2 CFR 200.303 requires that organizations receiving federal awards must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award.
Formal controls were not established or documented surrounding the following compliance requirements specified for this grant under 2 CFR Part 200, Appendix XI:
Activities allowed or unallowed and allowable cost principles – lack of documented, timely review and approval of expenditures for three of eight transactions selected for testing; specifically relating to payroll expenditures.
Suspension and Debarment – no established internal control policies to verify that vendors selected for use were not suspended or debarred from use for expenditures of federal awards.
Subrecipient monitoring – no established internal control policies surrounding monitoring of subrecipients for compliance with principles established under 2 CFR Part 200, Appendix XI.
The Foundation and its affiliates have not established internal control policies to ensure compliance with principles established under the Uniform Guidance.
Lack of internal controls could result in instances of noncompliance with federal grant requirements, which could lead to loss of future funding or requests for repayment of federal awards previously distributed by federal agencies.
Not applicable.
This is not a repeat finding.
The Foundation and its affiliates should establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the 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).
Management's response is reported in "Corrective Action Plan" at the end of this report.
Item 2023-004 – Performance Reporting
Significant Deficiency
Federal Program – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number – 21.027
Pass-through Grantor's Numbers – 2159FR0256, 2159FR0212
Federal Award Year – December 31, 2023
Federal Agency – U.S. Department of Treasury
Pass-Through Entity – Tulsa County/City of Tulsa
Tulsa County required both quarterly and annual performance reports to be submitted per the sub-recipient agreement for this federal grant. The City of Tulsa required monthly performance reports to be submitted per the sub-recipient agreements for this federal grant.
The Foundation had one affiliated entity who received federal funding through Tulsa County, however there were no formally established internal controls surrounding the accuracy of and timely submission for the required annual and quarterly reports.
The Foundation has two affiliated entities who received federal funding through sub-recipient agreements with the City of Tulsa. Neither affiliate could provide evidence that monthly reports were submitted to the City of Tulsa.
The Foundation's affiliates lacked formal review processes over performance reporting requirements to the pass-through agencies.
Lack of internal control policies could result in instances of noncompliance with federal standards. This could result in additional oversight of the awarding entities, or future lack of funding.
Not applicable.
This is not a repeat finding.
The Foundation's affiliates should appoint an individual to oversee all reporting requirements relating to federal awards received and establish a proper review process to ensure performance reports are accurate and filed timely.
Management's response is reported in "Corrective Action Plan" at the end of this report.
Item 2023-005 – Procurement
Significant Deficiency
Federal Program – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number – 21.027
Pass-through Grantor's Numbers – 2159FR0256, 2159FR0212
Federal Award Year – December 31, 2023
Federal Agency – U.S. Department of Treasury
Pass-Through Entity – Tulsa County/City of Tulsa
Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326, which stipulates that the organization must have a policy in place to comply with these standards.
The Foundation had no documented policies in place over procurement of goods or services with the use of federal awards. As such, evidence was not available to document that federal procurement standards were followed as transactions took place.
The Foundation and affiliates lacked a formally documented policy to prevent or detect inappropriate procurement from being entered into.
The Foundation may improperly award and/or pay more than what could have been obtained for comparable goods or services for the geographic area. If instances of non-compliance with federal procurement have occurred or occur in the future, it could result in loss of grant funds, additional federal oversight of federal funding, or repayment of overspent federal monies could be requested to be paid by the Foundation.
Not applicable.
This is not a repeat finding.
The Foundation should create a documented procurement policy that follows federal procurement policies and ensure that all affiliates establish and follow that policy. The Foundation and its affiliates should also establish formally documented controls to ensure that the procurement policies are being adhered.
Management's response is reported in "Corrective Action Plan" at the end of this report.
Item 2023-006 – Allowable Costs/Cost Principles
Significant Deficiency
Federal Program – Cooperative Extension Service
Assistance Listing Number – 10.500
Pass-through Grantor's Number – 1-575259-3
Federal Award Year – December 31, 2023
Federal Agency – U.S. Department of Agriculture
Pass-Through Entity – Oklahoma State University
2 CFR 200.302 (b) stipulates federal award recipients and subrecipients' financial management system must provide for the identification of all federal awards received and expended on their SEFA.
