Corrective Action Plans

Finding Number 2024-019 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425U) Planned Corrective Action OSDE maintains that these procedures are adequate to ensure compliance with 34 CFR §§ 75.600–75.618. Leadership in the Office of Title Services determined that OTS did not have the staff capacity to require review of payroll certifications during the application review process; therefore, this monitoring was conducted during onsite visits. Given the limited number of project managers available to perform onsite reviews during the ESSER period, OSDE believes the sampling completed onsite was reasonable and sufficient to assess compliance. Guidance and tools were provided to LEAs to support proper implementation of prevailing wage requirements. Monitoring results are reviewed and approved by OTS leadership, and corrective actions are required when non-compliance is identified. Anticipated Completion Date Sept-25 Responsible Contact Person Tammy Smith

Finding Number 2024-016 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; #84.425U) Planned Corrective Action The agency acknowledges that certain ESSER II and ARP ESSER III claims were approved without adequate review of supporting documentation by authorized claims reviewers. To address this finding, the agency has strengthened its claims review procedures and internal controls related to reimbursement processing. Additional training will be provided for all claims reviewers regarding: • allowable use of funds requirements, • supporting documentation standards, • verification of invoice documentation, • program coding requirements, and • review and approval expectations for federal claims. The agency will also implement enhanced supervisory review and monitoring procedures to help ensure claims are consistently reviewed in accordance with federal requirements prior to approval. The agency acknowledges that allocation notices were not consistently generated and provided to certain LEAs in accordance with the requirements of 2 CFR § 200.332(a)(1). Additionally, one allocation notice did not contain all required elements, including the Federal Award Identification Number (FAIN) and Federal award date. Although the audit confirmed that allocation amounts and approved budgets within the grants management system were accurate, the agency recognizes the need to strengthen procedures related to issuance and documentation of subrecipient award notifications. To address this finding, the agency will revise and strengthen internal procedures to ensure all required allocation notices are generated, maintained, and distributed timely and consistently to subrecipients. The agency will also coordinate with our third party vendor to implement additional quality control measures and staff training to ensure all required federal award information, including the FAIN and Federal award date, is included in future allocation notices in accordance with 2 CFR § 200.332 requirements. Anticipated Completion Date Sept-26 Responsible Contact Person Tammy Smith

Finding Number 2024-001 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.010 TITLE I, PART A – GRANTS TO LOCAL EDUCATIONAL AGENCIES AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; 84.425U) Planned Corrective Action OSDE agrees with the recommendation and will strengthen its subrecipient risk assessment and monitoring processes to ensure LEAs are consistently and accurately evaluated. Specifically, OSDE will: • Revise and formalize written policies and procedures governing the Risk Assessment Ranking Tool, including detailed guidance for assigning and documenting risk scores. • Implement a standardized review process requiring supervisory review and approval of all annual risk assessments prior to finalizing LEA risk classifications. • Develop a risk assessment checklist to ensure all required risk factors are evaluated consistently and supporting documentation is maintained. • Provide annual training to staff responsible for completing and reviewing risk assessments to ensure consistent application of scoring criteria. • Perform periodic quality assurance reviews of completed risk assessments to verify scoring accuracy, identify trends or errors, and implement corrective measures when needed. Anticipated Completion Date Aug -26 Responsible Contact Person Tammy Smith

Finding Number 2024-013 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.010 TITLE I, PART A – GRANTS TO LOCAL EDUCATIONAL AGENCIES Planned Corrective Action OSDE acknowledges the audit finding. During the FY24 audit period, monitoring procedures for LEA Supplement Not Supplant (SNS) methodologies were identified as lacking adequate documentation and verification measures. On July 25, 2024, OSDE submitted corrective action plans to USDE, which included revisions to the ESEA Resource Toolkit, Title I Handbook, and GMS review protocols. As of April 11, 2025, USDE determined that the SNS requirements have been satisfied and confirmed that OSDE’s revised resources are consistent with federal guidance. OSDE has subsequently strengthened internal controls and improved monitoring procedures to ensure ongoing compliance of LEA SNS methodologies and supporting documentation. Anticipated Completion Date Apr-25 Responsible Contact Person Tammy Smith

