Corrective Action Plans

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Contact Person – Matt Bakke, Executive Director Corrective Action Plan – The Project will review its policies and procedures over timely reporting submissions. Completion Date – 12/31/26
Contact Person – Matt Bakke, Executive Director Corrective Action Plan – The Project will review its policies and procedures over timely reporting submissions. Completion Date – 12/31/26
MCHA has created a documented policy and procedure for all significant accounting transactions which includes monitoring practices for financials and material account balances. Also included are procedures related to monthly and annual account reconciliation and filing of source documents.
MCHA has created a documented policy and procedure for all significant accounting transactions which includes monitoring practices for financials and material account balances. Also included are procedures related to monthly and annual account reconciliation and filing of source documents.
1. Comprehensive Grant Reconciliation Process- Management will perform a formal year-end reconciliation of all federal grant expenditures to the general ledger, grant agreements, reimbursement requests, and funding agency reports prior to completion of the SEFA. 2. Centralized Federal Award Inventor...
1. Comprehensive Grant Reconciliation Process- Management will perform a formal year-end reconciliation of all federal grant expenditures to the general ledger, grant agreements, reimbursement requests, and funding agency reports prior to completion of the SEFA. 2. Centralized Federal Award Inventory- Management has established a centralized schedule of all federal awards that identifies the fed eral agency, Assistance Listing Number {ALN), passthrough entity, grant number, award period, and responsible program personnel. This inventory will be reviewed and updated throughout the year. 3. Formal SEFA Review Control -A secondary review of the completed SE FA will be performed by a member of management independent of the preparer. The review will include verification of all federal programs, ALNs, pass-through awards, expenditures, and required disclosures. 4. Year-End Program Certifications - Program and finance personnel responsible for grant administration will provide written confirmation of all federal awards and expenditures incurred during the reporting period to ensure completeness. 5. Training and Compliance Monitoring- Finance staff responsible forfederal grant accounting and reporting will receive periodic training regardi ng Uniform Guidance requirements, including SEFA preparation and reporting responsibilities.
Based on the recommendation, management anticipates taking actions such as updating its process for recording transactions, addressing cutoff, and implementing a more rigorous review process to ensure compliance.
Based on the recommendation, management anticipates taking actions such as updating its process for recording transactions, addressing cutoff, and implementing a more rigorous review process to ensure compliance.
The Organization should develop a compliance calendar that includes financial reporting deadlines and set automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Organization should engage the audit firm well before t...
The Organization should develop a compliance calendar that includes financial reporting deadlines and set automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Organization should engage the audit firm well before the fiscal year end, and the auditors should put this engagement on their calendar well in advance of the due date. The Organization should establish a timeline with the auditors that aligns with internal deadlines to ensure sufficient time to conduct the audit. The Organization’s Board of Directors should be more actively engaged in the auditing and reporting process to establish a greater degree of accountability and oversight. Anticipated Completion Date: 09/30/2026 Actions Taken: The Organization has begun implementing the above-mentioned recommendations. The Organization will ensure that it has a working compliance calendar to assist in meeting the reporting deadline. Additionally, the Organization has engaged the audit firm for their upcoming fiscal year-end, and the audit firm has put it on its calendar to begin the audit process well in advance. The Organization’s board of directors has agreed to oversee the auditing and reporting processes to a greater extent. With these actions, the Organization expects to comply with the Uniform Guidance for single audits deadline for the fiscal year end December 31, 2025. Mr. Joel Stein, executive director, has been designated to monitor the plan of corrective action for this finding. He can be reached at 845-356-2761. Contact Person Responsible for Corrective Action: Joel Stein, Executive Director
2024-14 Segregation of Duties Material Weakness Recommendation: We recommend that management and the governing board be aware of the lack of segregation of duties and implement controls whenever possible to mitigate this risk. The governing board should remove the finance manager from the list of ch...
2024-14 Segregation of Duties Material Weakness Recommendation: We recommend that management and the governing board be aware of the lack of segregation of duties and implement controls whenever possible to mitigate this risk. The governing board should remove the finance manager from the list of check signers. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.
2024-006 Minutes/Resolutions Material Weakness Recommendation: Written minutes should be prepared for each council meeting along with any approved resolutions/recommendations. The minutes and resolutions should be centrally filed, maintained by the Council’s Secretary, and easily accessible to the a...
2024-006 Minutes/Resolutions Material Weakness Recommendation: Written minutes should be prepared for each council meeting along with any approved resolutions/recommendations. The minutes and resolutions should be centrally filed, maintained by the Council’s Secretary, and easily accessible to the auditor. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.
2024-001 Segregation of Duties – Loan Program Significant Deficiency Recommendation: The Housing Authority’s fiscal policies should be revised to ensure that preventive controls are in place over check disbursements for loan disbursements, such that checks must be signed with live signatures at leas...
