Corrective Action Plans

Finding 1155631 (2023-001)

Material Weakness 2023

Philadelphia Area Labor Management Committee

PA

Reporting Internal Control / Segregation of Duties § 200.512

U.S. Department of Commerce, Philadelphia Works, Inc. 2023-1 Timely submission of Data Collection Form – Assistance Listing Number 11.307 Recommendation: We recommend PALM engage a certified public accountant to conduct a Single Audit as long as the PALM meets the Single Audit criteria Explanation o...

U.S. Department of Commerce, Philadelphia Works, Inc. 2023-1 Timely submission of Data Collection Form – Assistance Listing Number 11.307 Recommendation: We recommend PALM engage a certified public accountant to conduct a Single Audit as long as the PALM meets the Single Audit criteria Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has engaged a certified public accountant to complete a Single Audit and assist in the submission of the data collection form. Name of contact person responsible for corrective action: Anthony Wigglesworth, Executive Director. Corrective action plan has been implemented prior to the due date of the December 31, 2024 data collection form.

View Audit 367886

Finding 1155487 (2023-003)

Material Weakness 2023

Oak Hill United School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-003 Finding Subject: COVID-19-Education Stabilization Fund - Reporting Summary of Finding: The School Corporation was required to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not lim...

FINDING 2023-003 Finding Subject: COVID-19-Education Stabilization Fund - Reporting Summary of Finding: The School Corporation was required to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were prepared by the Treasurer. Due to the lack of effective internal controls one of the six annual data reports was not supported by the School Corporation’s records. For the ESSER III, Year 2 report, which covered the period of July 1, 2021 to June 30, 2022, total expenses per the report were $688,778. However, the School Corporation’s ledger had total expenses for the award, for that time period, of $784,638. The lack of controls and noncompliance were isolated to the ESSER III, Year 2 report. Contact Person Responsible for Corrective Action: Leslie Rittenhouse Contact Phone Number and Email Address: 765-395-3341 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: As the finding and error occurred in one entry of one report the district will continue the practice of having a second party review financial system data against report entries. The error in this instance was a misunderstanding of the entry. A secondary review of reporting guidelines and entries will take place prior to submission of any ESSER Data Reporting. Anticipated Completion Date: Upon the next submission of ESSER Data reporting.

View Audit 367782

Finding 1155459 (2023-003)

Material Weakness 2023

Claremont Learning Partnership

NH

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.313 § 200.317 § 200.431

Finding 2023-003: Establish and maintain effective internal control over the Federal award Plan: We have ensured all policies and procedures have been vetted by an attorney and approved by the River View Board of Trustees and the Claremont Learning Partnership Board of Directors. Moving forward, the...

Finding 2023-003: Establish and maintain effective internal control over the Federal award Plan: We have ensured all policies and procedures have been vetted by an attorney and approved by the River View Board of Trustees and the Claremont Learning Partnership Board of Directors. Moving forward, the Executive Director will ensure that all policies and procedures stay current and are reviewed by the Board annually. FY-22 & FY-23 Audits were completed in tandem, all corrections were made as soon as the issue was identified. Expected Implementation Date: RiverView amended the policy on June 17, 2025, CLP amended the policy on July 3, 2025. Contact: Cathy Pellerin Executive Director, Claremont Learning Partnership 169 Main Street; Claremont, NH 03743 603-287-7120

View Audit 367741

Finding 1155375 (2023-004)

Material Weakness 2023

Vigo County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

FINDING 2023-004 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment The County had not performed procedures to ensure the vendors were not suspended or debarred or otherwise excluded or disqualified from participation in federal assistance progra...

