                                    Although the rental assistance portion of the ERA program has ended, the
                                    State will ensure that contractors continue to follow guidance on all future
                                    grants.

                                    The state partially concurs with this finding. We disagree with the
                                    questioned expenses in the first bullet. These expenses were appropriate as
             21.023 Emergency       a contractor and necessary expenses for the distribution of the ERA funds
2022-086   Rental Assistance (ERA   and fulfillment of the contract. We agree with bullets 2, 3, 4 and 5 as we     February 2024   Brandy Manek
               1 and ERA 2)         were not able to provide adequate documentation to support the
                                    expenses. The state will ensure that adequate supporting documentation
                                    will be retained for future expenses.

                                    OMES partially concurs with this finding. In the State Audit Report 2022-
                                    087, the question of administrative fees is raised as an unallowable
                                    expense. This finding is based on the interpretation that the State should
                                    have characterized the relationship between State and CFO/CCP as a
                                    subrecipient which was allowed by the Act but not required. The Federal
                                    Code of Regulations requires that the nature of the relationship determine
                                    the categorization of same; the reality that CCP had been created during
                                    CARES act and was continuing existing work under ERAP substantiates a
                                    contractor relationship. FAQ 21 clearly provides that the State could have
                                    made subawards to subrecipients or “enter into contracts…for goods or
                                    services to implement ERA programs.” As a contract for services, the
                                    questioned administrative fees are wholly appropriate.
             21.023 Emergency
                                    We strongly disagree with bullet point #6. In October 2021, along with
2022-087   Rental Assistance (ERA                                                                                   June 2024      Brandy Manek
                                    many other ERA recipients, Oklahoma was directed to submit a Program
               1 and ERA 2)
                                    Improvement Plan (PIP) by Treasury or the ERA grant would be subject to
                                    reallocation. Essentially, the funds set aside to help struggling
                                    Oklahomans during a pandemic, with unprecedented eviction rates, would
                                    have been clawed-back and redistributed to another jurisdiction. This
                                    would have left thousands of Oklahoma households facing eviction, ruined
                                    credit and homelessness. It was incumbent to improve the system, reduce
                                    the backlog of applications and become more efficient to fully serve
                                    Oklahomans and meet the requirements of the US Treasury.
                                    Oklahoma’s PIP was approved by Treasury on December 16, 2021. The
                                    submitted plan for improvement included implementation of software
                                    designed for the ERA program and engaging with a subcontractor who
                                    specialized in change management and efficiency. The work this
                                    subcontractor provided was absolutely essential to the PIP.




                                                                         163
The State of Oklahoma has sought to create and implement best practices
regarding the administration of federal grant funds, including subrecipient
monitoring protocols. These best practices include the creation of a Grant
Management Office, which has drafted policies and procedures for
administration of federal grants including a Grant Agreement and Grant
Award Notification, as well as other documents on Policies and
Procedures, Risk Assessment, Subrecipient Monitoring, Maintenance of
Effort and Close Out Procedures. The State engaged Eide Baily for
monitoring in FY22.




                                     164
                      STATE OF OKLAHOMA/OFFICE OF MANAGEMENT AND ENTERPRISE SERVICES
                                     STATE OF OKLAHOMA – SINGLE AUDIT
                                         CORRECTIVE ACTION PLAN
                                               2 CFR § 200.511(c)
                                                   SFY 2022

            Subject Heading
             (Financial) or                                                                                      Anticipated   Responsible
Finding
           Assistance Listing                         Planned Corrective Action                                  Completion      Contact
Number
           and program name                                                                                         Date         Person
                (Federal)
                                SAI Recommendation 1: “We recommend that OMES gain an
                                understanding of the requirements of federal awards applicable to activities
                                                                                                                               Caden Cleveland,
                                allowed and allowable costs.”
                                                                                                                               OMES
                                                                                                                               Director of
               AL #84.425 –     OMES Response to Rec. 1: This recommendation is considered complete. In
                                                                                                                               Public Affairs
               EDUCATION        January 2021, OMES established a Grants Management Office as a central
                                                                                                                               and Grants
             STABILIZATION      agency resource to track and ensure compliance of specific grant programs.
                                                                                                                               Management;
                FUND (ESF       Since the creation of this team, OMES has gained a fuller understanding of
2022-081      AL #84.425C –     program requirements of federal awards being overseen and has an ongoing         COMPLETE
                                                                                                                               John Laws,
              GOVERNOR’S        effort to ensure compliance with federal monitoring and reporting regulations.
                                                                                                                               Chief Financial
              EMERGENCY
                                                                                                                               Officer for the
           EDUCATION RELIEF     SAI Recommendation 2: “We recommend that OMES ensure all employees
                                                                                                                               State of
                  FUND          responsible for the administration of federal                                                  Oklahoma




                                                                  165
awards provides adequate oversight of any contracted services applicable to
those federal awards.”

OMES Response to Rec. 2: This recommendation is considered complete. In
January 2021, OMES established a Grants Management Office as a central
agency resource to track and ensure compliance of specific grant programs.
Since the creation of this team, OMES has gained a fuller understanding of
program requirements of federal awards being overseen and has an ongoing
effort to ensure compliance with federal monitoring and reporting regulations.

SAI Recommendation 3: “We recommend that OMES provide training to all
employees involved in the procurement of services with regard to federal
requirements and State purchasing rules including ethical considerations.”

OMES Response to Rec. 3: This recommendation is considered complete.
All employees of the Grants Management Office currently undergo monthly
grant training to ensure staff is up to date with the latest federal guidance and
knowledgeable on all facets of the grant lifecycle. Additionally, in September
2023 the Grants Management Office conducted a focused training with
OMES Central Purchasing personnel specifically focused on the state’s
procurement requirements for grants. This training with Central Purchasing is
planned to become an annual event to ensure staff is knowledgeable of any
updates to the Central Purchase Act, rules or subsequent procedures. The
Grants Management Office has maintained a continual line of communication
with OMES Central Purchasing in the event that clarification or guidance is
needed related to procurement.




                                   166
SAI Recommendation 4: “We recommend that OMES ensure individuals
responsible for procurement of services do not have a conflict of interest
with parties OMES contracts with.”

OMES Response to Rec. 4: This recommendation is considered complete.

SAI Recommendation 5: “We recommend that OMES does not pay for any
services until the services are appropriately performed and the invoiced
services are supported by adequate documentation verifying the number of
hours actually worked and the services actually performed.”

OMES Response to Rec. 5: This recommendation is considered complete.
In the case cited by SAI in Finding 2022- 081, OMES would disagree with
the statement that the agency continued to pay invoices to a consulting firm
without proper knowledge or documentation of services provided.
Specifically, for the GEER II consultation agreement OMES received weekly
risk mitigation reports, policies, procedures, templates, scoring sheets, review
documents, etc. during the timeframe of the agreement. Additionally, OMES
was invoiced and paid for services the month after work was provided.

OMES would also like to furnish the following responses to additional
statements made in this finding that were not included in the above
recommendations:

 a. Claim: “The contracts/agreements constituted unallowable fixed rate
     agreements.”

     Response:
      OMES asserts that the contract awarded for consultant services was
      deliverables-based, rather than a fixed rate agreement.




                                   167
A fixed rate contract is for services provided directly to the clients of
an agency by a third-party at a fixed rate. These contracts include six
necessary attributes:
1) In order to enter into a fixed rate contract, an agency must first
submit a request to the state purchasing director for preapproval before
issuing the contract. 2) The services must be for clients of the agency
(i.e., foster children in state custody or clients of the ODMHSAS); 3)
The services must be provided directly to clients of an agency (i.e.,
health care services, foster care services); 4) The services must be
provided by a third-party (i.e., a medical clinic, foster parents, mental
health facilities); 5) The services must be provided on a unit basis (i.e.,
per day, per bed, per office visit); and 6) The contract must be for
services that are not provided by the agency and the agency does not
have employees capable of providing the services.
For the above reasons, the type of contract contemplated by 74 O.S. §
85.7(A)(6)(f)(2) and cited within the State Auditor and Inspector’s
findings would not be the type of contract that was utilized to contract
with a c. Rather, what was utilized was a deliverables-based contract.
A deliverables-based contract differs from a fixed-rate contract in that
the client in a deliverables-based contract agrees to pay a fixed, pre-
negotiated price amount when the supplier completes and conveys the
deliverable to the client. A deliverables-based contract is not subject to
the provisions cited in 74 O.S. § 85.7. In this particular case, the
contractor was providing staff augmentation hours for a range of
services at a set price. The result of these hours was the foundation of
the GEER II program with subsequent supporting documentation
(policies, procedures, templates, review of applications, scoring, etc.).
Central Purchasing advises state entities to utilize a
deliverables-based contract as it helps agencies determine




                            168
            their budgets with better accuracy. The State Purchasing Director’s
            administrative code directs suppliers to provide a “firm, fixed price for
            the term of the contract” when submitting a bid (OAC 260:115-3-7(g)).

            Based on this information provided by the State Purchasing Director,
            the contract with a consulting firm referenced by SAI was a
            deliverables-based contract and was properly formed and paid in
            accordance with state law. We would request that the SAI reconsider
            including the related statements in Finding 2022-081.

     b.     Claim: “The consulting firm was paid prior to performing any services
            and, was paid for some services that were not performed.”

            Response:
              OMES would disagree with this statement. Invoices were received for
              services provided and payment was sent the month following
              services. When services were no longer needed, the consulting firm
              ceased invoicing the state and the state ceased payment for services.

c.        Claim: The GEER II consultant agreement entered in 2021 was a “no
          bid contract”.

            Response:
              After a competitive solicitation (sol. # 09000005512), which included
              an RFP, adequate time for questions and responses, blind evaluation
              (PIPS process), review committee member scoring, an interview with
              the respondent, and legal review, OMES entered into an agreement
              with a consulting firm to provide program support for the Governor’s
              Emergency Education Relief Fund, part two (GEER II). On Nov. 22,
              2021, after the full RFP, evaluation, and contracting process was
              completed, the agreement was finalized by both parties. The specific
              items outlined in this deliverables-based contract agreement
              numerous, including but not limited to, program organization,
              communication and planning, creation of policies, procedures and
              templates, program monitoring, and closeout (see full Statement of
              Works on pages 52-53 of contract).




                                       169
                                 SAI Recommendation 1: “We recommend that OMES develop policies and
                                 procedures to ensure that FFATA reports, and applicable revisions are
                                 submitted timely, and information is complete.”

                                 OMES Response to Rec. 1: The OMES Grants Management Office has
                                 implemented policies and procedures that include reporting requirements.                        Caden Cleveland,
                                 However, the office will review these policies and procedures to ensure it
                                                                                                                                 OMES
                                 effectively outlines steps to ensure applicable federal reports are submitted in
                                                                                                                                 Director of
               AL #84.425 –      an efficient and timely manner.
                                                                                                                                 Public Affairs
               EDUCATION
                                 SAI Recommendation 2: “We recommend that OMES develop policies and                              and Grants
             STABILIZATION
                                 procedures to ensure that GEER Annual reports are submitted timely, and                         Management;
                FUND (ESF        information is accurate and complete.”
2022-082      AL #84.425C –                                                                                         06/30/2024
                                                                                                                                 John Laws,
              GOVERNOR’S         OMES Response to Rec. 2: The OMES Grants Management Office has
                                 implemented policies and procedures that include reporting requirements.                        Chief Financial
              EMERGENCY
                                 However, the office will review these policies and procedures to ensure it                      Officer for the
           EDUCATION RELIEF
                                 effectively outlines steps to ensure applicable federal reports are submitted in                State of
                  FUND
                                 an efficient and timely manner.                                                                 Oklahoma

                                 SAI Recommendation 3: “We recommend that OMES revise the FFATA reports
                                 and GEER Annual reports to correct all
                                 inaccurate and incomplete information previously reported.”
                                 SAI Recommendation 1: “We recommend OESC and OMES ensure all related
                                 party transactions are properly reported on Question #28 of OMES GAAP
                                 Package X.”

                                 OMES Response to Rec. 1: OMES Finance will work to implement new                                 Megan Meers,
                                 procedures to ensure that all related party transactions are properly reported     07/01/2024     OMES Chief
                                 going forward.                                                                                  Financial Officer
                                 SAI Recommendation 2: “Further, we recommend both OMES and OESC
                                 work to strengthen the procurement control process by ensuring initial
           17.225 Unemployment   contracts for new vendors be competitively bid until a determination can be
2022-088
            Insurance Program
                                 made as to whether the vendor’s services were a benefit to the State of
                                 Oklahoma.”

                                                                                                                        N/A       Megan Meers,
                                 OMES Response to Rec. 2: In response to the specific action taken by OMES
                                                                                                                                   OMES Chief
                                 and OESC in hiring Phase 2 in the spring of 2020, the State was faced with an
                                                                                                                                 Financial Officer
                                 unprecedented global pandemic and needed to address a critical IT issue for the
                                 State. The procurement in question must be analyzed with all surrounding



                                                                    170
                      context and facts. OESC’s legacy systems were not able to address the demand
                      for services from Oklahoma’s citizens and risk of fraud and abuse caused by the
                      pandemic (as documented in the links provided below). The Governor
                      acknowledged the emergency created by the COVID-19 pandemic and issued
                      Executive Order # 2020-13 and suspended the requirement for competitive
                      bidding for emergency purchases not exceeding $250,000.00. OMES Finance
                      acknowledges the procurement was a result of a once in a lifetime emergency,
                      and requests SAI to acknowledge the same.

                      SAI Recommendation 3: “Lastly, we recommend that OMES and OESC not
                      contract with any vendor in the future they become aware of that could result in   07/01/2024    Megan Meers,
                      a conflict of interest.”                                                                          OMES Chief
                                                                                                                      Financial Officer
                      OMES Response to Rec. 3: OMES will work to implement new procedures to
                      follow for when we become aware of situations that could result in a conflict of
                      interest.

                       OMES Response to Rec. 3: OMES has confirmed with the USDOE that FFATA
                       reporting for GEER I and II are now accurate. OMES agrees that additional
                       revisions should be made to the GEER I and II Annual Performance Reports for
                       reporting years 1-2. OMES will work with the State Auditor and the USDOE on
                       applying revisions during the timeframes specified by the USDOE for reporting
                       adjustments.
                      SAI Recommendation 1: “We recommend the OMES develop and implement
                      policies and procedures for the Statewide Contract pilot programs to ensure all
                      federal contracts are properly executed.”

                      OMES Response to Rec. 1: This recommendation is considered complete. The            Sine Die      Amanda Otis,
                      OMES Central Purchasing Division has implemented published guidance for the                      State Purchasing
                      Statewide Contract pilot programs known as “rolling solicitations”.                              Director for the
                      https://oklahoma.gov/omes/divisions/central-purchasing/solicitations/rolling-
                                                                                                                      State of Oklahoma
                      solicitations/sw1025-it-staff-augmentation-services-pilot-program.html
                      The State Purchasing Director will develop training regarding this guidance so
2022-090   Multiple   Certified Procurement Officers (CPOs) are aware of the published guidance. This
                      will ensure CPOs effectively outline steps necessary to educate agencies of the
                      requirements for use of this new form of statewide contracts.

                      SAI Recommendation 2: “We recommend the OMES provide justification on
                      how vendors/consultants put on the Statewide Contract pilot programs are
                      exempt from competitive bidding requirements.”




                                                        171
OMES Response to Rec. 2: This recommendation cannot be completed as the              Sine Die     Amanda Otis,
OMES considers the solicitations conducted pursuant to the requirements of the                   State Purchasing
Statewide Contract pilot programs to meet competitive bidding requirements.                      Director for the
The Statewide Contract pilot programs utilize the same initial procedures as                    State of Oklahoma
statewide contracts prescribed in statute. Vendors are required to agree to
standard state terms as prescribed by the agency. Agencies utilizing contracts
under the Statewide Contract pilot programs conduct an evaluation process
relevant to the particular scope of services and negotiate price when choosing a
vendor pursuant to the direction of the State Purchasing Director.