2024-001 Segregation of Duties – Loan Program Significant Deficiency Recommendation: The Housing Authority’s fiscal policies should be revised to ensure that preventive controls are in place over check disbursements for loan disbursements, such that checks must be signed with live signatures at least the signature of one Tribal Council member. Further, individuals who benefit from the loan program should not have complete discretion over recording and processing of advances and repayment. We recommend a complete list of outstanding balances be presented to the Tribal Council, or its designee, for continued monitoring. Action Taken: The SCCHA discontinued the Loan Program as of November 2019. A complete list of balances owed has been submitted to the Tribal Council with the outstanding balances of those whom had signatory authority forwarded to the St. Croix Tribal Court for further repayment actions.
Condition: The Organization did not submit the budget to HUD within 30 days of the start of its fiscal year. Planned Corrective Action: Management has implemented a new review and oversight process related to the process for the budget submissions in question to ensure timely submission on a go-forw...
Condition: The Organization did not submit the budget to HUD within 30 days of the start of its fiscal year. Planned Corrective Action: Management has implemented a new review and oversight process related to the process for the budget submissions in question to ensure timely submission on a go-forward basis. Contact person responsible for corrective action: Louise Arzu, Vice President, Finance Anticipated Completion Date: 9/30/2026
Management has updated the policies and procedures manual to address this finding. For each housing unit, we are using the Department of Housing and Urban Development (HUB) rent reasonableness form at lease signing. This form will be updated annually for each unit. We will also be following the HUD ...
Management has updated the policies and procedures manual to address this finding. For each housing unit, we are using the Department of Housing and Urban Development (HUB) rent reasonableness form at lease signing. This form will be updated annually for each unit. We will also be following the HUD fair market rent determinations.
Finding Number 2024-053 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) acknowledges subrecipient monitoring process lacked the strength and co...
Finding Number 2024-053 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) acknowledges subrecipient monitoring process lacked the strength and consistency to ensure subrecipients established and maintained effective internal control. OMES acknowledges that OMES did not implement the proper internal controls and oversight of the ERA Program during FY2024. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI in these findings. Beginning with FY2025, OMES has taken the following measures: • OMES disagrees that they had sufficient and timely notice to make full corrective actions prior to this FY2024 audit for the following reasons: the FY2021 State auditor & Inspector (SAI) audit was released four days prior to the beginning of FY2024, the FY2022 SAI audit was released near the end of FY2025, and the FY2023 audit was released in FY2026; therefore, OMES could not take corrective action prior to the FY2024 audit began. At the beginning of FY2025, OMES began corrective measures as noted in SAI’s Condition and Context in this finding. • OMES acknowledges OMES subrecipient monitoring process lacked the strength and consistency to ensure subrecipients established and maintained effective internal control. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI as noted in SAI’s Condition and Context in this finding. Beginning with FY2025, OMES has taken the following measures:  Oversight and management of the ERA program has been transferred to the OMES Grant Management Office (OMES-GMO) which has staff with several years of grant experience. OMES-GMO has recently hired additional staff, and the two staff members dedicated to the management of the ERA program have 20+ years of combined federal grant specific experience.  OMES ensured that the subrecipient agreement included all the required terms under the ERA Program and that the agreement does not expire, OMES-GMO and the Communities of Foundation of Oklahoma (CFO) executed an updated Subrecipient Grant Agreement Amendment that details the responsibilities of OMES to monitor CFO and the duties and processes that CFO must follow in regard to ERA Program, including detailed cash management policies.  OMES-GMO required the return of the remaining ERA2 Program funds from CFO to ensure proper oversight and review of ERA expenditures is performed.  OMES-GMO has in place a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. For example, OMES-GMO’s process for disbursing funds to a subrecipient requires a written request from the subrecipient with supporting documentation, then OMES-GMO assigns a staff lead and secondary grant analyst to perform a primary and secondary review for compliance and to require additional supporting documentation if needed to approve the request. Once those reviews are completed and approved by the OMES-GMO staff, the Director of the OMES-GMO must approve the request before it is sent to the OMES Finance Division, who will then verify the calculated amount(s) before completing the disbursement to the subrecipient. These internal controls and policies have been implemented for the management and oversight of the ERA Program and provide a multilayer review that will prevent fraud and risk factors applicable to the ERA program. Additionally, the OMES-GMO staff assigned to the ERA program have the training and knowledge to ensure compliance with the Federal grant requirements.  Depending on the level of risk, OMES-GMO conducts monthly, bi-weekly or weekly meetings with each subrecipient to monitor the progress of projects and address any issues or changes that might impact the project. For the ERA Program, OMESGMO conducted bi-weekly monitoring meetings with CFO and reviewed documentation provided by CFO to ensure all ERA projects were eligible under the ERA guidelines and that CFO exercised the proper oversight over their subrecipients and spending. Anticipated Completion Date Completed Responsible Contact Person Brandy Manek
Finding Number 2024-038 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) acknowledges subrecipient monitoring process lacked the strength and co...
