Corrective Action Plans

Finding Number 2023-003 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action OHCA will continue to utilize control processes and procedures to ensure medical claims are meeting program requirements. These processes include prior authorizations, suspended claim reviews, system edits, post payment reviews, and our payment accuracy measurement study. OHCA will also continue National Correct Coding Initiative (NCCI) edit updates, as well as continue with provider training to better educate our providers. Partial costs questioned were reported on the September 30, 2024 and December 31, 2024 CMS 64.9C1, Line 5 ($64.62 and $312.47, respectively). The remaining $225.91 was reported on the CMS 64.9P, Line 10A on Cost of Service (COS) line 5 for the quarter ending March 31, 2025. Anticipated Completion Date 4/30/2025 Responsible Contact Person Kristine West, Senior Director of Program Integrity and Accountability

Finding Number 2023-004 Subject Heading (Financial) or AL no. and program name (Federal) 93.767 Children’s Health Insurance Program Planned Corrective Action OHCA will continue to utilize control processes and procedures to ensure medical claims are meeting program requirements. These processes include prior authorizations, suspended claim reviews, system edits, post payment reviews, and our payment accuracy measurement study. OHCA will also continue National Correct Coding Initiative (NCCI) edit updates, as well as continue with provider training to better educate our providers. The costs questioned were reported on the December 31, 2024 CMS 64.9C1, Line 5. Anticipated Completion Date 4/30/2025 Responsible Contact Person Kristine West, Senior Director of Program Integrity and Accountability

Finding Number 2023-106 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Planned Corrective Action The Oklahoma Department of Human Services (DHS) does not concur with the implication that all $12,396,987 in payments under the Kith Care program were unallowable. DHS acknowledges that improvements could have been made to documentation protocols and long-term record retention when working with a third-party platform; however, DHS does not agree with the assertion that the program was administered in violation of federal requirements. The Kith Care initiative was developed in response to a national crisis—the COVID-19 pandemic—during which ensuring continuity of child care for essential workers became a top priority. The program’s design followed the flexibility allowed under 42 USC § 601(a)(1) and 45 CFR § 98.67, with the aim of supporting low-income working families, including foster and adoptive parents, through innovative but time-limited means. The use of relative caregivers met the federal allowance for informal, license-exempt care and was consistent with CCDF guidance. Eligibility determinations were made by designated administrators in partnering agencies or by DHS staff in the child care subsidy and child welfare program areas. Weekly timesheets were submitted by caregivers and certified by parents through the application before payment was processed. Invoices submitted to DHS contained individual-level details on each child and caregiver, the dates of service, and the requested payment amounts. DHS further notes that delays in retrieving requested records were due in part to the age of the program, the sunset of the platform, and staff attrition. These limitations should not be construed as a lack of eligibility verification or failure of internal control at the time of program execution. Anticipated Completion Date This award is now closed. Responsible Contact Person Trevor Shelby, Deputy Director

Finding Number 2023-104 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 does not concur with the finding as written. We believe the State Auditor and Inspector (SAI) has not fully considered the federal flexibility afforded under the American Rescue Plan (ARP) Act, and that some conclusions were drawn from incomplete documentation. The Child Care Desert Grant program was thoughtfully developed in response to urgent needs during the COVID-19 recovery, with the goal of expanding access to child care in underserved communities using the discretion and authority granted to states under federal guidance. While OKDHS acknowledges that improvements could have been made to certain aspects of the program’s implementation—particularly regarding documentation clarity, post-award monitoring, and technical assistance— the SAI findings do not reflect the intent, structure, or compliance framework outlined in federal guidance. 2 CFR § 200.303(a) – Internal Controls DHS has strengthened internal controls consistent with federal expectations. For example, in the instance involving a grantee related to a DHS official, the potential conflict was identified and escalated by OKDHS to SAI as well as the Ethics Commission, and the individual was not directly involved in the reviewing and approving award process. In addition, the employee’s spouse was not included on any documentation included in the facilities application. This demonstrates that internal controls operated effectively. 2 CFR § 200.403 – Allowability of Costs This regulation applies to allowability under the Uniform Guidance, but per 45 CFR § 75.101(d), Subpart E (which ncludes § 200.403) does not apply to CCDF ARP discretionary funds unless explicitly stated. Federal guidance, including ACF-IM-2021-03, affirms that states were given broad flexibility in the design and implementation of such programs. Accordingly, DHS used its discretion to structure payments and allowable uses consistent with that guidance. Many costs questioned by SAI—such as business technology, minor remodeling, and start-up costs—were clearly allowable per the Desert Grant Guidance. 42 U.S. Code § 9858c(c)(2)(I) DHS did not fund sectarian instruction or activities. Expenditures were related to facility compliance and licensing, which is expressly permitted under this section when needed to meet health and safety standards. Providers affirmed compliance in their applications. 42 U.S. Code § 9858k(a) No funding was used for sectarian worship or instruction. All grantees signed affirmations that they would comply with all federal requirements, including those related to religious neutrality. Where expenditures were found that may raise concerns, they are being reviewed for compliance with these requirements. 42 U.S. Code § 9858k(b) DHS did not provide funding for services rendered during the regular school day or for academic credit. In the referenced after-school program, funds were used to expand access to licensed child care outside of regular instructional hours. Documentation of use is being reviewed, and additional guidance will be provided to ensure clarity in future programs. 42 U.S. Code § 9858d(b) and 45 CFR § 98.2 – Construction and Renovation DHS recognizes that one provider exceeded the $350,000 minor remodeling limit. This was an isolated case. At the time, DHS did not interpret the project scope as meeting the federal definition of "major renovation." DHS is enhancing its oversight process and guidance to providers to ensure full alignment with federal cost limits moving forward. Additional Clarifications • Expenditures cited as unallowable often fall within the scope of minor remodeling, technology, or business development explicitly allowed in Desert Grant FAQs and ACF guidance. • SAI’s estimate of questioned costs includes speculative assumptions based on documentation gaps—not confirmed misuse. • Many of the questioned costs SAI appears to be extrapolating were supplied directly from OKDHS’ own internal audit team and have either been addressed or are under investigation and should not be included in any additional questioned cost extrapolation. • The program was developed under severe federal timelines (obligation by 9/30/23), and ACF’s memoranda explicitly encouraged innovative approaches, including expansion grants to new and small providers. Corrective Actions (Planned or Completed) to be implemented on future emergency awards 1. Policy & Procedure Enhancements – Revised award language, documentation standards, and milestone disbursement options are being implemented. 2. Conflict of Interest Controls – OKDHS had a conflict of interest control in place to try and capture all potential conflicts based on the structure of the agency. OKDHS is expanding the process to extend to any staff members that have decision making approval. 3. Improved Monitoring – Targeted post-award reviews, site checks, and spending verification measures are being conducted. 4. Provider Training & Technical Assistance – Providers are receiving additional education on fiscal documentation, grant compliance, and reporting expectations. Anticipated Completion Date N/A Responsible Contact Person Kayla Urtz

Finding Number 2023-103 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action The QRIS incentive payments were designed as a strategic investment to increase participation in Oklahoma’s redesigned Stars Quality Rating and Improvement System (QRIS), which aligns directly with the statutory purposes outlined in 42 USC 9858c(c)(3)(B) — specifically, improving the quality and availability of child care services. The incentive structure was intentionally crafted to encourage engagement among providers who had not previously participated in quality rating efforts. Encouraging this engagement is a nationally recognized strategy to improve the quality of care across the system. 42 USC § 9858c(c)(3)(B) The incentive payments were issued for the express purpose of engaging providers in a new QRIS system designed to improve child care quality, directly aligned with this statute. The law permits “activities that improve the quality or availability of such services” and “any other activity that the State determines to be appropriate.” DHS determined the incentive model was an appropriate and effective method to encourage participation in quality rating, a commonly accepted CCDF quality activity. 45 CFR § 98.67(a) DHS did follow its internal policies and procedures in disbursing incentive payments. Providers submitted applications, were vetted through an internal process, and received payments based on eligibility criteria and Stars level requests. This structure complied with DHS’s established process and satisfied the requirements of §98.67(a). The regulation does not impose a requirement for retrospective receipts or cost documentation for incentive payments. 45 CFR § 98.67(c)(2) QRIS incentive payments were disbursed through traceable, documented transactions—each tied to a provider’s application, Stars level requested, and approved amount. These records are maintained in DHS’s internal systems. There was no requirement in the federal Notice of Award (NOA) to trace QRIS incentive funds to the recipient expenditure level 2 CFR § 200.303(a) DHS established pre-award internal controls, including a structured QRIS application process, eligibility screening, and fixed incentive tiers linked to Stars level requests. The Department maintained auditable records of participation and payment amounts. There was no requirement in the federal Notice of Award to trace these funds to the recipient expenditure level, as the child care providers were not subrecipients under 2 CFR § 200.1. Instead, they received non-reimbursement incentive payments tied to participation in a state-defined quality improvement activity. The internal control standard calls for “reasonable assurance,” which DHS satisfied through documented eligibility reviews, centralized approvals, and audit-ready payment tracking. Anticipated Completion Date N/A Responsible Contact Person Kayla Urtz