SAI Recommendation 3: “We recommend the OMES work in a timely manner
to either bring the Statewide Contract pilot programs before the legislature to
explain the benefits to the state and what should be written into law or eliminate
the program.”

OMES Response to Rec. 3: This recommendation is in process. The OMES                 Sine Die     Amanda Otis,
plans to present evidence of the success of the Statewide Contract pilot programs                State Purchasing
during the upcoming legislative session and request amendments to the Central                    Director for the
Purchasing Act to include this method of statewide contracting.                                 State of Oklahoma

OMES would also like to furnish the following responses to additional
statements made in this finding that were not specifically included in the above
recommendations:
     Claim: The OMES does not have adequate controls in place, including
     policies and procedures, to ensure federal grant contracts are properly
     executed.

     Response: Federal contracts awarded under the Statewide Contract pilot
     programs meet the state’s competitive bidding requirements pursuant to the
     OMES policies and procedures.
     The Grant Management Office (GMO) has a standard Grant Agreement
     with each sub-recipient of a federal award. This agreement requires the sub-
     recipient to document that specific terms and conditions required by the
     various federal awards are included in the sub-recipient’s contracts with
     vendors.

     Claim: Contracts with vendors may not contain the applicable provisions
     required by 2 CFR §200.327.

     Response: Recipients of federal funds are ultimately charged with ensuring
     and documenting that specific terms and conditions required under the
     federal award are included in their procurements.
                                    172
                                           RYAN WALTERS
                             STATE SUPERINTENDENT of PUBLIC INSTRUCTION
                              OKLAHOMA STATE DEPARTMENT of EDUCATION

                                    STATE OF OKLAHOMA – SINGLE AUDIT
                                        CORRECTIVE ACTION PLAN
                                              2 CFR § 200.511(c)
                                                  SFY 2022


           Subject Heading
            (Financial) or
                                                                                        Anticipated
Finding       Assistance                                                                               Responsible
                                           Planned Corrective Action                    Completion
Number       Listing and                                                                              Contact Person
                                                                                           Date
            program name
              (Federal)
             AL #84.425 –     The Office of Title Services will review all future
             EDUCATION        construction contracts for the required wage rate
           STABILIZATION      clauses. Current practices address the application of
              FUND (ESF       the Davis-Bacon Act to the extent possible given the
                              capacity of the Office of Title Services.

                              In the Assurances section of the COVID Relief
                              Construction Application, the Office of Title Services
                              requires LEAs to attest that they have read and will
                              comply with “Appendix II to Part 200 – Contract
                              Provision for Non-Federal Entity Under Federal
                              Awards,” and specifically with the “Davis-Bacon Act,
                              as amended (40 U.S.C. 3701-3708).” Furthermore, in
                              the Consolidated Monitoring process LEAs are
                              required to submit “Copies of relevant contracts
2022-012                      showing wage agreements (Davis-Bacon Act).                  Feb-24       Thomas Kirk
            AL #84.425C;      Written statements from contractors and
             84.425D;         accompanying documentation to demonstrate
             84.425U)         prevailing wages have been applied when paying
                              contractors and subcontractors (e.g., payment ledgers
                              of wages paid and a copy of the prevailing wage scale
                              for the area).”

                              The Office of Title Services does not have the capacity
                              to review all construction contracts past and present,
                              nor does the Office of Title Services have the capacity
                              to collect and examine wage data on all ESF funded
                              construction projects past and future. The Office of
                              Title Services will act on cases of non-compliance that
                              come to light through Consolidated Monitoring and
                              through required independent audits.




                                                          173
                                           RYAN WALTERS
                             STATE SUPERINTENDENT of PUBLIC INSTRUCTION
                              OKLAHOMA STATE DEPARTMENT of EDUCATION

                                    STATE OF OKLAHOMA – SINGLE AUDIT
                                        CORRECTIVE ACTION PLAN
                                              2 CFR § 200.511(c)
                                                  SFY 2022




           Subject Heading
            (Financial) or
                                                                                        Anticipated
Finding       Assistance                                                                               Responsible
                                           Planned Corrective Action                    Completion
Number       Listing and                                                                              Contact Person
                                                                                           Date
            program name
              (Federal)
             AL #84.425 –
                              The Oklahoma State Department of Education (OSDE)
             EDUCATION
                              has revised the risk assessment procedures to include a
           STABILIZATION
                              second review of data sourced for the risk assessment.
2022-022      FUND (ESF                                                                  1-Jul-23     Tammy Smith
                              The second review will reduce the likelihood of errors.
            AL #84.425C;      In addition, OSDE is taking steps to create an agency-
             84.425D;         wide risk assessment.
             84.425U)




                                                           174
                                           RYAN WALTERS
                             STATE SUPERINTENDENT of PUBLIC INSTRUCTION
                              OKLAHOMA STATE DEPARTMENT of EDUCATION


                                    STATE OF OKLAHOMA – SINGLE AUDIT
                                        CORRECTIVE ACTION PLAN
                                              2 CFR § 200.511(c)
                                                  SFY 2022


           Subject Heading
            (Financial) or
                                                                                        Anticipated
Finding       Assistance                                                                               Responsible
                                           Planned Corrective Action                    Completion
Number       Listing and                                                                              Contact Person
                                                                                           Date
            program name
              (Federal)

                              The Office of Title Services will continue to provide
             AL #84.425 –     additional training to all reviewers to strengthen its
             EDUCATION        claims review process. In addition, the Office of Title
           STABILIZATION      Services will work with MTW Solutions, our Grants
2022-043      FUND (ESF                                                                  30-Jun-24    Tammy Smith
                              Management System (GMS) vendor, to ensure that
                              there is something in place to prevent a district from
            AL #84.425D;      being able to submit a claim where the Function/Object
             84.425U)         Code is not in the LEAs budget.




                                                          175
                                           RYAN WALTERS
                             STATE SUPERINTENDENT of PUBLIC INSTRUCTION
                              OKLAHOMA STATE DEPARTMENT of EDUCATION

                                    STATE OF OKLAHOMA – SINGLE AUDIT
                                        CORRECTIVE ACTION PLAN
                                              2 CFR § 200.511(c)
                                                  SFY 2022


           Subject Heading
            (Financial) or
                                                                                       Anticipated
Finding       Assistance                                                                              Responsible
                                          Planned Corrective Action                    Completion
Number       Listing and                                                                             Contact Person
                                                                                          Date
            program name
              (Federal)
                              OSDE, in partnership with a third-party consulting
                              firm, has developed a formalized procedure of FFATA
             AL #84.425 –
                              reporting that includes an established timeline and
             EDUCATION
                              calendar notifications/reminders for the staff members
           STABILIZATION
                              involved in the FFATA reporting process to report in a
              FUND (ESF
                              timely manner in compliance with USDE
                              requirements.
2022-044    AL #84.425D;                                                                 22-Sep      Tammy Smith
              84.425U;
              84.425V;
             84.425W)
                              We have a Project Director of Data and Reporting in
                              place now to ensure the established timeline for
                              meeting FFATA reporting is being met.




                                                          176
                                           RYAN WALTERS
                             STATE SUPERINTENDENT of PUBLIC INSTRUCTION
                              OKLAHOMA STATE DEPARTMENT of EDUCATION

                                   STATE OF OKLAHOMA – SINGLE AUDIT
                                       CORRECTIVE ACTION PLAN
                                             2 CFR § 200.511(c)
                                                 SFY 2022


           Subject Heading
            (Financial) or
                                                                                     Anticipated
Finding       Assistance                                                                            Responsible
                                          Planned Corrective Action                  Completion
Number       Listing and                                                                           Contact Person
                                                                                        Date
            program name
              (Federal)

             AL #84.425 –
             EDUCATION        We now have a Project Director of Data and Reporting
2022-049   STABILIZATION      working closely with our CFO to ensure that EANS         24-May      Tammy Smith
           FUND (ESF - AL     reporting is being met, both accurately and timely.
              #84.425R)




                                                         177
                                           RYAN WALTERS
                             STATE SUPERINTENDENT of PUBLIC INSTRUCTION
                              OKLAHOMA STATE DEPARTMENT of EDUCATION


                                   STATE OF OKLAHOMA – SINGLE AUDIT
                                       CORRECTIVE ACTION PLAN
                                             2 CFR § 200.511(c)
                                                 SFY 2022


           Subject Heading
            (Financial) or
                                                                                      Anticipated
Finding       Assistance                                                                             Responsible
                                          Planned Corrective Action                   Completion
Number       Listing and                                                                            Contact Person
                                                                                         Date
            program name
              (Federal)

                              After initial allocations were made to the non-public
                              schools in GMS, leadership of the Office of Federal
                              Programs decided to amend the way services were
             AL #84.425 –
                              delivered. OSDE contracted with Catapult Learning
             EDUCATION
                              West, LLC, and Galt Foundation to provide services to
2022-070   STABILIZATION                                                                23-Jun      Tammy Smith
                              non-public schools based on services needed by the
           FUND (ESF - AL
                              school to respond to COVID-19. As services were
              #84.425V)
                              rendered to the non-public schools, Catapult Learning
                              West LLC and/or Galt Foundation were paid directly
                              from OSDE with EANS funds.




                                                         178
     Trae Rahill                                                                                                                                               J. Kevin Stitt
     Chief Executive Officer                                                                                                                                       Governor

     Representing Employers                                                                                                                    Representing Employees
     Christy Rawlings, Commissioner                                       Representing the Public                                           Aaron Johnson, Commissioner
     Dean Pennello, Commissioner                                             David Reid, Chair                                                  Traci Cook, Commissioner




                                                         STATE OF OKLAHOMA – SINGLE AUDIT
                                                             CORRECTIVE ACTION PLAN
                                                                   2 CFR § 200.511(c)
                                                                       SFY 2022

 Finding          Subject                                         Planned Corrective                                            Anticipated                 Responsible
 Number           Heading                                               Action                                                  Completion                 Contact Person
               (Financial) or                                                                                                      Date
                AL no. and
              program name
                 (Federal)
2022-038      #17.225                 OESC concurs with the audit finding and agrees with the                                 Ongoing until                 Sharon Smith,
              Unemployment            recommendation. The agency also acknowledges the                                       modernization of              RESEA Program
              Insurance               importance of data integrity when reporting ETA 9128                                   RESEA tools are                  Manager
                                      activities and the important role such reporting plays in                                 complete
                                      evaluating and monitoring the RESEA program. OESC
                                      realized there was an issue with the RESEA enrollments
                                      opened during 3rd quarter 2021 and worked on creating
                                      procedures to ensure enrollments opened properly. Beginning
                                      in 1st quarter 2022, RESEA administrative staff started
                                      verifying that every participant enrolled in RESEA had an open
                                      enrollment to ensure the data is captured on the ETA 9128
                                      Report. In January 2023, administrative staff identified issues
                                      with enrollments not opening with a recently implemented
                                      technology tool. The agency subsequently decided to abandon
                                      the new technology and revert to its original scheduling system.
                                      OESC worked with the OKJM vendor to ensure all required
                                      services are opened automatically when the RESEA enrollment
                                      is established. In December 2023, OESC initiated a process to
                                      verify the enrollments opened and perform monthly review of
                                      all enrollments to ensure all data elements are captured for all
                                      participants. This process is expected to continue until a
                                      reliable technology solution can be implemented.
2022-051      #17.225                 OESC concurs with the audit finding and agrees with the                               Ultimate resolution              Christopher
              Unemployment            recommendation. The processes underlying these issues are                                 expected in               O’Brien, Director
              Insurance               embedded in the agency’s legacy mainframe platform. IT                                 conjunction with             Integrity Division
                                      spends significant time addressing issues identified by agency                          modernization
                                      staff, so the recommended effort is ongoing. The agency has                            efforts, timing to
                                      been successful in gaining legislative support for technology                           be determined
                                      modernization efforts that are underway, and we expect those
                                      efforts to provide the ultimate resolution for these types of
                                      issues that have proven to be difficult to resolve in the legacy
                                      environment.
2022-053      #17.225                 While the agency does not completely disagree with the                                    The efforts                Michelle Britten,
              Unemployment            Condition, Cause and Effect as documented by the auditors, the                         required for fraud            Chief Financial
              Insurance               agency believes additional considerations are important in                            prevention are not                 Officer
                                      drawing conclusions about whether all payments associated                             expected to end, as
                                      with the 2 claims identified as unallowable payments should be                           bad actors are
            Will Rogers Memorial Office Building, 2401 North Lincoln Boulevard, P.O. Box 52003, Oklahoma City, OK 73152-2003 |Phone (405) 557-7100 · Fax (405) 557-7174


                                                                                       179
                          considered unallowable benefit expenditures. We agree that            expected to
                          both claims have unresolved fraud stops associated with them,      continually pursue
                          but there was also no record of subsequent contact with             new methods to
                          appropriate parties for either claim that would be necessary to          exploit
                          draw an absolute conclusion that any or all of the previous          unemployment
                          payments were unallowable. The lack of evidence that either        benefit systems in
                          claimant attempted to clear the fraud stop and allow further           all states.
                          payments could be the result of the claimant finding work. The
                          conclusion drawn by the auditors is the worst-case scenario
                          based on the information available. As mentioned by the
                          auditors, the agency implemented an enhanced version of
                          VerifyOK in November 2022, which would have likely
                          prevented either of the 2 claims from being filed if they
                          involved identity theft. This version of VerifyOK enables a
                          much higher degree of accuracy to ensure identity of claimants
                          thus minimizing the possibility of fraud. This new tool uses
                          similar technology to that used in airports around the globe by
                          security personnel.

                          The agency continues to make fraud prevention a priority and
                          is engaging with federal partners, other state agencies and
                          vendor partners to be vigilant in anticipating trends in fraud
                          activity. While we believe we are expending appropriate levels
                          of effort in this area, we also want to acknowledge that the
                          complexity and ever-changing nature of the fraud space will
                          continue to make this a difficult risk to mitigate entirely.
2022-077   #17.225        The agency concurs with the finding and agrees with the              May 31, 2023        Sharon Smith,
           Unemployment   recommendation. The agency acknowledges our responsibility                              RESEA Program
           Insurance      for program integrity and proper controls for the RESEA                                    Manager
                          program. The technology solution for RESEA during this
                          period is no longer in place, and the agency has reverted to the
                          previous process for scheduling participants that automatically
                          uploads the letters to Docushare. The agency is undertaking
                          modernization efforts that will continue to provide better
                          solutions for the RESEA program in the future.

                          A monthly review process was established in 3rd quarter 2022
                          to review and verify that any necessary documents for the
                          appointments were uploaded as required.

                          In July 2022, DOL guidelines ended the process of utilizing
                          declining industry to select RESEA participants. This change
                          addresses the exceptions related to industry codes and NAICS
                          numbers. Due to provisions within DOL’s annual
                          appropriations, states have been given additional flexibility to
                          include all Unemployment Insurance (UI) claimants and former
                          U.S. military service members receiving Unemployment
                          Compensation for Ex-service (UCX) claimants.

                          To ensure proper and effective controls are in place, the agency
                          most recently reviewed and updated its RESEA Policy
                          effective May 2023. The policy outlines how to conduct
                          RESEA appointments, complete and document RESEA
                          services. RESEA Staff were trained May 2023 and training will
                          be offered as needed on an ongoing basis. In addition, we
                          review RESEA data quarterly to assess the effectiveness of
                          controls, and follow-up occurs with the OESC Quality Control
                          group to assess any corrective action needed to address their
                          findings. The agency will continue to look for opportunities to
                          improve RESEA procedures.