Finding Number 2024-038 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) acknowledges subrecipient monitoring process lacked the strength and consistency to ensure subrecipients established and maintained effective internal control. OMES acknowledges that OMES did not implement the proper internal controls and oversight of the ERA Program during FY2024. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI in these findings. Beginning with FY2025, OMES has taken the following measures: • OMES disagrees that they had sufficient and timely notice to make full corrective actions prior to this FY2024 audit for the following reasons: the FY2021 State auditor & Inspector (SAI) audit was released four days prior to the beginning of FY2024, the FY2022 SAI audit was released near the end of FY2025, and the FY2023 audit was released in FY2026; therefore, OMES could not take corrective action prior to the FY2024 audit began. At the beginning of FY2025, OMES began corrective measures as noted in SAI’s Condition and Context in this finding. • OMES acknowledges OMES subrecipient monitoring process lacked the strength and consistency to ensure subrecipients established and maintained effective internal control. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI as noted in SAI’s Condition and Context in this finding. Beginning with FY2025, OMES has taken the following measures:  Oversight and management of the ERA program has been transferred to the OMES Grant Management Office (OMES-GMO) which has staff with several years of grant experience. OMES-GMO has recently hired additional staff, and the two staff members dedicated to the management of the ERA program have 20+ years of combined federal grant specific experience.  OMES ensured that the subrecipient agreement included all the required terms under the ERA Program and that the agreement does not expire, OMES-GMO and the Communities of Foundation of Oklahoma (CFO) executed an updated Subrecipient Grant Agreement Amendment that details the responsibilities of OMES to monitor CFO and the duties and processes that CFO must follow in regard to ERA Program, including detailed cash management policies.  OMES-GMO required the return of the remaining ERA2 Program funds from CFO to ensure proper oversight and review of ERA expenditures is performed.  OMES-GMO has in place a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. For example, OMES-GMO’s process for disbursing funds to a subrecipient requires a written request from the subrecipient with supporting documentation, then OMES-GMO assigns a staff lead and secondary grant analyst to perform a primary and secondary review for compliance and to require additional supporting documentation if needed to approve the request. Once those reviews are completed and approved by the OMES-GMO staff, the Director of the OMES-GMO must approve the request before it is sent to the OMES Finance Division, who will then verify the calculated amount(s) before completing the disbursement to the subrecipient. These internal controls and policies have been implemented for the management and oversight of the ERA Program and provide a multilayer review that will prevent fraud and risk factors applicable to the ERA program. Additionally, the OMES-GMO staff assigned to the ERA program have the training and knowledge to ensure compliance with the Federal grant requirements.  Depending on the level of risk, OMES-GMO conducts monthly, bi-weekly or weekly meetings with each subrecipient to monitor the progress of projects and address any issues or changes that might impact the project. For the ERA Program, OMESGMO conducted bi-weekly monitoring meetings with CFO and reviewed documentation provided by CFO to ensure all ERA projects were eligible under the ERA guidelines and that CFO exercised the proper oversight over their subrecipients and spending. Anticipated Completion Date Completed Responsible Contact Person Brandy Manek
Finding Number 2024-020 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) acknowledges they did not implement the proper internal controls and ov...
Finding Number 2024-020 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) acknowledges they did not implement the proper internal controls and oversight of the ERA Program during FY2024. However, OMES has taken steps to correct these findings and has followed the recommendations set forth by SAI as evidenced in the Recommendation section of this finding. Beginning with FY2025, OMES has taken the following measures:  Oversight and management of the ERA program has been transferred to the OMES Grant Management Office (OMES-GMO) which has staff with several years of grant experience. OMES-GMO has recently hired additional staff, and the two staff members dedicated to the management of the ERA program have 20+ years of combined federal grant specific experience.  OMES ensured that the subrecipient agreement included all the required terms under the ERA Program and that the agreement does not expire, OMES-GMO and the Communities of Foundation of Oklahoma (CFO) executed an updated Subrecipient Grant Agreement Amendment that details the responsibilities of OMES to monitor CFO and the duties and processes that CFO must follow in regard to ERA Program, including detailed cash management policies.  OMES-GMO required the return of the remaining ERA2 Program funds from CFO to ensure proper oversight and review of ERA expenditures is performed.  OMES-GMO has in place a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. For example, OMES-GMO’s process for disbursing funds to a subrecipient requires a written request from the subrecipient with supporting documentation, then OMES-GMO assigns a staff lead and secondary grant analyst to perform a primary and secondary review for compliance and to require additional supporting documentation if needed to approve the request. Once those reviews are completed and approved by the OMES-GMO staff, the Director of the OMES-GMO must approve the request before it is sent to the OMES Finance Division, who will then verify the calculated amount(s) before completing the disbursement to the subrecipient. These internal controls and policies have been implemented for the management and oversight of the ERA Program and provide a multilayer review that will prevent fraud and risk factors applicable to the ERA program. Additionally, the OMES-GMO staff assigned to the ERA program have the training and knowledge to ensure compliance with the Federal grant requirements. Depending on the level of risk, OMES-GMO conducts monthly, bi-weekly or weekly meetings with each subrecipient to monitor the progress of projects and address any issues or changes that might impact the project. For the ERA Program, OMES-GMO conducted bi-weekly monitoring meetings with CFO and reviewed documentation provided by CFO to ensure all ERA projects were eligible under the ERA guidelines and that CFO exercised the proper oversight over their subrecipients and spending. Anticipated Completion Date Completed Responsible Contact Person Brandy Manek
Finding Number 2024-084 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action OKDHS agrees with the finding and recommendation. The agency recognizes that the volume of GI DX discrepancy messages, combined with limited automated triage cap...
