Corrective Action Plans

Finding Number 2023-028 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 subrecipient program and administrative expenditures for the ERA 1 and ERA 2 grants, we noted that OMES did not require the subrecipients to submit supporting documentation for expenditures charged to the programs. Further, we determined one subrecipient, Communities Foundation of Oklahoma (CFO) did not have sufficient internal controls over program or administrative expenditures to ensure they were for allowable costs and activities. • 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 OMESGMO 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. • Community Foundation of Oklahoma (CFO) Due to a classification misunderstanding, CFO recently changed its financial process and is currently tracking expenditures as a subrecipient. CFO does have internal controls for expenditures and using their established process to update the tracking of their expenditures. (attachment internal controls – expenditures) CFO is reconciling the administrative expenses to capture and show the costs associated with administering the program. Condition and Context: While reviewing all administrative management fees, we noted one of the subrecipients charged the ERA 1 and ERA 2 grants $5,585,126.89 in unallowable administrative costs (management fees) that were retained by the subrecipient and were not attributable to providing financial assistance and housing stability services. The management fees the subrecipient charged to the grant do not represent actual admin expenditures, but rather an arbitrary amount retained by CFO (Questioned costs - $5,585,126.89). See management fees referenced in finding 2023-091. • A spreadsheet showing administrative expenses for FY23 is included with the finding response. CFO has used the allocable percentage of 90.33%, as provided by SAI in the finding 2023-088, to show the portion of expenditures attributed to the state ERA program. All previous and subsequent years are currently going through the same reconciliation effort. Any charges that were deemed unallowable by SAI during this audit or previous audits, such as credit card charges, will be removed from the actual expenditures spreadsheet and noted in the financial software. Transactional data from the subrecipients' financial system are included as backup for the administrative expenses. Documentation was previously not requested for CFO’s expenditures. Supporting documentation is being provided at this time to substantiate the response more fully. CFO has included a sample of personnel expenses in the response to this finding as a show of good faith. (Attachment 2022-08 CFO Payroll Support Docs, OneDrive _1 _4 _22-2025) Condition and Context: In addition, during our test work for the ERA 1 program administrative limit, we noted that administrative costs charged to the program exceeded the 10% allowable limit by 5.81%, or $1,259,429 • Being this is a multiple year grant program that was set up as earned administrative funds based upon programmatic spend, an ebb and flow of admin earned, and expended, is directly in relation to the programmatic spend. Looking at one fiscal year as a snapshot does not present the entire picture accurately. Over the course of the grant, the administrative funds earned have been at or under the cap established by Treasury. accurately. Over the course of the grant, the administrative funds earned have been at or under the cap established by Treasury. Anticipated Completion Date Ongoing throughout the life of the grant Responsible Contact Person Brandy Manek