                                                               180
2022-084     #17.225        OESC concurs with the audit finding and agrees with the                   Resolution        Mike Hemphill,
             Unemployment   recommendations. The processes underlying these issues are                expected in        Tax Manager
             Insurance      embedded in the agency’s legacy mainframe platform. Efforts            conjunction with
                            expended by both Tax and IT staff have been unsuccessful to             modernization
                            manually correct the penalty and interest on the 5 accounts            efforts, timing to
                            identified. Tax staff have confirmed this error has not occurred        be determined
                            in subsequent quarters, but IT efforts have been unsuccessful at
                            identifying the cause for the original issue. The agency is
                            undertaking modernization efforts expected to provide the
                            ultimate resolution for this issue. While the agency is not
                            satisfied with not having resolution, the amount of penalty and
                            interest in question is not significant and is not causing negative
                            impact to the employers involved. OESC staff will continue to
                            monitor these tax processes for similar issues and take
                            appropriate actions to address as timely as possible.
2022-088     #17.225        OESC - The agency acknowledges the audit finding and                    July 31, 2024       OESC - Michelle
             Unemployment   recommendation as appropriate. The agency intends to respond                                 Britten, Chief
             Insurance      to the recommendations as follows:                                                          Financial Officer
                              1. OESC will reinstitute the practice of completing Related
                                  Party Affidavits on an annual basis. Completion of these
                                  affidavits will strengthen the ability of the agency to
                                  properly report any related party transactions on Question                            OMES – Felicia
                                  #28 of OMES GAAP Package X each year.                                                  Clark, State
                              2. While OMES initiated the initial contract with the vendor                               Comptroller
                                  on behalf of OESC, the agency will commit to completing
                                  a review of our procurement procedures involving non-
                                  statewide contract vendors with the objective of
                                  exceeding state procurement requirements. As is currently
                                  the case with OESC’s contracts with the vendor, OESC
                                  seeks to utilize statewide contracts for services whenever
                                  possible. Statewide contracts provide the benefit of pre-
                                  negotiated terms and pricing.
                              3. OESC is committed to not contract with any vendor in the
                                  future that could result in a known conflict of interest, and
                                  our commitment to the first recommendation will provide
                                  the basis for monitoring for compliance with this
                                  commitment.

                            OMES - OMES Finance will work to implement new
                            procedures to ensure that all related party transactions are
                            properly reported going forward. In response to the specific
                            action taken by OMES and OESC in hiring Phase 2 in the
                            spring of 2020, the State was faced with an unprecedented
                            global pandemic and needed to address a critical IT issue for
                            the State. The procurement in question must be analyzed with
                            all surrounding context and facts. OESC’s legacy systems
                            were not able to address the demand for services from
                            Oklahoma’s citizens and risk of fraud and abuse caused by the
                            pandemic (as documented in the links provided below). The
                            Governor acknowledged the emergency created by the
                            COVID-19 pandemic and issued Executive Order # 2020-13
                            and suspended the requirement for competitive bidding for
                            emergency purchases not exceeding $250,000.00. OMES
                            Finance acknowledges the procurement was a result of a once
                            in a lifetime emergency, and requests SAI to acknowledge the
                            same.
22-290-035   ACFR –         While the agency does not completely disagree with the                    The efforts       Michelle Britten,
             Benefit        Condition, Cause and Effect as documented by the auditors, the         required for fraud   Chief Financial
             Expenditures   agency believes additional considerations are important in            prevention are not        Officer
                            drawing conclusions about whether all payments associated             expected to end, as
                            with the 2 claims identified as unallowable payments should be           bad actors are
                            considered unallowable benefit expenditures. We agree that                expected to


                                                                   181
                         both claims have unresolved fraud stops associated with them,       continually pursue
                         but there was also no record of subsequent contact with              new methods to
                         appropriate parties for either claim that would be necessary to           exploit
                         draw an absolute conclusion that any or all of the previous           unemployment
                         payments were unallowable. The lack of evidence that either         benefit systems in
                         claimant attempted to clear the fraud stop and allow further            all states.
                         payments could be the result of the claimant finding work. The
                         conclusion drawn by the auditors is the worst-case scenario
                         based on the information available. As mentioned by the
                         auditors, the agency implemented an enhanced version of
                         VerifyOK in November 2022, which would have likely
                         prevented either of the 2 claims from being filed if they
                         involved identity theft. This version of VerifyOK enables a
                         much higher degree of accuracy to ensure identity of claimants
                         thus minimizing the possibility of fraud. This new tool uses
                         similar technology to that used in airports around the globe by
                         security personnel.

                         The agency continues to make fraud prevention a priority and
                         is engaging with federal partners, other state agencies and
                         vendor partners to be vigilant in anticipating trends in fraud
                         activity. While we believe we are expending appropriate levels
                         of effort in this area, we also want to acknowledge that the
                         complexity and ever-changing nature of the fraud space will
                         continue to make this a difficult risk to mitigate entirely.
2022-078   #21.019 -     The agency concurs with the audit findings and agrees with the          Ongoing          Michelle Britten,
           Coronavirus   recommendation. The Back-to-Work Initiative was a one-time,                              Chief Financial
           Relief Fund   short-term program that was initiated by the agency while also                               Officer
                         winding down all other Pandemic-related benefit programs.
                         OESC acted quickly to design systems and processes to support
                         the conceptual program leveraging new tools and resources
                         involved in modernization efforts for the agency. The dynamics
                         of moving quickly and utilizing resources that were new to the
                         agency contributed to the audit findings that were identified.
                         OESC is committed to designing controls for strong eligibility
                         verification and fraud prevention in conjunction with any new
                         programs in the future. Since the timeframe in which these
                         findings occurred, the agency implemented enhanced identity
                         verification capabilities that have improved the agency’s ability
                         to prevent fraudulent attempts to obtain benefit payments.




                                                               182
                                  STATE OF OKLAHOMA – SINGLE AUDIT
                                      CORRECTIVE ACTION PLAN
                                           2 CFR § 200.511(c)
                                               SFY 2022


 Finding     Subject Heading                  Planned Corrective Action                      Anticipated    Responsible
 Number     (Financial) or AL                                                                Completion      Contact
            no. and program                                                                     Date          Person
              name (Federal)
2022-201   93.268:               Management agrees with this finding and recognized            6/30/24     Stefan Von
           Immunizations         these issues earlier this year,                                           Dollen
           Cooperative           and as a result, has already implemented the following
           Agreements            control changes in 2023:
                                 1. Simplified the COA from 1.5M to 500 options to limit
           93.323:               employees coding incorrectly.
           Epidemiology and      2. Locked down access where possible.
           Laboratory Capacity   3. Continuing to emphasize supervisor review.
           for Infectious        4. July 2023 Payroll began providing a weekly payroll
           Diseases              spreadsheet on a Teams Page (POC chat) for all agency
                                 Points of Contacts.
2022-202   93.268:               Management agrees with this finding and is working            6/30/24     Stefan Von
           Immunizations         on implementing procedures to ensure that the data                        Dollen
           Cooperative           reported on the SEFA and FFRs is timely and accurate.
           Agreements            Internal controls are currently being established to
                                 create a more formal and adequate review process and
           93.323:               to include adequate support documentation retention.
           Epidemiology and
           Laboratory Capacity
           for Infectious
           Diseases

2022-203   93.268:               In 2023, OSDH established a dedicated employee to be          6/30/24     Stefan Von
           Immunizations         responsible for tracking audit requests and ensuring a                    Dollen
           Cooperative           timelier response to all requests going forward.
           Agreements            Management has also revised the current report
                                 structure of the dedicated employee to report directly to
           93.323:               the Deputy CFO to help eliminate any bottlenecks and
           Epidemiology and      delays in providing responses. Management has also
           Laboratory Capacity   recently added a new Deputy CFO to the leadership
           for Infectious        team, with a background as a former Controller and
           Diseases              Auditor, to be designated as the primary contact person
                                 on OSDH audits.
2022-204   93.268:               OSDH management will work with the appropriate                6/30/24     Stefan Von
           Immunizations         area to provide guidance on document preparation and                      Dollen
           Cooperative           retention going forward.
           Agreements

2022-205   93.268:               Management agrees and accepts the finding and the             6/30/24     Stefan Von
           Immunizations         recommendation to complete a reconciliation for the                       Dollen
           Cooperative           identified period and agency. Additional controls are
           Agreements            currently being developed to ensure an adequate review




                                                         183
                                 of PMS claimed costs are being completed and
           93.323:               documentation of the review is retained.
           Epidemiology and
           Laboratory Capacity
           for Infectious
           Diseases

2022-206   93.268:               The OSDH Procurement team fully understands and           6/30/24   Stefan Von
           Immunizations         agrees with the audit findings. OSDH Procurement is                 Dollen
           Cooperative           being revamped, all processes will be re-examined, and
           Agreements            changes will occur to ensure only allowable expenses
                                 are authorized when a PO is issued. Procurement
           93.323:               management will work to standardize our practices to
           Epidemiology and      ensure SOWS are thoroughly reviewed.
           Laboratory Capacity
           for Infectious        Management is also adding a layer of oversight with the
           Diseases              reorganization plan for the Procurement team and the
                                 rest of the Logistics operation. OSDH Procurement
                                 initiatives are being revamped to ensure transparency
                                 and adherence to all state purchasing requirements.

                                 OSDH is establishing a more thorough reconciliation
                                 and review of expenditures prior to a draw down of
                                 funds through the PMS system. In addition, a
                                 separation of the preparation of the draw down
                                 worksheets and the final review and draw down
                                 submittal in PMS is currently being established and
                                 documented.




                                                        184
                                          STATE OF OKLAHOMA – SINGLE AUDIT
                                              CORRECTIVE ACTION PLAN
                                                   2 CFR § 200.511(c)
                                                       SFY 2022



Finding     Subject Heading                           Planned Corrective                            Anticipated    Responsible
Number     (Financial) or ALN                              Action                                   Completion       Contact
            no. and program                                                                            Date          Person
             name (Federal)
2022-029         93.778         After a comprehensive study of the G1DX edit creation                July 2024    Paulette
            Medicaid Cluster    process related to the findings in the 2021 audit, several issues                 Kendrick, Jeff
                                were found including:                                                             Rosebeary
                                                                                                                  (OKDHS)
                                    1.   Edits were being created for time periods in which no
                                         benefits were issued.                                                    Ginger Clayton
                                    2.   Edits were being created for cases that were closed,                     (OHCA)
                                         or for Household (HH) members who had been
                                         removed from the Household before the edit was
                                         created.
                                    3.   Edits were being created for cases outside of review
                                         cycle, thereby creating additional tasks for case
                                         management staff.
                                    4.   Duplicate edits were being generated for several
                                         reasons.
                                    5.   Staff were not addressing the edits in a timely
                                         manner.

                                The issues with the staff not addressing the edits in a timely
                                manner was addressed in the complete restructure of our
                                organization and case management process on April 10,
                                2023. In this new structure, G1DX edits creates tasks that are
                                served up in a queue as workers work through the workload.
                                G1DX edits on open cases are bundled with pending case
                                actions so that they can be addressed along with the case
                                actions. This change in structure highlighted the shortcomings
                                in the G1DX edit creation process. We expect to have changes
                                to the reports fully tested and in place by early spring, 2024,
                                which will account for a dramatic fall in the number of G1DX
                                edits that are demanding the staffs’ time and for a reduction of
                                the backlog of edits.

                                OHCA Member Audit will continuously monitor G1DX case
                                actions and inactions. The team monitors reports to determine
                                timely case actions as well as ensuring cleared discrepancies are
                                processed as expected according to the type of discrepancy.
                                There is no end date for this monitoring at the present time. The
                                outcome of this monitoring is reported to OHS leadership, and
                                failure to show progress in resolving the issues will require
                                further corrective action.




                                                               185
2022-025   93.767 Children’s   OHCA completed corrective actions for post-enrollment               June 2024     April Anonsen
           Health Insurance    verification issues prior to the Public Health Emergency (PHE);       unless      (OKHCA) Carla
               Program         however, with the requirement to maintain enrollment during        indicated as   McCarrell-
                               the PHE, the PHE protections had to be initiated quickly and         complete     Williams
               93.778          efforts taken to ensure continuous eligibility. The agency found                  (OKDHS)
           Medicaid Cluster    it necessary to suspend all post-enrollment verification
                               requests to ensure that those requirements were met as they                       Ginger Clayton
                               triggered closures when documents were not received. The                          (OKHCA
                               changes included verification requests and data exchange                          Member Audit)
                               updates that would result in verification requests.

                               OKDHS processes non-MAGI cases. OKDHS changed case
                               record maintenance practices and records are no longer
                               maintained in local county offices. The Records Management
                               Department does not have any records to support the
                               redetermination was completed. OKDHS confirmed that
                               caseworkers failed to assess a five-year lookback period to
                               evaluate Long Term Care eligibility at initial application.

                               OKDHS determined that systems change in 2021 had a coding
                               issue that resulted in failed notification to recipients. The
                               agency corrected the issue in May of 2022 and have no longer
                               found cases where the notice issue occurs.

                               For the MAGI deficiencies, OHCA ended suspension of
                               verification requests by the conclusion of the PHE and all
                               normal processes have resumed as Oklahoma is at the end of
                               the allowed unwinding period. Member Audit will complete a
                               minimum of three months of case reviews to ensure that post-
                               enrollment verification processes and PARIS match verification
                               processes are functioning as required.

                               For the Non-MAGI deficiencies, OKDHS will address case issues
                               through the establishment of a committee responsible for
                               monitoring corrective actions, providing training to all
                               appropriate employees, and updating training and
                               informational webpages utilized by eligibility staff. OHCA
                               Member Audit has been monitoring these issues through
                               monthly case reviews and provides feedback to OKDHS
                               leadership. This process will continue until the issues have
                               been corrected. Additional steps to correct issues are
                               requested as deemed necessary by Member Audit.

                               OKDHS has corrected coding issues that impacted notices.
                               Member Audit will complete a minimum of three months of
                               case reviews to ensure notices issues as required.




                                                             186
2022-039       93.778          Fraud overpayment: The Notice of Credible Allegation was sent             Fraud      Kristine West,
           Medicaid Cluster    from the MFCU to OHCA on November 23, 2021 for the                    overpayment:   Senior Director
                               $108,000 fraud overpayment. The May 11, 2022 draw was                   May 2024     of Program
                               reduced to reflect the overpayment. The amount was not                               Integrity and
                               reported on the CMS-64.9C1 to avoid duplicate reporting.                             Accountability
                               OHCA will work to improve the process of reporting the MFCU
                               overpayments.

                               Non-fraud overpayment: The historical cases were reported on           Non-fraud
                               the 9/30/2022 CMS-64.9C1 report. New procedures were                  overpayment:
                               implemented to ensure all overpayments are reported                    November
                               quarterly on the CMS-64.9C1 within one year of discovery.                 2022
                               Corrective action has been implemented.

2022-040       93.778          Phase 1 professional service edits went live on January 2, 2022.        May 2022     Karen Beam,
           Medicaid Cluster    Phase 2 institutional edits went live on April 29, 2022.                             Director,
                                                                                                                    Medical
                               For the Medically Unlikely Edits (MUE’s), a stricter version of the                  Administrative
                               NCCI requirements were implemented. The entire line will be                          Support
                               denied if the provider bills over the limit.                                         Services and
                                                                                                                    Thi Nguyen,
                               Corrective action was implemented by the end of SFY
                                                                                                                    Senior System
                               2022. The NCCI procedure to procedure edits were fully
                                                                                                                    Analyst
                               implemented and set to deny on April 29, 2022. OHCA
                                                                                                                    Manager
                               continuously utilizes the CMS Medically Unlikely Edits (MUEs)
                               to guide the limits placed in the system.

2022-006       93.778          OHCA revised its process and incorporated additional                  January 2023   Tanesha
           Medicaid Cluster    mechanisms to ensure timely independent reviews of the                               Hooks, Director
                               Service Quality Reviews (SQR) and accounts receivable set-up                         of Behavioral
                               for any potential recoupments.                                                       Health

2022-020   93.767 Children’s   Medicaid Payable/Receivable: The PDF data will be input by              November     Susan Crooke,
           Health Insurance    an individual other than the one responsible for preparing                2023       Director of
               Program         the spreadsheet, and a review of the manual entry into the                           Financial
                               Encumbered Funds by Date of Service spreadsheet will be                              Services
               93.778          completed by the Financial Services division before
           Medicaid Cluster    entering the data into the GAAP Package Q.