Finding Number 2024-084 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action OKDHS agrees with the finding and recommendation. The agency recognizes that the volume of GI DX discrepancy messages, combined with limited automated triage capabilities, contributed to delays in resolving exceptions within the required 45-calendar-day timeframe. As noted by the auditors, the existing process relied heavily on manual review and did not provide sufficient management oversight tools to effectively monitor aging discrepancies and ensure timely resolution. Corrective Action Planned: OKDHS has initiated a multi-faceted corrective action plan designed to improve the timeliness, consistency, and accountability of GI DX exception resolution. As part of this effort, OKDHS is developing an automated prescreening process for National New Hire (NNH), State New Hire (SNH), and Oklahoma Wage (OWG) discrepancy messages. The automated process is intended to evaluate discrepancies against established policy criteria and reduce the number of non-actionable matches requiring manual review. Discrepancies identified as requiring staff review will be routed to eligibility staff with standardized documentation and processing guida nee. Additionally, OKDHS is developing formal procedures governing the review, monitoring, and resolution of GIDX discrepancies. These procedures will def me staff responsibilities, supervisory oversight expectations, escalation requirements, and management use of exception monitoring reports to support timely resolution of discrepancies. Management reporting and monitoring controls are also being enhanced to improve visibility into outstanding discrepancies and aging trends. Supervisors and program management will utilize exception reporting to monitor workloads, identify training opportunities, and promote accountability for timely processing. OKDHS will also provide training and implementation guidance to staff and supervisors regarding revised workflows, discrepancy resolution requirements, documentation standards, and management monitoring expectations. The agency anticipates implementation of the planned enhancements beginning in October 2026, with continued monitoring and refinement following deployment to ensure the corrective actions effectively address the underlying control deficiencies identified in the finding. OHCA MEMBER AUDIT Auditor Response: Member Audit began receiving Medicaid files monthly in September of 2023. Files are continuing to be received from DHS each month. Audits are completed monthly and will continue indefinitely. Any discrepancies are discussed with OKDHS to determine the cause and remedy put in place to ensure any failed jobs were resolved. Anticipated Completion Date October 2026 Responsible Contact Person OKDHS Contact: Kayla Urtz, Director of Internal Audit OHCA Contact: Tana Parrott, Director of Member Audits
Finding Number 2024-084 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 - Medicaid Planned Corrective Action OKDHS agrees with the finding and recommendation. The agency recognizes that the volume of GI DX discrepancy messages, combined with limited automated triage capabilit...
Finding Number 2024-084 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 - Medicaid Planned Corrective Action OKDHS agrees with the finding and recommendation. The agency recognizes that the volume of GI DX discrepancy messages, combined with limited automated triage capabilities, contributed to delays in resolving exceptions within the required 45-calendar-day timeframe. As noted by the auditors, the existing process relied heavily on manual review and did not provide sufficient management oversight tools to effectively monitor aging discrepancies and ensure timely resolution. OKDHS has initiated a muti-faceted corrective action plan designed to improve the timeliness, consistency, and accountability of G1DX exception resolution. As part of this effort, OKDHS is developing an automated pre-screening process for National New Hire (NNH), State New Hire (SNH), and Oklahoma Wage (OWG) discrepancy messages. The automated process is intended to evaluate discrepancies against established policy criteria and reduce the number of non-actionable matches requiring manual review. Discrepancies identified as requiring staff review will be routed to eligibility staff with standardized documentation and processing guidance. Additionally, OKDHS is developing formal procedures governing the review, monitoring, and resolution of GIDX discrepancies. These procedures will define staff responsibilities, supervisory oversight expectations, escalation requirements, and management use of exception monitoring reports to support the timely resolution of discrepancies. Management reporting and monitoring controls are also being enhanced to improve visibility into outstanding discrepancies and aging trends. Supervisors and program management will utilize exception reporting to monitor workloads, identify training opportunities, and promote accountability for timely processing. OKDHS will also provide training and implementation guidance to staff and supervisors regarding revised workflows, discrepancy resolution requirements, documentation standards, and management monitoring expectations. The agency anticipates implementation of the planned enhancements beginning in October 2026, with continued monitoring and refinement following deployment to ensure the corrective actions effectively address the underlying control deficiencies identified in the finding. Anticipated Completion Date 10/5/26 and OHCA will continue monitoring through SFY2025 Responsible Contact Person Kayla Urtz and Tana Parrott, OHCA
Finding Number 2024-006 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action Per recommendation from the State Auditor & Inspector listed above. The Oklahoma Health Care Authority (OHCA) will continue to implement the Corrective Action Pl...
