Corrective Action Plans

Finding 1155182 (2023-004)

Material Weakness 2023

Recovery Connections of Central Florida, Inc.

FL

Procurement, Suspension & Debarment Equipment & Real Property Management

Property & Equipment, Procurement, Suspension and Debarment Recommendation: Recommended Recovery Connections of Central Florida, Inc. create a suspension and debarment policy and perform a physical inventory observation. Explanation of disagreement with audit finding: There is no disagreement with t...

Property & Equipment, Procurement, Suspension and Debarment Recommendation: Recommended Recovery Connections of Central Florida, Inc. create a suspension and debarment policy and perform a physical inventory observation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: We will establish policies and procedures for procurement, suspension, debarment, and inventory observations. Name of the contact person responsible for corrective action: Ira Burke Planned completion date for corrective action plan: December 31, 2025

View Audit 367424

Finding 1155060 (2023-009)

Material Weakness 2023

Muskogee County

OK

Questioned Costs Subrecipient Monitoring

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

The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the new county grant administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. The Board of County Commissioners will work with the new county grant administrator to ensure proper grant administration.

View Audit 367368 Questioned Costs: $1

Finding 1155059 (2023-008)

Material Weakness 2023

Muskogee County

OK

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

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

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

View Audit 367368 Questioned Costs: $1

Finding 1155058 (2023-007)

Material Weakness 2023

Muskogee County

OK

Reporting

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

The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the new county grant administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. The Board of County Commissioners will work with the new county grant administrator to ensure proper grant administration.

View Audit 367368

Finding 1155057 (2023-006)

Material Weakness 2023

Muskogee County

OK

Questioned Costs Procurement, Suspension & Debarment

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

The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the new county grant administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. The Board of County Commissioners will work with the new county grant administrator to ensure proper grant administration.

View Audit 367368 Questioned Costs: $1

Finding 1155056 (2023-005)

Material Weakness 2023

Muskogee County

OK

Internal Control / Segregation of Duties

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

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

View Audit 367368

Finding 1155055 (2023-004)

Material Weakness 2023

Muskogee County

OK

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

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

View Audit 367368

Finding 1155054 (2023-004)

Material Weakness 2023

County of Columbia, Pennsylvania

PA

Student Financial Aid Subrecipient Monitoring Reporting

2023-004 - (Noncompliance) Completion of Single Audit Federal Program: Assistance Listing #14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economi...

2023-004 - (Noncompliance) Completion of Single Audit Federal Program: Assistance Listing #14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economic Development and Pennsylvania Emergency Management Agency, Pass-Through Entity Identifying Numbers: C000073444, C000075689, C000082264, C000086078, and PEMA-2022-007 Assistance Listing #21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Number: not available Assistance Listing #21.023, COVID-19 Emergency Rental Assistance Program, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Assistance Listing #93.658, Foster Care - Title IV-E, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Condition/Context: The County’s December 31, 2022 Single Audit was not completed and submitted within the required time period. Recommendation: We recommend that as the County gets up and running on the new accounting system, the audit be prioritized in future periods. Views of Responsible Officials and Planned Corrective Actions: The County is working with its fee accountant and external auditors to ensure a timely filing of the Single Audit going forward. Individual Responsible: Finance Department Timeline for corrective action: By December 31, 2026

View Audit 367366

Finding 1155053 (2023-003)

Material Weakness 2023

County of Columbia, Pennsylvania

PA

Subrecipient Monitoring Cash Management

2024-003 – (Noncompliance) Uniform Guidance Written Policies/Procedures Federal Program: Assistance Listing #14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Com...

2024-003 – (Noncompliance) Uniform Guidance Written Policies/Procedures Federal Program: Assistance Listing #14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economic Development and Pennsylvania Emergency Management Agency, Pass-Through Entity Identifying Numbers: C000073444, C000075689, C000082264, C000086078, and PEMA-2022-007 Assistance Listing #21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Number: not available Assistance Listing #21.023, COVID-19 Emergency Rental Assistance Program, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Assistance Listing #93.658, Foster Care - Title IV-E, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Condition/Context: While the County has informal policies and procedures surrounding the administration of its federal programs, these policies and procedures have not been formally documented to ensure compliance with the areas of allowability of costs, cash management or subrecipient monitoring as required under the Uniform Guidance. Recommendation: We recommend that County management prepare the required written policies/procedures related to allowability of costs, cash management and subrecipient monitoring outlined with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: The County realizes that we are not compliant with our policies/procedures, we are currently working on them and plan to have them completed by 12/31/2025. The County does have several policies/procedures in place and in our handbook, but there are a few we do not and are working to complete them so we are compliant with the Uniform Guidance guidelines. Individual Responsible: Finance Department Timeline for corrective action: By December 31, 2025

