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Management agrees with the finding that payroll costs charged to HUD-funded programs were based on estimated allocations and did not consistently reflect actual time and effort in accordance with 2 CFR §200.430 (Compensation—Personal Services) and applicable HUD program requirements. Management ackn...
Management agrees with the finding that payroll costs charged to HUD-funded programs were based on estimated allocations and did not consistently reflect actual time and effort in accordance with 2 CFR §200.430 (Compensation—Personal Services) and applicable HUD program requirements. Management acknowledges the requirement that personnel costs charged to HUD awards (e.g., CDBG, HOME, CoC) must be supported by records that accurately reflect work performed on eligible program activities. Corrective Actions Implemented: The Organization has strengthened internal controls over payroll allocation for HUD-funded programs by implementing a formal monthly review and reconciliation process based on after-the-fact determinations of actual activity. Under this enhanced process: • Payroll costs charged to HUD awards are reviewed monthly and supported by documentation that reflects actual time and effort by eligible activity and funding source. • Payroll distribution reports are evaluated for accuracy, allowability, and alignment with HUD-eligible program activities. • Allocated payroll costs are compared to actual program delivery (e.g., beneficiary services, project activities, administrative vs. program caps, where applicable). • Timely cost adjustments are recorded, as necessary, to ensure payroll charges are properly aligned with work performed and eligible cost objectives. • All adjustments are documented, reviewed, and approved by appropriate supervisory and finance personnel. Expected Outcome: Management believes these corrective actions will ensure that payroll costs charged to HUD-funded programs are accurate, allowable, properly documented, and aligned with eligible program activities, and fully compliant with Uniform Guidance and HUD requirements. These enhancements will strengthen internal controls, improve reporting reliability (including IDIS/financial reporting where applicable), and reduce the risk of noncompliance in future monitoring or audit reviews.
Management has updated its policies and procedures to require a formal annual review and update of the cost allocation plan. This review will occur in conjunction with the finalization and Board approval of the organization’s annual operating budget, ensuring that the CAP aligns with the most curren...
Management has updated its policies and procedures to require a formal annual review and update of the cost allocation plan. This review will occur in conjunction with the finalization and Board approval of the organization’s annual operating budget, ensuring that the CAP aligns with the most current program structure, funding sources, and cost allocation methodologies. As part of this process, management will: • Evaluate the reasonableness and appropriateness of allocation methodologies; • Ensure consistency in application across all programs and funding streams; and • Document and approve any necessary revisions to the cost allocation plan prior to implementation. Management believes this corrective action will ensure that the CAP remains current, appropriately reflects organizational activities, and complies with applicable Federal requirements. Ongoing adherence to this process will strengthen internal controls over cost allocation and financial reporting.
Finding Number 2024-053 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) acknowledges subrecipient monitoring process lacked the strength and co...
Finding Number 2024-053 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) acknowledges subrecipient monitoring process lacked the strength and consistency to ensure subrecipients established and maintained effective internal control. OMES acknowledges that OMES did not implement the proper internal controls and oversight of the ERA Program during FY2024. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI in these findings. Beginning with FY2025, OMES has taken the following measures: • OMES disagrees that they had sufficient and timely notice to make full corrective actions prior to this FY2024 audit for the following reasons: the FY2021 State auditor & Inspector (SAI) audit was released four days prior to the beginning of FY2024, the FY2022 SAI audit was released near the end of FY2025, and the FY2023 audit was released in FY2026; therefore, OMES could not take corrective action prior to the FY2024 audit began. At the beginning of FY2025, OMES began corrective measures as noted in SAI’s Condition and Context in this finding. • OMES acknowledges OMES subrecipient monitoring process lacked the strength and consistency to ensure subrecipients established and maintained effective internal control. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI as noted in SAI’s Condition and Context in this finding. Beginning with FY2025, OMES has taken the following measures:  Oversight and management of the ERA program has been transferred to the OMES Grant Management Office (OMES-GMO) which has staff with several years of grant experience. OMES-GMO has recently hired additional staff, and the two staff members dedicated to the management of the ERA program have 20+ years of combined federal grant specific experience.  OMES ensured that the subrecipient agreement included all the required terms under the ERA Program and that the agreement does not expire, OMES-GMO and the Communities of Foundation of Oklahoma (CFO) executed an updated Subrecipient Grant Agreement Amendment that details the responsibilities of OMES to monitor CFO and the duties and processes that CFO must follow in regard to ERA Program, including detailed cash management policies.  OMES-GMO required the return of the remaining ERA2 Program funds from CFO to ensure proper oversight and review of ERA expenditures is performed.  OMES-GMO has in place a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. For example, OMES-GMO’s process for disbursing funds to a subrecipient requires a written request from the subrecipient with supporting documentation, then OMES-GMO assigns a staff lead and secondary grant analyst to perform a primary and secondary review for compliance and to require additional supporting documentation if needed to approve the request. Once those reviews are completed and approved by the OMES-GMO staff, the Director of the OMES-GMO must approve the request before it is sent to the OMES Finance Division, who will then verify the calculated amount(s) before completing the disbursement to the subrecipient. These internal controls and policies have been implemented for the management and oversight of the ERA Program and provide a multilayer review that will prevent fraud and risk factors applicable to the ERA program. Additionally, the OMES-GMO staff assigned to the ERA program have the training and knowledge to ensure compliance with the Federal grant requirements.  Depending on the level of risk, OMES-GMO conducts monthly, bi-weekly or weekly meetings with each subrecipient to monitor the progress of projects and address any issues or changes that might impact the project. For the ERA Program, OMESGMO conducted bi-weekly monitoring meetings with CFO and reviewed documentation provided by CFO to ensure all ERA projects were eligible under the ERA guidelines and that CFO exercised the proper oversight over their subrecipients and spending. Anticipated Completion Date Completed Responsible Contact Person Brandy Manek
Finding Number 2024-038 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) acknowledges subrecipient monitoring process lacked the strength and co...