Finding Number 2024-006 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action Per recommendation from the State Auditor & Inspector listed above. The Oklahoma Health Care Authority (OHCA) will continue to implement the Corrective Action Plan processes which include collaborating with the Medicaid Fraud Control Unit at the Oklahoma Attorney General’s office quarterly to track the status of closed cases, obtaining sufficient supporting documentation, and timely report and refund identified overpayments on the CMS-64. Anticipated Completion Date Review at end of State Fiscal Year (SFY) 2025 Responsible Contact Person Kristin Edwards OHCA Senior Director of Program and Integrity
Finding Number 2024-081 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action OKDHS agrees with the finding and recommendation. The agency recognizes that the volume of GI DX discrepancy messages, combined with limited automated triage capab...
Finding Number 2024-081 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action OKDHS agrees with the finding and recommendation. The agency recognizes that the volume of GI DX discrepancy messages, combined with limited automated triage capabilities, contributed to delays in resolving exceptions within the required 45-calendar-day timeframe. As noted by the auditors, the existing process relied heavily on manual review and did not provide sufficient management oversight tools to effectively monitor aging discrepancies and ensure timely resolution. OKDHS has initiated a muti-faceted corrective action plan designed to improve the timeliness, consistency, and accountability of G1DX exception resolution. As part of this effort, OKDHS is developing an automated pre-screening process for National New Hire (NNH), State New Hire (SNH), and Oklahoma Wage (OWG) discrepancy messages. The automated process is intended to evaluate discrepancies against established policy criteria and reduce the number of non-actionable matches requiring manual review. Discrepancies identified as requiring staff review will be routed to eligibility staff with standardized documentation and processing guidance. Additionally, OKDHS is developing formal procedures governing the review, monitoring, and resolution of GIDX discrepancies. These procedures will define staff responsibilities, supervisory oversight expectations, escalation requirements, and management use of exception monitoring reports to support the timely resolution of discrepancies. Management reporting and monitoring controls are also being enhanced to improve visibility into outstanding discrepancies and aging trends. Supervisors and program management will utilize exception reporting to monitor workloads, identify training opportunities, and promote accountability for timely processing. OKDHS will also provide training and implementation guidance to staff and supervisors regarding revised workflows, discrepancy resolution requirements, documentation standards, and management monitoring expectations. The agency anticipates implementation of the planned enhancements beginning in October 2026, with continued monitoring and refinement following deployment to ensure the corrective actions effectively address the underlying control deficiencies identified in the finding. Anticipated Completion Date 10/5/26 Responsible Contact Person Kayla Urtz
Finding Number 2024-037 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action The Oklahoma Department of Human Services (OKDHS) respectfully disagrees with this finding because the questioned costs are based on application of standard Child ...
Finding Number 2024-037 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action The Oklahoma Department of Human Services (OKDHS) respectfully disagrees with this finding because the questioned costs are based on application of standard Child Care payment requirements rather than the temporary COVID-19 payment flexibilities that governed the program during the audit period. Oklahoma's temporary Child Care payment flexibilities were incorporated into the Oklahoma Child Care and Development Fund (CCDF) State Plan Amendments and approved by the Administration for Children and Families (ACF). Those approved provisions constituted the governing payment requirements during the public health emergency and represent the appropriate criteria against which these transactions should be evaluated. The finding acknowledges that Oklahoma's temporary COVID-19 payment flexibilities included reimbursement of part-time school-age care at the full-time reimbursement rate and that these temporary policies were incorporated into the federally approved State Plan Amendments. These temporary payment methodologies were intentionally established to stabilize child care providers during the COVID-19 public health emergency. However, despite acknowledging the existence of these federally approved flexibilities, the questioned costs are derived by applying standard program requirements rather than the temporary payment framework approved by ACF and in effect during the audit period. Accordingly, the Agency believes the transactions should be evaluated using the federally approved emergency payment requirements rather than the standard reimbursement methodology that had been temporarily modified. The Agency further notes that the costs questioned are not based on payments for services provided during the regular school day, but rather on the auditors' interpretation of how the temporary COVID-19 payment flexibilities should have been applied. Likewise, the audit does not identify deficiencies in provider eligibility determinations, approved reimbursement rates, payment calculations, or the Agency's authority to implement the temporary payment flexibilities approved by ACF. Instead, the disagreement centers on the interpretation of the temporary payment rules that governed the program during the emergency period. OKDHS recognizes that the audit identified an opportunity to strengthen detective controls over attendance patterns and absent-day payments. The Agency has continued to enhance provider guidance, supervisory review, and analytical monitoring to better identify potential payment anomalies and improve consistency in the administration of payment policies. Because the questioned costs result from application of audit criteria that do not reflect the federally approved payment framework governing the audit period, OKDHS respectfully disagrees with the condition, cause, effect, recommendation, and questioned costs identified in this finding. Although the Agency disagrees with the audit's conclusions, Child Care Services has continued to review and clarify payment guidance, reinforce policy training, and strengthen oversight procedures to support consistent administration of both temporary and permanent payment policies. This will be implemented with the upcoming child care billing system. Anticipated Completion Date In Progress Responsible Contact Person Kayla Urtz
Finding Number 2024-032 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action The Oklahoma Department of Human Services (OKDHS) partially concurs with this finding. The Agency agrees opportunities existed to strengthen oversight of Child Car...
