Corrective Action Plans

2023-3 Allowable costs-credit cards – Assistance Listing Number 11.307 Recommendation: We recommend that management implement a more robust internal control system to ensure all federal expenditures are supported by proper documentation. Explanation of disagreement with audit finding: We believe the costs referred to were indeed for allowable expenses under the federal program. We will however start to maintain all original source documentation. Action taken in response to finding: Management has required all original source documentation be maintained regardless of dollar amount. Name of contact person responsible for corrective action: Anthony Wigglesworth, Executive Director Corrective action plan has been implemented in 2025.

U.S. Department of Commerce, Philadelphia Works, Inc. 2023-2 Direct Labor Costs – Assistance Listing Number 11.307 Recommendation: We recommend that the PALM utilize a time management software which integrates with their payroll processing, to easily identify direct labor costs related to the federal program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented a new time management software in 2025 to track and manage direct labor costs relating to the administration of federal programs.

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

Allowable Costs Recommendation: Recommended Recovery Connections of Central Florida, Inc. maintain documentation of disbursement approval and approval of services provided. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: We will implement a more structured process for documenting the approval of disbursements. This includes ensuring that disbursements are formally approved by the appropriate authority within the organization. We will also maintain a written record of the approval, including the name of the individual who authorized the disbursement and the date of approval. Name of the contact person responsible for corrective action: Joseph Dodi Planned completion date for corrective action plan: December 31, 2025

Allowable Costs, Period of Performance, and Cash Management Recommendation: Recommended Recovery Connections of Central Florida, Inc. maintain a copy of all contracts, documentation of disbursement approval and supporting documentation of costs included within requests for payment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: We will implement a more structured process for documenting the approval of disbursements. This includes ensuring that all underlying contracts are maintained and disbursements are formally approved by the appropriate authority within the organization. We will also maintain a written record of the approval, including the name of the individual who authorized the disbursement and the date of approval. Name of the contact person responsible for corrective action: Joseph Dodi Planned completion date for corrective action plan: December 31, 2025

The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. 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. The Board of County Commissioners will work with the new county grant administrator to ensure proper grant administration.

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. The Board of County Commissioners will work with the new county grant administrator to ensure proper grant administration.

The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. 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. The Board of County Commissioners will work with the new county grant administrator to ensure proper grant administration.

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

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

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

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

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

Finding Number 2023-104 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action The Oklahoma Department of Human Services (OKDHS) respectfully does not concur with the finding as written. We believe the State Auditor and Inspector (SAI) has not fully considered the federal flexibility afforded under the American Rescue Plan (ARP) Act, and that some conclusions were drawn from incomplete documentation. The Child Care Desert Grant program was thoughtfully developed in response to urgent needs during the COVID-19 recovery, with the goal of expanding access to child care in underserved communities using the discretion and authority granted to states under federal guidance. While OKDHS acknowledges that improvements could have been made to certain aspects of the program’s implementation—particularly regarding documentation clarity, post-award monitoring, and technical assistance— the SAI findings do not reflect the intent, structure, or compliance framework outlined in federal guidance. 2 CFR § 200.303(a) – Internal Controls DHS has strengthened internal controls consistent with federal expectations. For example, in the instance involving a grantee related to a DHS official, the potential conflict was identified and escalated by OKDHS to SAI as well as the Ethics Commission, and the individual was not directly involved in the reviewing and approving award process. In addition, the employee’s spouse was not included on any documentation included in the facilities application. This demonstrates that internal controls operated effectively. 2 CFR § 200.403 – Allowability of Costs This regulation applies to allowability under the Uniform Guidance, but per 45 CFR § 75.101(d), Subpart E (which ncludes § 200.403) does not apply to CCDF ARP discretionary funds unless explicitly stated. Federal guidance, including ACF-IM-2021-03, affirms that states were given broad flexibility in the design and implementation of such programs. Accordingly, DHS used its discretion to structure payments and allowable uses consistent with that guidance. Many costs questioned by SAI—such as business technology, minor remodeling, and start-up costs—were clearly allowable per the Desert Grant Guidance. 42 U.S. Code § 9858c(c)(2)(I) DHS did not fund sectarian instruction or activities. Expenditures were related to facility compliance and licensing, which is expressly permitted under this section when needed to meet health and safety standards. Providers affirmed compliance in their applications. 42 U.S. Code § 9858k(a) No funding was used for sectarian worship or instruction. All grantees signed affirmations that they would comply with all federal requirements, including those related to religious neutrality. Where expenditures were found that may raise concerns, they are being reviewed for compliance with these requirements. 42 U.S. Code § 9858k(b) DHS did not provide funding for services rendered during the regular school day or for academic credit. In the referenced after-school program, funds were used to expand access to licensed child care outside of regular instructional hours. Documentation of use is being reviewed, and additional guidance will be provided to ensure clarity in future programs. 42 U.S. Code § 9858d(b) and 45 CFR § 98.2 – Construction and Renovation DHS recognizes that one provider exceeded the $350,000 minor remodeling limit. This was an isolated case. At the time, DHS did not interpret the project scope as meeting the federal definition of "major renovation." DHS is enhancing its oversight process and guidance to providers to ensure full alignment with federal cost limits moving forward. Additional Clarifications • Expenditures cited as unallowable often fall within the scope of minor remodeling, technology, or business development explicitly allowed in Desert Grant FAQs and ACF guidance. • SAI’s estimate of questioned costs includes speculative assumptions based on documentation gaps—not confirmed misuse. • Many of the questioned costs SAI appears to be extrapolating were supplied directly from OKDHS’ own internal audit team and have either been addressed or are under investigation and should not be included in any additional questioned cost extrapolation. • The program was developed under severe federal timelines (obligation by 9/30/23), and ACF’s memoranda explicitly encouraged innovative approaches, including expansion grants to new and small providers. Corrective Actions (Planned or Completed) to be implemented on future emergency awards 1. Policy & Procedure Enhancements – Revised award language, documentation standards, and milestone disbursement options are being implemented. 2. Conflict of Interest Controls – OKDHS had a conflict of interest control in place to try and capture all potential conflicts based on the structure of the agency. OKDHS is expanding the process to extend to any staff members that have decision making approval. 3. Improved Monitoring – Targeted post-award reviews, site checks, and spending verification measures are being conducted. 4. Provider Training & Technical Assistance – Providers are receiving additional education on fiscal documentation, grant compliance, and reporting expectations. Anticipated Completion Date N/A Responsible Contact Person Kayla Urtz