                               HCBS: The HCBS will be classified in the Statewide Generally
                               Accepted Accounting Principles (GAAP) Package Z: Schedule
                               of Expenditures for Federal Awards (SEFA) as a passthrough as
                               instructed by the Office of Management and Enterprise
                               Services (OMES). OMES utilizes the GAAP Packages to make
                               necessary adjustments to the Statewide Financial Statements.




                                                               187
2022-054       93.778         OHCA Member Audits requests updates from OKDHS and                   Lottery      Ginger Clayton,
           Medicaid Cluster   OMES continuously to work toward obtaining the information         Commission     Director of
                              for ongoing review.                                               data exchange   Member
                                                                                                      was       Audits
                              OKDHS has resolved all issues preventing jobs from running as     implemented
                              expected and monitors to ensure jobs are running. The Lottery       on August,
                              Commission data exchange is now in production and being                2023;
                              utilized by the Oklahoma Human Services (OKDHS) as of
                              August 14, 2023.

                              OMES, the contracted entity coordinating data exchange job          OHCA
                              reports from OKDHS to OHCA for monitoring, has not                monitoring –
                              completed its work. OHCA has been working with OKDHS and          March 2024
                              OMES to develop a routine report that will be generated and
                              provided monthly for evaluation. Once received, OHCA will
                              monitor, on a monthly basis, the completion of scheduled data
                              exchange jobs. Failed jobs will result in a request to OKDHS to
                              determine the appropriate remedy occurred to address the
                              failed job.


2022-074       93.778         The OHCA and OKDHS failed to update Medicaid for TANF              September      April Anonsen
           Medicaid Cluster   recipients when the Welfare Reform Act of 1996 changed                2024        (OKHCA) Carla
                              eligibility requirements. OKDHS has continued to approve                          McCarrell-
                              Medicaid services automatically for individuals receiving TANF                    Williams
                              when that should have stopped. The members would have                             (OKDHS)
                              remained eligible based on income standards; however, the
                              processing was incorrect. When additional changes occurred                        Ginger Clayton
                              to require the use of Modified Adjusted Gross Income (MAGI) in                    (OKHCA
                              2013 the eligibility for TANF recipients was not moved under                      Member Audit)
                              MAGI income rules as required due to the agencies not
                              recognizing the change from the Welfare Reform Act.

                              OKDHS and OHCA are evaluating system changes required to
                              move Medicaid eligibility for TANF recipients to the MAGI
                              eligibility process. OKDHS will have to move forward with their
                              required changes prior to the OHCA implementation as the
                              two systems work together to direct eligibility to the proper
                              system. The agencies are in the process of creating
                              requirements based on the necessary changes and at this time
                              estimate the changes will be completed by June 30, 2024.

                              OHCA Member Audit will begin a post corrective action audit
                              for a minimum of three months to ensure all aspects of the
                              eligibility on the parts of both agencies are processing
                              members receiving TANF under the appropriate rules. If issues
                              persist the agencies will be required to identify additional
                              corrective actions and further reviews will be completed by
                              OHCA.




                                                            188
2022-002       93.778          The OHCA will continue to utilize control processes and           February 2024   Kristine West,
           Medicaid Cluster    procedures to ensure medical claims are meeting program                           Senior Director
                               requirements. These processes include prior authorizations,                       of Program
                               suspended claim reviews, system edits, post payment reviews,                      Integrity and
                               and our payment accuracy measurement study. OHCA will                             Accountability
                               also continue National Correct Coding Initiative (NCCI) edit
                               updates, as well as continue with provider training to better
                               educate our providers. The questioned costs will be reported
                               on the CMS 64.9P line 10A on Cost of Service (COS) line 5 for
                               the quarter ending December 31, 2023.

2022-004   93.767 Children’s   The OHCA will continue to utilize control processes and           February 2024   Kristine West,
           Health Insurance    procedures to ensure medical claims are meeting program                           Senior Director
               Program         requirements. These processes include prior authorizations,                       of Program
                               suspended claim reviews, system edits, post payment reviews,                      Integrity and
                               and our payment accuracy measurement study. OHCA will                             Accountability
                               also continue National Correct Coding Initiative (NCCI) edit
                               updates, as well as continue with provider training to better
                               educate our providers. The questioned costs will be reported
                               on the CMS 64.21UP line 10A on Cost of Service (COS) line 5 for
                               the quarter ending December 31, 2023.

2022-       General Fund –     A request has been made for Gainwell to produce the                November       Susan Crooke,
807-008    Accounts Payable    Service Date Reimbursement Analysis Report (MAR-2300-                2023         Director of
               & Federal       M) as an excel report to transfer the encumbered data to                          Financial
              Receivable       the Encumbered Funds excel more accurately. Gainwell’s                            Services
                               anticipated completion is January 2024. In the interim, the
                               PDF data will be input by an individual other than the one
                               responsible for preparing the spreadsheet, and a review of
                               the manual entry into the Encumbered Funds by Date of
                               Service spreadsheet will be completed by the Financial
                               Services division before entering the data into the GAAP
                               Package Q.




                                                             189
                                  DEPARTMENT OF HUMAN SERVICES
                                 STATE OF OKLAHOMA – SINGLE AUDIT
                                     CORRECTIVE ACTION PLAN
                                           45 CFR § 75.511(c)
                                               SFY 2022

 Finding       Subject                          Planned Corrective                           Anticipated    Responsible
 Number        Heading                                Action                                 Completion       Contact
            (Financial) or                                                                      Date          Person
             AL no. and
               program
                name
              (Federal)
2022-007   10.551 – SNAP     Checking Identity: In response to the control that was not      January 2024   Thomas
           Cluster           tested due to the non-utilization of the Daily Issuance form,                  Pennington
                             we wish to clarify that our 55C office had already
                             transitioned from the Daily Issuance Form to the Microsoft
                             List at the time of the walkthrough. Our EBT SNAP card
                             prints are requested through the IMS CARDR system,
                             ensuring that the 'EBT Specialist' at the office verifies the
                             client's identity and inputs necessary information prior to
                             requesting EPS to remotely print the EBT SNAP card.

                             Missing Signatures: OHS EPS identified and rectified this
                             issue prior to the audit. We have since undergone a
                             substantial transformation in our EBT card inventory
                             management procedures. The transition from Adobe PDF
                             documents to Microsoft Lists to account for EBT inventory
                             has resulted in a more centralized and streamlined approach.
                             Through a consolidation initiative, we moved from three
                             separate inventory documents to a singular, comprehensive
                             Microsoft List, significantly improving the accuracy of our
                             record-keeping processes. This transition was facilitated
                             through individual training sessions for all counties,
                             ensuring a seamless adaptation to the new system. The
                             Microsoft Lists platform offers enhanced accessibility and
                             electronic review capabilities, to further address concerns
                             related to manual signature verification. This digital
                             documentation and automation of online records enables
                             our teams to allocate additional time and resources to
                             identify and promptly resolve any discrepancies that may
                             impact the elements within the scope of this audit.

                             Destroyed Cards Still Active: OHS had identified the
                             deficiency prior to the audit and had established an internal
                             group of off-site staff dedicated to overseeing EBT
                             processes. This collaborative effort, involving AFS staff
                             both on-site, off-site, and State EPS staff, ensures accurate
                             accounting of cards and compliance with CFR
                             requirements.

                             Documented changes have been made to our EBT
                             Handbook in response to the deficiencies identified in the


                                                      190
                           audit, providing clear guidelines for compliance. Real-time
                           monitoring capabilities enable us to promptly identify and
                           address errors, fostering a proactive approach to
                           compliance.
2022-010   10.561 – SNAP   Additional reporting requirements for COVID funds created         December      Kevin
           Cluster         additional complexity to the reporting process that was not         2023        Haddock
                           anticipated when designing the existing internal controls.
                           Going forward, all worksheets for SNAP will be housed in
                           one workbook to ensure that the total funding on all reports
                           are tied out to a master worksheet and avoid possible
                           reporting duplications.
2022-014   93.575 and      Child Care Services has continually inspected child care         January 30,    Dione Smith
           93.596 – CCDF   programs for compliance with health and safety                      2023
           Cluster         requirements according to the Oklahoma Child Care
                           Facilities Licensing Act and Oklahoma Administrative
                           Code. Our inspection monitoring checklist that was used at
                           the time this was audited specifically contained health
                           inspection as a work step, but the checklist did not require
                           the worker to specifically mark it as performed. The
                           checklist did specifically state that the worker performed all
                           steps and only exceptions would be further documented.
                           The Oklahoma State Auditor and Inspectors took the
                           position that our process did not provide enough assurance
                           for them to validate that health inspections were performed,
                           and they wanted a specific tick mark on the inspection. We
                           do not agree on this point as one additional tick mark on a
                           form does not provide any more assurance than the
                           employees signature stating that all of the steps were
                           performed. We did however agree to change the form to
                           resolve this issue with the auditors. Quality review audits
                           are also being conducted annually with each supervisory
                           group in Child Care Services to address errors or
                           inconsistencies when monitoring child care programs.

                           On January 30th, 2023; Child Care Services implemented
                           the “Go-Live” phase of updating the monitoring checklists
                           and summaries to include visual verification that all health
                           and safety requirements are observed during inspections.
                           Licensing specialists indicate on each health and safety
                           item; compliance, non-compliance, or not reviewed while
                           completing inspections. Furthermore, Child Care Services
                           professional development unit has included a new training
                           module regarding documentation requirements. It is
                           important to note that the Oklahoma State Auditor and
                           Inspectors office is almost two years behind on conducting
                           audits so we expect repeat findings will appear in the 2023
                           audit report.
2022-017   93.659 –        The missing documents are required for any case to be            January 2024   Kevin
           Adoption        approved and proceed. We believe the forms were likely                          Haddock
           Assistance      misfiled but we will take immediate action to get these
           Program         documents added to the case file. This finding will be
                           added to the next Child Welfare meeting agenda to ensure
                           everyone in this process is aware of the documents required
                           and the importance of properly filing every document.
2022-018   93.658-Foster   We are in the process of amending contracts to include the        June 2024     Kevin
           Care            requirements of 2 CFR §200.332 (a). Ten of the 13 pass                          Haddock
                           though entities have been amended as of December 2023
                           and the remaining three are in process to be completed
                           before the end of State fiscal year 2024.

                           Foster Care has a risk analysis document that includes all


                                                    191
                               pass though entities with support for the conclusions.
                               Foster Care also performs monitoring activity on all
                               payments and that is documented on each individual claim
                               prior to payment. We will arrange a meeting with SAI to
                               explain this process in detail in the coming fiscal year to
                               explain the procedures performed and provide the
                               documents to resolve this issue.
2022-023   93.558 – TANF,      The AS400 based cost allocation system used for many             June 2023     Kevin
           93.658 – Foster     years ceased to function properly in January of 2022. We                       Haddock
           Care, 93.659 –      were forced to manually calculate allocated costs in March
           Adoption            and convert to a new automated system in June of 2022.
           Assistance          This is an extremely complex process and some errors in
           Program, 93.778     the pool allocations were made. We posted corrections in
           Medicaid            June 2023 and the related cost adjustment have been
           Cluster, 10.561 –   processed. For the QE 12/2021 the adjustments were made
           SNAP Cluster,       in QE June 2023 schedules 16, 17, and 18. For QE 6/2022
           93.658 – Child      the adjustment was made QE June 2023 schedule 12. It is
           Care                important to note that adjustments to cost allocation are
           Development         performed routinely each quarter as new information comes
           Cluster             to light. The adjustment results in a change to the cost
                               associated to each individual grant in the quarter it was
                               processed and offsets the prior recorded amount
                               accordingly.

                               The cost allocation system is new, and we have developed
                               additional procedures and reviews that reduce risk in the
                               areas of concern addressed in this finding.
2022-029   10.551 – SNAP       After a comprehensive study of the G1DX edit creation            Spring 2024   Paulette
           Cluster, 93.558 -   process related to the findings in the 2021 audit, several                     Kendrick, Jeff
           TANF, 93.575 -      issues were found including:                                                   Rosebeary
           Child Care               1. Edits were being created for time periods in which                     (OKDHS),
           Development                  no benefits were issued.                                              Ginger Clayton
           Cluster, 93.778 –        2. Edits were being created for Cases that were                           (OHCA)
           Medicaid                     closed, or for HH members who had been removed
           Cluster                      from the Household before the edit was created.
                                    3. Edits were being created for cases outside of
                                        review cycle, thereby creating additional tasks for
                                        case management staff.
                                    4. Duplicate edits were being generated for several
                                        reasons.
                                    5. Staff were not addressing the edits in a timely
                                        manner.

                               The issues with the staff not addressing the edits in a timely
                               manner was addressed in the complete restructure of our
                               organization and case management process on April 10,
                               2023. In this new structure, G1DX edits creates tasks that
                               are served up in a queue as workers work through the
                               workload. G1DX edits on open cases are bundled with
                               pending case actions so that they can be addressed along
                               with the case actions. This change in structure highlighted
                               the shortcomings in the G1DX edit creation process. We
                               expect to have changes to the reports fully tested and in
                               place by early spring, 2024, which will account for a
                               dramatic fall in the number of G1DX edits that are
                               demanding the staffs’ time and for a reduction of the
                               backlog of edits.
2022-031   93.658 – Foster     The file without a proper Difficulty of Care document will       June 2024     Kevin
           Care                be corrected immediately. The DHS will also conduct                            Haddock
                               additional training surrounding this finding to reinforce the
                               requirements and improve compliance with policy.


                                                        192
                            The OKDHS is taking action to bring the annual Foster
                            Home updates current through training employees. Annual
                            updates are required by DHS policy, but DHS policy also
                            grants Foster Home continuous approval unless action is
                            taken by either party to terminate the contract or close the
                            home. There are no eligibility issues on the Foster Homes,
                            but we are not in compliance with DHS policy.
2022-037   93.558 – TANF    Currently, Business Intelligence has a query that checks for     December 19,   Rhonda Archer
                            adults approaching their time limit and any approaching 60          2023        & Jeff
                            months. Moving forward they are updating the process to                         Rosebeary
                            create a table that compares that number of months reported
                            on the FTANF report to the current months of TANF
                            received for each adult recipient. This should resolve any
                            issues caused by only validating the number of months
                            received for adults approaching the time-limit for TANF
                            and validate the entirety of the populations’ months as
                            reported.
2022-041   10.542 – P-EBT   DHS - The P-EBT program was rapidly developed and                 March 30,     Sondra Shelby
                            implemented to meet the emergent nutritional needs of              2024             (DHS)
                            students and children affected by school and childcare                          Jennifer Weber
                            closures during the pandemic. It was an unprecedented                               (ODE)
                            situation that required swift action to ensure no child went
                            hungry due to the national health emergency. Upon
                            reviewing the instances of incorrect benefit calculation and
                            eligibility determination, we recognize that the program's
                            rapid deployment, while necessary, led to some
                            oversights. Should there be a need for a future emergency
                            or permanent program, we assure you that the lessons
                            learned from this experience will significantly inform its
                            structure and execution. We will execute improvements in
                            our internal controls and validation/reconciliation processes
                            to mitigate concerns similar to those identified in the audit.

                            We are working in conjunction with OSDE to correct the
                            exceptions noted. The PEBT program has now expired.

                            OSDE - The P-EBT process was put in place by Congress
                            to help children during school closures due to the pandemic.
                            It was an unprecedented time for the country and P-EBT
                            was the process that was put in place to ensure children had
                            funds for food during the Federal health emergency. The
                            States were tasked with standing up a brand new program in
                            the middle of a pandemic and based on that the processes
                            put in place things were overlooked, We recognize errors
                            were made and we have learned from those errors. Internal
                            controls will be evaluated and corrected where needed. We
                            will work with DHS to correct any exceptions noted. The P-
                            EBT program has now expired.

