Corrective Action Plans

Finding 2024-003 Allowability-Payroll: Federal Agency – U.S. Department of Housing and Urban Development Program Name – Community Development Block Grants/Entitlement Grants Federal Assistance Listing Number: 14.218 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (g)(1) states, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must : (i) Be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the recipient or subrecipient; (iii) Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities (for IHES, this the is the IBS); (iv) Encompass federally-assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipients written policy; (v) comply established accounting policies and procedures of the recipient or subrecipient (See paragraph (i)(1)(ii) of this section for treatment of incidental work for IHES.); and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than on Federal ward; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. 2 CFR 200.403 indicates that costs must “be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity” and must be “adequately documented”. Responsible Parties: The City Auditor will work with the Mayor’s Office of Economic and Community Development to enhance the policies and procedures in place to ensure that expenditures charged to the federal awards are properly reviewed and supported.

Management's Response: Management concurs with the above finding and will ensure that human resources, fiscal services and Title Ill all have proper approvals, budgets and written authorization of anything that deviates from the approved budget. The corrective action will be implemented immediately and completed by June 2025.

Upon identification of costs allocated to more than one grant, the Organization identified allowable costs previously charged to program income and reallocated the duplicated expenditures without creating other instances of noncompliance (such as cash management or period of performance). Although the initial support provided to auditors contained instances of expenditures charged to more than one grant, expenditure justification has been updated to reflect corrections and all subsequent grant expenditure detail has been reviewed to ensure no recurrence in the subsequent period. The Organization has also reviewed our internal processes to capture all salaries supported by grants accurately and timely. Additional internal controls such as limiting the number of grants an employee can be on at one time and the reduction of more catch-up drawdowns to account for staffing changes within the organization were implemented. We are also working with our accounting software vendor and payroll vendor to automate the allocation of grant salaries based on time and effort of each individual rather than after-the-fact allocations to grants. This will reduce the need to maintain manual spreadsheets to track staff and essentially eliminate the risk of charging expenditures to more than one grant. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters. Official Responsible for Ensuring the Corrective Action Plan: Danielle Hahn, Progressive Community Health Center Chief Financial Officer. Planned Completion Date for the Corrective Action Plan: The Organization has implemented the corrective action plan as of December 2024 and will continue to monitor throughout the year.

The Agency updated procedures for developing the SEFA in accordance with 2 CFR 200.502 which states, “The determination of when a federal award is expended must be based on when the activity related to the Federal award occurs.”The Agency is required to comply with 2 CFR 200.403 which indicates that allowable costs must be determined in accordance with accounting principles generally accepted in the United States of America (GAAP). The Agency updated procedures for developing the SEFA in accordance with both 2 CFR 200.502 and 2 CFR 200.403 to include the following process improvement: The agency has modified its current process to ensure the direct and indirect costs charged to the federal programs include only the costs incurred during the current fiscal year.

Condition: The District submitted the Sp. Ed. IDEA Preschool 2024 grant budget late and claimed costs preceding the budget submission date, resulting in questioned costs of $4,646. Recommendation: The District should take steps to submit grant applications in a timely manner to ensure that they are able to claim all expenses as budgeted. We recommend reviewing the general ledger to the expenditure reports before submitting for more accurate reporting. Management Response: The District will take steps to submit grant applications in a timely manner. The District will review the general ledger to the expenditure reports before submitting.

Condition: The District submitted the Title I 2024 grant budget late and claimed costs preceding the budget submission date, resulting in questioned costs of $114,912. Recommendation: The District should take steps to submit grant applications in a timely manner to ensure that they are able to claim all expenses as budgeted. We recommend reviewing the general ledger to the expenditure reports before submitting for more accurate reporting. Management Response: The District will take steps to submit grant applications in a timely manner. The District will review the general ledger to the expenditure reports before submitting.

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System has finalized the standard work procedure titled, Request for Funds/Reimbursement Claims (2-201’s), to ensure costs are appropriately charged based on the contract’s performance periods. Review of cost activity will occur in fiscal year 2025 to ensure policy is followed.