Finding Number 2024-075 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.027 Federal Program name: Coronavirus State And Local Fiscal Recovery Funds (CSLFRF) Planned Corrective Action Office of Management and Enterprise Services – Grants Management Office Response: OMES-GMO respectfully disagrees with several conclusions contained in this finding. The finding concludes that the transfer of CSLFRF funds to the twenty-two (22) state agencies does not create a subrecipient relationship because OMES and the agencies are part of the same State of Oklahoma Single Audit. OMESGMO respectfully disagrees with this conclusion. Pursuant to 62 O.S. § 255.1, “The Legislature authorizes the Office of Management and Enterprise Services to manage federal APRA funds by requiring all receiving entities known as subrecipients to sign a grant agreement. Any entity, without exception, including state agencies receiving an appropriation from the Statewide Recovery Fund or a similar fund with federal requirement attached to its use shall have a fully executed grant agreement in place within sixty (60) days after enactment of any legislation that appropriates funding from the Statewide Recovery Fund of the State Treasury created in Section 1, Chapter 319, O.S.L. 2022, and be in compliance with such agreement before a disbursement can be made.” Under this statutory framework, each agency enters into a Grant Agreement with OMES and is subject to grant-specific terms and conditions, reporting requirements, monitoring, and ongoing oversight. Accordingly, OMES has administered the CSLFRF grant in accordance with state law and consistent with its responsibilities as the State's designated pass-through entity since the inception of the program. The authorization from the Oklahoma State Legislature has provided for a much more extensive oversight of the state entity subrecipients than would exist if OMES followed the model suggested by SAI, as OMES would not be subject to the subrecipient monitoring Federal regulation under 2 CFR § 200.332, for these state entities. By following the state law passed by the Legislature, OMES monitors each state entity subrecipient, and in turn, has signed a grant agreement with these state entity subrecipients that requires them to do the same for any of their subrecipients that are administering projects set out specifically by the State Legislature through appropriation bills. OMES requests SAI to revisit the position that these state entities are not OMES’ subrecipients and consider the implications that if OMES were to treat the state entities as non-subrecipients, OMES would be in direct defiance of state law. OMES-GMO also disagrees with the conclusion that sufficient supporting documentation was unavailable for several of the transactions identified in this finding. OMESGMO is committed to strong documentation standards, reimbursement review procedures, and project oversight to ensure continued compliance with applicable federal and state requirements. Despite OMES-GMO’s request to be included in audit communication with the state entities, SAI’s documentation requests for the sampled expenditures were directed primarily to the individual agencies. Several agencies experienced staffing changes during the audit period, resulting in inconsistencies in responding to documentation requests and, in some instances, uncertainty regarding the specific information being requested by the auditors. In multiple cases, the supporting documentation ultimately existed and was available but was either maintained by OMES-GMO or inadvertently omitted from the agency's initial submission. If OMES-GMO was afforded the opportunity to submit or explain documentation maintained by its office before the finding was finalized, both the administering agency and OMES-GMO would have been able to provide a more complete record for evaluation and may have altered the conclusions reached for certain transactions. OMES-GMO has had recent conversations with SAI regarding this issue, and are encouraged by the willingness of SAI to be open to working with OMES-GMO to facilitate a different process for future audits that involves a coordinated with both the administering agency and OMES-GMO so that auditors have access to the complete record before audit conclusions are finalized. Agency Responses: Agency 025 – Oklahoma Military Department (OMD) OMD partially concurs with the finding regarding the level of supporting documentation submitted with the vendor's invoices for payment. However, the construction contracts in question were executed using Guaranteed Maximum Price (GMP) contract structures. Under these contracts, the contractor is responsible for maintaining all subcontractor invoices, material invoices, and supporting financial records associated with each progress payment. The contracts require these records to be retained for the applicable record retention period and made available for review by the agency, State, or federal government upon request. Agency 085 – Oklahoma Broadband Office (OBO) Broadband Mapping / Cross-Grant Expenditures The Oklahoma Broadband Office (OBO) requests the transactional detail associated with these findings to allow the agency to fully evaluate the questioned transactions. While OBO agrees that expenditures must be charged to the appropriate federal funding source and class fund, the office respectfully disagrees that the questioned expenditures represented unallowable supplementation of other federal awards. The contracts included shared deliverables necessary to complete the CSLFRF Broadband Mapping project. During contract administration, OBO identified billing discrepancies involving work performed under multiple grant programs. Following approximately eleven months of negotiations, OBO entered into a settlement agreement with the contractor that limited payment to services actually received and excluded services that were not performed. The resulting payments represented services provided under multiple funding sources and were processed together to accurately reflect work completed during FY2024. Procurement Finding – Lee Consulting Contract OBO concurs with the finding that services began prior to the execution of a purchase order for the April 2023 services. Upon identifying the issue, OBO completed the required ABS Form 009 Ratification Agreement to formally document the procurement exception and properly authorize payment. To prevent future occurrences, OBO has: • Hired a full-time General Counsel to oversee contract administration and procurement compliance. • Implemented a policy prohibiting execution of contracts or commencement of work until a purchase order has been fully approved and funds have been encumbered. • Provided procurement training to management and staff regarding Oklahoma encumbrance requirements. Agency 400 – Office of Juvenile Affairs (OJA) OJA partially concurs with the finding. The agency believes the purchase of a Keurig coffee maker and heater towers by Western Plains falls within the approved project scope for the purchase and installation of furniture, fixtures, and equipment. However, OJA acknowledges that decorative wall art purchased by Youth and Family Services of Hughes and Seminole Counties does not appear to fall within the approved project scope. Agency 452 – Oklahoma Department of Mental Health and Substance Abuse Services (ODMHSAS) ODMHSAS acknowledges the documentation and procurement concerns identified in the finding. Specifically, the agency recognizes that certain invoices lacked sufficient detail describing services performed and that one expenditure required ratification because services were obligated prior to encumbering funds. ODMHSAS agrees that federally funded expenditures should be supported by documentation demonstrating the services performed, the project purpose, and the relationship to the approved scope of work. ODMHSAS also agrees that obligations should not be incurred before a valid purchase order and encumbrance have been established. Agency 619 – Oklahoma Health Care Workers Training Commission (HWTC) During the period associated with the questioned expenditure, the Care Providers program submitted a significant volume of supporting documentation with each reimbursement request, often consisting of 500 to 1,000 pages transmitted through multiple emails over several days. In some instances, the documentation was not organized sequentially, making it difficult to efficiently compile and review the complete reimbursement package. As staff assembled documentation received through multiple transmissions, a portion of the supporting documentation was inadvertently omitted from the reimbursement file maintained by the agency. Consequently, the complete documentation package was not included in the materials submitted to OMES-GMO with the reimbursement request. To address this issue, management revised its documentation review procedures. Rather than requiring agency staff to reorganize incomplete or disorganized submissions, staff are now instructed to return reimbursement packages that are incomplete or not properly organized and require the submitting entity to provide a revised, complete documentation package. This change places responsibility for maintaining complete supporting documentation with the originating entity and has resulted in more organized reimbursement submissions while reducing the risk of incomplete supporting records. Agency 830 – Oklahoma Department of Human Services (DHS) DHS disagrees that the questioned incentive gift cards were outside the approved project scope. The PCCT Fatherhood Today program is designed to strengthen father-parent-child relationships by engaging fathers through education, support services, and community resources. The program targets fathers residing in underserved communities who often face barriers to participation, including transportation, childcare, financial hardship, and food insecurity. The $100 gift cards are provided only after participants successfully complete the twelve-week 24/7 Dad curriculum. The gift cards serve as an incentive to recruit and retain participants and support the program's objective of increasing father engagement. DHS believes the incentives directly support successful program participation and allow participants to obtain essential household items for their families. DHS further noted that participant outcomes are measured through pre- and post-program assessments demonstrating increased knowledge and engagement among participating fathers. Gift cards are purchased using agency purchasing procedures, maintained in secured storage, and distributed only upon successful completion of all program requirements with appropriate documentation maintained for each recipient Anticipated Completion Date OMES: December 31, 2026 025: Completed 085: Completed 400: Completed 452: December 31, 2026 619: December 31, 2026 830: Completed Responsible Contact Person OMES: Elizabeth Base 025: Angela Tackett 085: Beverlee Harbuck 400: Kevin Haddock 452: Chad Carden 619: Kami Fullingim 830: Lindsey Kanaly