2022-042   10.542 – P-EBT   The FNS-46 and FNS-388 reports are correctly stated. The          March 30,     Matthew
                            original reports were prepared using an internal report and        2024         Conley &
                            we did not identify the correct data. We discovered that                        Damian Lim
                            while preparing the information for the audit and
                            immediately corrected all reports. We advised the auditors
                            about the corrections immediately. The FNS encourages
                            States to correct any report if new information comes to
                            light. These reporting issued are fully corrected.

                            The FNS-292B report is on the United States Department of
                            Agriculture’s reporting system. This system will only
                            allows the user to enter one new reporting month at a time
                            and you must wait until the USDA approves that report

                                                     193
                           before entering the next month. The system will
                           automatically delete the previous unapproved monthly
                           report if you enter another report. We failed to note this on
                           one reporting month and a report was deleted by the
                           reporting system. We will obtain all the issuance amounts
                           and recipient count data for PEBT from our AFS analyst
                           group and recalculate the amounts that should have been
                           reported. We will contact FNS to determine how we can
                           correct any errors that may be discovered in that process.

                           The PEBT program has expired but we will use the lessons
                           learned to place better controls in place for any programs of
                           a similar nature going forward.
2022-048   93.558 – TANF   We agree that the Form 08TW013E was not present in the          September 30,   Rhonda Archer
                           case file, but a missing form does not in and of itself           2022
                           constitute an error on the ACF-199 report.

                           We restructured the entire statewide TANF staff as part of
                           our overall corrective action plan. As of May 1, 2022, we
                           vertically integrated the TANF Staff under the supervision
                           of two Field Managers to bring greater consistency in
                           policy, procedure, and service delivery to our families. We
                           conducted an all TANF staff back to basics training
                           addressing this issue.
2022-054   93.778 -        OHCA Member Audits requests updates from OKDHS and               March 2024     Ginger Clayton
           Medicaid        OMES continuously to work toward obtaining the
                           information for ongoing review.

                           OKDHS has resolved all issues preventing jobs from
                           running as expected and monitors to ensure jobs are
                           running. The Lottery Commission data exchange is now in
                           production and being utilized by the Oklahoma Human
                           Services (OKDHS) as of August 14, 2023.

                           OMES, the contracted entity coordinating data exchange
                           job reports from OKDHS to OHCA for monitoring, has not
                           completed its work. OHCA has been working with OKDHS
                           and OMES to develop a routine report that will be
                           generated and provided monthly for evaluation. Once
                           received, OHCA will monitor, on a monthly basis, the
                           completion of scheduled data exchange jobs. Failed jobs
                           will result in a request to OKDHS to determine the
                           appropriate remedy occurred to address the failed job.

2022-057   93.558 – TANF   A directive came from the OCSS to not penalize TANF               July 2022     Rhonda Archer
                           recipients for non-cooperation during this period due to the
                           pandemic. Non-Coop penalties have now been restored
                           within DHS. In the future, DHS will not waive non coop
                           penalties unless directed to do so by federal awarding
                           agencies.
2022-058   93.558 – TANF   The AS400 based cost allocation system used for many             June 2023      Kevin
                           years ceased to function properly in January of 2022. We                        Haddock
                           were forced to manually calculate allocated costs in March
                           and convert to a new automated system in June of 2022.
                           This is an extremely complex process and some errors in
                           the pool allocations were made. We posted corrections in
                           June 2023 on schedule 17 and the related cost adjustment
                           have been processed.

                           The cost allocation system is new, and we have developed
                           additional procedures and reviews that reduce risk in the
                           areas of concern addressed in this finding.

                                                    194
2022-059   93.558 – TANF   We did not receive the 2021 finding until the end of 2022        June 9, 2022    Rhonda Archer
                           due to delays from the pandemic. As a result, our corrective
                           action was not put in place until after the beginning of 2023
                           resulting in repeat findings.

                           We restructured the entire statewide TANF staff as part of
                           our overall corrective action plan. As of May 1, 2022, we
                           vertically integrated the TANF Staff under the supervision
                           of two Field Managers to bring greater consistency in
                           policy, procedure, and service delivery to our families. We
                           conducted an all TANF staff back to basics training
                           addressing this issue.
2022-060   93.558 – TANF   We did not receive the 2021 finding until the end of 2022        June 9, 2022    Rhonda Archer
                           due to delays from the pandemic. As a result, our corrective
                           action was not put in place until after the beginning of 2023
                           resulting in repeat findings.

                           We began a restructure of the entire statewide TANF staff
                           as part of our overall corrective action plan last year. As of
                           May 1, 2022, we vertically integrated the TANF Staff under
                           the supervision of 2 Field Managers to bring greater
                           consistency in policy, procedure, and service delivery to our
                           families. Through this vertical integration it is believed
                           TANF State Audit findings in general, should begin to be
                           minimized through these efforts beginning in October 2022.
                           We conducted an all TANF staff back to basics training
                           which included addressing the specific items noted on this
                           finding. We were able to address this to the entire TANF
                           unit at the same time on 06/09/2022.

2022-061   93.558 – TANF   We did not receive the 2021 finding until the end of 2022        June 9, 2022    Rhonda Archer
                           due to delays from the pandemic. As a result, our corrective
                           action was not put in place until after the beginning of 2023
                           resulting in repeat findings.

                           We restructured the entire statewide TANF staff as part of
                           our overall corrective action plan. As of May 1, 2022, we
                           vertically integrated the TANF Staff under the supervision
                           of two Field Managers to bring greater consistency in
                           policy, procedure and service delivery to our families. We
                           conducted an all TANF staff back to basics training
                           addressing this issue. We expect improvement in the
                           compliance in the 2023 audit.
2022-062   93.558 – TANF   We did not receive the 2021 finding until the end of 2022        September 30,   Rhonda Archer
                           due to delays from the pandemic. As a result, our corrective         2022
                           action was not put in place until after the beginning of 2023
                           resulting in repeat findings.

                           We are working with systems to try to make ACES
                           automatically attach to the applications. Until that is
                           accomplished, we are continual training new staff in TANF
                           academy to make sure that ACES are attached to all
                           applications. We conducted an all TANF staff back to
                           basics training addressing uploading the ACES Screens at
                           all applications and renewals when reviewed as well as
                           documenting in case notes. We expect improvement in the
                           compliance in the 2023 audit.




                                                    195
2022-063   93.558 – TANF   These were child only cases. The adult in each case was not     March 1, 2024   Rhonda Archer
                           required to participate in TANF work as they were not
                           included in the TANF benefits and receiving SSI at this
                           time. These two cases were coded incorrectly but were
                           eligible.

                           Our statewide training and TANF Academy that began in
                           2022 both include training on how to code cases correctly.
2022-064   93.558 – TANF   We did not receive the 2021 finding until the end of 2022       September 30,   Rhonda Archer
                           due to delays from the pandemic. As a result, our corrective        2022
                           action was not put in place until after the beginning of 2023
                           resulting in repeat findings.

                           We restructured the entire statewide TANF staff as part of
                           our overall corrective action plan. As of May 1, 2022, we
                           vertically integrated the TANF Staff under the supervision
                           of two Field Managers to bring greater consistency in
                           policy, procedure and service delivery to our families. We
                           conducted an all TANF staff back to basics training
                           addressing this issue. We expect improvement in the
                           compliance in the 2023 audit.
2022-065   93.558 – TANF   We restructured the entire statewide TANF staff as part of      September 30,   Rhonda Archer
                           our overall corrective action plan. As of May 1, 2022, we           2022
                           vertically integrated the TANF Staff under the supervision
                           of two Field Managers to bring greater consistency in
                           policy, procedure, and service delivery to our families. We
                           conducted an all TANF staff back to basics training which
                           addressed this issue.
2022-066   93.558 – TANF   We did not receive the 2021 finding until the end of 2022       September 30,   Rhonda Archer
                           due to delays from the pandemic. As a result, our corrective        2022
                           action was not put in place until after the beginning of 2023
                           resulting in repeat findings.

                           We restructured the entire statewide TANF staff as part of
                           our overall corrective action plan. As of May 1, 2022, we
                           vertically integrated the TANF Staff under the supervision
                           of two Field Managers to bring greater consistency in
                           policy, procedure, and service delivery to our families. We
                           conducted an all TANF staff back to basics training
                           addressing this issue. We expect improvement in the
                           compliance in the 2023 audit.
2022-067   93.558 – TANF   Medicaid was the primary example used in the discussion             N/A         Kevin
                           with OKDHS management and as it applies to children in                          Haddock
                           custody since children in custody have Medicaid. Children
                           not in custody who are clients of Medicaid, SNAP, TANF,
                           and Childcare are also able to be funded with TANF funds.
                           This test only looked at the documentation used to
                           determine custody children as eligible for TANF. The OCS
                           liaison researches other programs that this child could be a
                           client of and marks the log as whether any other programs
                           serve this child therefore making them eligible for TANF.
                           This is consistent with the previously submitted corrective
                           action plan to the State Auditor and Inspectors office, the
                           Public Assistance Cost Allocation Plan, and the TANF state
                           plan.
2022-068   93.558 – TANF   The AS400 based payment system that was in place at the         August 2022     Kayla Urtz
                           time of the audit was retired at the end of July in 2022. The
                           AS400 relied on the invoice processor to determine if the
                           proper approval was obtained based on a review of a
                           physical signature. The AS400 was replaced with a system
                           that has a workflow for processing, approval, and payment
                           of invoices. Specific people are authorized to approve

                                                    196
                      invoices for each division, and they are set up with specific
                      authorities within the system. The system determines the
                      correct authorized individual/individuals for approval of
                      each specific invoice and notifies them via e-mail. They log
                      on to the system and approve/deny payment after their
                      review. The log on credentials validate that the correct
                      individual approves the invoice and records who approved
                      it. This systematic workflow eliminates human error in the
                      process of determining if the correct individual physically
                      approved an invoice.
2022-074   93.778 -   OKDHS and OHCA are evaluating system changes required           June 30, 2024   April Anonsen
           Medicaid   to move Medicaid eligibility for TANF recipients to the                         (OKHCA),
                      MAGI eligibility process. OKDHS will have to move                               Carla
                      forward with their required changes prior to the OHCA                           McCarrell-
                      implementation as the two systems work together to direct                       Williams
                      eligibility to the proper system. The agencies are in the                       (OKDHS),
                      process of creating requirements based on the necessary                         Ginger Clayton
                      changes and at this time estimate the changes will be                           (OKHCA)
                      completed by June 30, 2024.

                      OHCA Member Audit will begin a post corrective action
                      audit for a minimum of three months to ensure all aspects of
                      the eligibility on the parts of both agencies are processing
                      members receiving TANF under the appropriate rules. If
                      issues persist the agencies will be required to identify
                      additional corrective actions and further reviews will be
                      completed by OHCA.




                                              197
 Financial Services
                       STATE OF OKLAHOMA – SINGLE AUDIT
                           CORRECTIVE ACTION PLAN
                                 2 CFR § 200.511(c)
                                     SFY 2022

  Finding       Subject             Planned Corrective Action            Anticipated   Responsible
  Number      Heading and                                                Completion      Contact
               program                                                      Date         Person
                Federal
               Program
                 Name


   2022-101      84.126 -      A correction plan has already been        October 31,      Mark
               Vocational      completed in the form of training           2022         Kinnison
              Rehabilitation   conducted by Field Services
                Services       Coordinators who oversee field
                Program        operations that occurred between           Trainings
                               August 2022 through October                 are on-
                               2022. All Vocational Rehabilitation          going
                               Counselors and Rehabilitation
                               Technicians, and Program Managers
                               received VR 101 training which covered
                               all topics case related. In addition to
                               this training all new VR counselors and
                               Rehabilitation Technicians coming
                               into the VR program receive new
                               employee orientation which covers
                               case processes. Further corrections
                               will be on going and addressed
                               through consistent case reviews
                               performed by our Process
                               Improvement staff as well as our Field
                               Services Coordinators and Programs
                               Managers.




       3535 N.W. 58th Street, Suite 500, Oklahoma City, OK 73112
 o: 405-951-3400 | f: 405 951-3529 | Oklahoma.gov | okdrs.gov

                Executive Director Melinda Fruendt
Commissioners Janet C. Barresi, DDS, Theresa Flannery and Wes Hilliard
                                          198
                                                                                       Chief Financial Officer
                                                                                          Ms. Chelley Hilmes
                                                                                                 200 N.E. 21st Street
                                                                                      Oklahoma City, OK 73105-3204
                                                                                                      www.odot.org




             Subject Heading                    Planned Corrective                       Anticipated       Responsible
 Finding
              (Financial) or                          Action                             Completion       Contact Person
 Number
            Assistance Listing                                                              Date
            no. and program
             name (Federal)
2022-024   20.509 - Formula      We concur with the auditor’s recommendation.          January 31, 2024    Holly Lowe,
           Grants for Rural      Since we became aware of this issue, we have          - CWO findings         CWO
           Areas                 created a central depository for all audit work
                                 papers of these types and are now placing all work
                                 papers in that central depository. We have also
                                 established an additional review process to review
                                 a sample of those work papers, this is beyond the
                                 manager review that already occurs. We will also
                                 work with OMPT in the development of a process
                                 to review audit results which are shared with
                                 OMPT for monitoring activities.
                                                                                       03/2024       –
                                 OMPT will develop & implement procedures to           OMPT findings
                                 ensure risk assessments are completed annually &                         Eric Rose/Jared
                                 the audit spreadsheet is updated monthly if                              Schwennesen/
                                 deadlines are not met. We also plan to include                               OMPT
                                 CWO to implement a process for audit reviews &
                                 results are shared with OMPT for monitoring
                                 activities.

2022-056   20.509 - Formula      We concur with the auditor’s recommendation.          Completed          Eric Rose/Jared
           Grants for Rural      Office of Mobility & Public Transit (OMPT)                                Schwennesen
           Areas                 implemented 100% documentation requirements
                                 for all subrecipient monthly claims as of 01/2022.
                                 Project Managers review all 100% of the
                                 supporting documentation to ensure allowability
                                 prior to reimbursement.

2022-079   20.509 - Formula      We concur with the auditor’s recommendation to        February 29,        Sam Ddamba/
           Grants for Rural      strengthen Internal Controls to follow weekly         2024               Robert Hackney
           Areas                 billing procedures properly. Additionally, staff
                                 training is ongoing to ensure draws are properly
                                 reviewed and adequately supported with approved
                                 documentation.

                                 The Office of Mobility and Public Transit
                                 (OMPT) is on an ECHO suspension from the
                                 Federal Transit Administration (FTA), which has
                                 been in effect since the last tri-annual review in
                                 2021. ECHO is the system used by FTA for


                                                           199
                  reimbursement. Consequently, this creates an
                  impact on the weekly billing timing. The
                  preauthorization approval process includes the
                  following: OMPT provides all documentation to
                  FTA for review. Once reviewed, conditional
                  approval is provided to enable the department to
                  submit the ECHO reimbursement request.




“The mission of the Oklahoma Department of Transportation is to provide a safe, economical, and
   Effective transportation network for the people, commerce and communities of Oklahoma.”

                          AN EQUAL OPPORTUNITY EMPLOYER
                                             200
Summary Schedule of Prior Audit Findings
                              STATE OF OKLAHOMA – CARES FORWARD
                                STATE OF OKLAHOMA – SINGLE AUDIT
                            SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
                                         2 CFR § 200.511(b)
                                             SFY 2022


ALN: 21.019
Finding No: 2021-072
Federal Program Name: Coronavirus Relief Fund
Status: Corrected

ALN: 21.023
FINDING NO: 2021-080
FEDERAL PROGRAM NAME: Emergency Rental Assistance (ERA)
STATUS: Not Corrected

Reason for recurrence: OMES received the FY2021 findings for this program after FY2022 ended. Also, due to the
nature of the relationship, the state maintains that the administrators contracted to deploy the Emergency Rental
Assistance Program were in fact vendors and not subrecipients. However, because the state auditors office disagrees
with this designation, the state has endeavored to follow the monitoring requirements until a determination is made
by Treasury.