View Audit 367366

Finding 1155052 (2023-006)

Material Weakness 2023

County of Columbia, Pennsylvania

PA

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

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

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

View Audit 367366

Finding 1155051 (2023-005)

Material Weakness 2023

County of Columbia, Pennsylvania

PA

Subrecipient Monitoring

2023-005 - Subrecipient Monitoring - Material Weakness/Noncompliance Federal Program: Assistance Listing #14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Commun...

2023-005 - Subrecipient Monitoring - Material Weakness/Noncompliance Federal Program: Assistance Listing #14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economic Development and Pennsylvania Emergency Management Agency, Pass-Through Entity Identifying Numbers: C000073444, C000075689, C000082264, C000086078, and PEMA-2022-007 Assistance Listing #21.023, COVID-19 Emergency Rental Assistance Program, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Condition/Context: The County does not have a formal risk assessment or oversight program in place to monitor its subrecipients as required under the Uniform Guidance, including ensuring that financial information reconciles between the underlying expenditure reports and the subrecipient/County audit reports. Recommendation: We recommend that the County revisit its policies and procedures related to subrecipient monitoring and ensure that there are formal subaward agreements with all subrecipients, prepare a formal, initial, risk assessment of each potential subrecipient and document its monitoring activities of each subrecipient. Views of Responsible Officials and Planned Corrective Actions: Columbia County is implementing procedures for reviewing agreements, updating to require information, document oversite, our anticipated date for this is 10/1/2025. Individual Responsible: Finance Department Timeline for corrective action: By December 31, 2025

View Audit 367366

Finding 1155030 (2023-001)

Material Weakness 2023

YMCA De San Juan (the Young Men's Christian Association of San Juan, Inc.)

PR

Reporting § 200.512

Finding 2023-001: The Organization did not timely submit audited financial statements to the Office of Management and Budget (OMB). YMCA of San Juan Response: The Organization agrees with the finding. Corrective action plan: During 2024, YMCA implemented a more timely process for closing its financi...

Finding 2023-001: The Organization did not timely submit audited financial statements to the Office of Management and Budget (OMB). YMCA of San Juan Response: The Organization agrees with the finding. Corrective action plan: During 2024, YMCA implemented a more timely process for closing its financial statements. Additionally, financial information is now presented to the Finance Committee of the Board of Directors on a quarterly basis. As part of these improvements and to prevent this finding in the future, the 2024 financial audit was initiated in March 2025, with the goal of completing both the 2024 financial audit and single audit by June 2025. Name (s) of person (s) responsible for corrective action: Lysbell Araujo, Finance Director YMCA Accounting Department Anticipated completion date: June 2025

View Audit 367359

Finding 1154956 (2023-005)

Material Weakness 2023

Copa Health, Inc.

AZ

Internal Control / Segregation of Duties § 200.303

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

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

View Audit 367290

Finding 1154859 (2023-002)

Material Weakness 2023

Hocking County

OH

Procurement, Suspension & Debarment Subrecipient Monitoring

The Auditor’s Office will work alongside the Commissioner’s Office to check vendors at the beginning of the year and recurring vendors will be checked.

View Audit 367200

Finding 1154855 (2023-003)

Material Weakness 2023

Hocking County

OH

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Cash Management § 200.302 § 200.318 § 200.319 § 200.320 § 200.430

The Auditor’s Office will work with the Commissioner’s Office and Prosecutor’s Office to implement the required policies.

View Audit 367200

Finding 1154795 (2023-200)

Material Weakness 2023

Oklahoma Water Resources Board

OK

Special Tests & Provisions

Finding Number 2023-200 Subject Heading (Financial) or AL no. and program name (Federal) 96.001: Social Security - Disability Insurance Program Planned Corrective Action The OkDRS’s Disability Determination Services (DDS) recognizes that some documentation of licensure verification was not completed...