Finding Number 2023-099 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action The Oklahoma Department of Human Services (DHS) respectfully disagrees with several assertions made in this finding and believes the State Auditor has misapplied certain federal guidance, including Section 2202(e)(1) of the ARP Act, and incorrectly characterized the Department’s internal controls and program intent. Specifically: 1. Allowability of Costs: The activities cited as “unallowable” by the auditor do not appear to violate Section 2202(e)(1) of the ARP Act. That provision explicitly allows for a broad set of uses including “goods and services necessary to maintain or resume child care services.” DHS maintains that the expenditures made by the providers fall within the permissible categories outlined in the statute and that the audit applies a narrower interpretation than what federal guidance supports. 2. Documentation and Internal Controls: DHS issued grant funding as stabilization support to preserve child care operations during a critical period of recovery and transition, as encouraged by the federal guidance. In accordance with ARP Act expectations around expediting support, DHS designed a simplified reapplication process focused on accessibility and participation, especially for providers historically underrepresented in the quality rating system. While DHS did not require pre-spending documentation from providers—consistent with the stabilization nature of the funding—it did provide clear guidance on allowable uses and will further strengthen post-award monitoring protocols going forward. DHS acknowledges that improvements could be made in documentation expectations and will take steps to implement a structured sampling and review process for provider expenditures to enhance accountability without deterring participation. 3. Stars System Reapplication and Ratings: The temporary policy to waive certain visits and allow self-nominated Stars levels was a deliberate effort to incentivize participation and improve provider engagement with the new QRIS. The assertion that increased Star ratings led to unjustified funding increases does not consider the system’s transitionary design nor the planned monitoring that follows implementation. DHS was transparent in its guidance to providers and structured the increases to align with system reforms in development since before the ARP funding was issued. 4. Commingling of Funds: DHS did not require separate accounts for stabilization grants, consistent with federal practice and provider burden considerations. We do, however, acknowledge that clearer expectations and technical assistance on fund tracking would be beneficial. DHS will issue revised guidance encouraging, but not mandating, the separation of grant-related expenditures and will explore cost-effective technical supports for provider-level financial documentation. Anticipated Completion Date N/A Responsible Contact Person Kayla Urtz

Finding Number 2023-107 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 - TANF Planned Corrective Action The new Current system used by AFS automatically sends TANF cases to staff to ensure reviews are completed timely. Current also sends reporting to Supervisors including cases that are not completed timely so appropriate action can be taken. Anticipated Completion Date 11/06/2024 Responsible Contact Person Rhonda Archer

Finding Number 2023-209 Subject Heading (Financial) or AL no. and program name (Federal) 93.323: Epidemiology and Laboratory Capacity for Infectious Diseases Planned Corrective Action The flagged contract and incorporated section were negotiated by OSDH's prior leadership at that time (May- June 2021). After a leadership change in October 2021, Commissioner Reed promptly terminated the contract - well before any such flagged services were engaged in or provided by the contractor. To OSDH's knowledge, it did not pay for any such services. Current OSDH leadership and Legal work diligently during the contract review process to ensure that unallowable activities are not included in vendor contracts. Anticipated Completion Date 6/30/24 Responsible Contact Person Stefan Von Dollen, Interim CFO

Finding Number 2023-204 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 and recognized these issues in early 2023, and as a result, has already implemented the following control changes in 2023: 5. Simplified the COA from 1.5M to 500 options to limit employees coding incorrectly. 6. Locked down access where possible. 7. Continuing to emphasize supervisor review. 8. July 2023 Payroll began providing a weekly payroll spreadsheet on a Teams Page (POC chat) for all agency Points of Contacts. Management is also currently working to create a report in Hyperion to reconcile booked (Budgeted) payroll recorded on the general ledger to the validated (Actual) payroll as coded by OSDH employees. This will identify variances between the two, by program area, to allow an adjusting entry to be made to true up the general ledger to reflect the actual recorded time and effort. The expected completion date for this is 6/30/25. Anticipated Completion Date 6/30/25 Responsible Contact Person Stefan Von Dollen, Interim CFO

Finding Number 2023-208 Subject Heading (Financial) or AL no. and program name (Federal) 93.268: Immunizations Cooperative Agreements Planned Corrective Action The flagged contract and incorporated section were negotiated by OSDH's prior leadership at that time (May- June 2021). After a leadership change in October 2021, Commissioner Reed promptly terminated the contract - well before any such flagged services were engaged in or provided by the contractor. To OSDH's knowledge, it did not pay for any such services. Current OSDH leadership and Legal work diligently during the contract review process to ensure that unallowable activities are not included in vendor contracts. Anticipated Completion Date 6/30/24 Responsible Contact Person Stefan Von Dollen, Interim CFO

Finding Number 2023-203 Subject Heading (Financial) or AL no. and program name (Federal) 93.268: Immunizations Cooperative Agreements Planned Corrective Action Management agrees with this finding and recognized these issues in early 2023, and as a result, has already implemented the following control changes in 2023: 1. Simplified the COA from 1.5M to 500 options to limit employees coding incorrectly. 2. Locked down access where possible. 3. Continuing to emphasize supervisor review. 4. July 2023 Payroll began providing a weekly payroll spreadsheet on a Teams Page (POC chat) for all agency Points of Contacts. Management is also currently working to create a report in Hyperion to reconcile booked (Budgeted) payroll recorded on the general ledger to the validated (Actual) payroll as coded by OSDH employees. This will identify variances between the two, by program area, to allow an adjusting entry to be made to true up the general ledger to reflect the actual recorded time and effort. The expected completion date for this is 6/30/25. Anticipated Completion Date 6/30/25 Responsible Contact Person Stefan Von Dollen, Interim CFO

Finding Number 2023-061 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425U) Planned Corrective Action The Office of Title Services will continue to provide additional training to all reviewers to strengthen the claims review process. Anticipated Completion Date August-2025 Responsible Contact Person Tammy Smith

Finding Number 2023-059 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; 84.425R; 84.425U) Planned Corrective Action Beginning with FY23, the ESSER Performance Report (formerly known as the ESSER Annual Reporting) data from LEAs has been collected in our Grants Management System (GMS). This has increased the accuracy of data reported annually to USDE. Anticipated Completion Date March-2024 Responsible Contact Person Tammy Smith

Finding Number 2023-047 Subject Heading (Financial) or AL no. and program name (Federal) TITLE I, PART A – GRANTS TO LOCAL EDUCATIONAL AGENCIES AL #84.010 SPECIAL EDUCATION IDEA PART B & PRESCHOOL AL #84.027; 84.173 AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; 84.425U) Planned Corrective Action The Office of Title Services will ensure that our department completes and collects Time and Effort records semi-annually. The Office of Special Education Services will ensure that this department completes and collects Time and Effort records semi-annually. Anticipated Completion Date Jan-2024 June-2025 Responsible Contact Person Tammy Smith Sherri Coats