Finding Number 2024-018 Subject Heading (Financial) or AL no. and program name (Federal) 20.509 – Formula Grants for Rural Areas Planned Corrective Action Contract Template and Review Process Improvements: OMPT has updated and corrected the standard contract templates to ensure all required federal award information is accurate and consistently included. In addition, the contract agreement review process has been strengthened and formalized into a two-step review. Agreements are now reviewed by a supervisor and/or manager prior to submission to the division head for final signature. This enhanced review structure is designed to ensure the completeness and accuracy of grant information and to reduce the risk of errors in subrecipient agreements. For active subrecipient agreements identified as containing incorrect federal award information, OMPT will issue formal written notifications (via letter or email) to provide corrected grant details and ensure subrecipients have accurate information for compliance purposes. Subrecipient Monitoring and Single Audit Procedures: OMPT will continue implementation of enhanced subrecipient risk assessment procedures as part of its monitoring process. This includes formal documentation of risk assessments, as well as required inquiries with subrecipients to determine the appropriate audit type based on expected federal expenditures. Procedures related to Single Audit tracking and followup are being strengthened. The Single Audit Tracking Sheet will be updated monthly and reviewed for completeness and timeliness. Anticipated Completion Date 12/31/2026 Responsible Contact Person Eric Rose / Bobby Parkinson (OMPT)

