HOPE COMMUNITY SERVICES, INC.

Finding: 2024-004: Record Retention Federal Programs - Block grants for Community Mental Health Services. Federal Financial Assistance Listings - 93.958. Federal Award Numbers - 4529066471 and 4529064876. Federal Agencies - Department of Health and Human Services Pass-through Entity - ODMHSAS. Allowable Activities or Unallowed, Allowable Costs/Cost Principles, Eligibility, and Period of Performance. Significant Deficiency in Internal Control over Compliance. Criteria: Uniform Guidance (2 CFR 200.334) establishes recipients and subrecipients must retain all federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Condition: Hope was unable to provide support for reimbursed expenditures totaling 31,673, as reported in the SEFA. Cause: Management's internal control for retaining documentation was not adequately designed to ensure the population of costs and underlying support could be timely identified and supported under the Uniform Guidance requirements. Effect or Potential Effect: Without adequate retention of support for expenditures reported and reimbursed, the auditor was unable to determine if they were in compliance with requirements under the federal award. Questioned Costs: 31,673. Context: The management team and personnel responsible for overseeing document approval and retention changed from the period the costs were initially incurred and approved to the period they were under audit and the current management team was not able to locate the supporting documentation. Repeat Finding from Prior Year: No. Recommendation: Management may consider implementing specific retention policies and controls to ensure digital copies as well as sub-listing of all applicable costs being reimbursed are maintained in accordance with the 2 CFR 200.334. Views of Responsible Officials: Management's response is included in the corrective action plan.

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

Finding: 2024-005: Payroll Allocation. Federal Programs - Continuum of Care. Federal Financial Assistance Listing - 14.267. Federal Award Numbers - OK0024L6I021111, OK0024L6I022113, OK0024L6I022212, OK0024L6I022213, OK0024L6I022214, OK0024L6I022215, OK0024L6I022316. Federal Agencies - Department of Housing and Urban Development. Pass-through Entities - City of Oklahoma City and the City of Norman. Allowable Activities or Unallowed, Allowable Costs/Cost Principles. Material Weakness in Internal Control over Compliance and Material Noncompliance. Criteria: Per Uniform Guidance (2 CFR 200.403) as it relates to federal grants: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: a) Be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles; b) Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items; c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the nonfederal entity; d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost; e) Be determined in accordance with generally accepted accounting principles (GAAP) , except, for state and local governments and Indian tribes only, as otherwise provided for in this part; (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period; g) Be adequately documented; h) Cost must be incurred during the approved budget period. 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 entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Hope could not readily provide the appropriate documentation to support the allocations of compensation applicable to the referenced programs for actual time worked, or to support the drawdown from grant funding. Cause: Management did not have procedures and controls in place to ensure allocated payroll was for time-and-effort applied to the award and ensure time was not allocated across multiple awards. Effect or Potential Effect: We were unable to determine whether the payroll costs allocated to the federal awards were allowable due to the lack of systematic application of payroll allocations to time and effort of the employees. Questioned Costs: 262,125. Context: Total allocated salaries and fringe benefits equal 262,125. None of the amounts were able to be supported by records that accurately reflect the work performed. Repeat Finding from Prior Year: No. Recommendation: Controls should be put in place to ensure that expenditures of program funds for payroll expense are reviewed and approved by program management and are properly allocated based on time and activities worked consistent with the grant requirements. Additionally, level of effort requirements as made known in grant contracts should be substantiated by payroll allocation or other records. Views of Responsible Officials: Management's response is included in the corrective action plan.

Management will improve internal processes and controls to include the following: Monthly reconciliation of payroll documentation with general ledger allocations, Monthly review of payroll allocation with program directors to ensure proper allocations, Quarterly review of payroll system to ensure proper grant tracking functionally, Annual review with program directors of program requirements, and Annual Uniform Guidance compliance training.