Finding Number 2023-046 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; 84.425R; 84.425V) Planned Corrective Action OSDE does not agree with the finding regarding $802,414.82 of claims for a non-public school that used unallowable proportionality data in their ARP EANS application. The Office of Title Services (OTS) used the limited federal guidance available at the time to manage the Emergency Assistance to Nonpublic Schools (EANS) funds. Due to limited guidance from the US Department of Education (USDE), OSDE allocated ARP EANS funding consistent with CRRSA EANS. After funds were allocated, USDE provided guidance on the allocation of ARP EANS funding using actual low income poverty data. As a result, OSDE’s reviewed the allocation of ARP EANS funding and determine that certain expenditures totaling $802,414 were ineligible under ARP EANS but eligible under CRSA EANS. In the fall of 2024, the Office of Title Services (OTS) provided documentation and adjusting journal entries to reallocate ineligible funds from ARP EANS to unspent CRSA EANS. This adjustment transferred the unallowable expenditures originally charged to ARP EANS to unspent funds under CRRSA EANS. All funds were obligated during the applicable period of availability. The United States Department of Education accepted evidence of this corrective action in an email received by OTS staff on February 5, 2025. A copy of this email was sent to the Oklahoma State Auditor and Inspector’s Office on Monday, May 19th, 2025. As a result, these expenditures were allowable and did not result in questioned costs. OSDE agrees with that low-income data used for EANS allocation was different than the low-income data used for Title I allocations. OSDE used Low-income counts based upon data provided by nonpublic schools. The Office of Title Services (OTS) used the limited federal guidance available at the time to manage the Emergency Assistance to Nonpublic Schools (EANS) funds. OSDE is not aware of expenditures that lacked supporting documentation. OSDE agrees with the finding on a duplicate Payment. Duplicate payments were erroneously made to Complete Book and Media Supply LLC. OSDE is working to resolve this matter. EANS Proportionality In the fall of 2024, the Office of Title Services (OTS) provided documentation and adjusting journal entries to re-allocate ineligible funds from ARP EANS to unspent CRSA EANS. This adjustment transferred the unallowable expenditures originally charged to ARP EANS to unspent funds under CRRSA EANS. All funds were obligated during the applicable period of availability. The United States Department of Education accepted evidence of this corrective action in an email received by OTS staff on February 5, 2025. A copy of this email was sent to the Oklahoma State Auditor and Inspector’s Office on Monday, May 19th, 2025. As a result, these expenditures were allowable and did not result in questioned costs. EANS Low-Income If low-income data for nonpublic school participants is necessary to determine eligibility, then OTS will create a written procedure to collect and verify the data. EANS Procurement To avoid duplicate payments only the Senior Director of Federal Programs will have approval on any invoice submitted for payment. Invoices will be tracked and documented by the Office of Title Services. In the future should it be necessary to allocate to non-LEA entities, the Office of Title Services will create written procedures to ensure any necessary supporting documentation be submitted prior to approving payment on an invoice. Anticipated Completion Date Responsible Contact Person Tammy Smith

Finding Number 2023-041 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.425 – EDUCATION STABILIZATION FUND (ESF – 84.425V) Planned Corrective Action The Office of Title Services (OTS) used the limited federal guidance available at the time to manage the Emergency Assistance to Nonpublic Schools (EANS) funds. Due to limited guidance from the US Department of Education (USDE), OSDE allocated ARP EANS funding consistent with CRRSA EANS. After funds were allocated, USDE provided guidance on the allocation of ARP EANS funding using actual low income poverty data. In the fall of 2024, the Office of Title Services (OTS) provided documentation and adjusting journal entries to reallocate ineligible funds from ARP EANS to unspent CRSA EANS. This adjustment transferred the unallowable expenditures originally charged to ARP EANS to unspent funds under CRRSA EANS. All funds were obligated during the applicable period of availability. The United States Department of Education accepted evidence of this corrective action in an email received by OTS staff on February 5, 2025. A copy of this email was sent to the Oklahoma State Auditor and Inspector’s Office on Monday, May 19th, 2025. OSDE agrees with that low-income data used for EANS allocation was different than the low-income data used for Title I allocations. OSDE used Lowincome counts based upon data provided by nonpublic schools. The Office of Title Services (OTS) used the limited federal guidance available at the time to manage the Emergency Assistance to Nonpublic Schools (EANS) funds. EANS Proportionality In the fall of 2024, the Office of Title Services (OTS) provided documentation and adjusting journal entries to re-allocate ineligible funds from ARP EANS to unspent CRSA EANS. This adjustment transferred the unallowable expenditures originally charged to ARP EANS to unspent funds under CRRSA EANS. All funds were obligated during the applicable period of availability. The United States Department of Education accepted evidence of this corrective action in an email received by OTS staff on February 5, 2025. A copy of this email was sent to the Oklahoma State Auditor and Inspector’s Office on Monday, May 19th, 2025. As a result, these expenditures were allowable and did not result in questioned costs. EANS Low-Income If low-income data for nonpublic school participants is necessary to determine eligibility, then OTS will create a written procedure to collect and verify the data. Anticipated Completion Date August 2025 Responsible Contact Person Amber Polach

Finding Number 2023-102 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.027 Federal Program name: Coronavirus State And Local Fiscal Recovery Funds (CSLFRF) Planned Corrective Action Management Response The Oklahoma Office of Management and Enterprise Services – Grants Management Office (OMES-GMO), in coordination with the Oklahoma State Department of Health (OSDH), acknowledges the importance of maintaining effective internal controls and complying with federal record retention requirements, as outlined in 2 CFR § 200.303 and 2 CFR § 200.334. OMES-GMO and OSDH concur that improvements to the earlier implemented processes would have served to strengthen protocols designed to garner greater assurances for reimbursed expenditures. In the case identified, ongoing partnership with OMES-GMO resulted in OSDH proactively initiating an internal review, identifying the ineligible expenditures, and taking corrective steps to partially offset the unallowable amount. Subsequently, OSDH Finance has enhanced its internal reimbursement review procedures. As of 2023, all invoices and supporting documentation submitted by subrecipients are subject to a dual-layered review and approval by both OSDH Finance and OMES-GMO prior to reimbursement. This advancement in oversight provides additional controls to reasonably assure that agency expenditures are consistent with approved project scopes, allowable under federal cost principles, and fully documented. Additionally, current staff have received targeted training, and OSDH has implemented a formal onboarding process to ensure that all new staff are trained in federal grant compliance, documentation standards, and internal control requirements. Corrective Actions • Strengthened Review and Approval Process: All subrecipient reimbursements are now reviewed and approved in layers by both OSDH Finance and OMES-GMO staff and leadership prior to payment. This ensures supporting documentation is complete, expenditures are allowable, and spending aligns with the terms of the award. • Ongoing Staff Training and Onboarding: All existing staff participate in continued training on federal cost principles, subrecipient monitoring, and documentation standards. A structured onboarding program is now in place to ensure consistent compliance knowledge across all new hires. • Monitoring and Recoupment Protocols: Post-award monitoring procedures have been updated to support early detection of ineligible expenditures. OSDH will ensure prompt recoupment or reallocation actions are taken, when necessary, in accordance with federal guidelines. These corrective actions demonstrate OMESGMO’s and OSDH’s ongoing commitment to effective stewardship of federal funds, compliance with grant regulations, and continuous improvement of internal controls. Anticipated Completion Date 5/1/2025 Responsible Contact Person OMES: Parker Wise OSDH: Diane Brown, Danielle Smith, Tracey Douglas