Actions taken: No actions taken. OMES received the FY2021 finding for this program after FY2022 ended.

Actions remaining: Awaiting determination of Treasury on the nature of the relationship between the state and its
partners.

ALN: 21.023
FINDING NO: 2021-081
FEDERAL PROGRAM NAME: Emergency Rental Assistance (ERA)
STATUS: Not Corrected

Reason for recurrence: OMES received the FY2021 findings for this program after FY2022 ended. Also, due to the
nature of the relationship, the state maintains that the administrators contracted to deploy the Emergency Rental
Assistance Program were in fact vendors and not subrecipients. However, because the state auditors office disagrees
with this designation, the state has endeavored to follow the monitoring requirements until a determination is made
by Treasury.

Actions taken: OMES contracted with Eide Bailly for monitoring services. This report was provided to SAI
10/25/2023. The OMES Grants Management Office was also stood up to assist with subrecipient monitoring for
future federal grants awarded at a statewide level.

Actions remaining: There is no additional action needed.

ALN: 21.019
Finding No: 2020-083, 2021-084
Federal Program Name: Coronavirus Relief Fund
Status: Partially Corrected

Reason for Recurrence: Due to the short term nature of this program, part of the action plans to correct findings
were forward looking to make improvements for future centralized grants.




                                                        201
Actions Remaining: As the Coronavirus Relief Fund grant has expired, CARES FORWARD no longer exists.
OMES will review the reimbursements contained in the bulleted samples and will present its determinations once
the review is complete.

Additionally, completed third party audits performed on the 2 of the 3 subrecipients for fiscal year 2022 noted no
questioned or unallowable costs related to federal expenditures. OMES is not yet in receipt of a third party audit for
the remaining subrecipient.

ALN: 21.019
Finding No: 2021-085
Federal Program Name: Coronavirus Relief Fund
Status: Corrected

ALN: 21.019
Finding No: 2021-091
Federal Program Name: Coronavirus Relief Fund
Status: Corrected

ALN: 21.019
Finding No: 2020-080, 2020-081, 2021-094
Federal Program Name: Coronavirus Relief Fund
Status: Partially Corrected

Reason for Recurrence: Due to the short term nature of this program, part of the action plans to correct findings were
forward looking to make improvements for future centralized grants.

Actions Remaining: As the Coronavirus Relief Fund grant has expired, CARES FORWARD no longer exists. The
CARES Forward team developed procedures during rapid deployment of $1.2 billion of pandemic relief funding
and, later in the process, in response to certain previous single audit findings. Specifically, In June of 2021, OMES
established a Grants Management Office (GMO) as a central agency resource to oversee and ensure compliance for
specific grant programs. The GMO previously designed and implemented, and currently continues to improve, its
controls to ensure that expenditures are properly incurred pursuant to the federal award and associated guidance.
OMES will review the bulleted samples, the reimbursement to OESC, and OMES will present its determinations
after it has conducted its review.

ALN: 21.023
FINDING NO: 2021-105
FEDERAL PROGRAM NAME: Emergency Rental Assistance (ERA)
STATUS: Corrected




                                                         202
                 STATE OF OKLAHOMA/OFFICE OF MANAGEMENT AND ENTERPRISE SERVICES
                                STATE OF OKLAHOMA – SINGLE AUDIT
                             SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
                                          2 CFR § 200.511(b)
                                              SFY 2022


ALN: 84.425C
Finding No: 2021-019
Federal Program Name: Education Stabilization Fund - GEER
Status: Partially Corrected

Reason for recurrence: The Single Audit Report for the Fiscal Year Ended June 30, 2021 (2021 Single Audit) was not published until
June 27, 2023. Accordingly, the response provided in the 2021 Single Audit represented the status as of the end of the fiscal year ended
June 30, 2022.

Actions taken: The Single Audit Report for the Fiscal Year Ended June 30, 2021 (2021 Single Audit) was not published until June 27,
2023. Accordingly, the response provided in the 2021 Single Audit represented the status as of the end of the fiscal year ended June 30,
2022.

Actions remaining: OMES, through the Grants Management Office, has continued to hold periodic meetings with the USDOE to
provide additional detail and complete the requests made of the State by the USDOE regarding GEER. OMES has completed a review
of the Bridge the Gap program and provided this information to the USDOE. Additionally, OMES completed the review of Stay in
School Scholarship program enrollment eligibility and has provided that information to the USDOE.

ALN: 84.425C
Finding No: 2021-060
Federal Program Name: Education Stabilization Fund - GEER
Status: Corrected

Finding No: 2021-078
Federal Program Name: Education Stabilization Fund - GEER
Status: Corrected

ALN: 84.425C
Finding No: 2021-109
Federal Program Name: Education Stabilization Fund - GEER
Status: Partially Corrected

Reason for recurrence: The Single Audit Report for the Fiscal Year Ended June 30, 2021 (2021 Single Audit) was not published until
June 27, 2023. Accordingly, the response provided in the 2021 Single Audit represented the status as of the end of the fiscal year ended
June 30, 2022.

Actions taken: The 2021 Single Audit was not published until June 27, 2023. Accordingly, the response provided in the 2021 Single
Audit represented the status as of the end of the fiscal year ended June 30, 2022

Actions remaining: OMES has continued to work with the USDOE and provide responses to all requests made in relation to GEER. In
addition, OMES has continued to develop the Grants Management Office as indicted in the 2021 Single Audit Corrective Action Plan.
OMES anticipates that the Grants Management Office will continue to develop and mature into the future.




                              STATE OF OKLAHOMA · OFFICE OF MANAGEMENT & ENTERPRISE SERVICES · OKLAHOMA.GOV/OMES



                                                                    203
                              STATE OF OKLAHOMA – SINGLE AUDIT
                           SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
                                        2 CFR § 200.511(b)
                                            SFY 2022

ALN: 10.558
Finding No: 2021-018
Federal Program Name: Child and Adult Care Food Program (CACFP)
Status: Corrected

ALN: 10.558
Finding No: 2021-020, 2020-073
Federal Program Name: Child and Adult Care Food Program (CACFP)
Status: Corrected

ALN: 10.558
Finding No: 2021-021, 2020-002, & 2020-07
Federal Program Name: Child and Adult Care Food Program (CACFP)
Status: Corrected

ALN: 84.425D
Finding No: 2021-036
Federal Program Name: Education Stabilization Fund (ESF); Elementary and Secondary School Emergency
                            Relief (ESER) Fund
Status: Partially Corrected

Reason for recurrence: The partnership with the third-party consulting firm was not established until January 30, 2023.

Actions taken: OSDE, in partnership with a third-party consulting firm, has developed a formalized procedure for
FFATA reporting that includes an established timeline and calendar notifications/reminders for the staff members
involved in the FFATA process to report in timely manner in compliance with USDE requirements.

Actions remaining: FFATA reports should be completed timely and in compliance with USDE requirements due to
the partnership with the third-party consulting firm.




                                                         204
                                                                                      PREPAREDNESS
                                                                                      RESPONSE
                                                                                      RECOVERY
                                                                                      MITIGATION


                          STATE OF OKLAHOMA – SINGLE AUDIT SUMMARY
                               SCHEDULE OF PRIOR AUDIT FINDINGS
                                       2 CFR § 200.511(b)
                                           SFY 2022


ALN: 97.036
Finding No: 2018-012
Program Name: Disaster Grants – Public Assistance
Status: Corrected

ALN: 97.036
Finding No: 2020-066, 2021-073
Program Name: Disaster Grants – Public Assistance
Status: Partially Corrected

Reason for recurrence: The agency was unable to update their subrecipient monitoring processes for state fiscal year
2022.

Actions taken: The agency updated the Subrecipient Monitoring Standard Operating Procedures in August of 2023.
The revised SOP can be found here, SOP 3.1.2 Agency Subrecipient Monitoring Policy. Approximately 773 PA
projects were monitored in calendar year 2023, proof of monitoring can be provided. PA monitoring activities are
recorded in SharePoint and OKEMGrants.

Actions remaining: A full implementation of the Monitoring SOP has not yet been adopted across all programs; we
anticipate it being implemented by June 30, 2024.

ALN: 97.036
Finding No: 2021-041
Program Name: Disaster Grants – Public Assistance
Status: Corrected

ALN: 97.036
Finding No: 2021-045
Program Name: Disaster Grants – Public Assistance
Status: Corrected




                   Oklahoma Department of Emergency Management and Homeland Security
           P.O. Box 53365, Oklahoma City, OK 73152 | 2401 N. Lincoln Blvd, Oklahoma City, OK 73105
                            (405) 521-2481 | Fax (405) 521-4053 | www.oem.ok.gov

                                                        205
Trae Rahill                                                                                                                                               J. Kevin Stitt
Chief Executive Officer                                                                                                                                       Governor

Representing Employers                                                                                                                    Representing Employees
Christy Rawlings, Commissioner                                       Representing the Public                                           Aaron Johnson, Commissioner
Dean Pennello, Commissioner                                             David Reid, Chair                                                  Traci Cook, Commissioner



                                                  STATE OF OKLAHOMA – SINGLE AUDIT
                                              SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
                                                           2 CFR § 200.511(b)
                                                               SFY 2022



          ALN: 17.225
          Finding No: 2021-001
          Federal Program Name: Unemployment Insurance Program
          Status: Partially Corrected

          Reason for recurrence: The agency continuously makes fraud prevention a priority and is engaging with federal
          partners, other state agencies and vendor partners to be vigilant in anticipating trends in fraud activity. While we
          believe we are expending appropriate levels of effort in this area, the complexity and ever-changing nature of the
          fraud space makes it difficult to mitigate this risk entirely.

          Actions taken: In addition to ongoing efforts to strengthen internal processes to identify fraudulent claims, in
          November 2022, the agency implemented an enhanced version of VerifyOK. This version enables a much higher
          degree of accuracy to ensure identity of claimants thus minimizing the possibility of fraud.

          Actions remaining: As mentioned above, the agency will continue to make fraud prevention a priority to minimize
          the possibility of fraud, but we also expect this to be a difficult risk to fully mitigate.

          ALN: 17.225
          Finding No: 2021-002
          Federal Program Name: Unemployment Insurance Program
          Status: Corrected

          ALN: 17.225
          Finding No: 2021-011
          Federal Program Name: Unemployment Insurance Program
          Status: Partially Corrected

          Reason for recurrence: Aged and/or antiquated technologies are at the root of the cause for the challenges the
          agency faces in the area of reliable data capture and reporting.

          Actions taken: A technology implementation project is currently underway to replace the current Oklahoma Job
          Match platform.

          Actions remaining: Completion of the technology project is expected during 2024 and is expected to address the
          issues underlying this finding.

          ALN: 17.225
          Finding No: 2021-012
          Federal Program Name: Unemployment Insurance Program
          Status: Corrected

          ALN: 17.225
          Finding No: 2021-022
       Will Rogers Memorial Office Building, 2401 North Lincoln Boulevard, P.O. Box 52003, Oklahoma City, OK 73152-2003 |Phone (405) 557-7100 · Fax (405) 557-7174


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Federal Program Name: Unemployment Insurance Program
Status: Not Corrected

Reason for recurrence: Aged and/or antiquated technologies are at the root of the cause for the challenges the
agency faces in the area of reliable data capture and reporting.

Actions taken: A technology implementation project is currently underway to replace the current Oklahoma Job
Match platform.

Actions remaining: Completion of the technology project is expected during 2024 and is expected to address the
issues underlying this finding.

ALN: 97.050
Finding No: 2021-042
Federal Program Name: Lost Wage Assistance
Status: Not Corrected

Reason for recurrence: The finding is no longer warranted because the program ended in SFY 2022 before the SFY
2021 findings were received.

ALN: 97.050
Finding No: 2021-071
Federal Program Name: Lost Wage Assistance
Status: Not Corrected

Reason for recurrence: The finding is no longer warranted because the program ended in SFY 2022 before the SFY
2021 findings were received.

ALN: 97.050
Finding No: 2021-093
Federal Program Name: Lost Wage Assistance
Status: Not Corrected

Reason for recurrence: The finding is no longer warranted because the program ended in SFY 2022 before the SFY
2021 findings were received.

ALN: 97.050
Finding No: 2021-095
Federal Program Name: Lost Wage Assistance
Status: Not Corrected

Reason for recurrence: The finding is no longer warranted because the program ended in SFY 2022 before the SFY
2021 findings were received.

ALN: 17.225
Finding No: 2021-114
Federal Program Name: Unemployment Insurance Program
Status: Corrected

ALN: 17.225
Finding No: 2021-290-013
Federal Program Name: Unemployment Insurance Program
Status: Partially Corrected

Reason for recurrence: The agency continuously makes fraud prevention a priority and is engaging with federal
partners, other state agencies and vendor partners to be vigilant in anticipating trends in fraud activity. While we
believe we are expending appropriate levels of effort in this area, the complexity and ever-changing nature of the
fraud space makes it difficult to mitigate this risk entirely.

Actions taken: In addition to ongoing efforts to strengthen internal processes to identify fraudulent claims, in
November 2022, the agency implemented an enhanced version of VerifyOK. This version enables a much higher


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degree of accuracy to ensure identity of claimants thus minimizing the possibility of fraud.

Actions remaining: As mentioned above, the agency will continue to make fraud prevention a priority to minimize
the possibility of fraud, but we also expect this to be a difficult risk to fully mitigate.




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                                STATE OF OKLAHOMA – SINGLE AUDIT
                            SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
                                         2 CFR § 200.511(b)
                                             SFY 2022




ALN: 10.557
Finding No: 2021-030
Federal Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Status: Not Corrected (as of June 2022)

Reason for Recurrence: The leadership responsible for this did not follow procedures and are no longer employed in
Finance or with OSDH.

Actions Taken: Regarding the follow-up on finding 2021-030 and how it is impacted by the finding mentioned in the
SFY 2022 audit, these are two separate issues with two separate programs. Over a two-year period, Finance has taken
the following actions:

    1.   Regarding the timely reconciliation between the “Time & Effort” system and the general ledger, the system
         used in 2021 has since been de-commissioned. Currently, OSDH uses WorkDay to input actual time worked.
         Workday is reconciled monthly, by program, to the time booked on the general ledger on the PeopleSoft
         system. A final reconciliation between Workday and the GL is completed at the close-out of each grant to
         determine if there is any difference and any necessary adjusting entry is then completed.

    2.   In regard to a lack of controls related to time recording, Finance has simplified the COA from 1.5M to 500
         options to limit employees coding incorrectly, locked down access where possible; are continuing to
         emphasize supervisor review. In July 2023 Payroll began providing a weekly payroll spreadsheet on a Teams
         Page (POC chat) for all agency Points of Contacts.

Actions Remaining: Finance is working with Innofin Solutions to create reporting in Hyperion to provide a payroll
variance report along with additional reports to ensure more accurate reporting for the SEFA.

ALN: 10.557
Finding No: 2021-061
Federal Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Status: Not Corrected (as of June 2022)

Reason for Recurrence:
    1. The finding for 2021-061 was impacted by temporary procedures put into place to accommodate a fast move
        to telework during the COVID-19 pandemic. The temporary procedures allowed agencies to submit vouchers
        without scanning and attaching the supporting documentation. Agencies were to retain the documentation to
        be made available upon request.

    2.   Finding 2022-204 was mentioned as the source for follow-up on 2021-061. OSDH provided the information
         on 12-19-2023; however, it was after the request date.

Actions Taken:

    1.   Management submitted responses from the programs that provided explanations and support and considers
         this corrected and closed.




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    2.   Management has added a layer of oversight by reorganizing Procurement and Warehousing functions under
         a new centralized Logistics team to ensure transparency and adherence to all state and federal purchasing
         requirements. One of the primary initiatives of this new organization is to establish a single inventory and
         asset tracking system to support all agency programs to ensure internal controls are consistently applied.