Finding Number 2024-038 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) acknowledges subrecipient monitoring process lacked the strength and consistency to ensure subrecipients established and maintained effective internal control. OMES acknowledges that OMES did not implement the proper internal controls and oversight of the ERA Program during FY2024. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI in these findings. Beginning with FY2025, OMES has taken the following measures: • OMES disagrees that they had sufficient and timely notice to make full corrective actions prior to this FY2024 audit for the following reasons: the FY2021 State auditor & Inspector (SAI) audit was released four days prior to the beginning of FY2024, the FY2022 SAI audit was released near the end of FY2025, and the FY2023 audit was released in FY2026; therefore, OMES could not take corrective action prior to the FY2024 audit began. At the beginning of FY2025, OMES began corrective measures as noted in SAI’s Condition and Context in this finding. • OMES acknowledges OMES subrecipient monitoring process lacked the strength and consistency to ensure subrecipients established and maintained effective internal control. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI as noted in SAI’s Condition and Context in this finding. Beginning with FY2025, OMES has taken the following measures:  Oversight and management of the ERA program has been transferred to the OMES Grant Management Office (OMES-GMO) which has staff with several years of grant experience. OMES-GMO has recently hired additional staff, and the two staff members dedicated to the management of the ERA program have 20+ years of combined federal grant specific experience.  OMES ensured that the subrecipient agreement included all the required terms under the ERA Program and that the agreement does not expire, OMES-GMO and the Communities of Foundation of Oklahoma (CFO) executed an updated Subrecipient Grant Agreement Amendment that details the responsibilities of OMES to monitor CFO and the duties and processes that CFO must follow in regard to ERA Program, including detailed cash management policies.  OMES-GMO required the return of the remaining ERA2 Program funds from CFO to ensure proper oversight and review of ERA expenditures is performed.  OMES-GMO has in place a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. For example, OMES-GMO’s process for disbursing funds to a subrecipient requires a written request from the subrecipient with supporting documentation, then OMES-GMO assigns a staff lead and secondary grant analyst to perform a primary and secondary review for compliance and to require additional supporting documentation if needed to approve the request. Once those reviews are completed and approved by the OMES-GMO staff, the Director of the OMES-GMO must approve the request before it is sent to the OMES Finance Division, who will then verify the calculated amount(s) before completing the disbursement to the subrecipient. These internal controls and policies have been implemented for the management and oversight of the ERA Program and provide a multilayer review that will prevent fraud and risk factors applicable to the ERA program. Additionally, the OMES-GMO staff assigned to the ERA program have the training and knowledge to ensure compliance with the Federal grant requirements.  Depending on the level of risk, OMES-GMO conducts monthly, bi-weekly or weekly meetings with each subrecipient to monitor the progress of projects and address any issues or changes that might impact the project. For the ERA Program, OMESGMO conducted bi-weekly monitoring meetings with CFO and reviewed documentation provided by CFO to ensure all ERA projects were eligible under the ERA guidelines and that CFO exercised the proper oversight over their subrecipients and spending. Anticipated Completion Date Completed Responsible Contact Person Brandy Manek
Finding Number 2024-024 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) acknowledges subrecipient monitoring process lacked the strength and co...
Finding Number 2024-024 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) acknowledges subrecipient monitoring process lacked the strength and consistency to ensure subrecipients established and maintained effective internal control. OMES acknowledges that OMES did not implement the proper internal controls and oversight of the ERA Program during FY2024. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI in these findings. Beginning with FY2025, OMES has taken the following measures: • OMES disagrees that they had sufficient and timely notice to make full corrective actions prior to this FY2024 audit for the following reasons: the FY2021 State auditor & Inspector (SAI) audit was released four days prior to the beginning of FY2024, the FY2022 SAI audit was released near the end of FY2025, and the FY2023 audit was released in FY2026; therefore, OMES could not take corrective action prior to the FY2024 audit began. At the beginning of FY2025, OMES began corrective measures as noted in SAI’s Condition and Context in this finding. • OMES acknowledges OMES subrecipient monitoring process lacked the strength and consistency to ensure subrecipients established and maintained effective internal control. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI as noted in SAI’s Condition and Context in this finding. Beginning with FY2025, OMES has taken the following measures:  Oversight and management of the ERA program has been transferred to the OMES Grant Management Office (OMES-GMO) which has staff with several years of grant experience. OMES-GMO has recently hired additional staff, and the two staff members dedicated to the management of the ERA program have 20+ years of combined federal grant specific experience.  OMES ensured that the subrecipient agreement included all the required terms under the ERA Program and that the agreement does not expire, OMES-GMO and the Communities of Foundation of Oklahoma (CFO) executed an updated Subrecipient Grant Agreement Amendment that details the responsibilities of OMES to monitor CFO and the duties and processes that CFO must follow in regard to ERA Program, including detailed cash management policies.  OMES-GMO required the return of the remaining ERA2 Program funds from CFO to ensure proper oversight and review of ERA expenditures is performed.  OMES-GMO has in place a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. For example, OMES-GMO’s process for disbursing funds to a subrecipient requires a written request from the subrecipient with supporting documentation, then OMES-GMO assigns a staff lead and secondary grant analyst to perform a primary and secondary review for compliance and to require additional supporting documentation if needed to approve the request. Once those reviews are completed and approved by the OMES-GMO staff, the Director of the OMES-GMO must approve the request before it is sent to the OMES Finance Division, who will then verify the calculated amount(s) before completing the disbursement to the subrecipient. These internal controls and policies have been implemented for the management and oversight of the ERA Program and provide a multilayer review that will prevent fraud and risk factors applicable to the ERA program. Additionally, the OMES-GMO staff assigned to the ERA program have the training and knowledge to ensure compliance with the Federal grant requirements.  Depending on the level of risk, OMES-GMO conducts monthly, bi-weekly or weekly meetings with each subrecipient to monitor the progress of projects and address any issues or changes that might impact the project. For the ERA Program, OMESGMO conducted bi-weekly monitoring meetings with CFO and reviewed documentation provided by CFO to ensure all ERA projects were eligible under the ERA guidelines and that CFO exercised the proper oversight over their subrecipients and spending. Anticipated Completion Date Completed Responsible Contact Person Brandy Manek
Finding Number 2024-014 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) partially concurs with these findings. • OMES disagrees that they had s...