FINDING 2024-002 Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School District to ensure compliance with requirements related to the Education Stabilization Fund and Activities Allowed or Unallowed. FINDING 2024-002 (Continued) Context: During the testing of payroll disbursements charged to the Education Stabilization Fund grant awards during the audit period, the following exceptions were noted: • For 16 payroll disbursements, in a sample of 40, management was unable to provide an approved employee contract or hourly rate ordinance to support the selected employees' bi-weekly pay rate. • For one transaction selection, an employee received a $730.43 one-time payment for a Teacher Appreciation Grant (TAG) funded by the 84.425U award. The Teacher Appreciation Grant has its own fund and is a state/local grant received to reward high-performing, eligible certified staff. The selected employee is a noncertified employee and did not qualify for a TAG award. There was no documentation provided to support work performed under this award to support allowability of the cost incurred. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will ensure records of approved contracts are maintained for all employees and that payroll charged to federal awards is reviewed each pay period for allowability. The HR Coordinator is currently storing each contract both by hard copy in the employee file and digitally in our software. The Deputy Treasurer/Payroll Coordinator reviewing the distribution report prior to payroll submission. The Treasurer is also reviewing and will sign off on the distribution report for each payroll. Responsible Party and Timeline for Completion: Kelli Kizzee - HR Coordinator, Jessica Elliot - Payroll Coordinator, Moriah Crane - Treasurer. The process is already in place.

FINDING 2024-004 Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): H027A220084, H027A230084 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School District to ensure compliance with requirements related to the Special Education Cluster and Activities Allowed or Unallowed. Context: During the testing of a sample of 40 payroll disbursements charged to the Special Education Cluster during the audit period, the following exceptions were noted: • For eight transactions selected, management was unable to provide an approved contract to support the selected employees' bi-weekly pay rate. • For two transactions selected, management was unable to provide approved timecards for the selected hourly employee and time period. • For seven transactions selected, management was unable to provide time and effort logs to support the allocation of one employee's salary between the federal grant and the Education fund. The lack of controls was systematic throughout the audit period. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will ensure records of approved contracts and approved timecards are maintained for all employees. Management will ensure payroll charged to federal awards is reviewed each pay period for allowability. The HR Coordinator is currently storing each contract both hard copy in the employee file and digitally in our software. The Deputy Treasurer/Payroll Coordinator will review the distribution report prior to payroll submission. As time cards are being approved in our software system, a print out of the approvals will be maintained for each payroll. The Treasurer will review and sign off on the distribution and approval report for each payroll. Responsible Party and Timeline for Completion: Kelli Kizzee - HR Coordinator, Jessica Elliot - Payroll Coordinator, Moriah Crane - Treasurer. The process is already except for the printed time card approval report which will be in place starting with the January 2025 payrolls.

Corrective Action Plan: The District has developed and implemented a Federal Funds Manual. Anticipated Corrective Action Plan Completion Date: November 18, 2024 Contact Information: For additional information regarding this finding please contact Blaise Paul, Chief Business & Finance Officer, at 414-768-6140.

Condition: The School District's controls did not prevent or detect and correct, in a timely manner, costs charged to the grant that were more than the related invoices. Planned Corrective Action: The Grant Accounting team will develop a standard operating procedure on review and approval of journal entries. The Grant Account Team will provide training to Grant Compliance staff members on the defined process. Grant Compliance Senior Director and Assistant Director will be responsible for ensuring journal requests are submitted following the outlined operating procedure. Grant Accounting staff members will review submitted materials to ensure no invoice is overcharged and then process journal request. Contact person responsible for corrective action: Jeremy Vidito, CFO Anticipated Completion Date: 3/1/2025

2024-002 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425U - COVID-19 - Elementary and Secondary School Emergency Relief Fund (ESSER III) Passed-through Colorado Department of Education Award Number - 4414/4431/9414; Award Year 2021 Summary of Finding: The District did not have adequate internal controls in place over the ESSER grant which resulted in unallowable costs being applied to the grant and inconsistently applying indirect costs to the grant. Status: Corrective action in progress Client Planned Action: The District concurs with the recommendations and is currently developing and implementing internal controls to ensure compliance. The inadequate internal controls that caused the inconsistency in supporting payroll information involved the End-of-Year Closeout process. The District will ensure End-of-Year Closeout procedures are up to date and adhered to. These procedures will include a second review of calculations used to determine the expenditure amount in accruals, to ensure it recalculates. The District will also conduct a second review of the supporting detail used to determine Indirect Costs to ensure they are consistent with CDE recommendations and District policies and procedures. Client Responsible Party: Annette Bass, Director of Grants Completion Date: Review of department End-of Year Closeout process began in September 2024. Adjustments and revisions will be made to these processes as needed, prior to End-of-Year Closeout, June 30, 2025.