The Foundation was unable to distinguish federal and non-federal expenditures during the fiscal year for one program administrated by its affiliate. As a result, the amount reported on the SEFA represents the amount of federal dollars reimbursed during the fiscal year, and does not directly correlate to an underlying expenditure detail.
Reconciliations of federal expenditures to revenues recorded were not prepared timely, nor were they reviewed for accuracy.
For this specific program, the Foundation is at an increased likelihood of expending federal awards for unallowable or questioned costs.
Not applicable.
This is not a repeat finding.
The Foundation should perform reconciliations of federal revenues to expenditures on a monthly basis, which should be reviewed for accuracy. The Foundation should maintain all records of underlying support of expenditures incurred as related to draws of federal money in order to support that the draws were appropriate and for allowable costs.
Management's response is reported in "Corrective Action Plan" at the end of this report.
2 CFR 200.303 requires that organizations receiving federal awards must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award.
Formal controls were not established or documented surrounding the following compliance requirements specified for this grant under 2 CFR Part 200, Appendix XI:
Activities allowed or unallowed and allowable cost principles – lack of documented, timely review and approval of expenditures for three of eight transactions selected for testing; specifically relating to payroll expenditures.
Suspension and Debarment – no established internal control policies to verify that vendors selected for use were not suspended or debarred from use for expenditures of federal awards.
Subrecipient monitoring – no established internal control policies surrounding monitoring of subrecipients for compliance with principles established under 2 CFR Part 200, Appendix XI.
The Foundation and its affiliates have not established internal control policies to ensure compliance with principles established under the Uniform Guidance.
Lack of internal controls could result in instances of noncompliance with federal grant requirements, which could lead to loss of future funding or requests for repayment of federal awards previously distributed by federal agencies.
Not applicable.
This is not a repeat finding.
The Foundation and its affiliates should establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the 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).
Management's response is reported in "Corrective Action Plan" at the end of this report.
Item 2023-004 – Performance Reporting
Significant Deficiency
Federal Program – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number – 21.027
Pass-through Grantor's Numbers – 2159FR0256, 2159FR0212
Federal Award Year – December 31, 2023
Federal Agency – U.S. Department of Treasury
Pass-Through Entity – Tulsa County/City of Tulsa
Tulsa County required both quarterly and annual performance reports to be submitted per the sub-recipient agreement for this federal grant. The City of Tulsa required monthly performance reports to be submitted per the sub-recipient agreements for this federal grant.
The Foundation had one affiliated entity who received federal funding through Tulsa County, however there were no formally established internal controls surrounding the accuracy of and timely submission for the required annual and quarterly reports.
The Foundation has two affiliated entities who received federal funding through sub-recipient agreements with the City of Tulsa. Neither affiliate could provide evidence that monthly reports were submitted to the City of Tulsa.
The Foundation's affiliates lacked formal review processes over performance reporting requirements to the pass-through agencies.
Lack of internal control policies could result in instances of noncompliance with federal standards. This could result in additional oversight of the awarding entities, or future lack of funding.
Not applicable.
This is not a repeat finding.
The Foundation's affiliates should appoint an individual to oversee all reporting requirements relating to federal awards received and establish a proper review process to ensure performance reports are accurate and filed timely.
Management's response is reported in "Corrective Action Plan" at the end of this report.
Item 2023-005 – Procurement
Significant Deficiency
Federal Program – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number – 21.027
Pass-through Grantor's Numbers – 2159FR0256, 2159FR0212
Federal Award Year – December 31, 2023
Federal Agency – U.S. Department of Treasury
Pass-Through Entity – Tulsa County/City of Tulsa
Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326, which stipulates that the organization must have a policy in place to comply with these standards.
The Foundation had no documented policies in place over procurement of goods or services with the use of federal awards. As such, evidence was not available to document that federal procurement standards were followed as transactions took place.
The Foundation and affiliates lacked a formally documented policy to prevent or detect inappropriate procurement from being entered into.
The Foundation may improperly award and/or pay more than what could have been obtained for comparable goods or services for the geographic area. If instances of non-compliance with federal procurement have occurred or occur in the future, it could result in loss of grant funds, additional federal oversight of federal funding, or repayment of overspent federal monies could be requested to be paid by the Foundation.