Finding Number 2024-014 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) partially concurs with these findings. • OMES disagrees that they had sufficient and timely notice to make full corrective actions prior to this FY2024 audit for the following reasons: the FY2021 State auditor & Inspector (SAI) audit was released four days prior to the beginning of FY2024, the FY2022 SAI audit was released near the end of FY2025, and the FY2023 audit was released in FY2026; therefore, OMES could not take corrective action prior to the FY2024 audit began. At the beginning of FY2025, OMES began corrective measures as noted in SAI’s Condition and Context in this finding. • OMES acknowledges OMES subrecipient monitoring process lacked the strength and consistency to ensure subrecipients established and maintained effective internal control. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI as noted in SAI’s Condition and Context in this finding. Beginning with FY2025, OMES has taken the following measures:  Oversight and management of the ERA program has been transferred to the OMES Grant Management Office (OMES-GMO) which has staff with several years of grant experience. OMES-GMO has recently hired additional staff, and the two staff members dedicated to the management of the ERA program have 20+ years of combined federal grant specific experience.  OMES ensured that the subrecipient agreement included all the required terms under the ERA Program and that the agreement does not expire, OMES-GMO and the Communities of Foundation of Oklahoma (CFO) executed an updated Subrecipient Grant Agreement Amendment that details the responsibilities of OMES to monitor CFO and the duties and processes that CFO must follow in regard to ERA Program, including detailed cash management policies.  OMES-GMO required the return of the remaining ERA2 Program funds from CFO to ensure proper oversight and review of ERA expenditures is performed.  OMES-GMO has in place a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. For example, OMES-GMO’s process for disbursing funds to a subrecipient requires a written request from the subrecipient with supporting documentation, then OMES-GMO assigns a staff lead and secondary grant analyst to perform a primary and secondary review for compliance and to require additional supporting documentation if needed to approve the request. Once those reviews are completed and approved by the OMES-GMO staff, the Director of the OMES-GMO must approve the request before it is sent to the OMES Finance Division, who will then verify the calculated amount(s) before completing the disbursement to the subrecipient. These internal controls and policies have been implemented for the management and oversight of the ERA Program and provide a multilayer review that will prevent fraud and risk factors applicable to the ERA program. Additionally, the OMES-GMO staff assigned to the ERA program have the training and knowledge to ensure compliance with the Federal grant requirements.  Depending on the level of risk, OMES-GMO conducts monthly, bi-weekly or weekly meetings with each subrecipient to monitor the progress of projects and address any issues or changes that might impact the project. For the ERA Program, OMESGMO conducted bi-weekly monitoring meetings with CFO and reviewed documentation provided by CFO to ensure all ERA projects were eligible under the ERA guidelines and that CFO exercised the proper oversight over their subrecipients and spending. Anticipated Completion Date Completed Responsible Contact Person Brandy Manek
Finding Number 2024-098 Subject Heading (Financial) or AL no. and program name (Federal) 97.036 – Disaster Grants – Public Assistance Planned Corrective Action Management has discussed this issue with ABS, and ABS is aware of the agency's expectation that all required Pathfinder correction entries, ...
Finding Number 2024-098 Subject Heading (Financial) or AL no. and program name (Federal) 97.036 – Disaster Grants – Public Assistance Planned Corrective Action Management has discussed this issue with ABS, and ABS is aware of the agency's expectation that all required Pathfinder correction entries, including both regular and supplemental payroll transactions, be processed as part of the correction process. Going forward, the agency will coordinate with ABS and perform periodic verification that both regular and supplemental payroll corrections have been included. The agency will also work with ABS to address any identified omissions to help ensure that only allowable employer retirement contributions are charged to federal awards. Anticipated Completion Date 1/31/2027 Responsible Contact Person Brianna Thomas
Finding Number 2024-005 Subject Heading (Financial) or AL no. and program name (Federal) 93.767 Children’s Health Insurance Program 93.778 Medicaid Cluster Planned Corrective Action OKDHS Response: We are using Azure DevOps to track the work related to the findings for the mentioned issues. The work...
Finding Number 2024-005 Subject Heading (Financial) or AL no. and program name (Federal) 93.767 Children’s Health Insurance Program 93.778 Medicaid Cluster Planned Corrective Action OKDHS Response: We are using Azure DevOps to track the work related to the findings for the mentioned issues. The work is being completed under User Story 455612 - PS2 | AFS | Notices | Update Medical Notices Language for CMS Audit Finding Corrective Action (2024-005). To ensure all required notice language updates are implemented accurately and consistently, OKDHS is currently utilizing an Azure DevOps tracking tool to conduct a thorough discovery and analysis of all aspects of this issue. Our primary focus is identifying every notice and process that may be impacted by this change. OHCA Response: Additional post-CAP audits will be conducted by Member Audits upon notification from OHS all corrective measures have been implemented, should occur after August 1, 2026. Anticipated Completion Date August 1, 2026 Responsible Contact Person Chris Dees, Eligibility and Coverage Services Technical Director; April Anonsen, Deputy State Medicaid Director; Aubrey McDonald, OKDHS Medicaid Program Administrator; Tana Parrott, OHCA Director of Member Audits; Kristin Edwards OHCA Senior Director of Program & Accountability
Finding Number 2024-010 Subject Heading (Financial) or AL no. and program name (Federal) 93.767 Children’s Health Insurance Program Planned Corrective Action OHCA remains committed to using established control processes and procedures to ensure medical claims are managed accurately and efficiently. ...