FINDING 2023-004 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment The County had not performed procedures to ensure the vendors were not suspended or debarred or otherwise excluded or disqualified from participation in federal assistance programs or activities during the audit period on all of the 3 vendors determined to have covered transactions, totaling $141,131, that were paid with SLFRF funds. Contact Person Responsible for Corrective Action: Larry Hutchings Larry.hutchings@vigocounty.in.gov 812-462-3361 Views of Responsible Officials: We concur with the findings Description of The Corrective Action Plan: The Auditors Office has created a Policy for Suspension and Debarment within the Subrecipient Ploicy. A clause or condition must also be included in the covered transaction with that entity to require reporting of any debarment or suspension occurring during the subgrant period; and, Maintain documentation to support the verification was done before or at the time of contract execution. Anticipated Completion Date – 08/13/2025

View Audit 367621

Finding 1155309 (2023-015)

Material Weakness 2023

The City of Frederick, Maryland

MD

Questioned Costs Subrecipient Monitoring Eligibility

All expenditures will be verified prior to disbursement to ensure they are paid within the defined grant period.

View Audit 367551 Questioned Costs: $1

Finding 1155308 (2023-014)

Material Weakness 2023

The City of Frederick, Maryland

MD

Subrecipient Monitoring Eligibility Reporting

The Maryland Departments of Human Services (DHS) and Housing and Community Development (DHCD) are the direct recipient of the federal funds for OHEP and WAP, respectively. Because of this, all verification occurs on the state level and HHS does not have access to all pertinent information. As the re...

The Maryland Departments of Human Services (DHS) and Housing and Community Development (DHCD) are the direct recipient of the federal funds for OHEP and WAP, respectively. Because of this, all verification occurs on the state level and HHS does not have access to all pertinent information. As the recipient of these funds, HHS is informed by DHS or DHCD when a Crisis Client is to be served by HHS. HHS is not responsible for the verification of Crisis Client eligibility for either program.

View Audit 367551

Finding 1155307 (2023-013)

Material Weakness 2023

The City of Frederick, Maryland

MD

Subrecipient Monitoring Reporting Significant Deficiency

SharePoint is being utilized to track reporting requirements to ensure timely filings. The Department will continue to explore ways to streamline the process. However, final numbers for the prior month are typically not available until the second week after the close of the month. This is complicate...

SharePoint is being utilized to track reporting requirements to ensure timely filings. The Department will continue to explore ways to streamline the process. However, final numbers for the prior month are typically not available until the second week after the close of the month. This is complicated by the need for controls in place to ensure the final numbers are correct.

View Audit 367551

Finding 1155299 (2023-005)

Material Weakness 2023

The City of Frederick, Maryland

MD

Internal Control / Segregation of Duties Special Tests & Provisions Allowable Costs / Cost Principles

Client intakes are now being updated within the fiscal year, ensuring that client information is accurate and timely. Additionally, the Department's new EHR will prompt providers to update proof of income on an annual basis.

View Audit 367551

Finding 1155297 (2023-003)

Material Weakness 2023

The City of Frederick, Maryland

MD

Reporting Internal Control / Segregation of Duties

The finance department will review Form SF-425 compared to financial reports prior to submittals. Quarterly reminders have been initiated to ensure timely reporting moving forward.

View Audit 367551

Finding 1155295 (2023-008)

Material Weakness 2023

West Side Community Health Services INC

MN

Reporting Internal Control / Segregation of Duties § 200.303

2023-008 Health Centers Cluster – Assistance Listing No. 93.2242/93.527 Recommendation: We recommend implementing a formal policy and procedure where there is a review of all required reporting by an individual that did not prepare the report. Documentation should be retained to support the review/a...

2023-008 Health Centers Cluster – Assistance Listing No. 93.2242/93.527 Recommendation: We recommend implementing a formal policy and procedure where there is a review of all required reporting by an individual that did not prepare the report. Documentation should be retained to support the review/approval occurrence. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will implement a formal review process for reporting and retain documentation of review. This has been incorporated in subsequent reporting years. Name(s) of the contact person(s) responsible for corrective action: Bobby Royal Planned completion date for corrective action plan: December 2025

View Audit 367533

Finding 1155294 (2023-007)

Material Weakness 2023

West Side Community Health Services INC

MN

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.303

2023-007 Health Centers Cluster – Assistance Listing No. 93.2242/93.527 Recommendation: We recommend in the future the Organization retain documentation of key control processes occurring for a reasonable retention period to be able to support control activities around grant compliance and financial...