Finding Number 2023-027 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Emergency Rental Assistance Program (ERA) Planned Corrective Action AUDIT BULLET POINT “Activities Allowed or Unallowed and Allowable Costs/Cost Principles and Eligibility exceptions: • For 22 of 89, or 24.72%, of items tested, the applicant was an Afghanistan refugee and not a renter who lived in Oklahoma at the time of applying for assistance; therefore, they were not eligible, and the payment was unallowable. The subrecipient, Communities Foundation of Oklahoma, paid for the applicant to be in a hotel and then subsequently paid for their rent and utilities. Since the applicants were not eligible all payments were unallowable; therefore, we did not determine if the payment was calculated correctly or if the assistance exceeded 15 months for ERA 1 or 18 months for ERA 2. However, of these unallowable costs, we noted the following: • Some applicants were reimbursed for monthly lawn services as part of their monthly rental payment. • Several payments were made to the applicants after the initial payment without receiving an additional application or additional funds request (AFR) form (See FAQ #10).” OMES RESPONSE: The State disagrees that payments made to Afghan refugees were unallowable. The finding asserts that 22 applicants were ineligible for Emergency Rental Assistance (ERA) because they were Afghan refugees and were not “renters who lived in Oklahoma at the time of applying.” This interpretation is inconsistent with U.S. Department of the Treasury guidance, which does not require U.S. citizenship, legal residency, or prior tenancy in Oklahoma as a condition of eligibility. • Citizenship or Legal Residency Is Not a Requirement for ERA Eligibility. It is never mentioned in the ERA statute or Treasury guidance that U.S. citizenship, lawful residency, or duration of tenancy required. The U.S. Treasury’s ERA FAQ #1 explicitly outlines the four criteria for eligibility: • The household must be obligated to pay rent on a residential dwelling; • One or more individuals within the household must have experienced financial hardship due to the pandemic; • The household must demonstrate a risk of homelessness or housing instability; • Household income must be at or below 80% of area median income (AMI). These Afghan households were invited by our government leaders to resettle in Oklahoma as part of the federal government’s Operation Allies Welcome initiative. When the Afghans arrived in Oklahoma, they immediately sought housing, being assisted by agencies such as Catholic Charities. Obviously, they were not homeowners. As tenants or households seeking to rent housing during the midst of a pandemic without any immediate means of securing employment, they were experiencing housing instability and fully met the ERA Program 1 and 2 criteria. Upon arrival: • They were not homeowners; • They had no permanent housing; • They were working with nonprofit agencies like Catholic Charities to find housing; • Because of the pandemic, they were not able to secure work and had no or extremely low income; • They were at imminent risk of homelessness. Treasury has further emphasized in FAQ #1, “… these requirements provide for various means of documentation so that grantees may extend this emergency assistance to vulnerable populations without imposing undue documentation burdens…” Again, never is the word “residence or citizen” used, even in the footnotes. This language was clearly intended to include undocumented individuals, newly arrived refugees, and others in nontraditional or transitional housing situations. Furthermore, as noted in the CFO/CCP ERA application for rental assistance previously provided to SAI, the eligibility requirements do not require residency but that only the applicant live in the State of Oklahoma. Further Support: • September 9, 2021, Email between CCP/CFO and the Director of Tax and Housing Advocacy for the National Council of State Housing Agencies. Discusses that CCP was working with housing stability service partners, specifically Catholic Charities, to help with housing Afghans when they came to Oklahoma. Emails also clarify that the Afghan refugees would only be able to apply once they moved to Oklahoma. (See attached) • Sept 29, 2021 – Email from U.S. Dept. of State, Bureau of Populations, Refugees, and Migration (PRM), U.S. Department of State, which invited a variety of Federal Agency representatives to a call to hear from the OK Catholic Charities director to speak about the Oklahoma Catholic Charities “model of utilizing CARES Act funding to support both temporary and long term housing for Afghan arrivals and an additional hour was set aside for discussion of this model. Executive Director of the Oklahoma City Catholic Charities forwarded this email to CCP asking if she would join to assist with the discussion of this model. Listed below are the agencies that had representatives on the email. the National Security Council and Subcommittees  The White House – Organization of the National Security Council and Subcommittees  Executive Office of the President.  U.S. Department  Federal FEMA Office  U.S. Citizenship and Immigration Services  Homeland Security  Catholic Charities  U.S. Conference of Catholic Bishops  Administration of Children & Families  Governors, Biden Administration point person for Afghan Parolee Assistance. (See attached) • October 3, 2021, Follow-up Email thanking people regarding the presentation and for joining the call. “The insight, creativity, and partnership is inspiring and has the potential to assist so many Afghans.” Furthermore, an email was to the attendees of the presentation clarifying ERA as the funding source for Oklahoma’s model for developing housing resource for Afghan arrival. Additionally, it was stated that “We hope that these clarifications and enclosed links will help us understand how these funds may be leveraged to house Afghans when they are resettled from the bases to other locations around the country.” (see attached) • October 24, 2021, Email from ERA Outreach Team Leader, Emergency Housing Team, U.S. Department of the Treasury, to CCP wanting to connect them with Chicago who was looking to do some work with asylum seekers/refugees and was wanting to talk to other grantees who have worked with these populations using ERA funds. Note, this is an ERA Team Leader from the Treasury wanting CCP to share CCP/CFO’s ERA model. Obviously, the Treasury would not reach out to connect CCP/CFO to speak about their Afghan refugee model if they did not approve of the use of ERA funds to assist with housing the refugees. (See attached) • Treasury FAQ #37 – Addresses how grantees can promote access to assistance for all eligible households and is clear that the Guidance contemplates serving individuals from all background and nationalities, stating that grantees “should address barriers … including by providing program documents in multiple languages.” Furthermore, the Guidance states “Grantees should also provide, whether directly or through partner organizations, culturally and linguistically relevant outreach and housing stability services to ensure access to assistance for all eligible households.” In accordance with Title VI of the Civil Rights Act of 1964 (Title VI) ERA grantees must ensure they provide meaningful access to their limited-Englishproficiency (LEP) applicants and beneficiaries of their federally assisted programs, services, and activities. Finally, “Denial of an LEP person’s access to federally assisted programs, services, and activities is a form of nationalorigin discrimination prohibited under Title VI and Treasury’s Title VI implementing regulations at 31 CFR Part 22.” • Treasury guidance on creating applications for the ERA