OKLAHOMA ASSOCIATION OF COMMUNITY ACTION AGENCIES, INC.Non-Profit

Condition: The Association did not perform adequate monitoring of its Community Service Block Grant (CSBG) subrecipients during the year ended September 30, 2025. Criteria and cause: Uniform Guidance requires CSBG grantees to determine that there is reasonable assurance that the CSBG funds provided to subrecipients are adequately protected, and that services were provided to the community as expected. Effect: During the year ended September 30, 2025, the Association established a timeline for monitoring to choose two months during the grant period for each subrecipient to conduct a desk monitoring. However, the Association did not follow their established procedures and only performed one desk monitoring. Recommendations: We recommend that the Association update and comply with policies and procedures over the monitoring process. Views of responsible officials and planned corrective actions: Management concurs with the auditor’s findings and recommendations. The Association will update and comply with policies and procedures over the monitoring process to ensure the appropriate number of monitoring activities are performed.

Condition: The Association did not perform adequate monitoring of its Community Service Block Grant (CSBG) subrecipients during the year ended September 30, 2023. Criteria and cause: Uniform Guidance requires CSBG grantees to determine that there is reasonable assurance that the CSBG funds provided to subrecipients are adequately protected, and that services were provided to the community as expected. Effect: During the year ended September 30, 2023, the Association established a timeline for monitoring and chose one month during the grant period for each subrecipient to conduct a desk monitoring. However, the Association did not follow up to ensure that each subrecipient provided support. The Association also did not perform proper review of the provided support. Recommendations: We recommend that the Association develop policies and procedures over the monitoring process. This should include a policy over what steps can be taken if a subrecipient does not comply with the monitoring. This should also include procedures to reconcile monthly expenditures reports/draw down requests to supporting documentation. Views of responsible officials and planned corrective actions: Management concurs with the auditor’s findings and recommendations. The Association will develop policies and procedures over the monitoring process. This will include a policy over what steps can be taken if a subrecipient does not comply with the monitoring. This will also include procedures to reconcile monthly expenditures reports/draw down requests to supporting documentation.

Contract: 90ET0478-03 & 90ET0478-01-C3 CARES Assistance Listing Number: 93.569 Criteria: Uniform Guidance requires CSBG grantees to determine that there is reasonable assurance that the CSBG funds provided to subrecipients are adequately protected, and that services were provided to the community as expected. Condition: During performance of audit procedures related to UG requirements, it was noted that the Association did not perform monitoring of its RPIC subrecipients during either FY21 OR FY22 Cause/Effect: The last evidence of monitoring was in 2018. In March 2020, COVID-19 was declared as a national pandemic and many businesses closed, or had restricted operations, which limited the ability to perform adequate monitoring procedures. There was no evidence that efforts have been made to recommence monitoring of OKACAA?s subrecipients during FY21. For FY22, OKACAA did establish a timeline for monitoring in their Corrective Action Plan, however, this timeline did not allow for monitoring to commence until FY23. Because of the failure to monitor for two fiscal years, OKACAA is out of compliance with UG requirements. Recommendation: A Management Letter was issued in FY ?20 addressing this issue. Failure to properly monitor OKACAA?s subrecipients has the potential to allow serious errors or irregularities such as fraud to occur and go undetected due to a lack of adequate oversight. SAUNDERS & ASSOCIATES, PLLC recommends that in addition to the time table for monitoring of subrecipients established by management, OKACAA ensure monitoring is conducted annually as required by Uniform Guidance. Reply: See Corrective Action Plan.

2021-002 CLOSEOUT REPORT DID NOT AGREE WITH GENERAL LEDGER Contract: 17773 HS 20 Assistance Listing Number: 93.600 Criteria: Contract reporting requirements require that a final Closeout Report be filed to report total contract monies received and expended. Amounts reported should be in agreement with the general ledger amounts reported. Condition: Revenues and expenditures reported on the Final Closeout Report filed on Contract 17773 HS 20 were not in agreement with the total expenditures recorded in the general ledger. While the receipts reported could be reconciled to the general ledger balance after adjusting for a posting error and an error that appears to have occurred in the transition from the old QuickBooks set up to the new one, no such reconciliation of expenditures could be identified. Expenditures in the general ledger were overstated by $7,152.02. These over expenditures had to be covered with unrestricted funds. Cause/Effect: The difference in revenues appears to have been the result of the software not picking up the 12/21/20 payment as revenue and a posting error on a miscellaneous receipt on contract 17455 HS 19 which closed out in FY ?20. As for expenses, the general ledger was not monitored against reports filed with HHS to ensure that they were in agreement. Recommendation: S&A recommends that all reports to funding agencies be reviewed and reconciled to the general ledger prior to filing. Discrepancies should be investigated and corrected at that time. Reply: See Corrective Action Plan.

2021-003 FAILURE TO MONITOR SUBRECIPIENTS Contract: 90ET0478-03 & 90ET0478-01-C3 CARES Assistance Listing Number: 93.569 Criteria: Uniform Guidance requires CSBG grantees to determine that there is reasonable assurance that the CSBG funds provided to subrecipients are adequately protected, and that services were provided to the community as expected. Condition: During performance of audit procedures related to UG requirements, it was noted that the Association has not performed monitoring of its RPIC subrecipients. Cause/Effect: The last evidence of monitoring was in 2018. In March 2020, COVID-19 was declared as a national pandemic and many businesses closed, or had restricted operations, which limited the ability to perform adequate monitoring procedures. There is no evidence that efforts have been made to recommence monitoring of OACAA?s subrecipients. Because of the failure to monitor in a timely manner, OACAA is out of compliance with UG requirements. Recommendation: A Management Letter was issued in FY ?20 addressing this issue. Failure to properly monitor OACAA?s subrecipients has the potential to allow serious errors or irregularities such as fraud to occur and go undetected due to a lack of adequate oversight. SAUNDERS & ASSOCIATES, PLLC recommends that management implement procedures that clearly establish a time table for annual monitoring of subrecipients. Reply: See Corrective Action Plan.