Finding Number 2024-010 Subject Heading (Financial) or AL no. and program name (Federal) 93.767 Children’s Health Insurance Program Planned Corrective Action OHCA remains committed to using established control processes and procedures to ensure medical claims are managed accurately and efficiently. Processes such as Provider Training, annual Payment Accuracy Measurement (PAM) project, medical reviews, data analytic processes, external CMS-UPIC CE and FFS audits, prior authorizations, system edits, continuously updating OHCA’s system with National Correct Coding Initiative (NCCI), and on a 3-year cycle the Federal Payment Error Rate Measurement (PERM) project. Anticipate the question costs of $1,996 will be reported in full by end of SFY2026 Q4 Below addresses each identified challenge from above and potential remedies to assist in mitigation in the future: One claim was unsupported by medical records. To address the finding associated with the claim containing unsupported medical records, the agency will return the federal share for SFY 2026, Quarter 4 associated with PI case number 2026E00013. The agency elected not to issue an error letter to the provider at this time because the provider is currently undergoing other reviews, and we do not want to jeopardize those processes. This type of error continues to be monitored by the PI team through PAM reviews and clinical provider audit reviews. When findings occur, those reviews will issue error letters, which also serve as provider education. One claim was for an evaluation that lacked supporting documentation for the start/stop time. Policy: OAC 317:30-3-15-units based on time – The finding related to one claim involved an evaluation that lacked supporting documentation for the start and stop time. A provider education letter addressing this issue was sent on 5/19/2026 under PI case number 2026E00014. The case will be forwarded to Finance and included in the quarterly reporting once all provider deadlines related to appeal rights have passed. The provider education letter informed the provider of the error—specifically, the absence of documented beginning and end times in the medical record. This type of error continues to be monitored by the PI team through PAM reviews and clinical provider audit reviews. When findings occur, those reviews will issue error letters, which also serve as provider education. One claim was for services performed by a provider not contracted as a Medicaid provider. To address the finding associated with the claim containing unsupported medical records, the agency will return the federal share for SFY 2026, Quarter 4 associated with PI case number 2026E00013. The agency elected not to issue an error letter to the provider at this time because the provider is currently undergoing other reviews, and we do not want to jeopardize those processes. This type of error continues to be monitored by the PI team through PAM reviews and clinical provider audit reviews. When findings occur, those reviews will issue error letters, which also serve as provider education. One claim had a payment error totaling $1,100, of which $850 ($1,100 x the applicable Federal Medical Assistance Percentage (FMAP) rate (77.27% for QE 6/30/24) is the federal questioned costs. To address the finding associated with the Single Contract Agreement (SCA) expenditure: Finance was notified and corrected the expenditure on 7/21/2025 for one day totaling $1,100 and is in PI case number 2026E00015. Two claims had documentation errors. One claim had a progress note in the medical records that was not signed by the rendering provider. The second was a DRG claim that billed for a beginning date of service that was prior to the doctor’s admission order. None of these claims resulted in an underpayment or overpayment. & One claim had a documentation error. The dates of service were entered incorrectly, resulting in 16 days instead of the correct 15 days. This claim did not result in an underpayment or overpayment. These types of deficiencies continue to be monitored by the PI team through PAM reviews and clinical provider audit reviews. Anticipated Completion Date September 30, 2026 Responsible Contact Person Kristin Edwards, OHCA Senior Director of Program Integrity and Accountability, James Keethler, OHCA Director Data Analytics & Payment Accuracy
Finding Number 2024-078 Subject Heading (Financial) or AL no. and program name (Federal) 93.658 – Foster Care Planned Corrective Action OKDHS concurs that documentation supporting the preparation, review, and reconciliation of the CB-496 report should be strengthened. OKDHS has previously directed t...
Finding Number 2024-078 Subject Heading (Financial) or AL no. and program name (Federal) 93.658 – Foster Care Planned Corrective Action OKDHS concurs that documentation supporting the preparation, review, and reconciliation of the CB-496 report should be strengthened. OKDHS has previously directed the CARE team to improve documentation of adjustments and corrections made during the financial reporting process so that changes are clearly supported and can be independently reviewed. OKDHS is currently working through its broader financial reporting and reconciliation processes to improve consistency in the preparation, documentation, review, and retention of supporting records. This work includes strengthening the documentation of adjustments and corrections and ensuring that differences between financial reports and underlying accounting or cost allocation records are clearly identified, explained, and supported. OKDHS will continue developing and implementing standardized procedures for the preparation and review of federal financial reports. The updated process will include clearer documentation requirements for adjustments and corrections, reconciliation of reported amounts to supporting financial records, and evidence of independent review prior to submission. Anticipated Completion Date 9/30/2026 Responsible Contact Person Kayla Urtz
Finding Number 2024-067 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action OKDHS agrees that additional review procedures would have strengthened controls over the Workforce Support Grant payment approval process and may have prevented th...