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

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

Finding Number 2023-085 Subject Heading (Financial) or AL no. and program name (Federal) 93.568 - LIHEAP Planned Corrective Action The OKDHS used the existing program infrastructure for the Low Income Home Energy Assistance Program (LIHEAP) to issue LIHWAP benefits. Before the coronavirus pandemic, The OKDHS had a system edit that flagged any energy crisis payment that would exceed $750 in a federal fiscal year. To accommodate LIHWAP processing, OKDHS modified this edit to permit LIHEAP energy crisis and LIHWAP payments. The $750 amount was the maximum a household could receive as an energy crisis benefit, and a household could potentially receive this benefit and LIHWAP payments. The OKDHS staff adjusted the allowed payment amount to reflect this reality resulting in these overpayments. The LIHWAP ended on September 30, 2023. Before receiving this finding, the OKDHS restored this edit to its pre-pandemic status. The current system prevents eligibility staff from paying more than $750 in a federal fiscal year. Anticipated Completion Date N/A Responsible Contact Person Caleb Turner

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

Finding Number 2023-082 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 – TANF Planned Corrective Action The worksheet for Cost Pool 612 was supplied to SAI which has child level eligibility on each invoice to determine the allocation basis of the OCS contracts. The eligibility is done in accordance with the Oklahoma TANF plan which states: Services that are designed to promote and allow children to be cared for in their own home or the homes of relatives; as well as provide emergency assistance. Children receiving TANF, SNAP, Childcare or Sooner Care benefits at the timeof service enrollment are automatically deemed eligible for this category. Services provided include but are not limited to in-home parenting, household management, budgeting. The worksheet clearly shows the children that are eligible for the other services which makes the children eligible for TANF. Anticipated Completion Date N/A Responsible Contact Person Kevin Haddock

Finding Number 2023-079 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 – TANF Planned Corrective Action The new Current system used by AFS automatically sends TANF cases to staff to ensure reviews are completed timely. Current also sends reporting to Supervisors including cases that are not completed timely so appropriate action can be taken. Anticipated Completion Date 11/06/2024 Responsible Contact Person Rhonda Archer

Finding Number 2023-073 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 – TANF Planned Corrective Action The OKDHS concurs that an error was made on the MOE calculation. We will add review procedures to ensure this complex calculation is correct prior to submission of the report going forward. The error noted by the auditor will be corrected in the March 2025 TANF reconciliation process. Anticipated Completion Date May, 2025 Responsible Contact Person Kevin Haddock