program with no mention of citizenship or residency requirements. Allow applicants to progress and self-attest if they cannot provide documentation - At the stage when applicants are asked to provide documents to establish COVID hardship, housing instability, income, or rental obligation, applicants should also be informed that they may self-attest and move forward in the application if they do not have those documents. • Disaster Housing Recovery Coalition, C/O National Low Income Housing Coalition (NLIHC) – Published an information sheet for recipients of Federal awards in response to the COVID-19 pandemic which detailed which awards did not consider immigration status when providing assistance. Under the ERA Program, the NLIHC stated that “The law establishing the Emergency Rental Assistance Program does not impose restrictions based on immigration status.” (Attached – labeled FAQs- Eligibility for Assistance Based on Immigration Status) 2. Hotel Stays Are Allowable Options for Temporarily Displaced Households Treasury provided a Broader Reading of “Obligated to Pay Rent on a Residential Dwelling,” and determined the costs of staying in a hotel are eligible expenses, and rental assistance could be provided to temporarily displaced households living in hotels. The audit finding narrowly interprets the term “obligated to pay rent” in FAQ #1. However, multiple Treasury FAQs — including FAQ #7, #26, and #35 — demonstrate that the Department intended a flexible, inclusive interpretation, recognizing the emergency nature of the program and the housing challenges faced by displaced individuals and families and reinforces that the term “residential dwelling” is not limited to traditional apartments with leases but includes hotels and other temporary housing used in transition. • FAQ #7: Permits hotel or motel costs to be covered using ERA funds when the household lacks alternative housing options, even without a formal lease. • FAQ #26: States that rental assistance may be provided to households residing temporarily in hotels or motels when they are • displaced or between housing. FAQ #27: Allows rental assistance for rent-to- own households, further demonstrating that the key is ERA CANNOT be used for homeowners (FAQ #20). • FAQ #35: Specifically authorizes relocation assistance for households who have been evicted or otherwise displaced and are attempting to secure new permanent housing. These provisions explicitly contemplate support for individuals and families—such as Afghan refugees— who were temporarily displaced and used hotels as the only available rental housing (in truth, many Oklahomans are forced to do this) until suitable housing could be secured (rendered more difficult for larger families – up to 10+ children). As allowed under Treasury ERA FAQs #7 and #26, hotel stays were covered when used as transitional housing due to lack of available rental stock—especially for large families. Afghan refugees fell squarely within this provision. 3. Lawn Services as Part of Rent This is allowable as part of the cost of the rental of the premises. For all rentals that have a yard there is lawn maintenance, and the landlord has the option to determine how to charge (or absorb) that cost. These costs were not reimbursed as separate utility costs, but as part of the monthly rental obligation agreed to in writing. 4. Subsequent Payments Without AFR Forms • ERA guidance allows grantees to implement streamlined processes to reduce burden and deliver aid efficiently. CCP’s internal policies permitted continued rental and utility assistance without requiring new applications or additional AFR forms, so long as eligibility remained unchanged and appropriate documentation was on file. This approach is aligned with Treasury’s consistent encouragement to minimize administrative barriers in the interest of program responsiveness and urgency. Treasury guidance also stated, Only ask applicants for information that is required by the ERA statutes and Treasury’s guidance to provide them assistance. AUDIT BULLET POINT “Further, while summarizing the data on ‘applicant’, we noted one line item was made up of 498 individual payments made to hotels on behalf of the Afghanistan refugees, which consisted of 186 applicants. We identified 185 of these applicants had payments for Afghanistan refugees to live in hotels prior to applying to the ERA program. Since, at the time of the application, they were not obligated to pay rent on a residential dwelling per Department of Treasury FAQ 1 and established CCP ERA policy, the cost is unallowable. This resulted in $1,727,687.64 in questioned costs (these costs do not include payments previously questioned in the first bullet).” OMES RESPONSE: OMES disagrees with this finding. Multiple Treasury FAQs, including #7, #26, and #35, reinforces the term “residential dwelling” is not limited to traditional apartments but may include hotels and other temporary housing used in transition. Also, FAQ #8 states that a beneficiary is not required to have rental arrears to receive assistance and permits enrollment “of households for only prospective benefits.” The only restriction is that for the ERA1 program, if an applicant is requesting prospective assistance and the applicant also has rental arrears, the grantee must also provide assistance to reduce those arrears (this restriction does not apply to ERA2). Finally, per FAQ # 13, eligible households do not have to be in their current rental home when the COVID-19 public health emergency was declared, stating, “Payments under ERA are provided to help households meet housing costs that they are unable to meet as a result of the COVID-19 pandemic. There is no requirement regarding the length of tenure in the current unit.” 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, OMESGMO’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 OMESGMO 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 biweekly 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 2023-026 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. (See page 15 of attached Grant Agreement.) • 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 OMESGMO 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. • Risk assessments have been obtained and are attached. • 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 biweekly 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 2023-108 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Coronavirus Relief Fund (CRF) Planned Corrective Action The State agrees with this finding. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO) which is staffed with individuals with several years of grant experience. 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. Finally, OMES Finance has developed processes which provide for a more thorough coding of expenditures and proper review of expenditures when reporting on their GAAP Z. The State disagrees with the finding. The State had two Grant Award Notifications in place with the Boys and Girls Club which reflects the monies awarded to be used on the capital improvements and Club on the Go Mobile Clubhouses. This indicates the funds were obligated during the covered period. Per the email from the Keri for Jill Geiger Consulting, no signatures on the GANs were required and the Uniform Guidance does not require the GAN to be signed. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO) which is staffed with individuals with several years of grant experience. 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. OMESGMO’s internal control processes ensure subrecipient risk assessments are performed and that proper grant awarding documentation is provided to subrecipients. Anticipated Completion Date September 2022 Responsible Contact Person Brandy Manek

