EIN: 736006419
UEI: NZLLEUA9G6K5
Data as of August 20, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 3, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by December 3, 2025, which was (261 days ago).
What is a management decision? →Lack of Internal Controls and Noncompliance with Compliance Requirement – Reporting – Emergency Rental Assistance Program (Repeat Finding – 2022-019) FEDERAL AGENCY: U.S. Department of the Treasury ASSISTANCE LISTING: 21.023 FEDERAL PROGRAM NAME: Emergency Rental Assistance Program FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2023 CONTROL CATEGORY: Reporting QUESTIONED COSTS: $0 Condition: Expenditures reported on the Emergency Rental Assistance Program (ERA) quarterly reports for ERA2 do not reconcile to payments made by the Subrecipient to qualifying families during those same quarters. The cumulative expenditures per the quarterly reports were $284,116 less than actual payments. Further, quarterly reports for ERA1 and ERA2 were not reviewed for accuracy and completeness. Cause of Condition: Policies and procedures have not been designed and implemented to ensure compliance with reporting compliance requirements. Amounts paid by the County to the Subrecipient were not reconciled to the Subrecipient’s quarterly payments. Further, ERA1 and ERA2 quarterly reports could not be modified or amended once they were submitted and accepted. Effect of Condition: These conditions resulted in noncompliance with federal requirements and could result in unrecorded transactions, undetected errors, and misappropriation of assets and funds. Recommendation: OSAI recommends the County gain an understanding of the compliance requirements for this federal program and implement internal control procedures to ensure compliance with all requirements. OSAI further recommends the County submit quarterly reports that have been fully reconciled with Subrecipient payments to beneficiaries and indicate proof of review and approval by someone other than the preparer. Management Response: Chairman of the Board of County Commissioners: The expenditures reported on the Emergency Rental Assistance Program (ERA2) quarterly reports were based on all available and accurate information at the time of submission. Once a quarterly report is submitted, it cannot be reopened for reclassification or corrections in subsequent periods. Any necessary corrections must be addressed in future submissions to ensure overall reporting accuracy. Currently, there is no alternative mechanism for the Clerk's Office to document such corrections, so we have followed the best possible approach to comply while maintaining the accuracy of the information. County Clerk: Once a quarterly report is submitted to the United States Treasury, it cannot be reopened in the event of a reclass or correction in later periods. Those corrections have to be “caught-up” in future submissions in order to make the overall reporting accurate. The data is provided by the sub-recipient, which is then reviewed by the submitter before the data is entered into the portal. There is currently no other mechanism by which we can document corrections, so there’s really nothing more we could have done to comply while maintaining accuracy of information. Criteria: 2 CFR § 200.303(a) Internal Controls reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing 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 or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Additionally, GAO Standards – Section 2 – Establishing an Effective Internal Control System – OV2.23 states in part: Objectives of an Entity – Compliance Objectives Management conducts activities in accordance with applicable laws and regulations. As part of specifying compliance objectives, the entity determines which laws and regulations apply to the entity. Management is expected to set objectives that incorporate these requirements. The 2023 Compliance Supplement for Assistance Listing 21.023 reads in part: All ERA grantees must submit quarterly reports with reporting periods of one calendar quarter and several cumulative fields covering all activity from the date of award through the quarter close. These reports provide financial and performance data regarding grantee administration of their ERA projects and capture program design in addition to program status data elements. Quarterly reports are intended to capture standard financial and performance data, as well as detailed information on qualifying direct and indirect expenditures pursuant to the government-wide Federal Funding Accountability and Transparency Act (FFATA) reporting requirements and in accordance with Section 15011 of the CARES Act, as amended and interpreted in Treasury’s reporting and compliance guidance on Treasury.gov.
Expenditures reported on the ERA I and ERA2 were reported to the best of the knowledge we had at the time of reporting. These figures were generally sourced from the third-party administrator. The US Treasury did not allow for corrections to be made to previously submitted reports within their online portal. When corrections were made known, adjustments would be made in the following quarter's report. Going forward, these reports can now be requested to be re-opened for corrections within that quarter.