Not applicable.
This is not a repeat finding.
The Foundation should create a documented procurement policy that follows federal procurement policies and ensure that all affiliates establish and follow that policy. The Foundation and its affiliates should also establish formally documented controls to ensure that the procurement policies are being adhered.
Management's response is reported in "Corrective Action Plan" at the end of this report.
2 CFR 200.303 requires that organizations receiving federal awards must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award.
Formal controls were not established or documented surrounding the following compliance requirements specified for this grant under 2 CFR Part 200, Appendix XI:
Activities allowed or unallowed and allowable cost principles – lack of documented, timely review and approval of expenditures for three of eight transactions selected for testing; specifically relating to payroll expenditures.
Suspension and Debarment – no established internal control policies to verify that vendors selected for use were not suspended or debarred from use for expenditures of federal awards.
Subrecipient monitoring – no established internal control policies surrounding monitoring of subrecipients for compliance with principles established under 2 CFR Part 200, Appendix XI.
The Foundation and its affiliates have not established internal control policies to ensure compliance with principles established under the Uniform Guidance.
Lack of internal controls could result in instances of noncompliance with federal grant requirements, which could lead to loss of future funding or requests for repayment of federal awards previously distributed by federal agencies.
Not applicable.
This is not a repeat finding.
The Foundation and its affiliates should establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the 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).
Management's response is reported in "Corrective Action Plan" at the end of this report.
Item 2023-004 – Performance Reporting
Significant Deficiency
Federal Program – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number – 21.027
Pass-through Grantor's Numbers – 2159FR0256, 2159FR0212
Federal Award Year – December 31, 2023
Federal Agency – U.S. Department of Treasury
Pass-Through Entity – Tulsa County/City of Tulsa
Tulsa County required both quarterly and annual performance reports to be submitted per the sub-recipient agreement for this federal grant. The City of Tulsa required monthly performance reports to be submitted per the sub-recipient agreements for this federal grant.
The Foundation had one affiliated entity who received federal funding through Tulsa County, however there were no formally established internal controls surrounding the accuracy of and timely submission for the required annual and quarterly reports.
The Foundation has two affiliated entities who received federal funding through sub-recipient agreements with the City of Tulsa. Neither affiliate could provide evidence that monthly reports were submitted to the City of Tulsa.
The Foundation's affiliates lacked formal review processes over performance reporting requirements to the pass-through agencies.
Lack of internal control policies could result in instances of noncompliance with federal standards. This could result in additional oversight of the awarding entities, or future lack of funding.
Not applicable.
This is not a repeat finding.
The Foundation's affiliates should appoint an individual to oversee all reporting requirements relating to federal awards received and establish a proper review process to ensure performance reports are accurate and filed timely.
Management's response is reported in "Corrective Action Plan" at the end of this report.
Item 2023-005 – Procurement
Significant Deficiency
Federal Program – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number – 21.027
Pass-through Grantor's Numbers – 2159FR0256, 2159FR0212
Federal Award Year – December 31, 2023
Federal Agency – U.S. Department of Treasury
Pass-Through Entity – Tulsa County/City of Tulsa
Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326, which stipulates that the organization must have a policy in place to comply with these standards.
The Foundation had no documented policies in place over procurement of goods or services with the use of federal awards. As such, evidence was not available to document that federal procurement standards were followed as transactions took place.
The Foundation and affiliates lacked a formally documented policy to prevent or detect inappropriate procurement from being entered into.
The Foundation may improperly award and/or pay more than what could have been obtained for comparable goods or services for the geographic area. If instances of non-compliance with federal procurement have occurred or occur in the future, it could result in loss of grant funds, additional federal oversight of federal funding, or repayment of overspent federal monies could be requested to be paid by the Foundation.
Not applicable.
This is not a repeat finding.
The Foundation should create a documented procurement policy that follows federal procurement policies and ensure that all affiliates establish and follow that policy. The Foundation and its affiliates should also establish formally documented controls to ensure that the procurement policies are being adhered.
Management's response is reported in "Corrective Action Plan" at the end of this report.