Finding Number 2023-098 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Coronavirus Relief Fund (CRF) Planned Corrective Action OMES Finance has implemented proper controls for their SEFA process to ensure costs are reported on the correct basis of accounting. OMES agrees with this finding and has put measures in place to correct this issue. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO) which is staffed with individuals with several years of grant experience. OMES-GMO has a multi-level system of internal controls which includes a process for reviewing funding requests to ensure expenditures are allowable under the federal guidelines. The State agrees. Although the delivery of the software occurred during the covered period, the invoice was paid outside of the liquidation period. The State agrees with this finding and has put measures in place to correct this issue. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO) which is staffed with individuals with several years of grant experience. OMES-GMO has a multi-level system of internal controls which includes a process for reviewing funding requests to ensure expenditures are allowable under the federal guidelines. Anticipated Completion Date September 2022 Responsible Contact Person Brandy Manek

Finding Number 2023-096 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Coronavirus Relief Fund (CRF) Planned Corrective Action The State agrees with this finding. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO) which is staffed with individuals with several years of grant experience. 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. Finally, OMES Finance has developed processes which provide for a more thorough coding of expenditures and proper review of expenditures when reporting on their GAAP Z. The State disagrees with the finding. The State had two Grant Award Notifications in place with the Boys and Girls Club which reflects the monies awarded to be used on the capital improvements and Club on the Go Mobile Clubhouses. This indicates the funds were obligated during the covered period. Per the email from the Keri for Jill Geiger Consulting, no signatures on the GANs were required and the Uniform Guidance does not require the GAN to be signed. Anticipated Completion Date September 2022 Responsible Contact Person Brandy Manek

Finding Number 2023-094 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Coronavirus Relief Fund (CRF) Planned Corrective Action The State agrees in part and the State disagrees in part. In regard to payments made to Jill Geiger Consulting in the amounts of $39,957.00 and $28,272.00, please see attached documentation of time and effort of services provided during FY2023 which were also paid with by CRF funds in FY2023. Please scroll down on the timesheet reports and refer to the Notes column for descriptions. Additionally, the CRF weekly update log is from JGC and gives more details for services provided. For the payments made to Jill Geiger Consulting for the other amounts ($27,083.33 and $34,650), these reimbursements occurred in FY2023 but were not for services provided in FY2023, but for FY2022. If you review the “Summary of requested vouchers Jill Geiger,” the payment of $34,650 occurred on 8/1/2022 but was paid to cover services in May and June 2022. For invoice v00160672 in the amount of $27,083.33, the payment was made July 5, 2022 (FY23) but covered services for April 22 (FY22). You will be able to see more instances of this in the Summary and attached invoices for that same amount. Therefore, the State requests these be taken out of the audit review and findings for FY2023 as the services were not provided in FY2023. The State of Oklahoma agrees in part and disagrees in part. The State agrees that 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, will help ensure allowability, accuracy, and assist in the detection of fraud. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO). The OMES-GMO is staffed with individuals, who have several years of grant experience implementing these internal controls and procedures. Anticipated Completion Date September 2022 Responsible Contact Person Brandy Manek

Finding Number 2023-025 Subject Heading (Financial) or AL no. and program name (Federal) 20.509 - Formula Grants for Rural Areas Planned Corrective Action We concur with the auditor’s recommendations. On 06/17/2024, FSO and OMPT met to review established procedures. As of that date, the procedures are being properly followed. Anticipated Completion Date 7/1/2025 Responsible Contact Person Sam Ddamba/Eric Rose

Finding Number 2023-018 Subject Heading (Financial) or AL no. and program name (Federal) 20.509 - Formula Grants for Rural Areas Planned Corrective Action We concur with the auditor’s recommendations. As of SFY 2025, OMPT has revised its procedures to strengthen internal controls and ensure payroll expenditures are charged to the appropriate grant. A project was established for each FTA grant program to receive payroll charges based on actual charges. Training was provided to OMPT staff on June 28, 2024. Anticipated Completion Date 7/1/2025 Responsible Contact Person Eric Rose/Bobby Parkinson