Finding Number 2023-101 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.027 Federal Program name: Coronavirus State And Local Fiscal Recovery Funds (CSLFRF) Planned Corrective Action The Oklahoma Office of Management and Enterprise Services – Grants Management Office (OMES-GMO) respectfully disagrees with this finding, specifically with the criteria from the Code of Federal Regulation utilized as the sole foundation for this finding, 2 CFR §200.303. This regulation states, in part that, “The Non-Federal entity must; (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” (emphasis added). For further clarity as to the standard for reasonableness, clarity can be found in 2 CFR § 200.1 Questioned cost, that states in part: Questioned cost means a cost that is questioned by the auditor because of an audit finding: … (4) where the costs incurred appear unreasonable and do not reflect the actions a prudent person would take in the circumstances. Findings bolstered by the reasonable prudent person standard in 2 CFR §200.303 must not rest on a perfect person standard, nor rest on an experienced auditor standard, but based on the care applied by the ordinary prudent person acting reasonably under the circumstances at the time of their review. From this perspective, the efforts of participants to obtain reasonable assurances included meetings, correspondence, and the gathering of documentation in support of work in furtherance of the program. If the determinations based on the documentation provided at the time satisfy reasonableness upon review, then subsequent documentation will not sustain the finding based on the criteria cited in 2 CFR §200.303. At the outset of the program, DHS was assessed as a low risk subrecipient in part due to its extensive experience with federal awards. Supporting documentation produced by the agency during the period associated with the finding reflected the breakout of the vendor’s hours and rate for the projects. Sustained communication and correspondence between the agencies and the vendor contributed to providing additional assurances that the work was consistent with the documentation in support. Agency-Specific Responses: The identified agency, DHS, provided the following independent response: OKDHS has the backup for each invoice submitted by its contractor, JGC, and reviews the invoices as the hours are reflected in the backup. OKDHS and the supplier keep detailed records and support for all activities related to CSLFRF. The Oklahoma legislation, HB 2884, effective 3/28/2023, appropriates $65 million from ARPA pandemic relief funds to OKDHS for use on 9 projects as approved by the Joint Committee on Pandemic Relief Funds. Without separating administrative costs per project, Section 13 of the bill provides that OKDHS may retain 2% of the funds appropriated in the bill for costs associated with administering the projects in the bill as a whole, "provided that no funds shall be retained that would be disallowable under the provisions of the American Rescue Plan Act of 2021". The total administrative allowance to implement HB2884 equates to $1,304,847.00. The American Rescue Plan Act of 2021 grant guidance for administrative fees at or lower than the accepted de minimis rate (10%) "does not require documentation to justify its use." Anticipated Completion Date N/A Responsible Contact Person OMES: Parker Wise DHS: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell

Finding Number 2023-005 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.027 Federal Program name: Coronavirus State And Local Fiscal Recovery Funds (CSLFRF) Planned Corrective Action Management Response: OMES-GMO concurs with the finding that CSLFRF program funds were applied to GEER and ERA expenses. OMES-GMO specifically notes that while the applied expenditures are indeed allowable under federal programs, the application of CSLFRF to these programs was in error ostensibly due to administrative challenges experienced throughout this tumultuous period. During the COVID-19 pandemic, states across the country faced numerous operational and compliance challenges, including frequently changing federal guidance and firsttime handling of federal funds. In response to the growing complexity of managing multiple federal funding programs, OMES established the Grants Management Office (OMESGMO). However, in its initial phase, the OMES-GMO experienced consistent instability with a high frequency of employee turnover, understaffing, limited resources, restricted internal controls, and practiced leadership. These factors contributed to classification errors and delays with internal review. Since then, OMES-GMO has taken steps to stabilize operations by maintaining consistent leadership, hiring additional staff, and the uniform application of organizational processes. These improvements have strengthened internal controls and allowed for the identification of previously misapplied expenditures. Prior to the finding, OMES-GMO reviewed and flagged these expenditures and is actively working to correct the issue. To resolve the misclassification, OMES has requested state appropriations to properly adjust and reallocate these expenses to their appropriate funding sources. Anticipated Completion Date Controls have been put into place and will continue through the end of the Federal Period of Performance and closeout. Responsible Contact Person Parker Wise

Finding Number 2023-093 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Emergency Rental Assistance Program (ERA) Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) acknowledges the Oklahoma State Auditor and Inspector Office’s (SAI) findings that OMES did not implement the proper internal controls and oversight of the ERA Program during FY2023. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI. 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. • To ensure that the subrecipient agreement includes 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) have recently executed a 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. See Attached – Grant Agreement Amendment. • 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 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 multi-layer 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, OMES-GMO conducts bi-weekly monitoring meetings with CFO and is currently reviewing documentation provided by CFO to ensure all current ERA projects are eligible under the ERA guidelines and that CFO is exercising the proper oversight over their subrecipients. • OMES-GMO will continue with their current ERA monitoring steps and internal controls and will work with CFO to ensure ERA program funds are spent in accordance with ERA program guidelines and state and federal regulations. Anticipated Completion Date Ongoing throughout the life of the grant Responsible Contact Person Brandy Manek

Finding Number 2023-092 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Emergency Rental Assistance Program (ERA) Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) disagrees with the report did include the demographic section, which is a required reporting element. Per the email titled 2025.03.24 Reporting download Issue OIG, page 7 of the pdf request verification the demographic data was received. On page 6 of the attachments a response states that the data for Q1, Q2 and Q3 2023 had been received. Oklahoma Office of Management and Enterprise Services (OMES) acknowledges the Oklahoma State Auditor and Inspector Office’s (SAI) findings that OMES did not implement the proper internal controls and oversight of the ERA Program during FY2023. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI. 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. • To ensure that the subrecipient agreement includes 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) have recently executed a 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. See Attached – Grant Agreement Amendment. • 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 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 multi-layer 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, OMES-GMO conducts bi-weekly monitoring meetings with CFO and is currently reviewing documentation provided by CFO to ensure all current ERA projects are eligible under the ERA guidelines and that CFO is exercising the proper oversight over their subrecipients. • OMES-GMO will continue with their current ERA monitoring steps and internal controls and will work with CFO to ensure ERA program funds are spent in accordance with ERA program guidelines and state and federal regulations. Anticipated Completion Date Ongoing throughout the life of the grant Responsible Contact Person Brandy Manek