2 CFR 200.303 requires that organizations receiving federal awards must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award.
Formal controls were not established or documented surrounding the following compliance requirements specified for this grant under 2 CFR Part 200, Appendix XI:
Activities allowed or unallowed and allowable cost principles – lack of documented, timely review and approval of expenditures for three of eight transactions selected for testing; specifically relating to payroll expenditures.
Suspension and Debarment – no established internal control policies to verify that vendors selected for use were not suspended or debarred from use for expenditures of federal awards.
Subrecipient monitoring – no established internal control policies surrounding monitoring of subrecipients for compliance with principles established under 2 CFR Part 200, Appendix XI.
The Foundation and its affiliates have not established internal control policies to ensure compliance with principles established under the Uniform Guidance.
Lack of internal controls could result in instances of noncompliance with federal grant requirements, which could lead to loss of future funding or requests for repayment of federal awards previously distributed by federal agencies.
Not applicable.
This is not a repeat finding.
The Foundation and its affiliates should establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the 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).
Management's response is reported in "Corrective Action Plan" at the end of this report.
Item 2023-004 – Performance Reporting
Significant Deficiency
Federal Program – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number – 21.027
Pass-through Grantor's Numbers – 2159FR0256, 2159FR0212
Federal Award Year – December 31, 2023
Federal Agency – U.S. Department of Treasury
Pass-Through Entity – Tulsa County/City of Tulsa
Tulsa County required both quarterly and annual performance reports to be submitted per the sub-recipient agreement for this federal grant. The City of Tulsa required monthly performance reports to be submitted per the sub-recipient agreements for this federal grant.
The Foundation had one affiliated entity who received federal funding through Tulsa County, however there were no formally established internal controls surrounding the accuracy of and timely submission for the required annual and quarterly reports.
The Foundation has two affiliated entities who received federal funding through sub-recipient agreements with the City of Tulsa. Neither affiliate could provide evidence that monthly reports were submitted to the City of Tulsa.
The Foundation's affiliates lacked formal review processes over performance reporting requirements to the pass-through agencies.
Lack of internal control policies could result in instances of noncompliance with federal standards. This could result in additional oversight of the awarding entities, or future lack of funding.
Not applicable.
This is not a repeat finding.
The Foundation's affiliates should appoint an individual to oversee all reporting requirements relating to federal awards received and establish a proper review process to ensure performance reports are accurate and filed timely.
Management's response is reported in "Corrective Action Plan" at the end of this report.
Item 2023-005 – Procurement
Significant Deficiency
Federal Program – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number – 21.027
Pass-through Grantor's Numbers – 2159FR0256, 2159FR0212
Federal Award Year – December 31, 2023
Federal Agency – U.S. Department of Treasury
Pass-Through Entity – Tulsa County/City of Tulsa
Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326, which stipulates that the organization must have a policy in place to comply with these standards.
The Foundation had no documented policies in place over procurement of goods or services with the use of federal awards. As such, evidence was not available to document that federal procurement standards were followed as transactions took place.
The Foundation and affiliates lacked a formally documented policy to prevent or detect inappropriate procurement from being entered into.
The Foundation may improperly award and/or pay more than what could have been obtained for comparable goods or services for the geographic area. If instances of non-compliance with federal procurement have occurred or occur in the future, it could result in loss of grant funds, additional federal oversight of federal funding, or repayment of overspent federal monies could be requested to be paid by the Foundation.
Not applicable.
This is not a repeat finding.
The Foundation should create a documented procurement policy that follows federal procurement policies and ensure that all affiliates establish and follow that policy. The Foundation and its affiliates should also establish formally documented controls to ensure that the procurement policies are being adhered.
Management's response is reported in "Corrective Action Plan" at the end of this report.
Item 2023-006 – Allowable Costs/Cost Principles
Significant Deficiency
Federal Program – Cooperative Extension Service
Assistance Listing Number – 10.500
Pass-through Grantor's Number – 1-575259-3
Federal Award Year – December 31, 2023
Federal Agency – U.S. Department of Agriculture
Pass-Through Entity – Oklahoma State University
2 CFR 200.302 (b) stipulates federal award recipients and subrecipients' financial management system must provide for the identification of all federal awards received and expended on their SEFA.