Finding Number 2024-032 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action The Oklahoma Department of Human Services (OKDHS) partially concurs with this finding. The Agency agrees opportunities existed to strengthen oversight of Child Care provider monitoring activities and has implemented corrective actions to enhance monitoring procedures, documentation, supervisory oversight, Quality Rating and Improvement System (QRIS) verification, and monitoring during non-traditional operating hours. Child Care Services has resumed full QRIS monitoring, implemented precertification visits, enhanced monitoring documentation, strengthened supervisory review, expanded staff training, and continues to refer suspected fraud or misuse of program funds to the Office of Inspector General for investigation. The Agency also recognizes the analytical techniques utilized during the audit as a valuable opportunity to strengthen its detective control environment. OKDHS is evaluating implementation of similar data analytics as part of its routine monitoring activities to better identify providers that warrant additional review. These analytics will enhance oversight by directing monitoring resources toward higher-risk providers while complementing existing licensing and investigative processes. This will become possible to implement shortly with the implementation of the new childcare invoicing system. However, the Agency respectfully disagrees with the questioned costs. The finding identifies a weakness in one component of the Agency's oversight framework but does not demonstrate that the underlying provider payments failed to satisfy applicable federal or state reimbursement requirements. Licensing monitoring is intended to evaluate compliance with health and safety requirements, while payment allowability is supported through separate controls, including child eligibility determinations, authorized rate assignments, electronic attendance records, and automated payment system edits. The audit did not identify deficiencies in these payment controls or demonstrate that providers receiving the questioned payments failed to meet the requirements governing reimbursement. The Agency also respectfully disagrees with the report's characterization of the non-traditional hours payment methodology. Non-traditional hours enhancements are payable only when established eligibility, attendance, and reimbursement requirements have been satisfied in accordance with the approved Child Care Provider Rate Schedule. Accordingly, the Agency does not believe the hypothetical examples contained in the finding accurately reflect how non-traditional hours payments are authorized or processed. While the Agency agrees that strengthening monitoring activities and expanding analytical oversight will further reduce program risk, the presence of analytical risk indicators or the absence of a monitoring visit during nontraditional hours does not, by itself, establish that otherwise supported expenditures are unsupported or unallowable. The Agency believes the audit appropriately identified opportunities to strengthen preventive and detective controls but does not believe the evidence demonstrates that the questioned costs represent improper expenditures. Anticipated Completion Date In Progress Responsible Contact Person Kayla Urtz
Finding Number 2024-082 Subject Heading (Financial) or AL no. and program name (Federal) 93.568 – LIHEAP Planned Corrective Action OKDHS agrees with the finding and recommendation. The agency recognizes that the volume of GI DX discrepancy messages, combined with limited automated triage capabilitie...
Finding Number 2024-082 Subject Heading (Financial) or AL no. and program name (Federal) 93.568 – LIHEAP Planned Corrective Action OKDHS agrees with the finding and recommendation. The agency recognizes that the volume of GI DX discrepancy messages, combined with limited automated triage capabilities, contributed to delays in resolving exceptions within the required 45-calendar-day timeframe. As noted by the auditors, the existing process relied heavily on manual review and did not provide sufficient management oversight tools to effectively monitor aging discrepancies and ensure timely resolution. OKDHS has initiated a muti-faceted corrective action plan designed to improve the timeliness, consistency, and accountability of G1DX exception resolution. As part of this effort, OKDHS is developing an automated pre-screening process for National New Hire (NNH), State New Hire (SNH), and Oklahoma Wage (OWG) discrepancy messages. The automated process is intended to evaluate discrepancies against established policy criteria and reduce the number of non-actionable matches requiring manual review. Discrepancies identified as requiring staff review will be routed to eligibility staff with standardized documentation and processing guidance. Additionally, OKDHS is developing formal procedures governing the review, monitoring, and resolution of GIDX discrepancies. These procedures will define staff responsibilities, supervisory oversight expectations, escalation requirements, and management use of exception monitoring reports to support the timely resolution of discrepancies. Management reporting and monitoring controls are also being enhanced to improve visibility into outstanding discrepancies and aging trends. Supervisors and program management will utilize exception reporting to monitor workloads, identify training opportunities, and promote accountability for timely processing. OKDHS will also provide training and implementation guidance to staff and supervisors regarding revised workflows, discrepancy resolution requirements, documentation standards, and management monitoring expectations. The agency anticipates implementation of the planned enhancements beginning in October 2026, with continued monitoring and refinement following deployment to ensure the corrective actions effectively address the underlying control deficiencies identified in the finding. Anticipated Completion Date 10/5/26 Responsible Contact Person Kayla Urtz
Finding Number 2024-060 Subject Heading (Financial) or AL no. and program name (Federal) 93.658 - LIHEAP Planned Corrective Action OKDHS concurs that the control environment in place during the period reviewed did not provide adequate segregation of duties and allowed incompatible responsibilities t...