2023-007 Health Centers Cluster – Assistance Listing No. 93.2242/93.527 Recommendation: We recommend in the future the Organization retain documentation of key control processes occurring for a reasonable retention period to be able to support control activities around grant compliance and financial reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will retain timesheet documentation moving forward to support control process in place. Name(s) of the contact person(s) responsible for corrective action: Bobby Royal Planned completion date for corrective action plan: December 2025

View Audit 367533

Finding 1155293 (2023-006)

Material Weakness 2023

West Side Community Health Services INC

MN

Internal Control / Segregation of Duties Significant Deficiency

2023-006 Health Centers Cluster – Assistance Listing No. 93.2242/93.527 Recommendation: We recommend the organization have a review process over determinations to ensure accuracy and provide training as needed to mitigate risk of future errors. We also recommend reviewing procedures in place for ret...

2023-006 Health Centers Cluster – Assistance Listing No. 93.2242/93.527 Recommendation: We recommend the organization have a review process over determinations to ensure accuracy and provide training as needed to mitigate risk of future errors. We also recommend reviewing procedures in place for retaining documentation for sliding fee applications to ensure sufficient detail is retained according to policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will review sliding fee policies and procedures in place to improve oversight and provide training to the team members conducting the patient intake and reviewing sliding fee applications. Name(s) of the contact person(s) responsible for corrective action: Bobby Royal Planned completion date for corrective action plan: December 2025

View Audit 367533

Finding 1155207 (2023-001)

Material Weakness 2023

Town of Granby

NY

Procurement, Suspension & Debarment Reporting Matching / Level of Effort / Earmarking

Corrective Action Plan: To address this issue and prevent recurrence, the Town has implemented the following measures: 1. Reconciliation Procedures: Finance Department staff will reconcile all expenditures reported on USDA Form E – RD Project Budget/Cost Certification Reporting to the general ledger...

Corrective Action Plan: To address this issue and prevent recurrence, the Town has implemented the following measures: 1. Reconciliation Procedures: Finance Department staff will reconcile all expenditures reported on USDA Form E – RD Project Budget/Cost Certification Reporting to the general ledger, ensuring both the accuracy of amounts and the correct vendor attribution. 2. Vendor Verification: A vendor cross-check process will be added to the review, requiring staff to match each reported expenditure to the appropriate invoice, purchase order, and vendor record before submission. 3. Review & Approval Controls: A supervisory review will be conducted prior to submission of Form E reports to verify vendor accuracy, in addition to ensuring no duplicate or misclassified expenditures are reported. The Town is committed to ensuring compliance with all USDA reporting requirements. By strengthening reconciliation, vendor verification, and review processes, we will reduce the risk of reporting errors and maintain accurate, reliable financial reporting moving forward.

View Audit 367451

Finding 1155187 (2023-008)

Material Weakness 2023

Recovery Connections of Central Florida, Inc.

FL

Subrecipient Monitoring Material Weakness Reporting

Reporting Recommendation: Recommended Recovery Connections of Central Florida, Inc. submit its financial reporting as noted in the agreements and maintain documentation of the approval and submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Ac...

Reporting Recommendation: Recommended Recovery Connections of Central Florida, Inc. submit its financial reporting as noted in the agreements and maintain documentation of the approval and submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: We will review each agreement to confirm the reporting requirements, deadlines, and any specific formats or templates that must be followed. A designated team member will be responsible for preparing, reviewing, and submitting the required reports. We will track submission deadlines and ensure that reports are submitted on time. Name of the contact person responsible for corrective action: Joseph Dodi Planned completion date for corrective action plan: December 31, 2025

View Audit 367424

Finding 1155183 (2023-005)

Material Weakness 2023

Recovery Connections of Central Florida, Inc.