Federal Program Title: Postconviction Testing of DNA Evidence; Capital Case Litigation Initiative ALN: 16.820; 16.746 Recommendation: We recommend the University review its current procedures to ensure disallowable costs are not being charged allocated to federal programs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Boise State University is reminding faculty and staff about lobbying and the basics of charging costs to a sponsored project with an emphasis on cost allocability. Name(s) of the contact person(s) responsible for corrective action: Jen Lutke Planned completion date for corrective action plan: December 31, 2024

Corrective Steps Taken – The District will implement the reinforcement of its internal controls. Expenditures will be verified against the MDE approved budget.

The Payroll Department has taken immediate action to develop additional safeguards to avoid duplicate pay. When Central Payroll adds to a payline, we will notify the requestor to inform them of this action and ask that they review their payline for accuracy. This should trigger a response from the requestor if they had also added the missing hours via a CU Special Pay. Additionally, as of 06/21/2024, the Late Timesheet option was turned off on CU Special Pay to strengthen controls. Individuals now contact payroll@clemson.edu for assistance. Once contacted the payroll/timekeeping team will update the timecard and ensure the missed pay is added to the next payroll cycle, assuming an emergency/off-cycle check is not needed. The College of Engineering and Applied Sciences (CECAS) will take action to strengthen internal controls to ensure accuracy and compliance. We will establish clear procedures to verify employee payroll data via paylines, as well as cross checking with CU Payroll to ensure changes are properly documented and authorized. We will provide ongoing training for departmental payroll staff on best practices and compliance requirements. Anticipated Completion Date: September 17, 2024 Person Responsible: Central Payroll – Ami Hood, Payroll Director; CECAS – Keri Cortese, Director of Procurement and Payroll Operations Contact/Responsible Party: Ami Hood, Payroll Director Contact Information: hooda@clemson.edu

2024-005 Period of Performance Corrective action planned: The Fiscal Supervisor and/or the Director of Fiscal Operations will review expenditures before payment to ensure that GAAP and the accrual basis of accounting are being followed. Month-end closing procedures will include a review of all prepaid expenses to assure that a separate schedule is maintained and reconciled to the general ledger. Anticipated completion date: 11-30-2024 Contact person responsible for corrective action: Cathy Liles, Director of Fiscal Operations

Description: Management’s schedule of Expenditures of Federal Awards was incomplete, resulting in lack of identification of the need for a Single Audit and the delay in its completion. The State funder indicated that no Federal Single Audit was required. Management had not implemented a formal process for preparation of the SEFA. Recommendation: Management should prepare a master tracking schedule for government grants which includes the source of funding and audit and reporting requirements. The schedule should be prepared by someone with knowledge of the grant agreements and reviewed by a leader in the accounting department to ensure completeness. Responsible Contact: Laura McQuay, Vice President & Chief Financial Officer Corrective Action Planned: Management has implemented a master tracking schedule for government grants that includes the source of funding and audit and reporting requirements. This tracker is a joint effort between finance and grants management teams. Anticipated Completion Date: December 31, 2025

We will allocate shared costs appropriately among federal awards

FINDING 2023-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Tyler Pearson, Clerk Treasurer Contact Phone Number and Email Address: 574-739-1416 clerktreasurer@cityoflogansport.org Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: As a measure of corrective action, I will be implementing a check sheet that will be attached to every claim sheet. This new procedure requires that you go through the check sheet and initial each item to ensure that all procedures have been followed correctly before submission. Additionally, I will also maintain a check sheet in my office since I am the last person to review each claim. This will help to ensure thoroughness and accuracy in our claims processing. Furthermore, moving forward, any grant funds will be placed into their own individual funds and distributed through an individual account. This approach will allow us to track payments for any expenses associated with these funds more effectively. Additionally, the BOT expenditure is done and in the future we will do a better job. Anticipated Completion Date: October 31,2025