Finding Number 2024-050 Subject Heading (Financial) or AL no. and program name (Federal) 20.205 - Highway Planning and Construction Planned Corrective Action The following actions will be taken to improve our payroll processes and ensure compliance with the Code of Federal Regulations (CFR) and the Oklahoma Department of Transportation (ODOT) Specifications and Construction Control Directive (CCD). We have detailed written procedures for the Residencies in the form of a Construction Control Directive (CCD). It is the expectation that the CCD will be followed, and this expectation will be relayed to those responsible for ensuring that ODOT is in compliance with the Davis- Bacon Act. It is unknown whether or not appropriate actions were taken by the Residency in response to the delayed submission of payroll records. The CCD will be emphasized at a future District Engineer meeting and at an upcoming Resident Engineer Academy. Steps will be taken to ensure each Residency has a date stamp and is instructed to use it appropriately. Steps will be taken to ensure that those responsible for verifying payroll with interview results are conducting the process correctly. Expectations will be made clear that interviews will be conducted with the appropriate contractor and subcontractor personnel. Management will stress to the Residencies that extra effort will be needed to diversify interviews on projects. We are in the process of activating the electronic payroll portion of AASHTOWare Project, which will automate much of our payroll process and reduce the occurrence of discrepancies such as those identified in this finding. The use of this system will become mandatory for our contractors with the October 2026 lettings. As part of this process, we will create a Special Provision and update the CCD. ODOT Audit Office conducted an internal Labor Wage Audit last year and covered the findings at the last Resident Engineer Academy. Anticipated Completion Date 10/31/2026 Responsible Contact Person John B. Leonard