FL

Subrecipient Monitoring Material Weakness Reporting

Reporting Recommendation: Recommended Recovery Connections of Central Florida, Inc. submit its financial and performance reporting as noted in the agreements and maintain documentation of the approval and submission. Explanation of disagreement with audit finding: There is no disagreement with the a...

Reporting Recommendation: Recommended Recovery Connections of Central Florida, Inc. submit its financial and performance reporting as noted in the agreements and maintain documentation of the approval and submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: We will review each agreement to confirm the reporting requirements, deadlines, and any specific formats or templates that must be followed. A designated team member will be responsible for preparing, reviewing, and submitting the required reports. We will track submission deadlines and ensure that reports are submitted on time. Name of the contact person responsible for corrective action: Joseph Dodi Planned completion date for corrective action plan: December 31, 2025

View Audit 367424

Finding 1155056 (2023-005)

Material Weakness 2023

Muskogee County

OK

Internal Control / Segregation of Duties

The Board of County Commissioners will work with all elected officials, the new county grant administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, an...

The Board of County Commissioners will work with all elected officials, the new county grant administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements.

View Audit 367368

Finding 1155052 (2023-006)

Material Weakness 2023

County of Columbia, Pennsylvania

PA

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

2024-006 - Reporting - Significant Deficiency/Noncompliance Federal Program: Assistance Listing #21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identi...

2024-006 - Reporting - Significant Deficiency/Noncompliance Federal Program: Assistance Listing #21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Number: not available Condition/Context: The County’s required reports for the quarters ended June 30, 2023, September 30, 2023, and December 31, 2023, were due to be filed by the end of the month after the report end date (July 31, 2023, October 31, 2023, and January 31, 2024, respectively). The County filed its report on August 23, 2023, November 17, 2023, and February 15, 2024 (23, 17, and 15 days, respectively), after the required due date. Views of Responsible Officials and Planned Corrective Actions: Management understands and will seek to implement procedures to ensure future reports are submitted timely. Individual Responsible: Finance Department Timeline for corrective action: By December 31, 2024

View Audit 367366

Finding 1154956 (2023-005)

Material Weakness 2023

Copa Health, Inc.

AZ

Internal Control / Segregation of Duties § 200.303

Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the Organization is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Con...

Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the Organization is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The Organization's special reports submitted to the Department of Health and Human Services were not reviewed and approved by a separate individual outside of the preparer. Context: Key line items were tested on the Period 4 special reports submitted to the Department of Health and Human Services. 2 reports were tested, which both lacked appropriate approval. Response: Copa Health, Inc will continue to monitor and review internal control systems and implement new policies and/or procedures when necessary or applicable

View Audit 367290

Finding 1154790 (2023-037)

Material Weakness 2023

Oklahoma Water Resources Board

OK

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Finding Number 2023-037 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster 93.767 Children’s Health Insurance Program Planned Corrective Action OHCA MAGI Response: OHCA implemented system changes to begin income verification requests for all selfattested income ...