Finding Number 2024-067 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action OKDHS agrees that additional review procedures would have strengthened controls over the Workforce Support Grant payment approval process and may have prevented the issuance of payments to individuals who did not meet all eligibility requirements at the time of application. The agency concurs that two Workforce Support Grant payments were issued to individuals whose employment termination dates preceded the application date. As a result, the individuals did not meet the program eligibility requirements for receipt of the workforce bonus payment. Upon identification of the issue, OKDHS reviewed the circumstances surrounding the payments and initiated appropriate corrective actions. The agency has evaluated the affected payments and will pursue recovery of funds as appropriate. OKDHS has reviewed the eligibility verification process associated with Workforce Support Grant payments and has implemented additional procedures designed to strengthen verification of employment status prior to payment approval. These procedures include enhanced review of available employment records and validation of eligibility information submitted as part of the application process. Additionally, OKDHS will continue recovery efforts related to identified ineligible payments and will monitor compliance with updated review procedures to reduce the likelihood of similar errors occurring in future provider assistance initiatives. Anticipated Completion Date N/A Responsible Contact Person Kayla Urtz
Finding Number 2024-037 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action The Oklahoma Department of Human Services (OKDHS) respectfully disagrees with this finding because the questioned costs are based on application of standard Child ...
Finding Number 2024-037 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action The Oklahoma Department of Human Services (OKDHS) respectfully disagrees with this finding because the questioned costs are based on application of standard Child Care payment requirements rather than the temporary COVID-19 payment flexibilities that governed the program during the audit period. Oklahoma's temporary Child Care payment flexibilities were incorporated into the Oklahoma Child Care and Development Fund (CCDF) State Plan Amendments and approved by the Administration for Children and Families (ACF). Those approved provisions constituted the governing payment requirements during the public health emergency and represent the appropriate criteria against which these transactions should be evaluated. The finding acknowledges that Oklahoma's temporary COVID-19 payment flexibilities included reimbursement of part-time school-age care at the full-time reimbursement rate and that these temporary policies were incorporated into the federally approved State Plan Amendments. These temporary payment methodologies were intentionally established to stabilize child care providers during the COVID-19 public health emergency. However, despite acknowledging the existence of these federally approved flexibilities, the questioned costs are derived by applying standard program requirements rather than the temporary payment framework approved by ACF and in effect during the audit period. Accordingly, the Agency believes the transactions should be evaluated using the federally approved emergency payment requirements rather than the standard reimbursement methodology that had been temporarily modified. The Agency further notes that the costs questioned are not based on payments for services provided during the regular school day, but rather on the auditors' interpretation of how the temporary COVID-19 payment flexibilities should have been applied. Likewise, the audit does not identify deficiencies in provider eligibility determinations, approved reimbursement rates, payment calculations, or the Agency's authority to implement the temporary payment flexibilities approved by ACF. Instead, the disagreement centers on the interpretation of the temporary payment rules that governed the program during the emergency period. OKDHS recognizes that the audit identified an opportunity to strengthen detective controls over attendance patterns and absent-day payments. The Agency has continued to enhance provider guidance, supervisory review, and analytical monitoring to better identify potential payment anomalies and improve consistency in the administration of payment policies. Because the questioned costs result from application of audit criteria that do not reflect the federally approved payment framework governing the audit period, OKDHS respectfully disagrees with the condition, cause, effect, recommendation, and questioned costs identified in this finding. Although the Agency disagrees with the audit's conclusions, Child Care Services has continued to review and clarify payment guidance, reinforce policy training, and strengthen oversight procedures to support consistent administration of both temporary and permanent payment policies. This will be implemented with the upcoming child care billing system. Anticipated Completion Date In Progress Responsible Contact Person Kayla Urtz
Finding Number 2024-033 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action The Agency agrees that additional oversight activities could have provided greater visibility into provider use of Stabilization Payments and has incorporated less...
Finding Number 2024-033 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action The Agency agrees that additional oversight activities could have provided greater visibility into provider use of Stabilization Payments and has incorporated lessons learned into subsequent provider assistance initiatives through enhanced monitoring, documentation expectations, and recovery procedures for confirmed noncompliance. However, OKDHS respectfully disagrees with several conclusions contained within the finding, including the characterization of questioned costs and the extrapolation of provider-specific exceptions across the broader population of Stabilization Payment recipients. The Child Care Stabilization Payment Program was established under the American Rescue Plan Act to provide emergency financial assistance intended to stabilize the child care industry during the COVID-19 public health emergency. Stabilization Payments were awarded using an approved payment methodology based upon provider eligibility, licensed capacity, and applicable STAR level. As previously communicated to the Administration for Children and Families (ACF), OKDHS does not concur with the assertion that the monitoring activities identified by SAI were required under the Stabilization Payment Program. The applicable Notice of Award specifically excluded significant portions of the traditional federal post-award administrative requirements, including most post-award requirements and the federal cost principles. Accordingly, OKDHS does not believe the Stabilization Payment Program should be evaluated using the same oversight framework applicable to traditional reimbursement or discretionary grant programs. Providers receiving Stabilization Payments were required to certify that funds would be used only for allowable purposes established by the American Rescue Plan Act and applicable program guidance and were responsible for maintaining supporting documentation for those expenditures. When information indicating potential misuse of funds is identified, OKDHS reviews the circumstances and pursues recovery actions as appropriate. While documentation obtained from providers may assist in evaluating provider compliance, the absence of documentation during the audit does not, by itself, establish that Stabilization Payments were improperly awarded or expended for unallowable purposes. OKDHS also respectfully disagrees with the treatment of unsupported expenditures as equivalent to known unallowable expenditures. Unsupported expenditures reflect circumstances in which documentation was unavailable for audit review and do not establish that funds were expended for unallowable purposes. As a result, the Agency believes the questioned costs materially overstate actual federal exposure. Finally, OKDHS does not concur that provider-specific exceptions may be extrapolated across the broader provider population. The exceptions identified by SAI reflect individual provider documentation and spending practices rather than a common agency-level eligibility, payment methodology, or processing error. Accordingly, the Agency does not believe the audit evidence supports extrapolating these exceptions to estimate program-wide questioned costs. Although the Stabilization Payment Program has concluded, OKDHS has strengthened oversight of subsequent provider assistance initiatives by enhancing monitoring procedures, documentation expectations, and recovery processes for confirmed provider noncompliance. The Agency will continue reviewing cases identified through audit activities and pursue recovery of confirmed unallowable expenditures in accordance with applicable federal requirements. Anticipated Completion Date N/A Responsible Contact Person Kayla Urtz
Finding Number 2024-032 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action The Oklahoma Department of Human Services (OKDHS) partially concurs with this finding. The Agency agrees opportunities existed to strengthen oversight of Child Car...