Finding Number 2023-091 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Emergency Rental Assistance Program (ERA) Planned Corrective Action 1. Condition and Context: While documenting controls over Period of Performance for the ERA 1 grant, we noted payments made to subrecipients in the Statewide Accounting System were all put under one fund and were not distinguishable between ERA 1 and ERA 2. Therefore, OMES was unable to determine at a glance whether the funds distributed to subrecipients were attributable to ERA 1 or ERA 2. Further, we determined one of the subrecipients, Communities Foundation of Oklahoma (CFO), did not have sufficient internal controls over ERA 1 program spending to ensure all funds were expended by the end of the period of performance. • We disagree with SAI on the Statewide Accounting System separation of funds. The Statewide Accounting System did distinguish between ERA1 and ERA2. The Statewide Accounting System has funds 49400 and 49200 shows establishment of both federal funds in 2021. • We disagree with SAI on CFO’s internal controls. CFO did have internal controls in place to ensure funds were expended during the period of performance. Per ERA 1 Closeout Resource “The end date of the award period of performance is the last day for a grantee to obligate funds for ERA1 activities (September 30, 2022, for award funds received pursuant to the grantee’s initial allocation and December 29, 2022, for reallocated funds). Per documentation provided by SAI the general ledger shows a date before December 29, 2022. (Attachment 494,492, ERA Closeout Resource) 2. For eight of 30, or 26.67% of adjustments tested, the adjustment was to move expenses from ERA 2 to ERA 1 to meet ERA 1 spending requirements prior to closeout of the program. CFO comingled ERA 1 and ERA 2 funds and could not directly support each recharacterization with documentation for the specific transactions involved, but stated it was recharacterized to meet ERA 1 spending limits prior to the end of the period. In addition, CFO did not go back to revise any prior monthly or quarterly reports as required by Treasury. • We partially agree. We agree that funds cannot be moved from ERA 2 to ERA 1. • We disagree with SAI on comingling of funds. CFO did not comingle funds. CFO has 31 separate accounts within C-Suite their financial software. All accounts are listed and examples provided in the ERA Fund Open Report. • We disagree with SAI’s evaluation of the Treasury reporting requirement. CFO was not required to go back and revise prior monthly and quarterly reports per federal guidance. “As of December 2022, ERA1 grantees will only be able to edit their Final Report or as applicable, their Q4 2022 report. However, grantees may submit revisions to certain financial data submitted with their past quarterly reports, specifically, subrecipient/contractor/direct payee records; subaward/contract/direct payment records; and expenditure records when completing their Final Report or as applicable, their Q4 2022 Report. “While ERA1 grantees are no longer able to submit or revise any prior ERA1 quarterly reports, grantees may receive additional communications from Treasury’s compliance team to make corrections to past quarterly reports and as appropriate, the Final Report…” (Attachment ERA Closeout Resource pg 5) 3. For 11 of 30, or 36.67%, the adjustment was to move expenses between jurisdictions (City, State, County), which is unallowable per FAQ #42 and ERA reporting guidance. • We disagree with SAI’s unallowable cost. Due to a misunderstanding, CFO staff misstated that funds were moved between jurisdictions. Funds were not moved between jurisdictions. If a computer error occurred due to the large volume of checks that were being sent every week (approximately 1,600), not all errors were caught immediately. However, when further reviews were conducted and it was discovered a payment was issued incorrectly, the proper accounting procedures for correcting the errors were completed. (Attachment OneDrive_2025- 4-23(1)) • We disagree. FAQ 42 says nothing about jurisdictions. FAQ #42 states, “May a grantee provide ERA funds to another entity for the purpose of making payments more rapidly? To speed the delivery of assistance, grantees may enter into a written agreement with a nonprofit organization to establish a payment fund for the sole purpose of delivering assistance using ERA funds while a household’s application remains in process. A grantee may use such a process if: The process is reserved for situations in which an expedited payment could reasonably be viewed as necessary to prevent an eviction or loss of utility services that precludes employing the grantee’s standard application and payment procedures on a timely basis. The nonprofit organization has the requisite financial capacity to manage the ERA funds, such as being a certified community development financial institution. The nonprofit organization deposits and maintains the ERA funds in a separate account that is not commingled with other funds. The grantee receives all required application and eligibility documentation within six months. The nonprofit organization agrees in writing to return to the grantee any assistance that the household was ineligible for or for which the required documentation is not received within six months. Any funds not used by the nonprofit organization are ultimately returned to the grantee. If a payment made by the nonprofit organization is subsequently found to have been used for an ineligible household or an ineligible expense, or if the required application and eligibility documentation are not timely submitted, the payment will be considered an ineligible use of ERA funds by the grantee. Any administrative expenses attributable to a payment fund should be considered in accordance with FAQ 29.” (Attachment ERA FAQs) 4. When performing our testwork to determine whether ERA 1 expenditures met period of performance requirements (incurred on or before September 30, 2022), we noted 207 transactions occurred after September 30, 2022. Of the 207 transactions, we noted 40 that resulted in $10,711,668 (of this amount $2,313,435 is already questioned above) in questioned costs. • We disagree with SAI’s questioning of expenditures incurred after September 30, 2022. Per the ERA 1 Closeout Resource, “The end date of the award period of performance is the last day for a grantee to obligate funds for ERA1 activities (September 30, 2022, for award funds received pursuant to the grantee’s initial allocation and December 29, 2022, for reallocated funds). Per documentation provided by SAI, the general ledger shows a date before December 29, 2022. (Attachment ERA Closeout Resource pgs 1, 4) 5. For 13 of 207, or 6.28% of transactions tested, the adjustment was to move funds between funding jurisdictions (City, State, County), which is unallowable per FAQ #42 and ERA reporting guidance. (This resulted in $1,594,881 in questioned costs, of which $24,450 is questioned above) • We disagree with SAI’s questioned cost. Due to a misunderstanding CFO staff misstated that funds were moved between jurisdictions. Funds were not moved between jurisdictions. If a computer error occurred due to the large volume of checks that were being sent every week (approximately 1,600), not all errors were caught immediately. However, when further reviews were conducted and it was discovered a payment was issued incorrectly, the proper accounting procedures for correcting the errors were completed. (Attachment OneDrive_2025- 4-23(1)) • We disagree. FAQ #42 says nothing about jurisdictions. FAQ #42 states “May a grantee provide ERA funds to another entity for the purpose of making payments more rapidly? To speed the delivery of assistance, grantees may enter into a written agreement with a nonprofit organization to establish a payment fund for the sole purpose of delivering assistance using ERA funds while a household’s application remains in process. A grantee may use such a process if: The process is reserved for situations in which an expedited payment could reasonably be viewed as necessary to prevent an eviction or loss of utility services that precludes employing the grantee’s standard application and payment procedures on a timely basis. The nonprofit organization has the requisite financial capacity to manage the ERA funds, such as being a certified community development financial institution. The nonprofit organization deposits and maintains the ERA funds in a separate account that is not commingled with other funds. The grantee receives all required application and eligibility documentation within six months. The nonprofit organization agrees in writing to return to the grantee any assistance that the household was ineligible for or for which the required documentation is not received within six months. Any funds not used by the nonprofit organization are ultimately returned to the grantee. If a payment made by the nonprofit organization is subsequently found to have been used for an ineligible household or an ineligible expense, or if the required application and eligibility documentation are not timely submitted, the payment will be considered an ineligible use of ERA funds by the grantee. Any administrative expenses attributable to a payment fund should be considered in accordance with FAQ 29.” (Attachment ERA FAQs) 6. For 11 of 207, or 5.31%, the adjustment was to move funds between ERA 2 and ERA 1 and the adjustment was not directly supported with documentation for the specific transactions involved. It was noted as recharacterized to meet ERA 1 spending limits prior to the end of the period, and CFO did not go back to revise any prior monthly or quarterly reports as required by Treasury. (This resulted in $7,003,715 in questioned costs, of which $2,200,000 is questioned above) • Partially agree. • We agree that funds cannot be moved from ERA2 to ERA1 • We disagree with SAI’s evaluation of the Treasury reporting requirement. CFO was not required to go back and revise prior monthly and quarterly reports per federal guidance. “As of December 2022, ERA1 grantees will only be able to edit their Final Report or as applicable, their Q4 2022 report. However, grantees may submit revisions to certain financial data submitted with their past quarterly reports, specifically, subrecipient/contractor/direct payee records; subaward/contract/direct payment records; and expenditure records when completing their Final Report or as applicable, their Q4 2022 Report. “While ERA1 grantees are no longer able to submit or revise any prior ERA1 quarterly reports, grantees may receive additional communications from Treasury’s compliance team to make corrections to past quarterly reports and as appropriate, the Final Report…” (Attachment ERA Closeout Resource pg 5) 7. For 7 of 207, or 3.38% of transactions tested, the adjustment was to ‘correct accounts’ or ‘tie out accounts’; we determined these were not attributable to specific transactions but were ‘plug’ numbers to zero out the ERA 1 balance prior to the end of the period of performance to meet spend down requirements and were not supported by actual expenditures that can be determined to have been incurred on or before September 30, 2022. (This resulted in $1,837,072 in questioned costs, of which $88,985 is questioned above) • We partially agree. • We agree that funds cannot be moved from ERA 1 to ERA 2 • We disagree with SAI’s questioning of expenditures incurred after September 30, 2022. Per the ERA 1 Closeout Resource, “The end date of the award period of performance is the last day for a grantee to obligate funds for ERA1 activities (September 30, 2022, for award funds received pursuant to the grantee’s initial allocation and December 29, 2022, for reallocated funds). Per documentation provided by SAI, the general ledger shows a date before December 29, 2022. (Attachment ERA Closeout Resource pgs 1, 4) 8. For 7 of 207, or 3.38% of transactions tested, the adjustment was to CFO management fees. Management fees were retained on a percentage basis; therefore, the fee is not supported by actual expenditures that can be determined to have been incurred on or before September 30, 2022. (This resulted in $1,430,228 in questioned costs which were all questioned on finding 2023-028). We disagree with SAI’s questioning of expenditures incurred after September 30, 2022. Per the ERA 1 Closeout Resource, “The end date of the award period of performance is the last day for a grantee to obligate funds for ERA1 activities (September 30, 2022, for award funds received pursuant to the grantee’s initial allocation and December 29, 2022, for reallocated funds). Per documentation provided by SAI, the general ledger shows a date before December 29, 2022. (Attachment ERA Closeout Resource pgs 1, 9. We noted a total of $8,271,796 in management fees that were not expended for ERA 1 and therefore were not spent within the period of performance. Of this amount, $6,841,568 were management fees questioned in the SFY2021 and SFY2022 State of Oklahoma Single Audit reports and the remaining $1,430,228 is questioned on finding 2023-028. We disagree with SAI’s questioning of expenditures incurred after September 30, 2022. Per the ERA 1 Closeout Resource, “The end date of the award period of performance is the last day for a grantee to obligate funds for ERA1 activities (September 30, 2022, for award funds received pursuant to the grantee’s initial allocation and December 29, 2022, for reallocated funds). Per documentation provided by SAI, the general ledger shows a date before December 29, 2022. (Attachment ERA Closeout Resource pgs 1, 4) 10. For 2 of 207, or 0.97% of transactions tested, the payment was not supported by an itemized invoice to enable a determination that all the costs were incurred prior to September 30, 2022. (This resulted in $276,000 in questioned costs) • We disagree with SAI questioning cost and have provided supporting documentation in OneDrive - 2025-04-23(2) to show questioned expenditures. • We disagree with SAI’s questioning of expenditures incurred after September 30, 2022. Per the ERA 1 Closeout Resource, “The end date of the award period of performance is the last day for a grantee to obligate funds for ERA1 activities (September 30, 2022, for award funds received pursuant to the grantee’s initial allocation and December 29, 2022, for reallocated funds). Per documentation provided by SAI, the general ledger shows a date before December 29, 2022. (Attachment OneDrive -2025-04-23(2), ERA Closeout Resource pgs 1, 4 ) Oklahoma Office of Management and Enterprise Services (OMES) acknowledges the Oklahoma State Auditor and Inspector Office’s (SAI) findings that OMES did not implement the proper internal controls and oversight of the ERA Program during FY2023. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI. 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. To ensure that the subrecipient agreement includes 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) have recently executed a 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. See Attached – Grant Agreement Amendment. • 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 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, OMES-GMO conducts bi-weekly monitoring meetings with CFO and is currently reviewing documentation provided by CFO to ensure all current ERA projects are eligible under the ERA guidelines and that CFO is exercising the proper oversight over their subrecipients. • OMES-GMO will continue with their current ERA monitoring steps and internal controls and will work with CFO to ensure ERA program funds are spent in accordance with ERA program guidelines and state and federal regulations. Anticipated Completion Date Ongoing throughout the life of the grant Responsible Contact Person Brandy Manek