Finding Number 2023-037 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster 93.767 Children’s Health Insurance Program Planned Corrective Action OHCA MAGI Response: OHCA implemented system changes to begin income verification requests for all selfattested income from sources unable to be verified through existing data exchange. The system changes went to production on January 13, 2022 but were impacted by Public Health Emergency (PHE) requirements prohibiting termination of eligibility. The system changes became effective at the end of the PHE and have resulted in appropriate verification of income that was previously unverified. Guidance from Centers for Medicare and Medicaid Services (CMS) during the PHE prohibited the agency from requiring verification, renewals, or termination of Medicaid during the PHE. The agency followed the requirements and guidance of CMS throughout the PHE to ensure maintenance of coverage. OHCA is in the process of implementing system changes to ensure only previously verified income is removed and to ensure that applications in a pending status due to incomplete information from the Federal Marketplace continue to receive new data exchange information. OHCA continues to improve zero income self-attestation procedures as the value of the attestations in ensuring accurate eligibility decisions is recognized, and upgrades went to Production on April 17, 2025. Guidance from Centers for Medicare and Medicaid Services (CMS) during the PHE prohibited the agency from requiring verification, renewals, or termination of Medicaid during the PHE. The agency followed the requirements and guidance of CMS throughout the PHE to ensure maintenance of coverage. OHCA concurs with the Soon-to-be-Sooners (STBS) exception. The questioned costs will be reported on the CMS 64.9P line 10A on Cost of Service (COS) line 5 for the quarter ending June 30, 2025. OHCA Member Audit MAGI Response: Member Audit will complete three months of post-corrective action audits to ensure completion. If corrective action results are not sufficient, additional corrective action will be requested, and post- corrective action audit will be repeated. OKDHS Non-MAGI Response: For the non-MAGI deficiencies, OKDHS has addressed case issues through the establishment of a committee responsible for monitoring corrective actions and provided training to all appropriate employees. Additional informational webpages utilized by eligibility staff have been updated. OHCA Member Audit Non-MAGI Response: OHCA Member Audit has been monitoring these issues through monthly case reviews and provides feedback to OKDHS leadership. This process will continue until the issues have been corrected. Additional steps to correct issues are requested as deemed necessary by Member Audit. Anticipated Completion Date 8/31/2025 Responsible Contact Person Chris Dees, Eligibility and Coverage Services Technical Director April Anonsen, Deputy State Medicaid Director Ginger Clayton, OHCA Director of Member Audits Aubrey McDonald , OKDHS Medicaid Program Administrator Ginger Clayton, OHCA Director of Member Audits

View Audit 367158 Questioned Costs: $1

Finding 1154789 (2023-030)

Material Weakness 2023

Oklahoma Water Resources Board

OK

Special Tests & Provisions Subrecipient Monitoring Matching / Level of Effort / Earmarking

Finding Number 2023-030 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action Internal control processes and procedures to ensure MFCU overpayments are timely reported and refunded to the Center for Medicare and Medicaid Services (CMS) wer...

Finding Number 2023-030 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action Internal control processes and procedures to ensure MFCU overpayments are timely reported and refunded to the Center for Medicare and Medicaid Services (CMS) were implemented beginning September 2024. These processes include collaborations with the Medicaid Fraud Control Unit at the Oklahoma Attorney General’s office quarterly to track the status of closed cases, obtain sufficient supporting documentation, and timely report and refund identified overpayments on the CMS- 64. Anticipated Completion Date 1/31/2025 Responsible Contact Person Kristine West, Senior Director of Program Integrity and Accountability

View Audit 367158

Finding 1154788 (2023-024)

Material Weakness 2023

Oklahoma Water Resources Board

OK

Eligibility Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Finding Number 2023-024 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action OKDHS Response: OKDHS experienced technical issues at OMES and certificate issues with the IRS. OKDHS upgraded our machine portal for IRS Axway to Windows 10, an...

Finding Number 2023-024 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action OKDHS Response: OKDHS experienced technical issues at OMES and certificate issues with the IRS. OKDHS upgraded our machine portal for IRS Axway to Windows 10, and corrected the certificate issues preventing the job moving to the mainframe. OHCA Member Audit Response: Member Audit began receiving files monthly in September of 2023. Job lists are reviewed and compared against schedules and any discrepancies are discussed with OKDHS to determine the cause and remedy put in place to ensure any failed jobs were resolved. This review will continue indefinitely. Anticipated Completion Date 5/31/2025 Responsible Contact Person Jeff Rosenberry, OKDHS Programs Administrator April Anonsen, Deputy State Medicaid Director Ginger Clayton, OHCA Director of Member Audits

View Audit 367158

Finding 1154786 (2023-016)

Material Weakness 2023

Oklahoma Water Resources Board

OK

Questioned Costs Special Tests & Provisions Reporting

Finding Number 2023-016 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action Program Integrity was actively implementing corrective action to ensure that all overpayments were reported within 12 months from identification when these cases...