Actions Remaining: None

ALN: 10.557
Finding No: 2021-086
Federal Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Status: Corrected

ALN: 21.019
Finding No: 2021-091
Federal Program Name: Coronavirus Relief Fund (CRF)
Status: Corrected

ALN: 10.557
Finding No: 2021-096
Federal Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Status: Not Corrected (as of June 2022)

Reason for Recurrence: The leadership responsible for this did not follow procedures and are no longer employed in
Finance or with OSDH.

Actions Taken: In 2023, OSDH established a dedicated employee to be responsible for tracking audit requests and
ensuring a timelier response to all requests going forward. Management has also revised the current report structure of
the dedicated employee to report directly to the Deputy CFO to help eliminate any bottlenecks and delays in providing
responses. Management has also recently added a new Deputy CFO to the leadership team, with a background in
Auditing, to be designated as the primary contact person on OSDH audits.

Actions Remaining: None.

ALN: 10.557
Finding No: 2018-071
Federal Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Status: ‘Do Not Warrant Further Actions’
    • 2 years have passed since the audit report in which the finding occurred was submitted to the FAC
    • The federal agency or pass-thru in not currently following up with the auditors on the finding •
    • A management decision was not issued.

ALN: 93.268
Finding No: 2019-084
Federal Program Name: Immunization Cooperative Agreements
Status: Status: ‘Do Not Warrant Further Actions’
    • 2 years have passed since the audit report in which the finding occurred was submitted to the FAC
    • The federal agency or pass-thru in not currently following up with the auditors on the finding •
    • A management decision was not issued.




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ALN: 93.917
Finding No: 2019-070
Federal Program Name: HIV Care Formula Grant
Status: Status: ‘Do Not Warrant Further Actions’
    • 2 years have passed since the audit report in which the finding occurred was submitted to the FAC
    • The federal agency or pass-thru in not currently following up with the auditors on the finding •
    • A management decision was not issued.




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ALN: 93.767; 93.778
Finding No: 2019-025, 2020-021, 2021-014
Federal Program Name: Children’s Health Insurance Program; Medicaid Cluster
Status: Not Corrected

Reason for recurrence: Clearing G1DX exceptions is a manual process that involves hundreds of caseworkers across the
state. Oklahoma Human Services (OKDHS) has provided training and emphasized the importance of clearing
exceptions in a timely manner. OKDHS should continue their work to improve the timeliness of clearing G1DX
exceptions.

Actions remaining: OKDHS is implementing a new structure for G1DX edits to create tasks in a queue as workers work
through the workload. G1DX edits on open cases will be bundled with pending case actions so that they can be
addressed along with the case actions. The OHCA Member Audit division continues to review cases and monitor
OKDHS progress to ensure G1DX cases are timely and appropriately resolved.


ALN: 93.778
Finding No: 2019-089, 2020-034, 2021-026
Federal Program Name: Medicaid Cluster
Status: Partially Corrected

Reason for recurrence: The timing of the finding and implementation of the corrective action occurred within a nine-
month period and encompassed multiple state fiscal years (SFY) – 2021, 2022, and 2023. The SFY 2021 Single Audit
finding reporting the Lottery Exchange deficiency was reported to OHCA during SFY 2023 (December 2022). Corrective
action implementation took place during SFY 2024 (August 2023). All other corrective action was implemented prior to
SFY 2022.

Actions taken: Correction of the IRS/SSA data exchange failures occurred immediately.

Actions remaining: The Lottery Commission change order is now in production and being utilized by the OKDHS) as
of August 14, 2023. OKDHS. Corrective Action was implemented during SFY 2024 (August 2023).

OKDHS has resolved all issues preventing jobs from running as expected and monitors to ensure jobs are running;
however, the Oklahoma Office of Management and Enterprise Services (OMES), the contracted entity coordinating
data exchange job reports from OKDHS to OHCA for monitoring, has not completed its work. OHCA Member Audit
requests updates from OKDHS and OMES continuously to work toward obtaining the information for ongoing
review.


ALN: 93.778
Finding No: 2021-028
Federal Program Name: Children’s Health Insurance Program; Medicaid Cluster
Status: Partially Corrected

Reason for recurrence: The system change was not put into production until May 1, 2023, at the end of the public
health emergency (PHE), due to a need to avoid inappropriate notices being sent to members.

Actions taken: OHCA has corrected the notice issue for terminated benefits since the end of the PHE. Corrective
action was fully implemented on May 1, 2023. Corrective action was implemented during SFY 2023.

OKDHS has implemented corrections to their termination notices. Death notices are in production. Corrective action
was implemented during SFY 2024.




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Actions remaining: OKDHS and OHCA are evaluating system changes required to move Medicaid eligibility for
Temporary Assistance for Needy Families (TANF) recipients to the Modified Adjusted Gross Income (MAGI) eligibility
process. OKDHS will have to move forward with their required changes prior to the OHCA implementation as the
two systems work together to direct eligibility to the proper system. The agencies are in the process of creating
requirements based on the necessary changes and at this time estimate the changes will be completed by June 30,
2024.

OHCA Member Audit will begin a post corrective action audit for a minimum of three months to ensure all aspects
of the eligibility on the parts of both agencies are processing members receiving TANF under the appropriate rules.
If issues persist the agencies will be required to identify additional corrective actions and further reviews will be
completed by OHCA.


ALN: 93.767; 93.778
Finding No: 2019-087, 2020-045, 2021-069
Federal Program Name: Children’s Health Insurance Program; Medicaid Cluster
Status: Not Corrected

Reason for recurrence: OHCA temporarily stopped income verification requests and changes due to data matches
to prevent closures during the public health emergency (PHE).

Actions remaining: The last corrections were complete effective August 22, 2023 to move members to a higher
coverage level. Corrective action has been implemented. Corrective action was implemented during SFY 2024.


ALN: 93.778
Finding No: 2020-051, 2021-008
Federal Program Name: Medicaid Cluster
Status: Partially Corrected

Reason for recurrence: A vendor was leveraged to implement to the National Correct Coding Initiative (NCCI) edit
codes into the sub-system. In addition to the time taken to procure the vendor, testing occurred in early SFY 2022, prior
to implementation by the end of SFY 2022.

Actions remaining: Phase 1 professional service edits went live January 3, 2022. Phase 2 institutional edits went live
April 29, 2022.

For the Medically Unlikely Edits (MUEs), a stricter version of the NCCI requirements were implemented. The entire line
will be denied if the provider bills over the limit. OHCA continuously utilizes the CMS MUEs to guide the limits placed in
the system.


Corrective action was implemented by the end of SFY 2022.



ALN: 93.778
Finding No: 12-807-008, 2013-043, 2014-026, 2015-035, 2016-006, 2017-033, 2018-025, 2019-046, 2020-068, 2021-010
Federal Program Name: Medicaid Cluster
Status: Not Corrected

Reason for recurrence: The agency continues to utilize actions in the “Actions remaining” section to mitigate
unallowable claims. Due to the high volume of claims submitted, reviewing every claim is not feasible.




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Actions remaining: The OHCA will continue to utilize control processes and procedures to ensure medical claims are
meeting program requirements. These processes include prior authorizations, suspended claim reviews, system
edits, post payment reviews, and our payment accuracy measurement study. OHCA will also continue National
Correct Coding Initiative (NCCI) edit updates, as well as continue with provider training to better educate our
providers. The $286 FFP was returned on the 9/30/2022 CMS-64 report as a Line 10A adjustment referencing 06-21-
010SAI. Corrective action has been implemented.


ALN: 93.778
Finding No: 2020-075, 2021-048
Federal Program Name: Medicaid Cluster
Status: Not Corrected

Reason for recurrence: The overpayment deficiency reported in the SFY 2021 Single Audit was issued to OHCA
during SFY 2023. The implementation of the corrective action occurred promptly after the finding was reported.
Corrective action implementation took place during SFY 2023 (September 2022).

Actions remaining: The historical cases were reported on the September 30, 2022 CMS-64.9C1 report. New
procedures were implemented to ensure all overpayments are reported quarterly on the CMS-64.9C1 within one year
of discovery. Corrective action was implemented during SFY 2023.


Fund Type: General Fund
Finding No: 21-807-010
Federal Program Name: Accounts Payable & Federal Receivable (GAAP Pkg. Q - Medicaid Payable and Receivable &
GAAP Pkg. Z – Schedule of Expenditures of Federal Awards)
Status: Not Corrected

Reason for recurrence: The report is delivered in a PDF format and hand keyed into the excel spreadsheet. Errors in
the manual process caused the deficiency.

Actions remaining: The Financial Services Unit developed a work around to address the issue until Gainwell
produces the Service Date Reimbursement Analysis Report (MAR-2300-M) as an excel report to transfer the
encumbered data to the Encumbered Funds excel more accurately. For the SFY 2023 Statewide Generally
Accepted Accounting Principles (GAAP) Package Q: Medicaid Summary, the PDF data was input by an individual
other than the one responsible for preparing the spreadsheet and reviewed by the preparer during preparation.




                                                         214
                              STATE OF OKLAHOMA – SINGLE AUDIT
                           SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
                                        2 CFR § 200.511(b)
                                            SFY 2022


ALN: 93.575, 93.596
Finding No: 2019-001, 2020-061, 2021-089
Program Name: CCDF Cluster
Status: Not Corrected

Reason for Recurrence: In the past we have not concurred with the auditor’s finding as one additional tick mark on
a form does not provide any more assurance than the employees signature stating that all of the steps were
performed. We are upgrading the related IT system where these steps are documented and decided this would be a
cost-effective time to resolve this issue.

Actions remaining: This finding identified a need for IT system changes to the inspection reports. On January
30th, 2023; Child Care Services implemented the “Go-Live” phase of updating the monitoring checklists and
summaries to include visual verification that all health and safety requirements are observed during inspections.
Child Care Services professional development unit has included a new training module regarding documentation
requirements. We expect repeat findings will appear in the 2023 audit as the new system was not implemented until
the middle of the fiscal year.

ALN: 10.551
Finding No: 2018-067, 2019-016, 2020-058, 2021-059
Program Name: SNAP Cluster
Status: Not Corrected

Reason for Recurrence: Due to the late timing of when DHS received the findings for the last two years, corrective
action was delayed, and we expected repeat findings. Inventory records were being moved from paper copies to an
electronic format from April 2022 to April 2023. We were also updating the destruction process to comply with
CFR requirements.

Actions remaining: Documented changes have been made to our EBT Handbook in response to the deficiencies
identified in the audit, providing clear guidelines for compliance. Real-time monitoring capabilities enable us to
promptly identify and address errors, fostering a proactive approach to compliance. We expect repeat findings will
appear in the 2023 audit as these changes have been ongoing through the 2023 fiscal year.

ALN: 93.558
Finding No: 07-830-015, 08-830-015, 09-830-027, 10-830-031, 11-830-012, 12-830-001, 2013-034, 2014-020,
2015-014, 2016-013, 2019-025, 2020-021, 2021-014
Program Name: Temporary Assistance for Needy Families
Anticipated Completion Date: Spring, 2024
Status: Not Corrected

Reason for Recurrence: Due to the timing of receiving the prior year finding we expected repeat findings. After a
comprehensive study of the G1DX edit creation process related to the findings in the 2021 audit, several issues were
found including:
    1. Edits were being created for time periods in which no benefits were issued.
    2. Edits were being created for Cases that were closed, or for HH members who had been removed from the
         Household before the edit was created.




                                                        215
    3.   Edits were being created for cases outside of review cycle, thereby creating additional tasks for case
         management staff.
    4.   Duplicate edits were being generated for several reasons.
    5.   Staff were not addressing the edits in a timely manner.

Actions remaining: The issues with the staff not addressing the edits in a timely manner was addressed in the
complete restructure of our organization and case management process on April 10, 2023. In this new structure,
G1DX edits creates tasks that are served up in a queue as workers work through the workload. G1DX edits on open
cases are bundled with pending case actions so that they can be addressed along with the case actions. This change
in structure highlighted the shortcomings in the G1DX edit creation process. We expect to have changes to the
reports fully tested and in place by early spring, 2024, which will account for a dramatic fall in the number of G1DX
edits that are demanding the staffs’ time and for a reduction of the backlog of edits.

ALN: 10.551
Finding No: 2019-025, 2020-021, 2021-014
Program Name: SNAP Cluster
Status: Not Corrected

Reason for Recurrence: Due to the timing of receiving the prior year finding we expected repeat findings. After a
comprehensive study of the G1DX edit creation process related to the findings in the 2021 audit, several issues were
found including:
    1. Edits were being created for time periods in which no benefits were issued.
    2. Edits were being created for Cases that were closed, or for HH members who had been removed from the
         Household before the edit was created.
    3. Edits were being created for cases outside of review cycle, thereby creating additional tasks for case
         management staff.
    4. Duplicate edits were being generated for several reasons.
    5. Staff were not addressing the edits in a timely manner.

Actions remaining: The issues with the staff not addressing the edits in a timely manner was addressed in the
complete restructure of our organization and case management process on April 10, 2023. In this new structure,
G1DX edits creates tasks that are served up in a queue as workers work through the workload. G1DX edits on open
cases are bundled with pending case actions so that they can be addressed along with the case actions. This change
in structure highlighted the shortcomings in the G1DX edit creation process. We expect to have changes to the
reports fully tested and in place by early spring, 2024, which will account for a dramatic fall in the number of G1DX
edits that are demanding the staffs’ time and for a reduction of the backlog of edits.

ALN: 93.575, 93.596
Finding No: 2019-025, 2020-021, 2021-014
Program Name: CCDF Cluster
Status: Not Corrected

Reason for Recurrence: Due to the timing of receiving the prior year finding we expected repeat findings. After a
comprehensive study of the G1DX edit creation process related to the findings in the 2021 audit, several issues were
found including:
    1. Edits were being created for time periods in which no benefits were issued.
    2. Edits were being created for Cases that were closed, or for HH members who had been removed from the
         Household before the edit was created.
    3. Edits were being created for cases outside of review cycle, thereby creating additional tasks for case
         management staff.
    4. Duplicate edits were being generated for several reasons.
    5. Staff were not addressing the edits in a timely manner.

Actions remaining: The issues with the staff not addressing the edits in a timely manner was addressed in the
complete restructure of our organization and case management process on April 10, 2023. In this new structure,
G1DX edits creates tasks that are served up in a queue as workers work through the workload. G1DX edits on open




                                                         216
cases are bundled with pending case actions so that they can be addressed along with the case actions. This change
in structure highlighted the shortcomings in the G1DX edit creation process. We expect to have changes to the
reports fully tested and in place by early spring, 2024, which will account for a dramatic fall in the number of G1DX
edits that are demanding the staffs’ time and for a reduction of the backlog of edits.

ALN: 93.778
Finding No: 2019-025, 2020-021, 2021-014
Program Name: Medicaid Cluster
Status: Not Corrected

Reason for Recurrence: Due to the timing of receiving the prior year finding we expected repeat findings. After a
comprehensive study of the G1DX edit creation process related to the findings in the 2021 audit, several issues were
found including:
    1. Edits were being created for time periods in which no benefits were issued.
    2. Edits were being created for Cases that were closed, or for HH members who had been removed from the
         Household before the edit was created.
    3. Edits were being created for cases outside of review cycle, thereby creating additional tasks for case
         management staff.
    4. Duplicate edits were being generated for several reasons.
    5. Staff were not addressing the edits in a timely manner.

Actions remaining: The issues with the staff not addressing the edits in a timely manner was addressed in the
complete restructure of our organization and case management process on April 10, 2023. In this new structure,
G1DX edits creates tasks that are served up in a queue as workers work through the workload. G1DX edits on open
cases are bundled with pending case actions so that they can be addressed along with the case actions. This change
in structure highlighted the shortcomings in the G1DX edit creation process. We expect to have changes to the
reports fully tested and in place by early spring, 2024, which will account for a dramatic fall in the number of G1DX
edits that are demanding the staffs’ time and for a reduction of the backlog of edits.