The Foundation was unable to distinguish federal and non-federal expenditures during the fiscal year for one program administrated by its affiliate. As a result, the amount reported on the SEFA represents the amount of federal dollars reimbursed during the fiscal year, and does not directly correlate to an underlying expenditure detail.
Reconciliations of federal expenditures to revenues recorded were not prepared timely, nor were they reviewed for accuracy.
For this specific program, the Foundation is at an increased likelihood of expending federal awards for unallowable or questioned costs.
Not applicable.
This is not a repeat finding.
The Foundation should perform reconciliations of federal revenues to expenditures on a monthly basis, which should be reviewed for accuracy. The Foundation should maintain all records of underlying support of expenditures incurred as related to draws of federal money in order to support that the draws were appropriate and for allowable costs.
Management's response is reported in "Corrective Action Plan" at the end of this report.
2 CFR 200.303 requires that organizations receiving federal awards must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award.
Formal controls were not established or documented surrounding the following compliance requirements specified for this grant under 2 CFR Part 200, Appendix XI:
Activities allowed or unallowed and allowable cost principles – lack of documented, timely review and approval of expenditures for three of eight transactions selected for testing; specifically relating to payroll expenditures.
Suspension and Debarment – no established internal control policies to verify that vendors selected for use were not suspended or debarred from use for expenditures of federal awards.
Subrecipient monitoring – no established internal control policies surrounding monitoring of subrecipients for compliance with principles established under 2 CFR Part 200, Appendix XI.
The Foundation and its affiliates have not established internal control policies to ensure compliance with principles established under the Uniform Guidance.
Lack of internal controls could result in instances of noncompliance with federal grant requirements, which could lead to loss of future funding or requests for repayment of federal awards previously distributed by federal agencies.
Not applicable.
This is not a repeat finding.
The Foundation and its affiliates should establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the 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).
Management's response is reported in "Corrective Action Plan" at the end of this report.
Item 2023-004 – Performance Reporting
Significant Deficiency
Federal Program – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number – 21.027
Pass-through Grantor's Numbers – 2159FR0256, 2159FR0212
Federal Award Year – December 31, 2023
Federal Agency – U.S. Department of Treasury
Pass-Through Entity – Tulsa County/City of Tulsa
Tulsa County required both quarterly and annual performance reports to be submitted per the sub-recipient agreement for this federal grant. The City of Tulsa required monthly performance reports to be submitted per the sub-recipient agreements for this federal grant.
The Foundation had one affiliated entity who received federal funding through Tulsa County, however there were no formally established internal controls surrounding the accuracy of and timely submission for the required annual and quarterly reports.
The Foundation has two affiliated entities who received federal funding through sub-recipient agreements with the City of Tulsa. Neither affiliate could provide evidence that monthly reports were submitted to the City of Tulsa.
The Foundation's affiliates lacked formal review processes over performance reporting requirements to the pass-through agencies.
Lack of internal control policies could result in instances of noncompliance with federal standards. This could result in additional oversight of the awarding entities, or future lack of funding.
Not applicable.
This is not a repeat finding.
The Foundation's affiliates should appoint an individual to oversee all reporting requirements relating to federal awards received and establish a proper review process to ensure performance reports are accurate and filed timely.
Management's response is reported in "Corrective Action Plan" at the end of this report.
Item 2023-005 – Procurement
Significant Deficiency
Federal Program – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number – 21.027
Pass-through Grantor's Numbers – 2159FR0256, 2159FR0212
Federal Award Year – December 31, 2023
Federal Agency – U.S. Department of Treasury
Pass-Through Entity – Tulsa County/City of Tulsa
Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326, which stipulates that the organization must have a policy in place to comply with these standards.
The Foundation had no documented policies in place over procurement of goods or services with the use of federal awards. As such, evidence was not available to document that federal procurement standards were followed as transactions took place.
The Foundation and affiliates lacked a formally documented policy to prevent or detect inappropriate procurement from being entered into.
The Foundation may improperly award and/or pay more than what could have been obtained for comparable goods or services for the geographic area. If instances of non-compliance with federal procurement have occurred or occur in the future, it could result in loss of grant funds, additional federal oversight of federal funding, or repayment of overspent federal monies could be requested to be paid by the Foundation.