Finding Number 2023-200 Subject Heading (Financial) or AL no. and program name (Federal) 96.001: Social Security - Disability Insurance Program Planned Corrective Action The OkDRS’s Disability Determination Services (DDS) recognizes that some documentation of licensure verification was not completed. While the actual verification was completed, completing a document that verifies this was not. This was an oversight and is being corrected. There are two areas that are affected, the first being the Professional Relations Office (PRO) who works with outside vendors who complete exams for OkDRS’ s claimants, and the internal Medical Consultants who are directly employed with OkDRS to do internal consulting while the staff makes medical decisions for the claimants. The PRO’s are working to fill in the gaps of the spreadsheet to ensure that the master listing has notations that are missing. The internal reviews were completed and documented in an SSA SharePoint site; however, OkDRS had no required internal process or procedure to notate these verifications. An official process and procedure is being developed and implemented. Please note, in the upcoming year, the DDS case processing system will be implementing required inputs regarding medical consultant licensing. This will provide an additional check point for OkDRS’s documentation and review of medical consultant licenses. Anticipated Completion Date 6/6/2025 Responsible Contact Person Jennifer L. Thornton

View Audit 367158

Finding 1154794 (2023-109)

Material Weakness 2023

Oklahoma Water Resources Board

OK

Procurement, Suspension & Debarment § 200.317 § 200.327 § 200.404

Finding Number 2023-109 Subject Heading (Financial) or AL no. and program name (Federal) ALN: Multiple Federal Program name: Multiple Planned Corrective Action The finding states two ongoing concerns: “1) there are no policies and procedures in place for the people on [the pilot program] Statewide C...

Finding Number 2023-109 Subject Heading (Financial) or AL no. and program name (Federal) ALN: Multiple Federal Program name: Multiple Planned Corrective Action The finding states two ongoing concerns: “1) there are no policies and procedures in place for the people on [the pilot program] Statewide Contracts [as is required by 2 CFR § 200.317], and 2) these vendors are not being vetted to ensure state agencies are getting contracts that are reasonable per 2 CFR 200.404.” On the first issue, Section 200.317 of Title 2 of the Code of Federal Regulations requires states to “follow the same policies and procedures it uses for procurements with non– Federal funds” when “conducting procurement transactions under a Federal award.” 2 CFR § 200.317. Our publicly available CPO training explains the process for purchasing off Statewide Contracts (See Attachment 1 and 2). Also, we provided agencies with procedures related to the pilot program to give guidance on ordering off those specific Statewide Contracts (See Attachment 3). Additionally, OMES reiterates that Recipients of federal funds are ultimately charged with ensuring and documenting compliance with specific requirements under the federal award. However, in an attempt to assist agencies in understanding requirements of spending federal dollars, OMES issued a Procurement Information Memorandum and a new contract attachment to be utilized by agencies. (See Attachments 4 and 5). Therefore, OMES disagrees that we do not have the required policies and procedures in place to comply with Section 200.317. On the second issue, Section 200.404 of Title 2 of the Code of Federal Regulations explains, “A cost is reasonable if it does not exceed an amount that a prudent person would incur under the circumstances prevailing when the decision was made to incur the cost.” All our Statewide Contracts are evaluated on specific criteria, including pricing. If a bidder’s pricing appears to be unreasonable, they do not receive an award. Additionally, in Attachment 3 it is demonstrated that when an agency ordered from the pilot program Statewide Contracts, the Information Services Division (“ISD”) of OMES works with the agency and the supplier to develop a Scope of Work (“SOW”). The SOW is comprised of detailed deliverables and pricing for the relevant goods and/or services. ISD stakeholders are subject matter experts in the relevant work and ensure that all pricing on SOWs is fair, competitive and reasonable. Therefore, OMES also disagrees with the assertion that the vendors on contract are not vetted to ensure that state agencies are getting reasonable costs on their contract. OMES further reiterates that we believe the relevant solicitations were conducted pursuant to the requirements of the Statewide Contract pilot programs and meet competitive bidding requirements. The Statewide Contract pilot programs utilized the same initial procedures as all other Statewide Contracts prescribed in statute. Vendors are required to agree to standard state terms and submit competitive pricing for the goods and/or services within scope of the solicitation. OMES identifies evaluators for every solicitation to conduct an evaluation process relevant to the particular scope of services and to negotiate price when choosing responsive and responsible suppliers. In conclusion, OMES respectfully disagrees with the concerns of the State Auditor’s Office and invites any member of the State Auditor’s team to meet with OMES personnel to further clarify our processes and standards for ensuring fair and competitive procurement practices. Anticipated Completion Date Sine Die Responsible Contact Person

View Audit 367158

Finding 1154792 (2023-083)

Material Weakness 2023

Oklahoma Water Resources Board

OK

Allowable Costs / Cost Principles

Finding Number 2023-083 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 – Medicaid Planned Corrective Action An adjustment will be made in the QE March 2025 cost allocation system. System changes have been made to prevent this going forward. Anticipated Completion Date 4/30/2...