Finding Number 2023-016 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action Program Integrity was actively implementing corrective action to ensure that all overpayments were reported within 12 months from identification when these cases were closed. The errors associated with this finding were first reported on January 21, 2023 (Finding 2022-039) which resulted in OHCA developing corrective action to evaluate past cases and ensure all cases were reviewed and all overpayments were reported during the initial corrective action cycle. In all three instances related to late reporting of overpayments, all cases were reported on CMS-64.9c1 during implementation of corrective action plan as a result of the previous audit finding. One case was erroneously excluded during the corrective action plan. This finalized case was reported and refunded on the CMS-64.9OFWA, Line 1B for the quarter ending September 30, 2024 utilizing an average FMAP for all impacted programs. Internal procedures have been evaluated to ensure Service Quality Review overpayments are timely reported and refunded to the Center for Medicare and Medicaid Services (CMS). The cost of $4,007 questioned were reported on the CMS 64.9P line 10A on Cost of Service (COS) line 5 for the quarter ending March 31, 2025. Anticipated Completion Date 3/31/2025 Responsible Contact Person Kristine West, Senior Director of Program Integrity and Accountability

View Audit 367158 Questioned Costs: $1

Finding 1154713 (2023-103)

Material Weakness 2023

Oklahoma Water Resources Board

OK

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Finding Number 2023-103 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action The QRIS incentive payments were designed as a strategic investment to increase participation in Oklahoma’s redesigned Stars Quality Rating and Improvement System ...

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

View Audit 367158 Questioned Costs: $1

Finding 1154701 (2023-100)

Material Weakness 2023

Oklahoma Water Resources Board

OK

Subrecipient Monitoring Eligibility Reporting § 200.303

Finding Number 2023-100 Subject Heading (Financial) or AL no. and program name (Federal) 93.568 - LIHEAP Planned Corrective Action Detail eligibility data is not used to complete the Household Report. OKDHS uses system-generated summary reports and eligibility data to complete the Household Report. ...

Finding Number 2023-100 Subject Heading (Financial) or AL no. and program name (Federal) 93.568 - LIHEAP Planned Corrective Action Detail eligibility data is not used to complete the Household Report. OKDHS uses system-generated summary reports and eligibility data to complete the Household Report. The reports are EN600R02, EN600R03, EN600R04, and EN601R. OKDHS provided SAI copies of these reports for both FFY 2022 and 2023 on January 15, 2025. An image of the email is attached below: Anticipated Completion Date N/A Responsible Contact Person Caleb Turner

View Audit 367158

Finding 1154698 (2023-032)

Material Weakness 2023

Oklahoma Water Resources Board

OK

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.303

Finding Number 2023-032 Subject Heading (Financial) or AL no. and program name (Federal) 93.568 - LIHEAP Planned Corrective Action The Oklahoma Department of Human Services will ensure data used to calculate LIHEAP Quarterly Performance Data and Management report is clearly documented regarding the ...

Finding Number 2023-032 Subject Heading (Financial) or AL no. and program name (Federal) 93.568 - LIHEAP Planned Corrective Action The Oklahoma Department of Human Services will ensure data used to calculate LIHEAP Quarterly Performance Data and Management report is clearly documented regarding the data is being used, how it was calculated for this report, and ensure this documentation saved at the time the report is created. Anticipated Completion Date 4/30/2025 Responsible Contact Person Matthew Conley

View Audit 367158

Corrective Action Plans

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