Finding Number 2024-047 Subject Heading (Financial) or AL no. and program name (Federal) 20.205 - Highway Planning and Construction Planned Corrective Action ODOT Contract Compliance Division (CCD) is updating the Guidelines for the Administration of Consultant Contracts, Standard Operating Procedures (SOPs) and training staff on correct procedures for filing documentation. Discussion was held with the ACEC Admin Working Group on 4/7/2026, that FAR Audits were not being submitted timely, and additional guidance would be issued by ODOT. ODOT CCD is partnering with the ODOT Audit Office for FAR Audit Requirements and the development of Self-Certification and Safe Harbor Rate Programs. FAR requirements will be discussed at the annual ACEC Partnering Conference in September 2026. ODOT will provide copies of updated Guidelines and SOPs as they are developed. Anticipated Completion Date 12/31/2026 Responsible Contact Person Jennifer Hankins

Finding Number 2024-087 Subject Heading (Financial) or AL no. and program name (Federal) #17.225 Unemployment Insurance Planned Corrective Action The agency concurs with the findings and agrees with the recommendations. The agency acknowledges our responsibility for program integrity and proper controls for the RESEA program. As we referenced in our response last year, the agency has undertaken modernization efforts to provide better solutions for the RESEA program. EmployOklahoma is the first result of this effort in the workforce employment area and it launched in January 2025 as the replacement for OKJM. We anticipate continued progress and improvement going forward, but there will continue to be elevated risk for inaccuracies until the agency’s modernization efforts are successful in implementing solutions to address both the case management and data reporting requirements needed to fully resolve these findings. In Fall 2025 and continuing through 2026, UI Program staff has provided guidance and training on unemployment compensation (UC) eligibility requirements, specifically as it relates to Able & Available issues and Job Search requirements. Additionally, RESEA Program staff continue to provide ongoing training to, and oversight of RESEA case management staff. While we expect continued issues through FY2024, we anticipate improvement in FY2025 as ongoing changes in the case management system and increased staff training on RESEA program requirements drive us closer toward improved reporting and program outcomes. Anticipated Completion Date Ongoing until modernization of RESEA tools is complete Responsible Contact Person Tammy Wood, RESEA/TAA Program Manager

Finding Number 2024-085 Subject Heading (Financial) or AL no. and program name (Federal) #17.225 Unemployment Insurance Planned Corrective Action The agency concurs with the finding and acknowledges our responsibility for program integrity and proper controls for the RESEA program. As we referenced in our response last year, the agency has undertaken modernization efforts to provide better solutions for the RESEA program. EmployOklahoma (EO) is the first result of this effort in the workforce employment area and launched in January 2025 as the replacement for Oklahoma Job Match (OKJM). The recommendation as detailed above (to continue development of OKJM) is no longer applicable, due to the successful transition to the new EmployOklahoma system, which generates accurate, reliable data. Additionally, we instituted, and continue to provide ongoing training to RESEA staff to ensure proper implementation of new policies and procedures. We anticipate there will continue to be elevated risk for inaccuracies through early FY2025 (December 2024), as reporting data was still being provided through OKJM legacy data. Beginning January 2025 the agency’s EO modernization initiatives were initiated. OESC believes we’ve successfully implemented comprehensive solutions to address both the case management and data reporting requirements needed to fully resolve this finding. Anticipated Completion Date Completed in March 2026 Responsible Contact Person Tammy Wood, RESEA/TAA Program Manager