Finding Number 2023-052 Subject Heading (Financial) or AL no. and program name (Federal) #17.225 Unemployment Insurance Planned Corrective Action While the agency does not completely disagree with the Condition, Cause and Effect as documented by the auditors, the agency believes additional considerations are important in drawing conclusions about whether all payments associated with the $1,578,278 in claims identified in this finding are conclusively fraudulent. We worked closely with the auditors to review these claims and had previously identified over 90% of the claims through the agency’s own internal fraud review processes and initiated recovery of any funds paid for claims identified as fraudulent. As we have stated in previous years, conclusions drawn by the auditors around this risk reflect the worst-case scenario based on the information available. OESC processes are ever-evolving and improving to address fraud prevention and detection, as the threat from bad actors will continue in perpetuity. Oklahoma is one of few states that utilizes identity proofing as a gatekeeper to the claim application process. Though OESC launched an improved version of VerifyOK in November 2022, it took time to refine the logic behind the application that is expected to further decrease the potential findings of fraudulent claims for future audits. The agency continues to make fraud prevention a priority and is engaging with federal partners, other state agencies and vendor partners to be vigilant in anticipating trends in fraud activity. While we believe we are expending appropriate levels of effort in this area, we also want to acknowledge that the complexity and ever-changing nature of the fraud space will continue to make this a difficult risk to mitigate entirely. Anticipated Completion Date The efforts required for fraud prevention are not expected to end, as bad actors are expected to continually pursue new methods to exploit unemployment benefit systems in all states. Responsible Contact Person Michelle Britten, Chief Administrative Officer

Finding Number 2023-033 Subject Heading (Financial) or AL no. and program name (Federal) #17.225 Unemployment Insurance Planned Corrective Action OESC concurs with the audit finding and agrees with the recommendation. The decrease in the total dollars associated with this finding in comparison to the prior year demonstrates that the issue has been addressed with the programming that was completed in February 2023. The agency will continue to monitor ongoing results of the new programming to address any further adjustments needed for edge-case scenarios or to appropriately handle other system changes. Anticipated Completion Date Completed in February 2023 Responsible Contact Person Christopher O’Brien, Vice President - OESC UI

Finding Number 2023-210 Subject Heading (Financial) or AL no. and program name (Federal) 12.401: National Guard Military Operations and Maintenance Projects Program Planned Corrective Action OMD agrees with the auditors’ finding that OMD did not always use the proper state expenditure codes on construction purchase orders (PO); however, the total PO amounts were correct. Since being made aware of this issue, the CFO has taken action to update the Certified Procurement Officers’ procedures when processing Construction Management or Design Build Purchase Orders. Rather than increasing the distribution line for architectural and engineering (A&E) costs, the Certified Procurement Officer will add a new distribution line to the PO to identify the construction or renovation costs separately from A&E costs. The CFO will periodically review these construction POs to confirm the proper use of expenditure codes as well as improve the accuracy of the OMD’s financial reporting. Anticipated Completion Date Immediately Responsible Contact Person Angela Tackett, CFO

Finding Number 2023-201 Subject Heading (Financial) or AL no. and program name (Federal) 12.401: National Guard Military Operations and Maintenance Projects Program Planned Corrective Action OMD agrees with the auditors’ finding that OMD could not locate or provide the proper documentation to verify the federal cost share for maintenance personnel assigned to Appendix 1. The CFO will request an updated personnel listing from the federal Director of Engineering for state employees authorized federal reimbursement through Appendix 1 as well as the supporting documentation to validate the allowable costs for reimbursement. These source documents will be maintained in the Appendix 1 files on the Oklahoma National Guard shared portal for the required records retention period with training provided to OMD staff on where to locate the documents. Anticipated Completion Date Beginning of new fiscal year—July 1, 2025 Responsible Contact Person Angela Tackett, CFO

Finding Number 2023-038 Subject Heading (Financial) or AL no. and program name (Federal) CN CLUSTER – SCHOOL BREAKFAST PROGRAM; NATIONAL SCHOOL LUNCH PROGRAM, SPECIAL MILK PROGRAM FOR CHILDREN, FRESH FRUITS AND VEGETABLES PROGRAM AL #10.553, 10.555; 10.556; 10.559; 10.582 Planned Corrective Action Additional training of field-based staff will take place covering the areas of the SFSP review to ensure that meal counts and claim numbers are correct. A SFSP review will not be conducted prior to a claim being filed unless the SFSP program ends prior to a claim being filed. USDA guidance “encourages” a claim review to be conducted when an SFSP review is being conducted. If a sponsor operates for a month or less the review must take place while the program is operating therefore a claim would not be able to be validated. Anticipated Completion Date May 2025 (once SFSP reviews start for summer 2025) Responsible Contact Person Jennifer Weber

CONDITION: The City of McKeesport inadvertently charged as eligible expenditures two (2) purchases totaling $144,000 on the third quarter financial report required to be filed with the Department of Treasury that had already been claimed as eligible expenditures in the second quarter financial report. CRITERIA: Section 2 CFR 200.1 of the Uniform Guidance defines a disallowed cost as a charge to a Federal Award that is determined to be unallowable under the Award’s terms, which would include duplicate payments. Section 2 CFR 200.339 of the Uniform Guidance gives the federal agency the authority to disallow costs if the recipient fails to comply with the aforementioned Award terms and conditions. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City will reallocate the two vendor payments totaling $144,000 which were inadvertently duplicated in the financial reports required to be submitted to the Department of Treasury. The $144,000 in duplicate payments will be reallocated for eligible road salt purchases made during calendar year 2023.