Finding Number 2023-090 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Emergency Rental Assistance Program (ERA) Planned Corrective Action • Condition and Context: While documenting controls over housing stability expenditures for the ERA 1 and ERA 2 programs, we noted one expenditure for payroll costs to an organization contracting with one of the subrecipients that provides employment and career resources, which is not an allowable housing stability activity. • We disagree employment and careers are an essential in creating housing stability. The 2024- ERA Compliance Supplement Section A. Activities Allowed or Unallowed; 1. Activities Allowed (c) states in part “Housing Stability Services: Under ERA 1, housing stability services includes case management and other services related to the COVID-19 outbreak intended to help keep households stably housed. Under ERA 2, housing stability services do not have to be related to the COVID-19 outbreak. For ERA 1 and ERA 2, housing stability services include those that enable households to maintain or obtain housing. Such services may include, among other things, eviction prevention and eviction diversion programs.” It is apparent from the guidance and division of funds for a portion to be used for housing stability, the Treasury is supporting measures to first keep vulnerable individuals and families housed during the emergency, but secondly, provide services that will assist them for the future. Program guidance from the Treasury (Building Housing Stability Infrastructure | U.S. Department of the Treasury) encourages the integration of wrap-around services, stating these services “can be particularly important for tenants who have more than a temporary hardship related to the pandemic and for whom financial assistance covering rental arrears is not enough ‘to catch up’ over the long term. Having a network of support services can help households move out of a cycle of housing instability and into a pathway of financial stability.” The Treasury goes on to provide examples of those who may be served by this practice include eligible households which include those that need additional support and coaching to develop a reliable self-sufficiency plan for maintaining housing. The Treasury stresses that by implementing these services, a long-term infrastructure is built that can help break the cycle of housing instability and support a holistic community recovery.” Treasury concludes with their support of preventative programs, stating “An infrastructure of housing stability services can ensure that support for the most vulnerable will be available. Financial assistance is not the only priority, and services can be primarily focused on coaching and educating vulnerable households. When rental assistance is scarce, support services can still play a role in preventing eviction and homelessness.” (Attachment HAP 2-SidexSide program tie to housing stability) • For 6 of 15, or 40%, of items tested, the payment allowable activities/costs such as sick pay, moving offices, ices, non-ERA training, and general admin activities not RA. This resulted in $21,442.50 in questioned costs. • We agree with the finding. CFO has strengthened internal controls and understanding to identify appropriate expenses more accurately to invoice against the LASO contract. • For 2 of 15, or 13.33%, of items tested, the invoices paid between March 2023 and June 2023, included unallowable activities/costs such as management fees and moving/storing furniture. Further, there was not a valid contract in place at the time the expense was incurred or paid. The contract ended 2/28/2023 and was not renewed or modified until 7/11/2023. This resulted in $17,648.56 in questioned costs. • We disagree with this finding. The expenses associated with the payment in question were for scaling the organization to a point where it could accommodate a larger number of clientele and more effectively serve clients. It was essential to SidexSide’s ERA program that they had enough furniture in their offices to support a full cohort of clients coming on to the program. This allowed SidexSide the ability to fully execute their program. The contract in question has a one-year option to renew. The independent contractors continued to work under the same terms and conditions and continued to be paid the same remuneration in the time period between the expiration of the original contracts and the signing of the new contracts and/or addendums. According to 15 O.S. Section 133, an implied contract is one where the existence and terms are not explicitly stated but are inferred from the conduct of the parties. Because the original contracts contained the specific terms regarding services and payment and because these independent contractors continued to operate under those same terms and receive payment even in the interim between signed contracts, this shows that an implied contract existed under Oklahoma law. (Attachment ERA2 HSP Last Mile Contract) • For 1 of 15, or 6.67%, of items tested, the payment was for unallowable activities/costs such as supplies and equipment to establish the organization that did not directly go to providing housing stability services. This resulted in $75,000 in questioned costs. • We disagree, the expenses associated with the $75,000 payment in question were not for establishing the organization but for scaling the organization to a point where it could accommodate a larger number of clientele and more effectively serve their clients. ALN was established as a Not For-Profit Corporation on March 29, 2022, filing number 2113093942, and began assisting refugees in April 2022 (documented in the Oklahoma Watch article). ALN was a fully operating organization by the time the ERA grant was received, and the expenses shown associated with the grant was essential to increase the capacity of ALN to serve their clients but the expenses were not to create the organization itself. Attachments https://oklahomawatch.org/2022/05/05/protected-for-nowthe- race-to-provide-afghan-evacuees-with-legal-services/ https://www.sos.ok.gov/corp/charityInquiryFind.aspx • For 1 of 15, or 6.67%, of items tested totaling $1,575, the payment included unallowable activities/costs that were refunded using private funds on 7/18/2023, after the SFY23 but prior to SAI's audit. Since the amounts were refunded, SAI did not question these costs. • We agree money was refunded before completion of the audit. Oklahoma Office of Management and Enterprise Services (OMES) acknowledges the Oklahoma State Auditor and Inspector Office’s (SAI) findings that OMES did not implement the proper internal controls and oversight of the ERA Program during FY2023. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI. 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. • To ensure that the subrecipient agreement includes 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) have recently executed a 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. See Attached – Grant Agreement Amendment. • 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 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, OMES-GMO conducts bi-weekly monitoring meetings with CFO and is currently reviewing documentation provided by CFO to ensure all current ERA projects are eligible under the ERA guidelines and that CFO is exercising the proper oversight over their subrecipients. • OMES-GMO will continue with their current ERA monitoring steps and internal controls and will work with CFO to ensure ERA program funds are spent in accordance with ERA program guidelines and state and federal regulations. Anticipated Completion Date Ongoing throughout the life of the grant Responsible Contact Person Brandy Manek