Finding: 2024-006 Voided Rental Payments. Federal Programs - Continuum of Care. Federal Financial Assistance Listing - 14.267. Federal Award Numbers - OK0024L6I021111, OK0024L6I022113, OK0024L6I022212, OK0024L6I022213, OK0024L6I022214, OK0024L6I022215, OK0024L6I022316. Federal Agency - Department of Housing and Urban Development. Pass-through Entities - City of Oklahoma City and the City of Norman. Allowable Activities or Unallowed, Allowable Costs/Cost Principles. Significant deficiency in Internal Control over Compliance. Criteria: Uniform Guidance (2 CFR 200.302(b) ) requires recipients and subrecipients to maintain financial management systems that provide accurate, current, and complete disclosure of financial results. In addition, 2 CFR 200.403 requires costs charged to federal awards to be allowable and adequately supported. 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 entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Hope received reimbursement for rental expenditures that were later voided due to tenants no longer being current residents. Cause: Management did not maintain controls to ensure that expenditures claimed for reimbursement were supported by actual costs incurred. Backdated and adjusting entries were recorded without reconciliation to underlying expense documentation or budget tracking schedules and ultimately claimed to the granting pass-through agency. Effect or Potential Effect: Expenditures claimed for reimbursement exceed actual expenditures incurred. As a result, a portion of grant expenditures recorded is unsupported and may be unallowable. Questioned Costs: 1,305 questioned and 9,675 of likely questioned costs. Context: A nonstatistical sampling of 54 out of over 3,000 transactions were selected for testing of Activities Allowed and Unallowed, and Allowable Costs/Cost Principles. Two transactions totaling 1,305 were selected for testing that were voided after invoicing. The expenditure detail included 9,675 of other expenditures with the description "voided." Repeat Finding from Prior Year: No. Recommendation: Management may consider a subsequent review or an additional review when adjusting and removing costs after drawdowns to ensure any claimed expenses that subsequently become voided are adjusted in future drawdowns. Views of Responsible Officials: Management's response is included in the corrective action plan.

Management will improve internal processes and controls to include the following: Monthly review of program expenditures for overall grant period, Quarterly reconciliation of voided checks against program drawdown invoices, and Annual Uniform Guidance compliance training.

Finding: 2024-007 Late Fees. Federal Programs - Continuum of Care. Federal Financial Assistance Listing - 14.267. Federal Award Number - OK0024L6I021111, OK0024L6I022113, OK0024L6I022212, OK0024L6I022213, OK0024L6I022214, OK0024L6I022215, OK0024L6I022316. Federal Agency - Department of Housing and Urban Development. Pass-through Entity - City of Oklahoma City and the City of Norman. Allowable Activities or Unallowed, Allowable Costs/Cost Principles. Significant deficiency in Internal Control over Compliance. Criteria: Uniform Guidance (2 CFR 200.302(b) ) requires recipients and subrecipients to maintain financial management systems that provide accurate, current, and complete disclosure of financial results. In addition, 2 CFR 200.403 requires costs charged to federal awards to be allowable and adequately supported. 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 entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Hope incurred rental late fees related to housing units of participants in the program. These late fees resulted from rent payments remitted after the contractual due date and were claimed as part of rental costs. Late fees represent penalties and are not an allowable cost under the program. The tenant-caused damage exception permitted under 24 CFR Part 578 does not extend to late fees. Cause: Hope did not establish internal controls to identify and exclude unallowable late fees from rent charged to the program. Additionally, reimbursement requests were not reviewed to ensure penalties were segregated from allowable rental costs. Effect or Potential Effect: Hope incurred unallowable costs. Questioned Costs: 500. Context: A nonstatistical sampling of 54 out of over 3,000 transactions were selected for testing of Activities Allowed and Unallowed, and Allowable Costs/Cost Principles. Four transactions included rental late fees in the rent expense claimed. Repeat Finding from Prior Year: No. Recommendation: Management may consider reviewing both the approval of rental expenses prior to issuing rental assistance checks as well as reimbursement processing of rental costs to ensure late fees are not included. Views of Responsible Officials: Management's response is included in the corrective action plan.