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 2023-099 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 2023-209 Subject Heading (Financial) or AL no. and program name (Federal) 93.323: Epidemiology and Laboratory Capacity for Infectious Diseases Planned Corrective Action The flagged contract and incorporated section were negotiated by OSDH's prior leadership at that time (May- June 2021). After a leadership change in October 2021, Commissioner Reed promptly terminated the contract - well before any such flagged services were engaged in or provided by the contractor. To OSDH's knowledge, it did not pay for any such services. Current OSDH leadership and Legal work diligently during the contract review process to ensure that unallowable activities are not included in vendor contracts. Anticipated Completion Date 6/30/24 Responsible Contact Person Stefan Von Dollen, Interim CFO

Finding Number 2023-208 Subject Heading (Financial) or AL no. and program name (Federal) 93.268: Immunizations Cooperative Agreements Planned Corrective Action The flagged contract and incorporated section were negotiated by OSDH's prior leadership at that time (May- June 2021). After a leadership change in October 2021, Commissioner Reed promptly terminated the contract - well before any such flagged services were engaged in or provided by the contractor. To OSDH's knowledge, it did not pay for any such services. Current OSDH leadership and Legal work diligently during the contract review process to ensure that unallowable activities are not included in vendor contracts. Anticipated Completion Date 6/30/24 Responsible Contact Person Stefan Von Dollen, Interim CFO

Finding Number 2023-005 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 Management Response: OMES-GMO concurs with the finding that CSLFRF program funds were applied to GEER and ERA expenses. OMES-GMO specifically notes that while the applied expenditures are indeed allowable under federal programs, the application of CSLFRF to these programs was in error ostensibly due to administrative challenges experienced throughout this tumultuous period. During the COVID-19 pandemic, states across the country faced numerous operational and compliance challenges, including frequently changing federal guidance and firsttime handling of federal funds. In response to the growing complexity of managing multiple federal funding programs, OMES established the Grants Management Office (OMESGMO). However, in its initial phase, the OMES-GMO experienced consistent instability with a high frequency of employee turnover, understaffing, limited resources, restricted internal controls, and practiced leadership. These factors contributed to classification errors and delays with internal review. Since then, OMES-GMO has taken steps to stabilize operations by maintaining consistent leadership, hiring additional staff, and the uniform application of organizational processes. These improvements have strengthened internal controls and allowed for the identification of previously misapplied expenditures. Prior to the finding, OMES-GMO reviewed and flagged these expenditures and is actively working to correct the issue. To resolve the misclassification, OMES has requested state appropriations to properly adjust and reallocate these expenses to their appropriate funding sources. Anticipated Completion Date Controls have been put into place and will continue through the end of the Federal Period of Performance and closeout. Responsible Contact Person Parker Wise