Finding Number 2023-089 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Emergency Rental Assistance Program (ERA) Planned Corrective Action While documenting controls over subrecipient administrative expenditures for the ERA 1 and ERA 2 grants, we noted that OMES did not require the subrecipients to submit supporting documentation for administrative expenditures charged to the programs. Further, we determined one of the subrecipients, Communities Foundation of Oklahoma (CFO), did not have sufficient internal controls over administrative expenditures to ensure they were for allowable costs and activities. Community Foundation of Oklahoma 1. For 15 of 17, or 88.24%, of credit cards tested, the included at least one expenditure for unallowable costs. These costs also included gift cards. ($53,248.41 questioned costs) • We disagree with the finding and questioned costs as the amount for all mentioned questioned costs has been returned to the ERA program. CFO has also strengthened their internal controls and understanding to more accurately identify appropriate expenses to allocate to ERA Admin funds in the future. See attached Internal Controls. 2. For $28,661 of allowable credit card administrative expenditures, the expense was attributable to multiple jurisdictions and only 90.33% of the cost should have been charged to the State of Oklahoma; however, CFO was unable to support the proper allocation was completed and that 100% of the cost was not charged to the State. We determined we would question 9.67% of the allowable expenditures ($2,771.52 questioned costs), since the State paid for expenditures that were the responsibility of other jurisdictions. Note: all credit card transactions were ‘multi’ jurisdictions; however, the unallowable costs are questioned in the first bullet. • See response to 2023-028 - Second Condition and Context. 3. For 2 of 48, or 4.17%, of claims tested, the invoice was not itemized, and we were unable to determine if the administrative costs were allowable. ($32,589.33 questioned costs) • We disagree with the finding. Itemized invoices have been attached in Attachment “OneDrive_1_4_22-2025.zip” 4. For 3 of 48, or 6.25%, of claims tested, the costs were for services to non-profit Shelterwell, which is an organization that was formed by the Executive Director of Community Cares Partners (CCP) with CCP team members after CCP stopped accepting ERA applications. Shelterwell works with tenants and landlords to provide education and mediation between tenants and landlords but is not legally part of Communities Foundation of Oklahoma (CFO)/CCP and does not directly provide rental assistance. Therefore, all payments to Shelterwell do not directly support the administration of the ERA program and are not allowable administrative costs. ($3,847.90 questioned costs) • We partially agree in that the expenses listed for Shelterwell were incorrectly allocated to the Admin account. These expenses should have been expensed from their ERA2 Housing Stability grants. CFO has strengthened our internal controls and understanding to more accurately code and identify expenses, so they are expensed to the correct fund in the future. We partially disagree that the payments made to Shelterwell are unallowable. According to the 2024 ERA Compliance Supplement and FAQ 23, 10% of the funds under ERA1 and ERA2 may be used for housing stability services. The 2024 Compliance Supplement in describing Administrative Expenses, states, "Under ERA 1, a grantee may use up to 10 percent of the total award amount for direct and indirect administrative costs and may use up to 10 percent of the total award amount for housing stability services. Under ERA 2, a grantee may use up to 15 percent of the total award amount for direct and indirect administrative costs and may use up to 10 percent of the total award amount for housing stability services ..." This is also repeated in FAQ23. According to both 2024 Compliance Supplement and FAQ23, housing stability services include but are not limited to: eviction prevention and eviction diversion programs; mediation between landlords and tenants; housing counseling; fair housing counseling; housing navigators or promotors that help households access programs or find housing; case management related to housing stability; housing-related services for survivors of domestic abuse or human trafficking; legal services or attorney’s fees related to eviction proceedings and maintaining housing stability; and specialized services for individuals with disabilities or seniors that support their ability to access or maintain housing. Additionally, under FAQ 21, grantees may use ERA payments to make subawards to other entities, including nonprofit organizations and local governments, to administer ERA programs on behalf of the grantees. Therefore, payments to Shelterwell are allowable expenses b/c these non-profits provided services that fell under the allowable uses for Housing Stability Services and CFO was able to make a subaward to these non- profits in accordance with FAQ 21. 5. For 3 of 48, or 6.25%, of claims tested, the costs were for services for non-profit SidexSide (formerly LastMile) also created by CFO/CCP, which is an organization that provides job skills training and connects employers with participants seeking employment. SidexSide is not legally part of CFO/CCP and does not directly provide rental assistance; therefore, payments made to SidexSide do not directly support the administration of ERA program and are not allowable administrative costs. ($8,824.00 questioned costs) • We partially agree in that the expenses listed for SidexSide were incorrectly allocated to the Admin account. These expenses should have been expensed from their ERA2 Housing Stability grants. CFO has strengthened our internal controls and understanding to more accurately code and identify expenses, so they are expensed to the correct fund in the future. We partially disagree that the payments made to SidexSide are unallowable. According to the 2024 ERA Compliance Supplement and FAQ 23, 10% of the funds under ERA1 and ERA2 may be used for housing stability services. The 2024 Compliance Supplement in describing Administrative Expenses, states, "Under ERA 1, a grantee may use up to 10 percent of the total award amount for direct and indirect administrative costs and may use up to 10 percent of the total award amount for housing stability services. Under ERA 2, a grantee may use up to 15 percent of the total award amount for direct and indirect administrative costs and may use up to 10 percent of the total award amount for housing stability services ..." This is also repeated in FAQ23. According to both 2024 Compliance Supplement and FAQ23, housing stability services include but are not limited to: eviction prevention and eviction diversion programs; mediation between landlords and tenants; housing counseling; fair housing counseling; housing navigators or promotors that help households access programs or find housing; case management related to housing stability; housing-related services for survivors of domestic abuse or human trafficking; legal services or attorney’s fees related to eviction proceedings and maintaining housing stability; and specialized services for individuals with disabilities or seniors that support their ability to access or maintain housing. Additionally, under FAQ 21, grantees may use ERA payments to make subawards to other entities, including non-profit organizations and local governments, to administer ERA programs on behalf of the grantees. Therefore, payments to SidexSide are allowable expenses b/c these non-profits provided services that fell under the allowable uses for Housing Stability Services and CFO was able to make a subaward to these non- profits in accordance with FAQ 21. See attached NON CC 3-SidexSide.program tie to housing stability. 6. For 4 of 48, or 8.33%, of claims tested, the costs were unallowable and included items such as trainings unrelated to ERA, gift cards, alcohol, and food. ($1,549.76 questioned costs) • We agree and the funds were returned. See Attachment “NON CC 4 Refund” 7. For 1 of 48, or 2.08%, of claims tested, the costs were for the Afghan Legal Network project which partnered with CFO to provide ERA funds to Afghanistan refugees; SAI determined these costs are unallowable as the refugees were not Oklahoma residents, and not eligible for assistance. Therefore, administrative costs related to this project were also unallowable. ($498.00 questioned costs) • The expense listed for ALN was incorrectly allocated to the Admin account. This expense should have been expensed from their ERA2 Housing Stability grants. CFO has strengthened our internal controls and understanding to more accurately code and identify expenses, so they are expensed to the correct fund in the future. See also the response to Finding 2023-027. 8. For 1 of 48, or 2.08%, of claims tested, the cost was unrelated to ERA and unallowable. CFO/CCP has refunded the expense using private funds after SAI determined it was unallowable. ($250.00 questioned costs) • We acknowledge that CFO has refunded this expense while the FY23 audit was in process. 9. For 27 of 48, or 56.25%, of claims tested, the cost was allowable; however, the expense was attributable to multiple jurisdictions and only 90.33% of the cost should have been charged to the State. However, CFO/CCP was unable to support the proper allocation was completed and that 100% of the cost was not charged to the State. We question 9.67% of the allowable expenditures ($16,527.61 questioned costs) • See the response to Finding 2023-028 – Second Condition and Context. Oklahoma Office of Management and Enterprise Services (OMES) acknowledges the Oklahoma State Auditor and Inspector Office’s (SAI) findings that OMES did not implement the proper internal controls and oversight of the ERA Program during FY2023. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI. 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. • To ensure that the subrecipient agreement includes 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) have recently executed a 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. See Attached – Grant Agreement Amendment. • 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 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, OMES-GMO conducts bi-weekly monitoring meetings with CFO and is currently reviewing documentation provided by CFO to ensure all current ERA projects are eligible under the ERA guidelines and that CFO is exercising the proper oversight over their subrecipients. • OMES-GMO will continue with their current ERA monitoring steps and internal controls and will work with CFO to ensure ERA program funds are spent in accordance with ERA program guidelines and state and federal regulations. Anticipated Completion Date Ongoing throughout the life of the grant Responsible Contact Person Brandy Manek