Finding Number 2024-079 Subject Heading (Financial) or AL no. and program name (Federal) 10.565 – Food Distribution Cluster Planned Corrective Action OKDHS agrees that documentation supporting the approval and eligibility of participating CSFP agencies should be consistently completed, reviewed, and retained. The condition identified by the auditors reflects a documentation and record-retention control weakness. The absence of documentation available for audit does not, by itself, establish that the participating agency was ineligible; however, OKDHS recognizes that sufficient documentation must be maintained to demonstrate compliance with applicable program requirements. To strengthen controls over the onboarding, approval, and ongoing oversight of participating agencies, the Food Distribution Unit is implementing a standardized onboarding process. The process will include a checklist identifying required eligibility and program documentation that must be submitted by the food bank and reviewed by OKDHS as part of the approval process. Required documentation will include, as applicable, the Civil Rights Questionnaire, nonprofit and identifying information, required agreements, and confirmation that appropriate program information and training have been provided. Following review of the required documentation, OKDHS will document its approval of eligible participating agencies and maintain final agreements and supporting documentation within the Food Distribution Unit's program files in accordance with applicable record-retention requirements. OKDHS will also review its agreements and related procedures with its food bank partners to improve consistency in the documentation, retention, and availability of records supporting participating agencies. As part of this effort, OKDHS will work with the food banks to strengthen centralized record-retention practices and clarify responsibilities for maintaining records required by federal and state program requirements. Ongoing monitoring activities will include review of applicable eligibility, agreement, and record-retention documentation. Identified instances of noncompliance will be addressed through corrective action and technical assistance, as appropriate. In addition, OKDHS will provide annual training to food bank partners addressing participating-agency eligibility, record retention, civil rights requirements, and other applicable CSFP and TEFAP program requirements. These actions are intended to strengthen the consistency of the eligibility approval process and provide reasonable assurance that required documentation is complete, appropriately reviewed, retained, and available for subsequent monitoring or audit. Anticipated Completion Date Standardized onboarding checklist: July 30, 2026 Annual training materials: August 30, 2026 Review of food bank greements and centralized recordretention processes: September 30, 2026 Responsible Contact Person Kayla Urtz

Finding Number 2024-076 Subject Heading (Financial) or AL no. and program name (Federal) 10.565 – Food Distribution Cluster Planned Corrective Action OKDHS agrees that documentation supporting participant eligibility should be consistently maintained and retained in accordance with program requirements. The condition identified by the auditors represents a documentation and record-retention weakness at one participating local pantry during a limited period. The absence of documentation available during the audit does not, by itself, establish that participant eligibility determinations were incorrect or that ineligible individuals received program benefits; rather, it limits the ability to independently verify those determinations after the fact. It should also be noted that OKDHS conducted an on-site review of this pantry in June 2023 and again in August 2025. During the 2025 review, current participant intake records were available and reviewed to verify that eligibility determinations were being performed in accordance with program requirements. Contrary to the finding's characterization, OKDHS reviews completed participant intake forms during monitoring activities, not merely blank application forms. In accordance with federal requirements, routine CSFP reviews are conducted every two years unless a participating agency is identified as higher risk, in which case more frequent monitoring is performed. To further strengthen oversight, OKDHS is implementing a standardized onboarding process for new participating pantries and new local management. This process will include standardized checklists, verification of required agreements and documentation, confirmation that required program training has been completed, and notification requirements when management changes occur at participating agencies. OKDHS will also work with its food bank partners to strengthen centralized record-retention practices, clarify documentation responsibilities, and reinforce record retention requirements through annual training and technical assistance. Ongoing monitoring activities will continue to include reviews of participant eligibility documentation, agreements, and record-retention practices, with corrective actions implemented whenever deficiencies are identified. These enhancements build upon existing monitoring activities and provide additional assurance that required documentation is consistently maintained and available for future monitoring and audit. Anticipated Completion Date In Progress Responsible Contact Person Kayla Urtz