Finding Number 2023-091 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Emergency Rental Assistance Program (ERA) Planned Corrective Action 1. Condition and Context: While documenting controls over Period of Performance for the ERA 1 grant, we noted payments made to subrecipients in the Statewide Accounting System were all put under one fund and were not distinguishable between ERA 1 and ERA 2. Therefore, OMES was unable to determine at a glance whether the funds distributed to subrecipients were attributable to ERA 1 or ERA 2. Further, we determined one of the subrecipients, Communities Foundation of Oklahoma (CFO), did not have sufficient internal controls over ERA 1 program spending to ensure all funds were expended by the end of the period of performance. • We disagree with SAI on the Statewide Accounting System separation of funds. The Statewide Accounting System did distinguish between ERA1 and ERA2. The Statewide Accounting System has funds 49400 and 49200 shows establishment of both federal funds in 2021. • We disagree with SAI on CFO’s internal controls. CFO did have internal controls in place to ensure funds were expended during the period of performance. Per ERA 1 Closeout Resource “The end date of the award period of performance is the last day for a grantee to obligate funds for ERA1 activities (September 30, 2022, for award funds received pursuant to the grantee’s initial allocation and December 29, 2022, for reallocated funds). Per documentation provided by SAI the general ledger shows a date before December 29, 2022. (Attachment 494,492, ERA Closeout Resource) 2. For eight of 30, or 26.67% of adjustments tested, the adjustment was to move expenses from ERA 2 to ERA 1 to meet ERA 1 spending requirements prior to closeout of the program. CFO comingled ERA 1 and ERA 2 funds and could not directly support each recharacterization with documentation for the specific transactions involved, but stated it was recharacterized to meet ERA 1 spending limits prior to the end of the period. In addition, CFO did not go back to revise any prior monthly or quarterly reports as required by Treasury. • We partially agree. We agree that funds cannot be moved from ERA 2 to ERA 1. • We disagree with SAI on comingling of funds. CFO did not comingle funds. CFO has 31 separate accounts within C-Suite their financial software. All accounts are listed and examples provided in the ERA Fund Open Report. • We disagree with SAI’s evaluation of the Treasury reporting requirement. CFO was not required to go back and revise prior monthly and quarterly reports per federal guidance. “As of December 2022, ERA1 grantees will only be able to edit their Final Report or as applicable, their Q4 2022 report. However, grantees may submit revisions to certain financial data submitted with their past quarterly reports, specifically, subrecipient/contractor/direct payee records; subaward/contract/direct payment records; and expenditure records when completing their Final Report or as applicable, their Q4 2022 Report. “While ERA1 grantees are no longer able to submit or revise any prior ERA1 quarterly reports, grantees may receive additional communications from Treasury’s compliance team to make corrections to past quarterly reports and as appropriate, the Final Report…” (Attachment ERA Closeout Resource pg 5) 3. For 11 of 30, or 36.67%, the adjustment was to move expenses between jurisdictions (City, State, County), which is unallowable per FAQ #42 and ERA reporting guidance. • We disagree with SAI’s unallowable cost. Due to a misunderstanding, CFO staff misstated that funds were moved between jurisdictions. Funds were not moved between jurisdictions. If a computer error occurred due to the large volume of checks that were being sent every week (approximately 1,600), not all errors were caught immediately. However, when further reviews were conducted and it was discovered a payment was issued incorrectly, the proper accounting procedures for correcting the errors were completed. (Attachment OneDrive_2025- 4-23(1)) • We disagree. FAQ 42 says nothing about jurisdictions. FAQ #42 states, “May a grantee provide ERA funds to another entity for the purpose of making payments more rapidly? To speed the delivery of assistance, grantees may enter into a written agreement with a nonprofit organization to establish a payment fund for the sole purpose of delivering assistance using ERA funds while a household’s application remains in process. A grantee may use such a process if: The process is reserved for situations in which an expedited payment could reasonably be viewed as necessary to prevent an eviction or loss of utility services that precludes employing the grantee’s standard application and payment procedures on a timely basis. The nonprofit organization has the requisite financial capacity to manage the ERA funds, such as being a certified community development financial institution. The nonprofit organization deposits and maintains the ERA funds in a separate account that is not commingled with other funds. The grantee receives all required application and eligibility documentation within six months. The nonprofit organization agrees in writing to return to the grantee any assistance that the household was ineligible for or for which the required documentation is not received within six months. Any funds not used by the nonprofit organization are ultimately returned to the grantee. If a payment made by the nonprofit organization is subsequently found to have been used for an ineligible household or an ineligible expense, or if the required application and eligibility documentation are not timely submitted, the payment will be considered an ineligible use of ERA funds by the grantee. Any administrative expenses attributable to a payment fund should be considered in accordance with FAQ 29.” (Attachment ERA FAQs) 4. When performing our testwork to determine whether ERA 1 expenditures