Finding Number 2024-032 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action The Oklahoma Department of Human Services (OKDHS) partially concurs with this finding. The Agency agrees opportunities existed to strengthen oversight of Child Care provider monitoring activities and has implemented corrective actions to enhance monitoring procedures, documentation, supervisory oversight, Quality Rating and Improvement System (QRIS) verification, and monitoring during non-traditional operating hours. Child Care Services has resumed full QRIS monitoring, implemented precertification visits, enhanced monitoring documentation, strengthened supervisory review, expanded staff training, and continues to refer suspected fraud or misuse of program funds to the Office of Inspector General for investigation. The Agency also recognizes the analytical techniques utilized during the audit as a valuable opportunity to strengthen its detective control environment. OKDHS is evaluating implementation of similar data analytics as part of its routine monitoring activities to better identify providers that warrant additional review. These analytics will enhance oversight by directing monitoring resources toward higher-risk providers while complementing existing licensing and investigative processes. This will become possible to implement shortly with the implementation of the new childcare invoicing system. However, the Agency respectfully disagrees with the questioned costs. The finding identifies a weakness in one component of the Agency's oversight framework but does not demonstrate that the underlying provider payments failed to satisfy applicable federal or state reimbursement requirements. Licensing monitoring is intended to evaluate compliance with health and safety requirements, while payment allowability is supported through separate controls, including child eligibility determinations, authorized rate assignments, electronic attendance records, and automated payment system edits. The audit did not identify deficiencies in these payment controls or demonstrate that providers receiving the questioned payments failed to meet the requirements governing reimbursement. The Agency also respectfully disagrees with the report's characterization of the non-traditional hours payment methodology. Non-traditional hours enhancements are payable only when established eligibility, attendance, and reimbursement requirements have been satisfied in accordance with the approved Child Care Provider Rate Schedule. Accordingly, the Agency does not believe the hypothetical examples contained in the finding accurately reflect how non-traditional hours payments are authorized or processed. While the Agency agrees that strengthening monitoring activities and expanding analytical oversight will further reduce program risk, the presence of analytical risk indicators or the absence of a monitoring visit during nontraditional hours does not, by itself, establish that otherwise supported expenditures are unsupported or unallowable. The Agency believes the audit appropriately identified opportunities to strengthen preventive and detective controls but does not believe the evidence demonstrates that the questioned costs represent improper expenditures. Anticipated Completion Date In Progress Responsible Contact Person Kayla Urtz
Finding Number 2024-031 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action OKDHS agrees that certain administrative errors identified through program reviews and audit activities, including confirmed payment calculation errors, eligibilit...
Finding Number 2024-031 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action OKDHS agrees that certain administrative errors identified through program reviews and audit activities, including confirmed payment calculation errors, eligibility determination issues, attendance verification deficiencies, and provider noncompliance, require corrective action. The Agency has initiated reviews and recovery efforts for confirmed overpayments and instances of provider noncompliance and continues to strengthen monitoring, award calculations, documentation requirements, and recovery procedures for provider assistance programs. However, OKDHS respectfully disagrees with several conclusions contained within this finding, including the characterization of questioned costs, the treatment of unsupported expenditures as unallowable expenditures, the attribution of provider actions directly to the Agency, the extrapolation methodology, and conclusions regarding the overall design and effectiveness of the Desert Grant Program. The Desert Grant Program was developed using emergency American Rescue Plan Act (ARPA) funding to rapidly increase child care capacity in underserved areas of Oklahoma within federally established obligation and liquidation deadlines. As previously communicated to the Administration for Children and Families (ACF), the applicable Notice of Award expressly excluded substantial portions of the traditional federal grant administration requirements, including most pre-award requirements, most post-award requirements, and the federal cost principles. Accordingly, OKDHS does not concur that the program should be evaluated using the same framework applicable to traditional federal grant programs or that retrospective disagreement with the program's design, funding methodology, or implementation strategy constitutes evidence of noncompliance. The Agency further does not concur with the treatment of unsupported expenditures as equivalent to unallowable expenditures. Providers receiving Desert Grant funding certified that grant funds would be used only for allowable purposes, agreed to maintain supporting documentation, and acknowledged their obligation to repay funds if they failed to comply with program requirements. While the absence of documentation during audit testing may warrant additional review, it does not independently establish that funds were expended for unallowable purposes. Likewise, the closure of a provider or other post-award business outcomes do not, by themselves, establish misuse of grant funds or Agency noncompliance. The Agency continues to evaluate these cases individually and pursue recovery when the facts demonstrate noncompliance with the terms of the award. OKDHS also respectfully disagrees with conclusions regarding the overall effectiveness or sustainability of the Desert Grant Program. The audit contains numerous observations regarding alternative funding methodologies, incremental payment structures, business planning considerations, sustainability assumptions, and other program design decisions. While these observations may identify opportunities for future program improvement, they represent differences in program design philosophy rather than evidence that the Agency failed to administer the federal award in accordance with applicable requirements. The Agency does not believe retrospective assessments regarding how the program could have been structured differently constitute a basis for questioned costs. Finally, OKDHS does not concur with the extrapolation methodology reflected in this finding. The questioned costs combine fundamentally different exception types, including confirmed administrative errors, unsupported expenditures, provider documentation deficiencies, provider closures, provider spending decisions, and observations regarding program design. These categories arise from different causes, involve different responsibilities, and require different corrective actions. Accordingly, OKDHS does not believe combining these distinct exception types into a single projected questioned cost accurately reflects actual noncompliance or federal exposure associated with the program. Although the Agency respectfully disagrees with significant portions of the finding, OKDHS has strengthened oversight of provider assistance initiatives by enhancing award calculations, documentation expectations, provider certifications, monitoring activities, analytical review procedures, and recovery processes. The Agency will continue reviewing Desert Grant awards, recovering confirmed overpayments and unallowable expenditures where appropriate, and incorporating lessons learned into future program implementation. Anticipated Completion Date On Going Responsible Contact Person Kayla Urtz
Finding Number 2024-066 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 – TANF Planned Corrective Action OKDHS agrees that controls related to the timely completion and documentation of T ANF eligibility redeterminations can be strengthened. During the period reviewed, eligib...