Finding Number 2024-088 Subject Heading (Financial) or AL no. and program name (Federal) 10.565 – Food Distribution Cluster Planned Corrective Action OKDHS agrees that documentation supporting the receipt, distribution, and accountability of CSFP food packages should be consistently maintained in accordance with federal program requirements. The condition identified by the auditors represents a documentation and recordkeeping weakness at one participating local pantry and does not, by itself, establish that USDA commodities were lost, misused, or improperly distributed. With respect to the reported inventory discrepancy, the issue identified during the audit related to documentation supporting home deliveries. While the local pantry did not maintain documentation at the site to support the number of food packages assigned to a delivery route, OKDHS does not agree that the food packages should be characterized as unaccounted for. Home delivery distributions are finalized after the delivery route is completed to ensure inventory records accurately reflect the commodities actually delivered and any packages returned to the pantry if a delivery cannot be completed. Requiring documentation to be completed before deliveries are finalized could result in inaccurate inventory records when circumstances change during the delivery route. The documentation weakness identified was the lack of retained supporting documentation demonstrating the number of packages assigned for home delivery. OKDHS currently performs management reviews in accordance with 7 CFR 247.34, including on-site reviews of participating agencies at least once every two years, with more frequent monitoring of agencies identified as higher risk. Agencies with identified deficiencies are required to submit corrective action plans, and follow-up reviews are conducted until corrective actions have been satisfactorily implemented. Accordingly, OKDHS believes its existing monitoring process is consistent with federal requirements while recognizing that documentation controls can be strengthened. To further enhance internal controls, OKDHS will work with its food bank partners to standardize documentation requirements for home deliveries, strengthen record retention practices, and clarify responsibilities for maintaining receiving, inventory, and distribution records. OKDHS will also require food banks to incorporate these documentation requirements into their oversight of local pantries and will provide annual training reinforcing federal inventory accountability, documentation, and record retention requirements. In addition, OKDHS will continue evaluating monitoring practices and available resources to determine the most effective methods for strengthening oversight of participating agencies while continuing to meet all applicable federal monitoring requirements. These enhancements build upon the existing management review process and are intended to provide additional assurance that inventory records are complete, accurate, and available for future monitoring and audit activities. Anticipated Completion Date In Progress Responsible Contact Person Kayla Urtz

Finding Number 2024-107 Subject Heading (Financial) or AL no. and program name (Federal) 10.557: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Planned Corrective Action OSDH management agrees with this finding and will work with OMES to ensure Workday payroll expenditures are accurately reflected in PeopleSoft’s general ledger based on actual project time worked rather than budgeted position setup allocations. We are actively exploring reconciliation steps within PeopleSoft to accurately record project time worked in accordance with approved timecards to the appropriate funding within the general ledger. Anticipated Completion Date 06/30/27 Responsible Contact Person Ryon Fields, Interim CFO

Finding Number 2024-083 Subject Heading (Financial) or AL no. and program name (Federal) 10.551 – SNAP 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