CONDITION: During the calendar year 2023, the City did not utilize a formal general ledger system of accounting to track the financial activity (financial position and results of operations) for several ‘Funds’ held at the City. The activity of these funds is either 1) maintained in spreadsheet fashion similar to a checkbook used in personal finances, 2) recorded partially (expenses only with no revenue), or 3) not tracked at all. As these funds are not maintained using the City’s accounting software package, management does not have the ability to efficiently generate financial reports necessary to provide management with the proper fiscal oversight. This condition included the American Rescue Plan Act (ARPA) funding known as the Coronavirus State and Local Fiscal Recovery Fund. However, it should be noted that City personnel were able to prepare spreadsheets to document which expenditures were utilized to prepare the necessary quarterly reporting requirements to the Department of Treasury. This is a repeat finding (2022-002) from the prior year. CRITERIA: Prudent internal control procedures in the areas of general ledger management and financial reporting include maintaining a formal general ledger system of accounting to track the activity of all ‘Funds’ maintained by the City. In specific as it relates to federal programs, Section 2 CFR 200.403(g) of the Uniform Guidance requires that federal costs must be adequately documented which would include the maintaining of a formal general ledger system of accounting for all ‘Funds’ of the City. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City will assess the current workload and expertise of the City’s business office personnel in an effort to determine a feasible timeframe to continue the process of creating a formal general ledger system of accounting for all City ‘Funds’ that are not already entered into the software accounting system. The timeframe for completion of this review will occur during the first nine months of calendar year 2025 with the intention of having the City be in full compliance with Section 2 CFR 200.403(g) of the Uniform Guidance which requires federal costs to be adequately documented which would include the maintaining of a formal general ledger system of accounting for all ‘Funds’ of the City.

CONDITION: During the calendar year 2023, the City did not record the necessary adjustments to the various ‘Fund’ general ledgers of the City to properly reconcile the balance sheet accounts, such as cash, receivables, payables, and payroll-related liabilities to the underlying supporting documentation available at the City (which includes reconciliations of cash prepared independently by City personnel but do not agree to amounts reported in the various general ledgers). This included ‘Funds” containing significant federal funding such as the City’s Community Development Block Grant (CDBG) Program and American Rescue Plan Act (ARPA) funding known as the Coronavirus State and Local Fiscal Recovery Fund. As a result, the financial position and results of operations as shown throughout the calendar year were inaccurately stated. However, it should be noted that the Community Development Department of the City and other City personnel maintain separate financial reporting for these federal funds, independent of the aforementioned ‘Fund’ general ledgers sufficient to ascertain the revenues and expenditures of the federal programs. This is a repeat finding (2022-001) for the prior year. CRITERIA: Prudent internal control procedures in the areas of general ledger management and financial reporting include the reconciliation of all general ledger account balances to underlying supporting documentation monthly with independent oversight and approval as part of the process. In specific as it relates to federal programs, Section 2 CFR 200.403(g) of the Uniform Guidance requires that federal costs must be adequately documented which would include the applicable general ledgers of the City. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City will review the recommended options as presented by the Audit Firm’s recommendation for feasibility considering current manpower, expertise, and budgetary constraints. In addition, the City plans to ensure that written procedures for all accounting functions are implemented, reviewed and updated as necessary with the objective of ensuring that all balance sheet account balances are supported by the underlying documentation available at the City. The timeframe for completion of this review will occur during the first nine months of calendar year 2025 with the intention of having the City be in full compliance with Section 2 CFR 200.403(g) of the Uniform Guidance which requires federal costs to be adequately documented which would include the applicable general ledgers of the City.

The Center will ensure we have all supporting documentation saved and reviewed prior to payment being issued.