Finding Number 2024-060 Subject Heading (Financial) or AL no. and program name (Federal) 93.658 - LIHEAP Planned Corrective Action OKDHS concurs that the control environment in place during the period reviewed did not provide adequate segregation of duties and allowed incompatible responsibilities to be concentrated within the program area. OKDHS takes the identified fraudulent activity and associated control weaknesses seriously. The fraudulent activity involved intentional actions by a former employee who was able to exploit excessive access and insufficient segregation between program administration, vendor maintenance, and payment-related processes. Upon identification of the suspected activity, OKDHS took action to remove the employee's access, terminate employment, and refer the matter for investigation and appropriate legal action. OKDHS continues to cooperate with investigative authorities regarding the full scope of the activity. In response, OKDHS is not limiting corrective action to additional review within the existing LIHEAP process. The Agency is redesigning the underlying business processes to separate program administration from vendor registration, vendor maintenance, contracting, financial reporting, and payment processing. The corrective actions described below are intended to establish independent controls across multiple organizational functions and reduce reliance on information prepared and controlled solely within the program area. Enhanced Financial Reporting and Oversight OKDHS Finance is working to obtain more detailed, transaction-level LIHEAP information to support independent financial oversight and reconciliation. Historically, Finance relied substantially on summarized information provided by the program area. The enhanced reporting structure is intended to provide Finance with greater visibility into underlying LIHEAP transactions and improve its ability to independently reconcile, review, and analyze program expenditures. This increased access to detailed information will also support the development of exception reporting and other analytical procedures designed to identify unusual payment activity, vendor activity, or other anomalies requiring additional review. Transition of LIHEAP Payments to PeopleSoft OKDHS is working with its technical teams to transition LIHEAP payment processing to PeopleSoft. This change will integrate LIHEAP payments into the Agency's established financial system and associated financial controls rather than maintaining a separate program controlled vendor and payment process. Under the redesigned process, LIHEAP providers will be required to complete the applicable statewide vendor registration process before receiving payment. Vendor establishment and maintenance, including changes to vendor information, will therefore be subject to controls outside of the LIHEAP program area. The transition will eliminate the program area's ability to independently maintain the vendor information used to facilitate LIHEAP payments and will provide greater segregation between program eligibility and benefit authorization responsibilities and the vendor establishment and payment functions. Centralized Vendor Registration and Maintenance As part of the transition to PeopleSoft, the existing AFS vendor-maintenance process will be replaced by the statewide vendor registration and maintenance process. LIHEAP program staff will no longer independently control the establishment or maintenance of the vendor records used for payment. This change is intended to ensure that vendor creation and modification are performed through an independent process and are appropriately separated from program functions responsible for determining eligibility and authorizing benefits. Formal Provider Contracting OKDHS Procurement is working to establish contracts with LIHEAP providers. Formalizing provider relationships through the procurement and contracting process will establish additional independent review and documentation before providers participate in the program and receive payments. The contracting process will also provide a defined mechanism for establishing provider responsibilities, maintaining provider information, and addressing compliance or performance concerns. Strengthened Segregation of Duties Collectively, these changes are designed to establish segregation across the major components of the LIHEAP process: • AFS/LIHEAP program staff will remain responsible for program administration and applicable eligibility and benefit determinations; • Statewide vendor registration and financial system processes will control vendor establishment and maintenance; • Procurement will oversee the formal contracting process with participating providers; and • Finance will have increased access to detailed transaction information to support independent financial oversight, reconciliation, and analysis. This structure is intended to prevent a single employee or organizational unit from controlling the program, vendor, and payment functions necessary to initiate and conceal improper transactions. System Controls and Monitoring As the redesigned processes are implemented, OKDHS will continue to evaluate system controls, access permissions, exception reporting, and data analytics to identify unusual vendor or payment activity. The transition to centralized vendor registration, PeopleSoft payment processing, formal provider contracting, and enhanced financial reporting will provide additional opportunities for independent review and monitoring. OKDHS will also continue to cooperate with OIG and other appropriate investigative and legal authorities regarding the identified fraudulent activity and will pursue appropriate recovery and corrective actions based on the results of those proceedings. These actions represent a significant redesign of the LIHEAP control environment and are intended to address the underlying conditions that allowed the fraudulent activity to occur and remain undetected. By distributing responsibility for program administration, vendor registration and maintenance, contracting, financial oversight, and payment processing across independent functions, OKDHS is establishing a more sustainable control structure designed to reduce the risk of similar fraudulent activity in the future. Anticipated Completion Date In Progress Responsible Contact Person Kayla Urtz
Finding Number 2024-027 Subject Heading (Financial) or AL no. and program name (Federal) 93.568 - LIHEAP Planned Corrective Action Due to the age and sophistication of updating our current systems, many of our LIHEAP processes and reporting have become outdated. AFS, Finance, and DTO have several pr...