Finding Number 2024-066 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 – TANF Planned Corrective Action OKDHS agrees that controls related to the timely completion and documentation of T ANF eligibility redeterminations can be strengthened. During the period reviewed, eligibility operations were impacted by the Public Health Emergency (PHE) and associated continuous coverage requirements. As the agency worked through the post-PHE unwinding process, efforts were focused on reviewing and updating affected cases. During this period, some staff incorrectly believed T ANF reviews were subject to the same review flexibilities that applied to medical programs, resulting in untimely completion of certain TANF eligibility redeterminations. To strengthen controls, OKDHS has implemented the Current system, which automatically assigns cases requiring review and provides enhanced workload management and monitoring capabilities. Current includes tracking and reporting functionality that identifies untimely reviews, places overdue items on management reports, and alerts staff and supervisors when action is needed. In addition, supervisory staff conduct monitoring activities, including spot checks and review of workload reports, to ensure eligibility reviews are completed and documented within required timeframes. OKDHS believes these system enhancements and monitoring activities strengthen oversight of T ANF eligibility redeterminations and provide greater assurance that reviews are completed timely and appropriately documented. Anticipated Completion Date In progress Responsible Contact Person Kayla Urtz
Finding Number 2024-064 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 – TANF Planned Corrective Action OKDHS concurs and will ensure that staff are refreshed on the importance of including all verifications in the case file at certification. Anticipated Completion Date N/A ...
Finding Number 2024-064 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 – TANF Planned Corrective Action OKDHS concurs and will ensure that staff are refreshed on the importance of including all verifications in the case file at certification. Anticipated Completion Date N/A Responsible Contact Person Kayla Urtz
Finding Number 2024-063 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 – TANF Planned Corrective Action OKDHS agrees that controls related to the timely completion and documentation of TANF eligibility redeterminations can be strengthened. During the period reviewed, eligibi...
Finding Number 2024-063 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 – TANF Planned Corrective Action OKDHS agrees that controls related to the timely completion and documentation of TANF eligibility redeterminations can be strengthened. During the period reviewed, eligibility operations were impacted by the Public Health Emergency (PHE) and associated continuous coverage requirements. As the agency worked through the post-PHE unwinding process, efforts were focused on reviewing and updating affected cases. During this period, some staff incorrectly believed TANF reviews were subject to the same review flexibilities that applied to medical programs, resulting in untimely completion of certain TANF eligibility redeterminations. To strengthen controls, OKDHS has implemented the Current system, which automatically assigns cases requiring review and provides enhanced workload management and monitoring capabilities. Current includes tracking and reporting functionality that identifies untimely reviews, places overdue items on management reports, and alerts staff and supervisors when action is needed. In addition, supervisory staff conduct monitoring activities, including spot checks and review of workload reports, to ensure eligibility reviews are completed and documented within required timeframes. OKDHS believes these system enhancements and monitoring activities strengthen oversight of T ANF eligibility redeterminations and provide greater assurance that reviews are completed timely and appropriately documented. Anticipated Completion Date In progress Responsible Contact Person Kayla Urtz
Finding Number 2024-058 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 – TANF Planned Corrective Action OKDHS agrees that controls supporting the compilation and validation of the Child Welfare Services (CWS) population used in the TANF allocation methodology can be strength...
Finding Number 2024-058 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 – TANF Planned Corrective Action OKDHS agrees that controls supporting the compilation and validation of the Child Welfare Services (CWS) population used in the TANF allocation methodology can be strengthened. OKDHS will enhance procedures used to compile and validate the population included in the Child Welfare Services TANF allocation methodology. Management will implement additional review procedures to verify that participants included in the allocation methodology meet the applicable eligibility criteria established by the Oklahoma TANF State Plan and that supporting documentation is available to substantiate eligibility. The agency will also formalize review procedures for the preparation and approval of the allocation calculation, including validation of source data used to determine the applicable percentage applied to Child Welfare Services contract expenditures. These procedures will include management review of supporting documentation and reconciliation of the underlying population prior to completion of the allocation methodology. These enhancements are intended to strengthen internal controls over the allocation process, improve the reliability of the supporting data, and provide greater assurance that expenditures charged to the TANF program are based on an accurately supported eligible population. Anticipated Completion Date In Progress Responsible Contact Person Kayla Urtz
Finding Number 2024-111 Subject Heading (Financial) or AL no. and program name (Federal) 93.323: Epidemiology and Laboratory Capacity for Infectious Diseases Planned Corrective Action Management agrees with this finding. To mitigate this issue going forward, the established network drive for FFR sup...