Finding Number: 2023-023 Finding Name: Failure to Perform Recovery Audits over Medicaid Underpayments and Overpayment Claims Finding Condition(s): The Illinois Department of Healthcare and Family Services (DHFS) did not initiate any recovery audits over Medicaid claims during fiscal year 2023. Name of Contact Person(s): • Ismaila Jagne, Administrative Assistant II - Illinois Department of Healthcare and Family Services, Office of Inspector General • Brian Dunn, Inspector General - Illinois Department of Healthcare and Family Services, Office of Inspector General Corrective Action(s): The DHFS’ Office of Inspector General and the recovery audit contractor (RAC) vendor developed and implemented an audit system. As the program’s administrator, the DHFS OIG monitors its efficacy on an on-going basis and will adjust as necessary. While the RAC vendor did work to complete 13 audits in fiscal year 2023, pursuant to a former contract, the DHFS did not execute its 2023 RAC contract until August 12, 2022. By law, no work could begin under that contract until it was finalized. Once the contract was executed, DHFS’ OIG began working with the vendor to develop the policies, procedures, templates, and systems needed to run an efficient and effective auditing program. The DHFS’ OIG and the RAC vendor met on a bi-weekly basis to develop and implement this system. After all planning and development was completed, the vendor programmed its system and auditing began. RAC audits have a three-year look-back period; therefore, audits in the system will cover fiscal year 2023. Proposed Completion Date: October 31, 2023 – Completed

Finding Number: 2023-022 Finding Name: Failure to Discontinue CHIP Benefits for Ineligible Individuals Finding Condition(s): The Illinois Department of Healthcare and Family Services (DHFS) improperly continued providing benefits under the Children’s Health Insurance Program (CHIP) program to individuals who were over the age of 19 prior to the start of the federal Public Health Emergency for COVID-19 (PHE) on March 13, 2020. Name of Contact Person(s): • Jacqueline Myers, Bureau Chief - Illinois Department of Healthcare and Family Services, Division of Eligibility • Phronsie Spaulding, Audit Compliance - Illinois Department of Healthcare and Family Services, Division of Eligibility Corrective Action(s): The DHFS accepts this finding for the 19-year-olds identified as receiving assistance under the CHIP program prior to the onset of the federal PHE. Those receiving assistance during the PHE were allowable under the Centers for Medicare and Medicaid Services’ Award Letter. CHIP eligibility for 19-year-olds was not allowable 14 months following the end of the PHE. These cases were redetermined in the State's federally required Unwinding Plan for which additional staff were hired and trained. The DHFS continues to review eligibility determinations for effectiveness and create a plan of action. Current data, as of April 2025, supports the success of the plan as these cases have decreased by 98%. Proposed Completion Date: December 31, 2025

Finding Number: 2023-021 Finding Name: Inadequate Procedures to Determine Provider Eligibility Finding Condition(s): The Illinois Department of Healthcare and Family Services (DHFS) did not adequately screen providers of the Children’s Health Insurance Program (CHIP) and the Medicaid Cluster programs to ensure that Medicaid providers were not on the USDHHS Office of the Inspector General’s (OIG) List of Excluded Individuals/Entities (LEIE) at the time the vouchers for the related services performed were paid. Name of Contact Person(s): • Susie Brown, Assistance Bureau Chief - Illinois Department of Healthcare and Family Services, Provider Enrollment Services • Anthony Kolbeck, Bureau Chief - Illinois Department of Healthcare and Family Services, Provider Enrollment Services Corrective Action(s): The Illinois Medicaid Program Advanced Cloud Technology (IMPACT) system is used by the DHFS for the enrollment and screening of CHIP and Medicaid providers. On a monthly basis, IMPACT automatically checks providers enrolled within IMPACT to the LEIE to verify the provider is not on the LEIE. The IMPACT system is updated through quarterly system releases. As part of the 1.6 quarterly release, the DHFS’ Provider Enrollment Services (PES) updated the system to address the monthly screening check box defect causing the issue. In the Lexis Nexis monthly job, as part of license information, the DHFS receives files from the American Board of Medical Specialties (ABMS), the Clinical Laboratory Improvement Amendments (CLIA), the Drug Enforcement Administration (DEA), and the NCPDP (National Council for Prescription Drug Programs (NCPDP) and other states (out-of-state license/medical license files). Only the corresponding license check boxes are checked for the provider. As an example, for a provider with an ABMS license, the corresponding ABMS check box would be checked. Furthermore, as part of sanction information, the DHFS receives a discipline file, which has the information from the Excluded Parties List System (EPLS), the LEIE, the Medicaid Services Administration (MSA), and other federal and state databases to ensure all are checked for active providers in a monthly batch. Proposed Completion Date: March 31, 2023 – Completed