Finance Finding: 2024-002 - Reporting Corrective Action Plan Type of Finding: Noncompliance and Material Weakness in Internal Control Over Compliance Federal Agency: U.S. Department of Treasury Federal Program Title: COVID 19 - Coronavirus State and Local Fiscal Recover Funds ALN: 21.027 Corrective Action: The City recognizes the importance of timely and accurate financial reporting for grant-funded programs. To address the root causes of this finding and strengthen internal controls over grant accounting, the City is implementing the following corrective actions: 1. Dedicated Grant Accounting Oversight The City has established a Senior Accountant position dedicated to grant accounting and compliance. This position will be responsible for overseeing grant-related financial activity, monitoring grant expenditures and revenues, coordinating reimbursement requests, ensuring compliance with grant requirements, and reviewing transactions for proper accounting period recognition. 2. Enhanced Communication with Grant Departments Finance will implement regular communication with departments responsible for managing grants to ensure grant activity is identified and recorded timely. Departments will be expected to notify Finance of significant grant expenditures, reimbursement requests, project milestones, and other events affecting grant accounting. Regular meetings will be scheduled, as appropriate, to discuss grant status, upcoming deadlines, and financial reporting requirements. 3. Routine Grant Reconciliations The Finance Department will perform recurring reconciliations of grant expenditures, revenues, receivables, deferred revenues, and reimbursement requests. These reconciliations will compare the general ledger to grant reimbursement activity and supporting documentation to identify and resolve timing differences before month-end and year-end financial reporting. A comprehensive reconciliation will also be performed during the fiscal year-end closing process to ensure all grant transactions are recorded in the appropriate accounting period. 4. Grant Accounting Training The newly assigned Senior Accountant will receive formal training in governmental grant accounting, Uniform Guidance (2 CFR Part 200), federal and state grant compliance requirements, and applicable GASB reporting standards. In addition, the City will provide ongoing professional development opportunities through external training, webinars, professional organizations, and auditor recommendations to maintain current knowledge of grant accounting requirements. 5. Strengthened Year-End Closing Procedures Grant-specific procedures will be incorporated into the City's year-end closing checklist. Finance will perform a detailed review of outstanding grant expenditures, reimbursement requests, accrued revenues, deferred inflows, and subsequent receipts to verify that grant transactions are recognized in the appropriate fiscal period prior to issuance of the Annual Comprehensive Financial Report (ACFR). Responsible Department: Finance Department Responsible Official: Chief Financial Officer, Finance Director (or equivalent) Senior Accountant - Grants & Special Revenue Implementation Date: Began implementation in FY 2026 and will be fully incorporated into the City's ongoing financial reporting and year-end closing processes.

Audit Finding Reference: 2024-002 Document Policies and Procedures Over Federal Awards Planned Corrective Action: A Uniform Guidance policy and Procedure document has been adopted. Planned Implementation Date of Corrective Action: The policy was effective 03/21/2025. Person Responsible for Corrective Action: Finance Director

Planned Corrective Action: The Organization has a procurement policy within the Organization’s Internal Controls. The Organization has a procurement process within the Organization’s Operations Manual. However, they are missing key elements required in federal procurement. Both of these will be reviewed to ensure they align with CFR standards for federal procurement. Planned Implementation Date of Corrective Action: June 12, 2025 Name of Contact Person: Melinda Lequin, Executive Finance Director

Planned Corrective Action: While the Organization’s existing internal controls address management of invoices and payments, there was no written process within the organization’s internal controls that identified the required documentation, workpapers, review, and approval for federal grant reimbursements. Planned Implementation Date of Corrective Action: October 1, 2025 Name of Contact Person: Melinda Lequin, Executive Finance Director

Planned Corrective Action: There was no written process within the Organization’s Internal Controls that identified the requirements for federal grant management and subrecipient oversight. The draft for these internal controls has been updated to include a subrecipient monitoring / risk assessment process. Planned Implementation Date of Corrective Action: October 1, 2025 Name of Contact Person: Melinda Lequin, Executive Finance Director

Recommendation: The federal single audit report must be submitted to the FAC in accordance with the deadlines set forth in the federal guidelines.

Recommendation: We recommend that the City implement controls over USDA reports to ensure that they are reviewed prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The City will work to ensure that the management reports are reviewed prior to submission. Name of the contact person responsible for corrective action: Christina Regas, City Administrator Planned completion date for corrective action plan: December 31, 2025.

Management will: Establish grant drawdown submission deadlines, Implement automated compliance calendar reminders and list of important dates for grant period, and Annual Uniform Guidance compliance training.

Management will improve internal processes and controls to include the following: Creation of a subset of general ledger codes for unallowed program costs, Management review of program expenditure requests prior to payment, and Annual Uniform Guidance compliance training.

Management will improve internal processes and controls to include the following: Monthly staff training for documentation retention requirements and policies, Quarterly audits of program expenditure documentation, and Annual Uniform Guidance compliance training.