Not applicable.
This is not a repeat finding.
The Foundation should create a documented procurement policy that follows federal procurement policies and ensure that all affiliates establish and follow that policy. The Foundation and its affiliates should also establish formally documented controls to ensure that the procurement policies are being adhered.
Management's response is reported in "Corrective Action Plan" at the end of this report.
2 CFR 200.303 requires that organizations receiving federal awards must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award.
Formal controls were not established or documented surrounding the following compliance requirements specified for this grant under 2 CFR Part 200, Appendix XI:
Activities allowed or unallowed and allowable cost principles – lack of documented, timely review and approval of expenditures for three of eight transactions selected for testing; specifically relating to payroll expenditures.
Suspension and Debarment – no established internal control policies to verify that vendors selected for use were not suspended or debarred from use for expenditures of federal awards.
Subrecipient monitoring – no established internal control policies surrounding monitoring of subrecipients for compliance with principles established under 2 CFR Part 200, Appendix XI.
The Foundation and its affiliates have not established internal control policies to ensure compliance with principles established under the Uniform Guidance.
Lack of internal controls could result in instances of noncompliance with federal grant requirements, which could lead to loss of future funding or requests for repayment of federal awards previously distributed by federal agencies.
Not applicable.
This is not a repeat finding.
The Foundation and its affiliates should establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the 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).
Management's response is reported in "Corrective Action Plan" at the end of this report.
Item 2023-004 – Performance Reporting
Significant Deficiency
Federal Program – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number – 21.027
Pass-through Grantor's Numbers – 2159FR0256, 2159FR0212
Federal Award Year – December 31, 2023
Federal Agency – U.S. Department of Treasury
Pass-Through Entity – Tulsa County/City of Tulsa
Tulsa County required both quarterly and annual performance reports to be submitted per the sub-recipient agreement for this federal grant. The City of Tulsa required monthly performance reports to be submitted per the sub-recipient agreements for this federal grant.
The Foundation had one affiliated entity who received federal funding through Tulsa County, however there were no formally established internal controls surrounding the accuracy of and timely submission for the required annual and quarterly reports.
The Foundation has two affiliated entities who received federal funding through sub-recipient agreements with the City of Tulsa. Neither affiliate could provide evidence that monthly reports were submitted to the City of Tulsa.
The Foundation's affiliates lacked formal review processes over performance reporting requirements to the pass-through agencies.
Lack of internal control policies could result in instances of noncompliance with federal standards. This could result in additional oversight of the awarding entities, or future lack of funding.
Not applicable.
This is not a repeat finding.
The Foundation's affiliates should appoint an individual to oversee all reporting requirements relating to federal awards received and establish a proper review process to ensure performance reports are accurate and filed timely.
Management's response is reported in "Corrective Action Plan" at the end of this report.
Item 2023-005 – Procurement
Significant Deficiency
Federal Program – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number – 21.027
Pass-through Grantor's Numbers – 2159FR0256, 2159FR0212
Federal Award Year – December 31, 2023
Federal Agency – U.S. Department of Treasury
Pass-Through Entity – Tulsa County/City of Tulsa
Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326, which stipulates that the organization must have a policy in place to comply with these standards.
The Foundation had no documented policies in place over procurement of goods or services with the use of federal awards. As such, evidence was not available to document that federal procurement standards were followed as transactions took place.
The Foundation and affiliates lacked a formally documented policy to prevent or detect inappropriate procurement from being entered into.
The Foundation may improperly award and/or pay more than what could have been obtained for comparable goods or services for the geographic area. If instances of non-compliance with federal procurement have occurred or occur in the future, it could result in loss of grant funds, additional federal oversight of federal funding, or repayment of overspent federal monies could be requested to be paid by the Foundation.
Not applicable.
This is not a repeat finding.
The Foundation should create a documented procurement policy that follows federal procurement policies and ensure that all affiliates establish and follow that policy. The Foundation and its affiliates should also establish formally documented controls to ensure that the procurement policies are being adhered.
Management's response is reported in "Corrective Action Plan" at the end of this report.