2022-019
Lack of Internal Controls and Noncompliance Over Subrecipient Monitoring - Coronavirus State and Local Fiscal Recovery Funds (Repeat Finding 2022-021) FEDERAL AGENCY: U.S. Department of the Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2023 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Condition: While performing testwork to determine whether Tulsa County met subrecipient monitoring requirements, OSAI noted the County did not obtain, and did not ensure the subrecipient Tulsa Community Foundation (the Foundation) obtained, a single audit for the year ended December 31, 2022 in which the Foundation did have federal program expenditures in excess of $750,000. Tulsa County contracted with Program Management Group, LLC (PMg) to perform subrecipient monitoring of their subrecipients, but did not ensure the contractor performed an adequate risk assessment of the Foundation, including ensuring it had appropriate internal controls in place to provide reasonable assurance it would manage the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Tulsa County is ultimately responsible for appropriate subrecipient monitoring. The County did obtain the Foundation’s December 31, 2023 Single Audit, which covered the last six months of Tulsa County’s fiscal year 2023 and contained the following findings related to the County’s pass-through: Preparation of Schedule of Expenditures of Federal Awards (SEFA) The initial SEFA prepared by the Foundation was based on revenue transactions, not expenditures, and did not include all of the required elements per 2 CFR 200.302 (b). Additionally, a grant agreement was not obtained nor maintained on file for one of the federal grants received in order to verify the ALN presented on the SEFA is accurate or if the grant was a direct or indirect receipt by the Foundation's affiliate who received the federal funding. Internal Controls over Federal Programs Formal controls were not established or documented surrounding the following compliance requirements specified for this grant under 2 CFR Part 200, Appendix XI: Activities Allowed or Unallowed and Allowable Cost Principles, Suspension and Debarment, and Subrecipient Monitoring. Performance Reporting The Foundation had one affiliated entity who received federal funding through Tulsa County; however, there were no formally established internal controls surrounding the accuracy of and timely submission for the required annual and quarterly reports. Procurement The Foundation had no documented policies in place over procurement of goods or services with the use of federal awards. As such, evidence was not available to document that federal procurement standards were followed as transactions took place. The deficiencies reported in the Foundation’s 2023 Single Audit are indicative of inadequate subrecipient monitoring by Tulsa County. Cause of Condition: The County did not establish and maintain effective internal controls over the Federal award to provide reasonable assurance the Foundation managed the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Adequate subrecipient monitoring policies and procedures were not established by the County prior to entering into agreements with the subrecipient. Effect of Condition: This condition resulted in noncompliance with Federal requirements over the funding the County passed through to the Foundation. Additionally, there is an increased risk of unrecorded transactions, misstated reports, undetected errors, and misappropriation of assets and funds. Recommendation: OSAI recommends the County establish and maintain effective internal controls to ensure subrecipients submit timely reports and comply with program requirements. Further, OSAI recommends the County establish and maintain effective internal controls to ensure subrecipients obtain a single audit when required. The County should follow up with subrecipients to ensure they take appropriate action on all deficiencies pertaining to the federal award, and then issue a management decision for audit findings pertaining to the federal award. Management Response: Chairman of the Board of County Commissioners: The subrecipient was provided with all necessary documentation to ensure compliance with the grant. Tulsa County will maintain ongoing communication with the subrecipient to ensure a clear understanding of when a Single Audit is required and will continue to monitor compliance to reduce future risk. County Clerk: The subrecipient was provided with all the documentation to ensure compliance with this grant. Tulsa County will continue its communications and monitoring with this subrecipient to mitigate future risk. Criteria: Part 3 of the May 2023 Compliance Requirements read, in relevant part, as follows: A pass-through entity (PTE) must: • Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Title 2 CFR § 200.303(a) Internal Controls reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR § 200.332 Requirements for pass-through entities states in part, All pass-through entities must: (b) evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring, which may include consideration of such factors as: 1) The subrecipient's prior experience with the same or similar subawards; 2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; 3) Whether the subrecipient has new personnel or new or substantially changed systems; and 4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). … (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: … 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. … (f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501.
The subrecipient was provided with the documentation to ensure compliance with this grant. Tulsa County will continue to communicate and monitor this subrecipient to mitigate future risk.
2022-021
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 28, 2024. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by April 28, 2025, which was (480 days ago).