ALN: 93.558
Finding No: 2019-027, 2020-040, 2021-088
Program Name: Temporary Assistance for Needy Families
Status: Not Corrected

Reason for recurrence: We did not receive the 2021 finding until the end of 2022 due to delays from the pandemic.
As a result, our corrective action was not put in place until after the beginning of 2023 resulting in repeat findings.

Actions remaining: We restructured the entire statewide TANF staff as part of our overall corrective action plan.
As of May 1, 2022, we vertically integrated the TANF Staff under the supervision of two Field Managers to bring
greater consistency in policy, procedure, and service delivery to our families. We conducted an all TANF staff back
to basics training addressing this issue.

ALN: 93.558
Finding No: 2019-043, 2020-035, 2021-065
Program Name: Temporary Assistance for Needy Families
Anticipated Completion Date: 06/09/2022
Status: Not Corrected

Reason for recurrence: We did not receive the 2021 finding until the end of 2022 due to delays from the pandemic.
As a result, our corrective action was not put in place until after the beginning of 2023 resulting in repeat findings.

Actions remaining: We restructured the entire statewide TANF staff as part of our overall corrective action plan.
As of May 1, 2022, we vertically integrated the TANF Staff under the supervision of two Field Managers to bring
greater consistency in policy, procedure, and service delivery to our families. We conducted an all TANF staff back
to basics training addressing this issue.




                                                         217
ALN: 93.558
Finding No: 2019-044, 2020-037, 2021-067
Program Name: Temporary Assistance for Needy Families
Anticipated Completion Date: 09/30/2022
Status: Not Corrected

Reason for recurrence: We did not receive the 2021 finding until the end of 2022 due to delays from the pandemic.
As a result, our corrective action was not put in place until after the beginning of 2023 resulting in repeat findings.

Actions remaining: We are working with system developers to try to make ACES automatically attach to the
applications. Until that is accomplished, we are continuing training all staff in TANF academy to make sure that
ACES are attached to all applications. We conducted an all TANF staff back to basics training addressing uploading
the ACES Screens on all applications and renewals when reviewed as well as documenting in case notes.

ALN: 93.558
Finding No: 2019-045, 2020-057, 2021-046
Program Name: Temporary Assistance for Needy Families
Status: Not Corrected

Reason for recurrence: We did not receive the 2021 finding until the end of 2022 due to delays from the pandemic.
As a result, our corrective action was not put in place until after the beginning of 2023 resulting in repeat findings.

Actions remaining: We restructured the entire statewide TANF staff as part of our overall corrective action plan.
As of May 1, 2022, we vertically integrated the TANF Staff under the supervision of two Field Managers to bring
greater consistency in policy, procedure, and service delivery to our families. We conducted an all TANF staff back
to basics training addressing this issue.

ALN: 93.667
Finding No: 2019-050, 2020-086, 2021-110
Program Name: Social Services Block Grant
Status: Corrected

ALN: 93.658
Finding No: 2017-050, 2018-052, 2019-063, 2020-053, 2021-099
Program Name: Foster Care – Title IV-E
Status: Not Corrected

Reason for recurrence: We did not receive the 2021 finding until the end of 2022 due to delays from the pandemic.
As a result, our corrective action was not put in place until after the beginning of 2023 resulting in repeat findings.

Actions remaining: We are in the process of amending contracts to include the requirements of 2 CFR §200.332
(a). Ten of the 13 pass though entities have been amended as of December 2023 and the remaining three are in
process to be completed before the end of State fiscal year 2024.

ALN: 93.778
Finding No: 2019-089, 2020-034, 2021-026
Program Name: Medicaid Cluster
Status: Partially Corrected

Reason for recurrence: The timing of the finding and implementation of the corrective action occurred within a nine-
month period and encompassed multiple state fiscal years (SFY) – 2021, 2022, and 2023. The SFY 2021 Single Audit
finding reporting the Lottery Exchange deficiency was reported to OHCA during SFY 2022 (December 2022).
Corrective action implementation took place during SFY 2024 (August 2023). All other corrective action was
implemented prior to SFY 2022.




                                                         218
Actions taken: Correction of the IRS/SSA data exchange failures occurred immediately.

Actions remaining: The Lottery Commission change order is now in production and being utilized by the
Oklahoma Human Services (OKDHS) as of August 14, 2023. OKDHS. Corrective Action was implemented during
SFY 2024 (August 2023).

OKDHS has resolved all issues preventing jobs from running as expected and monitors to ensure jobs are running;
however, the Oklahoma Office of Management and Enterprise Services (OMES), the contracted entity coordinating
data exchange job reports from OKDHS to OHCA for monitoring, has not completed its work. OHCA Member
Audit requests updates from OKDHS and OMES continuously to work toward obtaining the information for
ongoing review.

ALN: 93.558
Finding No: 2020-033, 2021-053
Program Name: Temporary Assistance for Needy Families
Status: Not Corrected

Reason for recurrence: We did not receive the 2021 finding until the end of 2022 due to delays from the pandemic.
As a result, our corrective action was not put in place until after the beginning of 2023 resulting in repeat findings.

Actions remaining: As of May 1, 2022, we vertically integrated the TANF Staff under the supervision of two Field
Managers to bring greater consistency in policy, procedure, and service delivery to our families. We conducted an
all TANF staff back to basics training addressing this issue.

ALN: 93.558
Finding No: 2020-036, 2021-066
Program Name: Temporary Assistance for Needy Families
Status: Corrected

ALN: 93.575, 93.596
Finding No: 2020-038, 2021-079
Program Name: CCDF Cluster
Status: Corrected

ALN: 93.558
Finding No: 2021-015
Program Name: Temporary Assistance for Needy Families
Status: Not Corrected

Reason for recurrence: The cause for this finding stems from several changes in administration and personnel
without an established process in place to ensure continuity.

Actions remaining: Business Intelligence has a query that checks for adults approaching their time limit and any
approaching 60 months. Moving forward they are updating the process to create a table that compares that number
of months reported on the FTANF report to the current months of TANF received for each adult recipient. This
should resolve any issues caused by only validating the number of months received for adults approaching the time-
limit for TANF and validate the entirety of the populations’ months as reported.

ALN: 93.767; 93.778
Finding No: 2021-028
Program Name: Children’s Health Insurance Program; Medicaid Cluster
Status: Partially Corrected

Reason for recurrence: The system change was not put into production until May 1, 2023, at the end of the PHE,
due to a need to avoid inappropriate notices being sent to members.




                                                         219
Actions taken: OHCA has corrected the notice issue for terminated benefits since the end of the public health
emergency (PHE). Corrective action was fully implemented on May 1, 2023. Corrective action was implemented
during SFY 2023.

The Oklahoma Human Services (OKDHS) has implemented corrections to their termination notices. Death notices
are in production. Corrective action was implemented during SFY 2024.

Actions remaining: OKDHS and OHCA are evaluating system changes required to move Medicaid eligibility for
Temporary Assistance for Needy Families (TANF) recipients to the Modified Adjusted Gross Income (MAGI)
eligibility process. OKDHS will have to move forward with their required changes prior to the OHCA
implementation as the two systems work together to direct eligibility to the proper system. The agencies are in the
process of creating requirements based on the necessary changes and at this time estimate the changes will be
completed by June 30, 2024.

OHCA Member Audit will begin a post corrective action audit for a minimum of three months to ensure all aspects
of the eligibility on the parts of both agencies are processing members receiving TANF under the appropriate rules.
If issues persist the agencies will be required to identify additional corrective actions and further reviews will be
completed by OHCA.

ALN: 93.558
Finding No: 2021-029
Program Name: Temporary Assistance for Needy Families
Status: Corrected

ALN: 10.551
Finding No: 2021-037
Program Name: SNAP Cluster
Status: Corrected

ALN: 10.542
Finding No: 2021-037
Program Name: Pandemic EBT Food Benefits (P-EBT)
Status: Corrected

ALN: 93.558
Finding No: 2021-040
Program Name: Temporary Assistance for Needy Families
Status: Corrected

ALN: 93.558
Finding No: 2021-049
Program Name: Temporary Assistance for Needy Families
Status: Corrected

ALN: 10.542
Finding No: 2021-062
Program Name: Pandemic EBT Food Benefits (P-EBT)
Status: Not Corrected

Reason for recurrence: Additional reporting requirements for COVID funds created additional complexity to the
reporting process that was not anticipated when designing the existing internal controls.

Actions remaining: We are presently working to obtain system data to correct reporting as needed. The PEBT
program has expired but we will use the lessons learned to place better controls in place for any programs of a
similar nature going forward.




                                                         220
ALN: 93.558
Finding No: 2021-064
Program Name: Temporary Assistance for Needy Families
Status: Not Corrected

Reason for recurrence: A directive came from the OCSS to not penalize TANF recipients for non-cooperation
during this period due to the pandemic. The 2021 findings were also not received until 2023 so corrective action
was delayed.

Actions remaining: Non-Coop penalties have now been restored within DHS. In the future, DHS will not waive non
coop penalties unless directed to do so by federal awarding agencies.

ALN: 93.558
Finding No: 2021-068
Program Name: Temporary Assistance for Needy Families
Status: Not Corrected

Reason for recurrence: The Oklahoma Department of Human Services does not concur with the finding.

Actions remaining: Medicaid was the primary example used in the discussion with OKDHS management and as it
applies to children in custody since children in custody have Medicaid. Children not in custody who are clients of
Medicaid, SNAP, TANF, and Childcare are also able to be funded with TANF funds. This test only looked at the
documentation used to determine custody children as eligible for TANF. The OCS liaison researches other programs
that this child could be a client of and marks the log as whether any other programs serve this child therefore making
them eligible for TANF. This is consistent with the previously submitted corrective action plan to the State Auditor
and Inspectors office, the Public Assistance Cost Allocation Plan, and the TANF state plan.

ALN: 93.558
Finding No: 2021-076
Program Name: Temporary Assistance for Needy Families
Status: Corrected

ALN: 93.659
Finding No: 2021-100
Program Name: Adoption Assistance
Status: Not Corrected

Reason for recurrence: The missing documents are required for any case to be approved and proceed. We believe
the forms were likely misfiled but we will take immediate action to get these documents added to the case file.

Actions remaining: The missing documents are required for any case to be approved and proceed. We believe the
forms were likely misfiled but we will take immediate action to get these documents added to the case file. This
finding will be added to the next Child Welfare meeting agenda to ensure everyone in this process is aware of the
documents required and the importance of properly filing every document.

ALN: 93.658
Finding No: 2021-101
Program Name: Foster Care – Title IV-E
Status: Not Corrected

Reason for recurrence: We did not receive the 2021 finding until the end of 2022 due to delays from the
pandemic. As a result, our corrective action was not put in place until after the beginning of 2023 resulting in repeat
findings.




                                                         221
Actions remaining: The file without a proper Difficulty of Care document will be corrected immediately. The
DHS will also conduct additional training surrounding this finding to reinforce the requirements and improve
compliance with policy.

The OKDHS is taking action to bring the annual Foster Home updates current through training employees. Annual
updates are required by DHS policy, but DHS policy also grants Foster Home continuous approval unless action is
taken by either party to terminate the contract or close the home. There are no eligibility issues on the Foster
Homes, but we are not in compliance with DHS policy.

ALN: 10.565, 10.568, 10.569
Finding No: 2021-106
Program Name: Food Distribution Cluster
Status: Not corrected

Reason for recurrence: This finding was received after the 2022 SEFA process was completed so we were unable
to put the put any corrective action in place for 2022.

Actions remaining: We have since implemented a review process to review the supporting data to ensure that only
funds related to food actually delivered is included in the SEFA.

ALN: 93.667
Finding No: 2021-107
Program Name: Social Services Block Grant
Status: Corrected

ALN: 10.565, 10.568, 10.569
Finding No: 2021-112
Program Name: Food Distribution Cluster
Status: Corrected




                                                      222
                                                                                         Chief Financial Officer
                                                                                            Ms. Chelley Hilmes
                                                                                                  200 N.E. 21st Street
                                                                                       Oklahoma City, OK 73105-3204
                                                                                                       www.odot.org


                                   STATE OF OKLAHOMA – SINGLE AUDIT
                                SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
                                             2 CFR § 200.511(b)
                                                 SFY 2022


ALN: 20.509
Finding No: 2021-017
Federal Program Name: Formula Grants for Rural Areas
Status: Not corrected
Reason for recurrence: The finding was issued after 6/30/2022; consequently, corrective actions could not be implemented.

Actions remaining: Multi-Modal will update the Single Audit Spreadsheet by the date identified, and ongoing throughout the
year, to know the audit type required by each sub-recipient. Contract Compliance Division will complete a risk assessment
with each subrecipient by 12/31/2022. An employee has been tasked with this responsibility. In addition, the Multi-Modal and
Contract Compliance Division now share office space, and ease of communication has increased. Multi-Modal completed the
single audit spreadsheet on 9/2022. Contract Compliance will review each annual risk assessment by 12/31/2023.

ALN: 20.509
Finding No: 2021-044
Federal Program Name: Formula Grants for Rural Areas
Status: Corrected

ALN: 20.205
Finding No: 2021-025
Federal Program Name: Highway Planning and Construction Cluster
Status: Not corrected

Reason for recurrence: The finding was issued after 6/30/2022; consequently, corrective actions could not be implemented.

Actions remaining: The Contract Compliance Division was created in March of 2022. A major function of the Division is to
establish, support, and ensure adequate subrecipient monitoring of ODOT-administered federal programs. The policy was
adopted on 7/26/2022.

ALN: 20.205
Finding No: 2021-051
Federal Program Name: Highway Planning and Construction Cluster
Status: Not corrected

Reason for recurrence: The finding was issued after 6/30/2022; consequently, corrective actions could not be implemented.

Actions remaining: The Quality Assurance / Independent Assurance process will be modified to provide an alternative for
performance or review/approval in the event of an absence. Effective immediately. Materials Certification procedures are
currently in place. We plan on providing training and awareness through the annual Resident Engineer Academy training and
the monthly District Engineer meeting to emphasize the required steps for the materials certification documentation.

ALN: 20.509
Finding No: 2021-058
Federal Program Name: Formula Grants for Rural Areas
Status: Corrected




                                                             223
ALN: 20.205
Finding No: 2021-077
Federal Program Name: Highway Planning and Construction Cluster
Status: Not corrected

Reason for recurrence: The finding was issued after 6/30/2022; consequently, corrective actions could not be implemented.

Actions remaining: We have reviewed and revised our procedures and instructions to ensure closed projects are processed in a
timely basis.

ALN: 20.509
Finding No: 2021-082
Federal Program Name: Formula Grants for Rural Areas
Status: Corrected

ALN: 20.509
Finding No: 2021-108
Federal Program Name: Formula Grants for Rural Areas
Status: Corrected




                   “The mission of the Oklahoma Department of Transportation is to provide a safe, economical, and
                     Effective transportation network for the people, commerce, and communities of Oklahoma.”

                                             AN EQUAL OPPORTUNITY EMPLOYER

                                                                224
  Greg Slavonic                                                                                                               J. KEVIN STITT
EXECUTIVE DIRECTOR                                                                                                               GOVERNOR




                                                         STATE OF OKLAHOMA
                                              DEPARTMENT OF VETERANS AFFAIRS


                                        STATE OF OKLAHOMA – SINGLE AUDIT
                                     SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
                                                  2 CFR § 200.511(b)
                                                      SFY 2022


ALN: 64.015
Finding No: 2021-111
Federal Program Name: Veterans State Nursing Home Care
Status: Corrected




                                                              Serving those who served
                                           OKLAHOMA VETERANS COMMISSION * CONTROLLING BOARD
  VETERANS MEMORIAL BUILDING * 2311 N. CENTRAL AVE. * P.O. BOX 53067 * OKLAHOMA CITY, OK 73152 * TELEPHONE (405) 521-3684 * FAX (405) 521-6533

                                                                       225


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