Finding Number 2024-027 Subject Heading (Financial) or AL no. and program name (Federal) 93.568 - LIHEAP Planned Corrective Action Due to the age and sophistication of updating our current systems, many of our LIHEAP processes and reporting have become outdated. AFS, Finance, and DTO have several projects in the pipeline to improve system and program reporting and to improve the reconciliation of eligibility and payment data. Anticipated Completion Date 10/31/2026 Responsible Contact Person Kayla Urtz
Finding Number 2024-012 Subject Heading (Financial) or AL no. and program name (Federal) 93.568 – LIHEAP Planned Corrective Action OKDHS's vendor currently utilizes a live database to source the data needed for the Quarterly Report. OKDHS will require those pulling the data to provide a snapshot of ...
Finding Number 2024-012 Subject Heading (Financial) or AL no. and program name (Federal) 93.568 – LIHEAP Planned Corrective Action OKDHS's vendor currently utilizes a live database to source the data needed for the Quarterly Report. OKDHS will require those pulling the data to provide a snapshot of the database that supports the data used and store these snapshots for our records to better support point in time federal reports. OKDHS program staff will continue to review data submissions and monitor for inconsistencies. OKDHS will add instructions to the Standard Operating Procedures that detail the Program Field Representative and Program Manager reviews. Anticipated Completion Date 10/31/2026 Responsible Contact Person Kayla Urtz
Finding Number 2024-062 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 – TANF Planned Corrective Action OKDHS concurs that documentation supporting the preparation, reconciliation, and review of the ACF-196R should be strengthened. OKDHS has previously directed the CARE team...
Finding Number 2024-062 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 – TANF Planned Corrective Action OKDHS concurs that documentation supporting the preparation, reconciliation, and review of the ACF-196R should be strengthened. OKDHS has previously directed the CARE team to improve documentation of adjustments and corrections made during the financial reporting process, including maintaining sufficient support to clearly identify the nature and basis of changes made to reported amounts. OKDHS is currently working through its financial reporting and reconciliation processes to strengthen the connection between federal financial reports, supporting worksheets, and underlying accounting records. This effort is intended to improve the consistency and transparency of adjustments and corrections and provide a clearer audit trail supporting both report preparation and independent review. OKDHS will continue to formalize and standardize its federal financial reporting and reconciliation procedures. The updated process will include requirements for documenting adjustments and corrections, reconciling reported amounts to underlying financial records, retaining supporting documentation, and documenting independent review of the completed report and related reconciliations. Anticipated Completion Date 9/30/2026 Responsible Contact Person Kayla Urtz
Finding Number 2024-041 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 – TANF Planned Corrective Action OKDHS agrees with the finding and recommendation. The agency recognizes that the volume of GI DX discrepancy messages, combined with limited automated triage capabilities,...
Finding Number 2024-041 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 – TANF Planned Corrective Action OKDHS agrees with the finding and recommendation. The agency recognizes that the volume of GI DX discrepancy messages, combined with limited automated triage capabilities, contributed to delays in resolving exceptions within the required 45-calendar-day timeframe. As noted by the auditors, the existing process relied heavily on manual review and did not provide sufficient management oversight tools to effectively monitor aging discrepancies and ensure timely resolution. OKDHS has initiated a muti-faceted corrective action plan designed to improve the timeliness, consistency, and accountability of G1DX exception resolution. As part of this effort, OKDHS is developing an automated pre-screening process for National New Hire (NNH), State New Hire (SNH), and Oklahoma Wage (OWG) discrepancy messages. The automated process is intended to evaluate discrepancies against established policy criteria and reduce the number of non-actionable matches requiring manual review. Discrepancies identified as requiring staff review will be routed to eligibility staff with standardized documentation and processing guidance. Additionally, OKDHS is developing formal procedures governing the review, monitoring, and resolution of GIDX discrepancies. These procedures will define staff responsibilities, supervisory oversight expectations, escalation requirements, and management use of exception monitoring reports to support the timely resolution of discrepancies. Management reporting and monitoring controls are also being enhanced to improve visibility into outstanding discrepancies and aging trends. Supervisors and program management will utilize exception reporting to monitor workloads, identify training opportunities, and promote accountability for timely processing. OKDHS will also provide training and implementation guidance to staff and supervisors regarding revised workflows, discrepancy resolution requirements, documentation standards, and management monitoring expectations. The agency anticipates implementation of the planned enhancements beginning in October 2026, with continued monitoring and refinement following deployment to ensure the corrective actions effectively address the underlying control deficiencies identified in the finding. Anticipated Completion Date 10/5/26 Responsible Contact Person Kayla Urtz
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