What is a management decision? →Lack of Internal Controls Over the Schedule of Expenditures of Federal Awards (SEFA) (Repeat Finding – 2019-009, 2020-010, and 2021-010) FEDERAL AGENCY: All ASSISTANCE LISTING: All FEDERAL PROGRAM NAME: All FEDERAL AWARD NUMBER: All FEDERAL AWARD YEAR: 2022 CONTROL CATEGORY: Reporting QUESTIONED COSTS: $0 Condition: The County’s Schedule of Expenditures of Federal Awards (SEFA) was revised multiple times between when the County provided OSAI the original draft on October 3, 2022, and when OSAI received the final draft from the County on January 12, 2024. Revisions included changes to program titles, assistance listing numbers, as well as the amounts passed through to subrecipients and program expenditures. These errors resulted in the following: Reported amounts passed through to subrecipients were overstated by $17,056,155 as follows: Further, there is no evidence the SEFA is reviewed by someone other than the preparer to ensure accuracy and completeness. Cause of Condition: Policies and procedures have not been designed and implemented to ensure a complete and accurate reporting of expenditures for all federal awards. Effect of Condition: These conditions resulted in the misidentification of major programs in the fiscal year 2022 audit and could result in the loss of federal funds to the County. Recommendation: OSAI recommends county officials and department heads gain an understanding of federal programs awarded to the County. Internal control procedures should be designed and implemented to ensure complete and accurate reporting of federal expenditures and payments to subrecipients on the SEFA and to ensure compliance with federal requirements. Management Response: Board of County Commissioners Chairman: Tulsa County implemented a new Enterprise Resource Planning (ERP) system for financial management and fiscal year 2022 is the first year it was used to help prepare the SEFA. Additionally, the Financial Services Division of the County Clerk’s Office had significant staff turnover that year, which contributed to our need to rework the SEFA report multiple times. We are confident that the final SEFA was accurate and believe we will not have the same issues in subsequent years. County Clerk: Tulsa County implemented a new ERP system for financial management and fiscal year 2022 is the first year it was used to help prepare the SEFA. Additionally, the Financial Services Division of the County Clerk’s Office had significant staff turnover that year, which contributed to our need to rework the SEFA report multiple times. I am confident that our final report was accurate and believe we will not have the same issues in subsequent years. Criteria: 2 CFR § 200.303(a) Internal Controls reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing 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 or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR § 200.508(b) Auditee responsibilities reads as follows: The auditee must: Prepare appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with §200.510 Financial statements. 2 CFR § 200.510(b) Financial statements reads as follows: chedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended…Include the total amount provided to subrecipients from each Federal program. [….] Further, GAO Standards – Section 2 – Objective of an Entity - OV2.23 states in part: Compliance Objective Management conducts activities in accordance with applicable laws and regulations. As part of specifying compliance objectives, the entity determines which laws and regulations apply to the entity. Management is expected to set objectives that incorporate these requirements. Furthermore, GAO Standards – Principle 6 – Define Objectives and Risk Tolerances – 6.05 states: Definitions of Objectives Management considers external requirements and internal expectations when defining objectives to enable the design of internal control. Legislators, regulators, and standard setting bodies set external requirements by establishing the laws, regulations, and standards with which the entity is required to comply. Management identifies, understands, and incorporates these requirements into the entity’s objectives. Management sets internal expectations and requirements through the established standards of conduct, oversight structure, organizational structure, and expectations of competence as part of the control environment.
The preparation of the SEF A is complicated and involves communication with almost all of our departments receiving federal awards. The Fiscal Year 2022 SEFA was further complicated due to the conversion of financial software during that year as well as the addition of a new preparer. There have been several conversations with SA&I for guidance and the preparer has also attended additional training to further her knowledge of the preparation of this report. A stronger review process has also been added so that the number of revisions may be mitigated in the future.