Finding Number: 2023-017 Finding Name: Inadequate Process for Monitoring Interagency Program Expenditures Finding Condition(s): The Illinois Department of Human Services (IDHS) does not have an adequate process for monitoring interagency expenditures claimed under or used to meet maintenance of effort (MOE) requirements of the Supplemental Nutrition Assistance Program (SNAP) Cluster, the Temporary Assistance for Needy Families (TANF), and the Child Care Development Fund (CCDF) Cluster programs. Specific issues noted included the following: • Program questionnaires describing internal control procedures for the CCDF program were not obtained by the IDHS from the Illinois Student Assistance Commission, the Illinois Board of Higher Education, and the Illinois Community College Board. Additionally, the program questionnaire describing internal control procedures for the TANF program was not updated for the period under audit by the Department of Children and Family Services, • Quarterly certification reports were not prepared during the period for the CCDF program by the Illinois Student Assistance Commission, the Illinois Board of Higher Education, and the Illinois Community College Board, and • The IDHS did not perform a detailed review of costs claimed from expenditures reported by any of the other State agencies to ensure they met the specific program requirements. The other State agencies do not necessarily know which federal program or maintenance of effort requirement the costs they are providing to the IDHS will be claimed or used and are not able to assess whether the costs are allowable. Further, the IDHS did not assess whether the expenditures reported by other State agencies were paid during fiscal year 2023 to ensure the amounts reported to the Illinois Office of the Comptroller (IOC) and used to prepare the schedule of expenditures of federal awards (SEFA) were cash basis expenditures. Name of Contact Person(s): Sarah Eves, Bureau Chief of General Accounting – Illinois Department of Human Services, Office of Fiscal Services Corrective Action(s): The IDHS’ Bureau of Federal Reporting (Bureau) will contact the program fiscal liaison for all major programs regarding the process of reporting and appropriate use of federal funds by other agencies. Furthermore, the Bureau will request quarterly certifications and program questionnaires for those agencies receiving funds from federal awards. Proposed Completion Date: March 31, 2025 – Completed

Finding Number: 2023-016 Finding Name: Improper TANF Beneficiary Payments Finding Condition(s): The Illinois Department of Human Services (IDHS) made improper payments to beneficiaries of the Temporary Assistance for Needy Families (TANF) program. In addition, the IDHS identified a system error in June 2025 impacting beneficiaries whose benefit payments were calculated using diverted income. Name of Contact Person(s): Elizabth Lusk, Social Service Program Planner – Illinois Department of Human Services, Division of Family and Community Services Corrective Action(s): As of June 30, 2025, the IDHS’ Office of Policy and Program Integrity and the IDHS’ Office of Family Community Resource Centers discussed and formulated a plan to ensure payments are properly calculated and paid. Additionally, a training will be provided for caseworkers that pertains to reviewing the case summary for income errors or sanction errors, etc. Proposed Completion Date: June 30, 2026

Finding Number: 2023-014 Finding Name: Unallowable Costs Charged to the TANF and CCDF Cluster Programs Finding Condition(s): The Illinois Department of Human Services (IDHS) could not provide documentation to support payments made on behalf of beneficiaries of the Temporary Assistance for Needy Families (TANF) and CCDF Cluster (CCDF) programs. Additionally, the IDHS had not performed a monitoring review in 2023 or either of the previous two fiscal years to ensure billing information provided by the child care providers is accurate for any of the providers sampled. As a result, IDHS does not have adequate controls in place to ensure information provided by providers is accurate and the related child care payments made were appropriate. Name of Contact Person(s): • Felicia Gray, Associate Director of Operations – Illinois Department of Human Services, Division of Early Childhood • Elizabeth Lusk, Social Service Program Planner – Illinois Department of Human Services, Division of Family and Community Services Corrective Action(s): The IDHS will develop a procedure for periodic reviews of billing certificates for payments entered through the Interactive Voice Response (IVR) system. Additionally, the IDHS will develop forms, notices, and tools needed to implement the review process. Furthermore, the IDHS will develop and implement a communication plan to announce upcoming reviews that includes the Service Employees International Union (SEIU), the Division of Early Childhood (DEC), Child Care Resource and Referrals (CCR&Rs), and all providers using the Interactive Voice Response (IVR). Once these items are developed, the IDHS will determine needed changes to the IDHS’ administrative rules, its Child Care Assistance Program (CCAP) Policy, and its CCDF State Plan response. After obtaining the necessary leadership approvals, the IDHS will begin conducting IVR reviews. Proposed Completion Date: January 1, 2026

Finding Number: 2023-013 Finding Name: Unallowable Costs Charged to the SAPT Program Finding Condition(s): The Illinois Department of Human Services (IDHS) charged subrecipient expenditures to the Block Grants for Prevention and Treatment of Substance Abuse (SAPT) program which were incurred after the period of performance ended. Name of Contact Person(s): Christina Miller, Fund Disbursement Manager – Illinois Department of Human Services, Division of Substance Use, Prevention, and Recovery Corrective Action(s): The IDHS established a procedure to run billing data which will be filtered to determine if dates fall outside of the performance period of the grant. Additionally, the IDHS will ensure that any bills that fall outside of the performance period of the grant are paid as separate payments so as not to be paid out of incorrect funds. Proposed Completion Date: October 15, 2024 – Completed