Finding Number 2024-111 Subject Heading (Financial) or AL no. and program name (Federal) 93.323: Epidemiology and Laboratory Capacity for Infectious Diseases Planned Corrective Action Management agrees with this finding. To mitigate this issue going forward, the established network drive for FFR supporting documentation retention will now be reviewed at closeout of each FFR to ensure all detailed schedules are centrally retained and accessible prior to certification. Anticipated Completion Date 6/30/2026 Responsible Contact Person Kimberly Courtney, Director of Accounting
Finding Number 2024-109 Subject Heading (Financial) or AL no. and program name (Federal) 93.323: Epidemiology and Laboratory Capacity for Infectious Diseases Planned Corrective Action OSDH management agrees with this finding and will work with OMES to ensure Workday payroll expenditures are accurate...
Finding Number 2024-109 Subject Heading (Financial) or AL no. and program name (Federal) 93.323: Epidemiology and Laboratory Capacity for Infectious Diseases Planned Corrective Action OSDH management agrees with this finding and will work with OMES to ensure Workday payroll expenditures are accurately reflected in PeopleSoft’s general ledger based on actual project time worked rather than budgeted position setup allocations. We are actively exploring reconciliation steps within PeopleSoft to accurately record project time worked in accordance with approved timecards to the appropriate funding within the general ledger. Anticipated Completion Date 06/30/27 Responsible Contact Person Ryon Fields, Interim CFO
Finding Number 2024-108 Subject Heading (Financial) or AL no. and program name (Federal) 93.268: Immunizations Cooperative Agreements Planned Corrective Action OSDH management agrees with this finding and will work with OMES to ensure Workday payroll expenditures are accurately reflected in PeopleSo...
Finding Number 2024-108 Subject Heading (Financial) or AL no. and program name (Federal) 93.268: Immunizations Cooperative Agreements Planned Corrective Action OSDH management agrees with this finding and will work with OMES to ensure Workday payroll expenditures are accurately reflected in PeopleSoft’s general ledger based on actual project time worked rather than budgeted position setup allocations. We are actively exploring reconciliation steps within PeopleSoft to accurately record project time worked in accordance with approved timecards to the appropriate funding within the general ledger. Anticipated Completion Date 06/30/27 Responsible Contact Person Ryon Fields, Interim CFO
Finding Number 2024-028 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.010 TITLE I, PART A – GRANTS TO LOCAL EDUCATIONAL AGENCIES AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; 84.425U) Planned Corrective Action Since January 2025, the Office of Title Services...
Finding Number 2024-028 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.010 TITLE I, PART A – GRANTS TO LOCAL EDUCATIONAL AGENCIES AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; 84.425U) Planned Corrective Action Since January 2025, the Office of Title Services (OTS) has maintained time and effort records per internal guidelines. OSDE is drafting policies to ensure all employees meet the requirements of 2 CFR §200.430. After implementation, OTS will train staff on these procedures. Anticipated Completion Date Jan-2025 Responsible Contact Person Tammy Smith
Finding Number 2024-016 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; #84.425U) Planned Corrective Action The agency acknowledges that certain ESSER II and ARP ESSER III claims were approved without adequate review of s...
Finding Number 2024-016 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; #84.425U) Planned Corrective Action The agency acknowledges that certain ESSER II and ARP ESSER III claims were approved without adequate review of supporting documentation by authorized claims reviewers. To address this finding, the agency has strengthened its claims review procedures and internal controls related to reimbursement processing. Additional training will be provided for all claims reviewers regarding: • allowable use of funds requirements, • supporting documentation standards, • verification of invoice documentation, • program coding requirements, and • review and approval expectations for federal claims. The agency will also implement enhanced supervisory review and monitoring procedures to help ensure claims are consistently reviewed in accordance with federal requirements prior to approval. The agency acknowledges that allocation notices were not consistently generated and provided to certain LEAs in accordance with the requirements of 2 CFR § 200.332(a)(1). Additionally, one allocation notice did not contain all required elements, including the Federal Award Identification Number (FAIN) and Federal award date. Although the audit confirmed that allocation amounts and approved budgets within the grants management system were accurate, the agency recognizes the need to strengthen procedures related to issuance and documentation of subrecipient award notifications. To address this finding, the agency will revise and strengthen internal procedures to ensure all required allocation notices are generated, maintained, and distributed timely and consistently to subrecipients. The agency will also coordinate with our third party vendor to implement additional quality control measures and staff training to ensure all required federal award information, including the FAIN and Federal award date, is included in future allocation notices in accordance with 2 CFR § 200.332 requirements. Anticipated Completion Date Sept-26 Responsible Contact Person Tammy Smith
Finding Number 2024-015 Subject Heading (Financial) or AL no. and program name (Federal) AL #10.558 CHILD AND ADULT CARE FOOD PROGRAM (CACFP) AL #84.010 TITLE I, PART A – GRANTS TO LOCAL EDUCATIONAL AGENCIES AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.4 25U) Planned Corrective Action The...
Finding Number 2024-015 Subject Heading (Financial) or AL no. and program name (Federal) AL #10.558 CHILD AND ADULT CARE FOOD PROGRAM (CACFP) AL #84.010 TITLE I, PART A – GRANTS TO LOCAL EDUCATIONAL AGENCIES AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.4 25U) Planned Corrective Action The LEA did not upload sufficient supporting documentation to substantiate the amount claimed. Additionally, the reviewer did not conduct an adequate review of the supporting documentation submitted with the claim. To address this finding, the agency will provide additional training to reviewers on claim review procedures, required supporting documentation, and documentation verification standards. The agency will also strengthen internal review procedures to help ensure claims are properly supported and consistently reviewed prior to approval. Anticipated Completion Date Jul-26 Responsible Contact Person Tammy Smith
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