Finding Number 2023-054 Subject Heading (Financial) or AL no. and program name (Federal) 93.558 – TANF Planned Corrective Action With the addition of Current, everything uploaded into OnBase triggers a task. Program staff approve or deny extension requests and upload the documents to OnBase which generates a task for the field staff. The field staff processes the extension request by adding the ET&E line and documenting it to the case notes. Anticipated Completion Date 04/04/2025 Responsible Contact Person Rhonda Archer

Finding Number 2023-213 Subject Heading (Financial) or AL no. and program name (Federal) 93.323: Epidemiology and Laboratory Capacity for Infectious Diseases Planned Corrective Action 1. Implementation of Time Distribution Record (TDR) Procedures: OSDE has adopted the Time Distribution Records (TDR) procedures as outlined in the ESEA Consolidated Monitoring Toolkit and the "Time Distribution Records" presentation provided to districts on October 3, 2023 . These documents establish that all employees whose salaries are funded by federal programs must document their time and effort based on actual work performed, not budget estimates. 2. Required Documentation from Subrecipients: Going forward, LEAs will be required to submit certified time and effort records using the templates provided in the ESEA Resource Toolkit (June 2024) . These forms are designed to ensure: o Records are maintained for employees working on a single or multiple cost objectives. o Monthly or semi-annual certifications, depending on the funding structure, are completed by employees and supervisors. o Reconciliations are conducted to adjust salary allocations if actual time varies from budget estimates. 3. Training and Technical Assistance: OSDE's Office of Title Services will conduct training sessions and provide technical assistance to LEAs to ensure proper understanding and implementation of the TDR process. OSDE will also establish a central repository to track and audit submitted TDRs. 4. Monitoring and Compliance Checks: A risk-based monitoring system will be implemented to conduct periodic reviews of LEA payroll reimbursements. During desk reviews and on-site monitoring, OSDE will verify that certified time and effort records support all payroll expenditures submitted for reimbursement. 5. Policy Revision and Dissemination: OSDE will revise its federal programs procedures manual to formally include the updated TDR requirements. This policy will be shared with all LEAs and included in routine programmatic updates. These steps demonstrate OSDE’s commitment to compliance and accountability. We believe that the implementation of the certified time and effort process will provide sufficient assurance that payroll reimbursements are accurate, allowable, and appropriately allocated under Assistance Listing Number 93.323. Anticipated Completion Date 6/30/2025 Responsible Contact Person Kellie Carter, Program Manager, School Health Services

Finding Number 2023-212 Subject Heading (Financial) or AL no. and program name (Federal) 93.323: Epidemiology and Laboratory Capacity for Infectious Diseases Planned Corrective Action The Oklahoma State Department of Education (OSDE) is committed to strengthening its subgrant management processes in response to the audit findings. To address the identified issues, OSDE will implement a more robust and clearly defined application procedure for Local Education Agencies (LEAs) applying for subgrants. This will include standardized guidance and documentation requirements to ensure consistency and transparency. In addition, OSDE will establish comprehensive procedures to conduct risk assessments of individual LEAs prior to awarding subgrants. These procedures will detail specific steps for identifying and addressing noncompliance, ensuring that higher-risk LEAs receive the appropriate level of oversight and support. To further improve the integrity of the reimbursement process, OSDE will provide regular training sessions and technical assistance to LEAs. These sessions will emphasize the importance of submitting complete and accurate documentation to support reimbursement claims. OSDE will also collaborate with our vendor, MTW, to ensure that LEAs can efficiently upload required documentation through the Grants Management System (GMS). Finally, OSDE will conduct targeted training for internal reviewers to ensure they are well-versed in identifying allowable versus unallowable expenditures and understand the documentation requirements associated with each type of expense. This will help promote consistency and compliance in the review and approval of claims. Anticipated Completion Date 6/30/2025 Responsible Contact Person Shawn Richmond, Comptroller

Finding Number 2023-211 Subject Heading (Financial) or AL no. and program name (Federal) 93.323: Epidemiology and Laboratory Capacity for Infectious Diseases Planned Corrective Action Action planned/taken in response to finding: For the year ending June 30, 2024 OSDE implemented a robust reconciliation process over the SEFA. With the new process, all federal expenditures and drawdowns reported on the SEFA / Schedule Z are reconciled to expenditure transactions and drawdown detail from the Statewide Accounting Software (PeopleSoft). The new process will ensure the SEFA / Schedule Z is appropriately supported by individual transactions and sufficient review is performed. The reconciliation is prepared by an OSDE contractor and reviewed and approved by the Comptroller before finalizing. Anticipated Completion Date 6/30/2024 Responsible Contact Person Shawn Richmond, Comptroller