Finding Number 2023-083 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 – Medicaid Planned Corrective Action An adjustment will be made in the QE March 2025 cost allocation system. System changes have been made to prevent this going forward. Anticipated Completion Date 4/30/2025 Responsible Contact Person Kevin Haddock

View Audit 367158

Finding 1154791 (2023-071)

Material Weakness 2023

Oklahoma Water Resources Board

OK

Eligibility Subrecipient Monitoring Matching / Level of Effort / Earmarking

Finding Number 2023-071 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action OKDHS Response: The agency will manually load the workflow queues using the monitoring transactions for the G1dx discrepancies, and we will continuously work to ...

Finding Number 2023-071 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action OKDHS Response: The agency will manually load the workflow queues using the monitoring transactions for the G1dx discrepancies, and we will continuously work to improve the system failures preventing automatic workload management. This includes bi-weekly updates to ensure all items are properly queued for resolution until the system can fully resume this functionality. OHCA Member Audit Response: Member Audit began receiving Medicaid G1DX files monthly in September of 2023. Files are continuing to be received from DHS each month. Audits are completed monthly and will continue indefinitely. Any discrepancies are discussed with OKDHS to determine the cause and remedy put in place to ensure any failed jobs were resolved. Anticipated Completion Date 9/30/2025 Responsible Contact Person Jennifer McSparrin, OKDHS Programs Administrator of Business Intelligence April Anonsen, Deputy State Medicaid Director Ginger Clayton, Director of Member Audits

View Audit 367158

Finding 1154790 (2023-037)

Material Weakness 2023

Oklahoma Water Resources Board

OK

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

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

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

View Audit 367158 Questioned Costs: $1

Finding 1154789 (2023-030)

Material Weakness 2023

Oklahoma Water Resources Board

OK

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

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

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

View Audit 367158

Finding 1154788 (2023-024)

Material Weakness 2023

Oklahoma Water Resources Board

OK

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

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

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

View Audit 367158

Finding 1154787 (2023-020)

Material Weakness 2023

Oklahoma Water Resources Board

OK

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Eligibility

Finding Number 2023-020 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action To improve accuracy and timeliness of expenditure reporting, OHCA plans to schedule internal meetings between Long Term Services and Supports (LTSS) staff, finan...

Finding Number 2023-020 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action To improve accuracy and timeliness of expenditure reporting, OHCA plans to schedule internal meetings between Long Term Services and Supports (LTSS) staff, financial management team, and federal reporting team, at a minimum, quarterly. The team will discuss project progress and review budget to actual expenditures to be reported in the quarterly spending plan. As needed, OHCA will request the Center for Medicare and Medicaid (CMS) Technical Assistance (TA) to ensure OHCA is reporting in the manner CMS requires. Prior to submitting an American Rescue Plan Act of 2021 (ARPA) spending plan, the completed document will be circulated to the internal team for review and approved by the LTSS Senior Director. Because the amount reported is cumulative, the error self-corrects in future spending plans; therefore, OHCA does not plan to re-submit previously reported spending plans. Anticipated Completion Date 10/31/2024 Responsible Contact Person David Ward, Senior Director of Sooner Care Operations

View Audit 367158

Finding 1154786 (2023-016)

Material Weakness 2023

Oklahoma Water Resources Board

OK

Questioned Costs Special Tests & Provisions Reporting

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

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

View Audit 367158 Questioned Costs: $1

Finding 1154785 (2023-008)

Material Weakness 2023

Oklahoma Water Resources Board

OK

Reporting Cash Management § 200.510

Finding Number 2023-008 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action The Schedule of Expenditures of Federal Awards (SEFA) errors were corrected on October 16, 2024. To ensure the support for the Schedule of Expenditures of Federa...

Finding Number 2023-008 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action The Schedule of Expenditures of Federal Awards (SEFA) errors were corrected on October 16, 2024. To ensure the support for the Schedule of Expenditures of Federal Awards is transferred accurately from the calculation worksheets and the other GAAP packages, we will implement a GAAP Package Z – SEFA Reviewer Checklist that will be included with the backup data of the GAAP Z. This will ensure the sources of data for the Schedule of Expenditures of Federal Awards are transferred correctly and tied back to their original source. Anticipated Completion Date 10/31/2024 Responsible Contact Person Calvin Cole, Financial Manager III

View Audit 367158

Corrective Action Plans

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