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

Department of Health and Human Services, Passed Through Substance Abuse and Mental Health Services Administration, Section 223 Demonstration Programs to Improve Community Mental Health Services Listing 93.829, H79SM085287, 8/31/2022 – 8/30/2023 Allowable Activities or Unallowed, Allowable Costs/Cost Principles, Cash Management, and Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Uniform Guidance (2 CFR Section 200.403) as it relates to federal grants: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items; c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity; d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost; e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part; f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period; g) Be adequately documented; h) Cost must be incurred during the approved budget period. Per the grant policy manual for Department of Health and Human Services: Non-federal entities must minimize the time elapsing between any advance payment under this award and the disbursement of the funds for direct program costs. 2 CFR Part 200, OMB Compliance Supplement, defines Level of Effort as follows: Level of effort includes requirements for (a) a specified level of service to be provided from period to period, (b) a specified level of expenditures from non-federal or federal sources for specified activities to be maintained from period to period, and (c) federal funds to supplement and not supplant non-federal funding of services. 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 entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Hope could not readily provide the appropriate documentation to support the allocations of compensation applicable to the referenced programs for actual time worked, or to support the drawdown from grant funding or that the level of effort requirements, as outlined in the grant contract, was achieved. Cause: The process used to track employee payroll does not adequately track the allocations of payroll or time worked to the respective federal grant programs. Or, if such documentation did exist, it could not be provided as audit evidence. As a result, certain expenditures were claimed as program expenditures, but could not be substantiated for purposes of allowable costs or level of effort. Much of the issue can be attributed to employee turnover. Effect: Hope is at risk for noncompliance with allowable activities and allowable costs, as well as cash management and level of effort requirements. Questioned costs: None reported. Context: A nonstatistical sampling of 70 out of over 1,500 transactions were selected for testing of Activities Allowed and Unallowed, and Allowable Costs/Cost Principles. Allocation support could not be provided for any of the 60 items selected. Two of 7 drawdowns of grant funds were selected for testing of Cash Management which where nonstatistical. Support could not be provided for the 2 items selected. 2 of 2 employees were tested with respect to level of effort requirements as outlined in the program contract, but supporting information could not be provided. Repeat Finding From Prior Year: Yes Recommendation: Controls should be put in place to ensure that expenditures of program funds allocated through payroll expense are reviewed and approved by program management and are properly allocated based on time and activities worked consistent with the grant requirements. Additionally, level of effort requirements as made known in grant contracts should be substantiated by payroll allocation or other records. Controls should be put in place to ensure that direct expenditures of program funds are reviewed and approved by program management and are consistent with the grant reimbursements for those expenditures. Such reconciliations can be done monthly, quarterly, or annually, at Hope’s discretion. Controls should also ensure that program expenditures are made prior to requesting reimbursement of funds and are allowable in accordance with the federal program requirements. Views of Responsible Officials: We agree with the finding.

Department of Health and Human Services, Passed Through Substance Abuse and Mental Health Services Administration, Section 223 Demonstration Programs to Improve Community Mental Health Services Listing 93.829, H79SM085287, 8/31/2022- 8/30/2023 Allowable Activities or Unallowed, Allowable Costs/Cost Principles, Cash Management, and Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: As part of the audit, Eide Bailly LLP identified that the process for allocating payroll or time worked to respective federal programs was insufficient and did not substantiate allowability under the federal award guidelines. Responsible Individuals: Chief Financial Officer and Chief Human Resources Officer Corrective Action Plan: In December 2024, changes were made to the payroll system to improve tracking of time worked and appropriate allocations to respective federal grant programs. Completion Date: December 2024

2022-003

Department of Health and Human Services, Passed Through Oklahoma Department of Mental Health and Substance Abuse Services, Block Grants for Community Mental Health Services Listing 93.958, 4529063664/4529063519, 7/1/2022 – 6/30/2023 Allowable Activities or Unallowed and Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Uniform Guidance (2 CFR Section 200.403) as it relates to federal grants: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items; c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity; d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost; e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part; f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period; g) Be adequately documented; h) Cost must be incurred during the approved budget period. 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 entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Hope could not readily provide the appropriate documentation to support the allocations of compensation applicable to the referenced programs for actual time worked, or to support allowable costs. Cause: The process used to track employee payroll does not adequately track the allocations of payroll or time worked to the respective federal grant programs. Or, if such documentation did exist, it could not be provided as audit evidence. As a result, certain expenditures were claimed as program expenditures, but could not be substantiated for purposes of allowable costs. Much of the issue can be attributed to employee turnover. Effect: Hope is at risk for noncompliance with allowable activities and allowable costs. Questioned costs: $116,222 in payroll was identified as questionable allowable costs that could not be substantiated. Context: A nonstatistical sampling of 40 out of over 4,000 transactions were selected for testing of Activities Allowed and Unallowed, and Allowable Costs/Cost Principles. Allocation support could not be provided for any of the 40 items selected. Repeat Finding From Prior Year: No Recommendation: Controls should be put in place to ensure that expenditures of program funds allocated through payroll expense are reviewed and approved by program management and are properly allocated based on time and activities worked consistent with the grant requirements. Such support should be retained. Views of Responsible Officials: We agree with the finding.