Finding Number 2023-088 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Emergency Rental Assistance Program (ERA) Planned Corrective Action Condition and Context: When reviewing SFY23 payroll administrative expenditures, we noted that Communities Foundation of Oklahoma paid $2,372,400 in bonuses to 146 employees. Of these bonuses, 47 people received between $10,000 - $19,999, and 44 people received more than $20,000. We found the expenditures to be unallowable; we found no guidance that stated ERA administrative funds could be expended on bonuses. • Community Cares Partners (CCP) was established as a temporary, emergencyresponse initiative tasked with administering Emergency Rental Assistance Program (ERAP) funds on behalf of the State of Oklahoma and multiple jurisdictions. Although initially conceived as a short-term project, CCP ultimately administered nearly $150 million in federal funds over multiple years in response to a historic public health and housing crisis. To meet U.S. Treasury mandates to rapidly disburse funds—or risk recapture—CCP had to scale quickly, adapt continuously, and deliver results under unprecedented pressure. The complexity of federal guidance, evolving compliance expectations, and intense audit scrutiny required a workforce that was agile, highly skilled, and capable of operating in a fast- paced, high-stakes environment. To achieve this, Communities Foundation of Oklahoma (CFO), as CCP’s fiscal sponsor, implemented an innovative staffing model in which all CCP team members—including leadership—were engaged as independent contractors. This model allowed for rapid onboarding and deployment of services without placing undue strain on CFO’s internal team or disrupting the core functions of other nonprofit and government agencies during the pandemic. However, because these contractors were not employees, they did not receive traditional benefits such as health insurance, paid time off, or retirement contributions. To support retention, motivation, and high performance in the absence of such benefits, CCP established a performance bonus structure, as outlined in its “Fee-for-Services Rendered” policy. Bonuses were based on merit and tied directly to both individual and team accomplishments. Performance Bonuses Were Structured, Purposeful, and Aligned with Program Goals Bonuses were awarded in recognition of critical achievements, such as the complete spend-down of ERA-1 funds before the federal deadline—a milestone that required sustained, coordinated effort well beyond routine contract deliverables. These incentives were calculated using a combination of objective factors, including: · Tenure with the organization (recognizing longterm commitment); Recommendation of the team director (based on direct performance observations); · Average weekly hours worked (accounting for parttime vs. full-time contributions); · Pay rate and level of responsibility (reflecting role complexity and expectations); · Performance indicators such as quality of work, accuracy, initiative, leadership, teamwork, positive attitude, and contributions to process improvements. Bonuses were not automatic or uniformly distributed. Rather, they were awarded based on documented performance and in alignment with the responsibilities and accomplishments of each contractor. The process involved director-level recommendations and required approvals from CCP’s Chief Operating Officer and the Executive Director of CFO, ensuring appropriate oversight and accountability. Allowability Under Federal Guidelines While the ERA guidance does not specifically address performance bonuses, U.S. Treasury FAQs instruct grantees to establish their own internal policies and procedures—consistent with the statutes—and to follow them consistently when specific guidance is not provided. CCP’s bonus practices followed this directive. Moreover, the incentive structure aligns with the principles in 2 CFR § 200.430(f), which permits incentive compensation when it is reasonable, tied to performance, and paid pursuant to a good-faith agreement established before services are rendered. These bonus payments were not arbitrary. They were essential tools for incentivizing high-quality performance, encouraging efficiency and innovation, and sustaining a capable team during a national emergency. Each bonus was grounded in documented policy, approved through established protocols, and tied to clearly defined. For 4 of 116, or 3.45% of claims tested, the contract was for an unreasonable rate and the invoices provided were not itemized and specific enough to determine if the time spent was for an allowable activity related to ERA 1 or ERA 2. • The contract rates for CCP’s executive leadership—specifically, Executive Director and Chief Operating Officer were reasonable and justified given the scope of responsibility, experience, and industry standards. Both leaders operated as full-time independent contractors (a structure applied to all team members at CCP), and neither received employee benefits such as health insurance or paid time off, which materially impacts total compensation calculations. CCP was a high-capacity public-private partnership program of CFO. CCP/CFO was responsible for administering over $440 million in Emergency Rental Assistance Program (ERAP) funds from the U.S. Department of the Treasury on behalf of the State of Oklahoma and multiple local jurisdictions. CCP executive leadership managed a team of more than 150 individuals and carried out complex, time- sensitive operations to deliver critical housing stability services during the COVID- 19 public health emergency. Industry benchmarks (e.g., Guidestar / Candid data, 990 analyses) show that for nonprofits with comparable annual budgets ($150M+), full-time executive compensation for experienced leaders often ranges from $175,000 to over $300,000 annually— excluding benefits. Both contractors brought more than 15 years of relevant leadership experience and operated within that reasonable range. Their rates reflected both the magnitude of the public responsibility and the demands of launching and managing a large-scale, federally funded program under emergency conditions. Regarding invoice specificity, the submitted invoices reflected agreed- upon deliverables and outcomes consistent with contract terms and allowable activities under federal guidance. While not time-stamped or broken down by hour, they were reviewed and approved based on performance milestones. Additional documentation is uploaded to further demonstrate the alignment of time spent with allowable ERAP administrative activities. Invoices submitted followed the contract terms, including hours rendered. A sample calendar page was provided and redacted for PII. § 200.338 Restrictions on public access to records. For 9 of 116, or 7.76% of claims tested, the payment was for more than the contracted rate. • PARTIALLY AGREE: overpayment of $37 • DISAGREE: see Bonus justification below. • 4.2.22 addendum with $29.60/hr rate • 4.2.22 addendum with $29.60/hr • 4.2.22 addendum with $36/hr rate • 4.2.22 addendum with $31.25/hr rate • 4.2.22 addendum with $29.60/hr rate • 4.2.22 addendum with $38/hr rate • 4.2.22 addendum with $28/hr rate Also see CCP Contractor Increases April, 2022 spreadsheet Attachments OneDrive_1_4-22-2025 OneDrive_3_4-22-2025- Contracts For 23 of 116, or 9.83% of claims tested, the subrecipient was unable to provide a contract for the period paid. • The Independent contractors each signed contracts in 2021 which laid out specific terms and conditions under which the independent contractors would provide their services and be compensated. Although some of these contracts expired, second contracts and/or addendums were signed by those same independent contractors in 2023. The independent contractors continued to work under the same terms and conditions and continued to be paid the same remuneration in the time period between the expiration of the original contracts and when the new contracts and/or addendums were created and signed. According to 15 O.S. Section 133, an implied contract is on where the existence and terms are not explicitly stated but are inferred from the conduct of the parties. Because the original contracts contained the specific terms regarding services and payment and because these independent contractors continued to operate under those same terms and receive payment even in the interim between signed contracts, this shows that an implied contract existed under Oklahoma law. The original contracts expired in 2021 which was at the height of the Covid- 19 crisis. The entities involved were addressing more urgent matters to assist the people of Oklahoma with the objectives of the program and did not have the bandwidth to draft and sign new agreements when responding to more urgent matters. Therefore, given the surrounding circumstances and the overall intent of the parties, it can be logically deduced that an implied contract existed in the interim periods between any expiration of an original contract and the second contract and/or addendum being signed. For 9 of 116, or 7.76% of claims tested, the contract was not signed by the Executive Director and was not valid. • We partially agree the contracts for three are not currently available with the Executive Director’s signature. • We disagree, fully executed contracts for two are available for review in the attachment OneDrive_3_4-22- 2025. For 22 of 115, or 19.13% of claims tested, the payroll cost was allowable; however, the expense was attributable to multiple jurisdictions and only 90.33% of the cost should have been charged to the State of Oklahoma, but the subrecipient was unable to support the allocation was completed and that 100% of the cost was not charged to the State. • See response to audit finding 2023-028 regarding the second Condition and Context. Oklahoma Office of Management and Enterprise Services (OMES) acknowledges the Oklahoma State Auditor and Inspector Office’s (SAI) findings that OMES did not implement the proper internal controls and oversight of the ERA Program during FY2023. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI. 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. • To ensure that the subrecipient agreement includes 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) have recently executed a 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. See Attached – Grant Agreement Amendment. • 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 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, OMES-GMO conducts bi-weekly monitoring meetings with CFO and is currently reviewing documentation provided by CFO to ensure all current ERA projects are eligible under the ERA guidelines and that CFO is exercising the proper oversight over their subrecipients. OMES-GMO will continue with their current ERA monitoring steps and internal controls and will work with CFO to ensure ERA program funds are spent in accordance with ERA program guidelines and state and federal regulations. Anticipated Completion Date Ongoing throughout the life of the grant Responsible Contact Person Brandy Manek