met period of performance requirements (incurred on or before September 30, 2022), we noted 207 transactions occurred after September 30, 2022. Of the 207 transactions, we noted 40 that resulted in $10,711,668 (of this amount $2,313,435 is already questioned above) in questioned costs. • We disagree with SAI’s questioning of expenditures incurred after September 30, 2022. Per the ERA 1 Closeout Resource, “The end date of the award period of performance is the last day for a grantee to obligate funds for ERA1 activities (September 30, 2022, for award funds received pursuant to the grantee’s initial allocation and December 29, 2022, for reallocated funds). Per documentation provided by SAI, the general ledger shows a date before December 29, 2022. (Attachment ERA Closeout Resource pgs 1, 4) 5. For 13 of 207, or 6.28% of transactions tested, the adjustment was to move funds between funding jurisdictions (City, State, County), which is unallowable per FAQ #42 and ERA reporting guidance. (This resulted in $1,594,881 in questioned costs, of which $24,450 is questioned above) • We disagree with SAI’s questioned cost. Due to a misunderstanding CFO staff misstated that funds were moved between jurisdictions. Funds were not moved between jurisdictions. If a computer error occurred due to the large volume of checks that were being sent every week (approximately 1,600), not all errors were caught immediately. However, when further reviews were conducted and it was discovered a payment was issued incorrectly, the proper accounting procedures for correcting the errors were completed. (Attachment OneDrive_2025- 4-23(1)) • We disagree. FAQ #42 says nothing about jurisdictions. FAQ #42 states “May a grantee provide ERA funds to another entity for the purpose of making payments more rapidly? To speed the delivery of assistance, grantees may enter into a written agreement with a nonprofit organization to establish a payment fund for the sole purpose of delivering assistance using ERA funds while a household’s application remains in process. A grantee may use such a process if: The process is reserved for situations in which an expedited payment could reasonably be viewed as necessary to prevent an eviction or loss of utility services that precludes employing the grantee’s standard application and payment procedures on a timely basis. The nonprofit organization has the requisite financial capacity to manage the ERA funds, such as being a certified community development financial institution. The nonprofit organization deposits and maintains the ERA funds in a separate account that is not commingled with other funds. The grantee receives all required application and eligibility documentation within six months. The nonprofit organization agrees in writing to return to the grantee any assistance that the household was ineligible for or for which the required documentation is not received within six months. Any funds not used by the nonprofit organization are ultimately returned to the grantee. If a payment made by the nonprofit organization is subsequently found to have been used for an ineligible household or an ineligible expense, or if the required application and eligibility documentation are not timely submitted, the payment will be considered an ineligible use of ERA funds by the grantee. Any administrative expenses attributable to a payment fund should be considered in accordance with FAQ 29.” (Attachment ERA FAQs) 6. For 11 of 207, or 5.31%, the adjustment was to move funds between ERA 2 and ERA 1 and the adjustment was not directly supported with documentation for the specific transactions involved. It was noted as recharacterized to meet ERA 1 spending limits prior to the end of the period, and CFO did not go back to revise any prior monthly or quarterly reports as required by Treasury. (This resulted in $7,003,715 in questioned costs, of which $2,200,000 is questioned above) • Partially agree. • We agree that funds cannot be moved from ERA2 to ERA1 • We disagree with SAI’s evaluation of the Treasury reporting requirement. CFO was not required to go back and revise prior monthly and quarterly reports per federal guidance. “As of December 2022, ERA1 grantees will only be able to edit their Final Report or as applicable, their Q4 2022 report. However, grantees may submit revisions to certain financial data submitted with their past quarterly reports, specifically, subrecipient/contractor/direct payee records; subaward/contract/direct payment records; and expenditure records when completing their Final Report or as applicable, their Q4 2022 Report. “While ERA1 grantees are no longer able to submit or revise any prior ERA1 quarterly reports, grantees may receive additional communications from Treasury’s compliance team to make corrections to past quarterly reports and as appropriate, the Final Report…” (Attachment ERA Closeout Resource pg 5) 7. For 7 of 207, or 3.38% of transactions tested, the adjustment was to ‘correct accounts’ or ‘tie out accounts’; we determined these were not attributable to specific transactions but were ‘plug’ numbers to zero out the ERA 1 balance prior to the end of the period of performance to meet spend down requirements and were not supported by actual expenditures that can be determined to have been incurred on or before September 30, 2022. (This resulted in $1,837,072 in questioned costs, of which $88,985 is questioned above) • We partially agree. • We agree that funds cannot be moved from ERA 1 to ERA 2 • We disagree with SAI’s questioning of expenditures incurred after September 30, 2022. Per the ERA 1 Closeout Resource, “The end date of the award period of performance is the last day for a grantee to obligate funds for ERA1 activities (September 30, 2022, for award funds received pursuant to the grantee’s initial allocation and December 29, 2022, for reallocated funds). Per documentation provided by SAI, the general ledger shows a date