Department of Health and Human Services, Passed Through Oklahoma Department of Mental Health and Substance Abuse Services, Block Grants for Community Mental Health Services Listing 93.958, 4529063664/4529063519, 711/2022- 6/30/2023 Allowable Activities or Unallowed and Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: As part of the audit, Eide Bailly LLP identified that the process for allocating payroll or time worked to respective federal programs was insufficient and did not substantiate allowability under the federal award guidelines. Responsible Individuals: Chief Financial Officer and Chief Human Resources Officer Corrective Action Plan: In December 2024, changes were made to the payroll system to improve tracking of time worked and appropriate allocations to respective federal grant programs. Completion Date: December 2024

2022-003 Department of Health and Human Services, Passed Through Substance Abuse andMental Health Services Administration,Section 223 Demonstration Programs to Improve Community Mental Health ServicesListing 93.829, H79SM085287, 8/31/2021 ? 8/30/2022Allowable Activities or Unallowed, Allowable Costs/Cost Principles and Cash ManagementMaterial Weakness in Internal Control over Compliance and Material NoncomplianceCriteria: Per Uniform Guidance (2 CFR Section 200.403) as it relates to federal grants:Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles;b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items;c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity;d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost;e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part;f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period;g) Be adequately documented;h) Cost must be incurred during the approved budget period. Per the grant policy manual for Department of Health and Human Services: Non-federal entities must minimize the time elapsing between any advance payment under this award and the disbursement of the funds for direct program costs.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 entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: Hope could not readily provide the appropriate documentation for grant expenditures to support the drawdown from grant funding. Additionally, one of the items submitted for reimbursement under the grant, was not an allowable activity or cost in fiscal year 2022 as it was not in accordance with accounting treatment under GAAP.Hope did not adequately minimize the time between draw down of program funds and disbursement.Cause: The process used to ensure that grant expenditures are allowable and reconciled was not clearly communicated to appropriate parties. As a result, certain expenditures were inappropriately claimed in the wrong fiscal year. These expenditures were not made in a reasonable time in relation to receipt of program reimbursements.Effect: Hope is at risk for noncompliance with allowable activities and allowable costs, as well as cash management requirements.Questioned costs: $54,158 was claimed for reimbursement in the current year that did not relate to the fiscal year. Further, grant receipts of $54,158 were received in June 2022 but not disbursed until April 2023.Context: A nonstatistical sampling of 40 out of 702 total transactions were selected for testing, which accounted for $134,724 of $1,021,571 total program expenditures.Repeat FindingFrom Prior Year: NoRecommendation: Controls should be put in place to ensure that direct expenditures of program funds are reviewed and approved by program management and are consistent with the grant reimbursements for those expenditures. Such reconciliations can be done monthly, quarterly, or annually, at Hope?s discretion. Controls should also ensure that program expenditures are made prior to requesting reimbursement of funds and are allowable in accordance with the federal program requirements.Views ofResponsible Officials: We agree with the finding.

Finding 2022-003 - Allowable Activities or Unallowed, Allowable Costs/Cost Principles and CashManagementMaterial Weakness in Internal Control over Compliance and Material Noncompliancefinding Summary: During the audit, the appropriate documentation for grant expenditures to supportthe drawdown from grant funding was not readily provided. In addition, the process to ensure thatgrant expenditures are allowable and reconciled was not clearly communicated to appropriate partiescausing expenditures to be inappropriately claimed in the wrong fiscal year.Responsible Individual: Chief Financial OfficerCorrective Action Plan; We have designated a member of management to participate in monthly,quarterly, or annual reconciliations as proposed by the auditors. The existing controls will be clearlycommunicated to ensure that program expenditures are made prior to requesting reimbursement offunds.Anticipated Completion Date: Ongoing