before December 29, 2022. (Attachment ERA Closeout Resource pgs 1, 4) 8. For 7 of 207, or 3.38% of transactions tested, the adjustment was to CFO management fees. Management fees were retained on a percentage basis; therefore, the fee is not supported by actual expenditures that can be determined to have been incurred on or before September 30, 2022. (This resulted in $1,430,228 in questioned costs which were all questioned on finding 2023-028). We disagree with SAI’s questioning of expenditures incurred after September 30, 2022. Per the ERA 1 Closeout Resource, “The end date of the award period of performance is the last day for a grantee to obligate funds for ERA1 activities (September 30, 2022, for award funds received pursuant to the grantee’s initial allocation and December 29, 2022, for reallocated funds). Per documentation provided by SAI, the general ledger shows a date before December 29, 2022. (Attachment ERA Closeout Resource pgs 1, 9. We noted a total of $8,271,796 in management fees that were not expended for ERA 1 and therefore were not spent within the period of performance. Of this amount, $6,841,568 were management fees questioned in the SFY2021 and SFY2022 State of Oklahoma Single Audit reports and the remaining $1,430,228 is questioned on finding 2023-028. We disagree with SAI’s questioning of expenditures incurred after September 30, 2022. Per the ERA 1 Closeout Resource, “The end date of the award period of performance is the last day for a grantee to obligate funds for ERA1 activities (September 30, 2022, for award funds received pursuant to the grantee’s initial allocation and December 29, 2022, for reallocated funds). Per documentation provided by SAI, the general ledger shows a date before December 29, 2022. (Attachment ERA Closeout Resource pgs 1, 4) 10. For 2 of 207, or 0.97% of transactions tested, the payment was not supported by an itemized invoice to enable a determination that all the costs were incurred prior to September 30, 2022. (This resulted in $276,000 in questioned costs) • We disagree with SAI questioning cost and have provided supporting documentation in OneDrive - 2025-04-23(2) to show questioned expenditures. • We disagree with SAI’s questioning of expenditures incurred after September 30, 2022. Per the ERA 1 Closeout Resource, “The end date of the award period of performance is the last day for a grantee to obligate funds for ERA1 activities (September 30, 2022, for award funds received pursuant to the grantee’s initial allocation and December 29, 2022, for reallocated funds). Per documentation provided by SAI, the general ledger shows a date before December 29, 2022. (Attachment OneDrive -2025-04-23(2), ERA Closeout Resource pgs 1, 4 ) Oklahoma Office of Management and Enterprise Services (OMES) acknowledges the Oklahoma State Auditor and Inspector Office’s (SAI) findings that OMES did not implement the proper internal controls and oversight of the ERA Program during FY2023. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI. Beginning with FY2025, OMES has taken the following measures: • Oversight and management of the ERA program has been transferred to the OMES Grant Management Office (OMES-GMO) which has staff with several years of grant experience. OMES-GMO has recently hired additional staff, and the two staff members dedicated to the management of the ERA program have 20+ years of combined federal grant specific experience. To ensure that the subrecipient agreement includes all the required terms under the ERA Program and that the agreement does not expire, OMES-GMO and the Communities of Foundation of Oklahoma (CFO) have recently executed a Subrecipient Grant Agreement Amendment that details the responsibilities of OMES to monitor CFO and the duties and processes that CFO must follow in regard to ERA Program, including detailed cash management policies. See Attached – Grant Agreement Amendment. • OMES-GMO required the return of the remaining ERA2 Program funds from CFO to ensure proper oversight and review of ERA expenditures is performed. • OMES-GMO has a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. For example, OMES-GMO’s process for disbursing funds to a subrecipient requires a written request from the subrecipient with supporting documentation, then OMES-GMO assigns a staff lead and secondary grant analyst to perform a primary and secondary review for compliance and to require additional supporting documentation if needed to approve the request. Once those reviews are completed and approved by the OMES-GMO staff, the Director of the OMES-GMO must approve the request before it is sent to the OMES Finance Division, who will then verify the calculated amount(s) before completing the disbursement to the subrecipient. These internal controls and policies have been implemented for the management and oversight of the ERA Program and provide a multilayer review that will prevent fraud and risk factors applicable to the ERA program. Additionally, the OMES-GMO staff assigned to the ERA program have the training and knowledge to ensure compliance with the Federal grant requirements. • Depending on the level of risk, OMES-GMO conducts monthly, bi-weekly or weekly meetings with each subrecipient to monitor the progress of projects and address any issues or changes that might impact the project. For the ERA Program, OMES-GMO conducts bi-weekly monitoring meetings with CFO and is currently reviewing documentation provided by CFO to ensure all current ERA projects are eligible under the ERA guidelines and that CFO is exercising the proper oversight over their subrecipients. • OMES-GMO will continue with their current ERA monitoring steps and internal controls and will work with CFO to ensure ERA program funds are spent in accordance with ERA program guidelines and state and federal regulations. Anticipated Completion Date Ongoing throughout the life of the grant Responsible Contact Person Brandy Manek