2021-010
Lack of Internal Controls and Noncompliance Over Subrecipient Monitoring - Coronavirus Relief Fund FEDERAL AGENCY: U.S. Department of the Treasury ASSISTANCE LISTING: 21.019 FEDERAL PROGRAM NAME: Coronavirus Relief Fund FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2022 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Condition: While performing testwork to determine that Tulsa County met subrecipient monitoring requirements, OSAI noted the County did not obtain the required subrecipient’s single audit from Tulsa Community Foundation (TCF) for the periods ending December 31, 2021 and December 31, 2022 and has not established procedures to ensure compliance with the subrecipient monitoring requirements. Cause of Condition: Policies and procedures have not been designed and implemented to ensure the County complies with federal laws and regulations. Effect of Condition: This condition resulted in noncompliance with federal requirements and increases the risk of unrecorded transactions, misstated reports, undetected errors, and misappropriation of assets and funds. Recommendation: OSAI recommends the County implement policies and procedures to monitor whether the subrecipient obtains a required Single Audit and takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient by the County. Management Response: Board of County Commissioners Chairman: Tulsa County awarded significant funds to the Tulsa Community Foundation through ARPA. We will work with the leadership of the Tulsa Community Foundation to ensure the requirement for the single audit is understood moving forward. County Clerk: Tulsa County awarded significant funds to the Tulsa Community Foundation through ARPA. We will work with the leadership of the Tulsa Community Foundation to ensure the requirement for the single audit is understood moving forward. Criteria: Part 3 of the July 2022 Compliance Requirements read, in relevant part, as follows: A pass-through entity (PTE) must: Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. 2 CFR § 200.303(a) Internal Controls reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing 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 or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR § 200.331(c) Subrecipient and contractor determinations reads as follows: Use of judgment in making determination. In determining whether an agreement between a pass-through entity and another non-Federal entity casts the latter as a subrecipient or a contractor, the substance of the relationship is more important than the form of the agreement. All of the characteristics listed above may not be present in all cases, and the pass-through entity must use judgment in classifying each agreement as a subaward or a procurement contract. 2 CFR § 501(a) Audit requirements reads as follows: Audit required. A non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part. Additionally, GAO Standards – Section 2 – Establishing an Effective Internal Control System – OV2.23 states in part: Objectives of an Entity Compliance Objectives Management conducts activities in accordance with applicable laws and regulations. As part of specifying compliance objectives, the entity determines which laws and regulations apply to the entity. Management is expected to set objectives that incorporate these requirements.
Tulsa Community Foundation continues to state that they were not subject to a Single Audit for their FY2 l and FY22 years. However, after further discussion with them, a FY23 single audit will be performed. The County will also work more closely with subrecipients to ensure they understand when a Single Audit is necessary.
Lack of Internal Controls and Noncompliance with Compliance Requirement – Reporting - Emergency Rental Assistance Program FEDERAL AGENCY: U.S. Department of the Treasury ASSISTANCE LISTING: 21.023 FEDERAL PROGRAM NAME: Emergency Rental Assistance Program FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2022 CONTROL CATEGORY: Reporting QUESTIONED COSTS: $0 Condition: Expenditures reported on Emergency Rental Assistance (ERA1 and ERA2) quarterly reports do not reconcile to payments made by the Subrecipient to qualifying families during those same quarters. Further, quarterly reports were not reviewed for accuracy and completeness. Cause of Condition: Policies and procedures have not been designed and implemented to ensure compliance with reporting compliance requirements. Amounts paid by the County to the Subrecipient were not reconciled to the Subrecipient’s quarterly payments. Further, ERA1 and ERA2 quarterly reports could not be modified or amended once they were submitted and accepted. Effect of Condition: This condition resulted in noncompliance with federal requirements and could result in unrecorded transactions, undetected errors, and misappropriation of assets and funds. Recommendation: OSAI recommends the County gain an understanding of the compliance requirements for this federal program and implement internal control procedures to ensure compliance with all requirements. OSAI further recommends the County submit quarterly reports that have been fully reconciled with Subrecipient payments to beneficiaries. Management Response: Board of County Commissioners Chairman: The Treasury Department did not allow amended reports for the ERA1 and ERA2 programs until recently. This would have allowed the Clerk’s office to make changes to reports that would have reconciled any discrepancies. County Clerk: The Treasury Department did not allow amended reports for the ERA1 and ERA2 programs until recently. This would have allowed us to make changes to reports that would have reconciled any discrepancies. Criteria: 2 CFR § 200.303(a) Internal Controls reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing 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 or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Additionally, GAO Standards – Section 2 – Establishing an Effective Internal Control System – OV2.23 states in part: Objectives of an Entity – Compliance Objectives Management conducts activities in accordance with applicable laws and regulations. As part of specifying compliance objectives, the entity determines which laws and regulations apply to the entity. Management is expected to set objectives that incorporate these requirements. The 2022 Compliance Supplement for Assistance Listing 21.023 reads in part: All ERA grantees must submit quarterly reports with reporting periods of one calendar quarter and several cumulative fields covering all activity from the date of award through the quarter close. These reports provide financial and performance data regarding grantee administration of their ERA projects and capture program design in addition to program status data elements. Quarterly reports are intended to capture standard financial and performance data, as well as detailed information on qualifying direct and indirect expenditures pursuant to the government-wide Federal Funding Accountability and Transparency Act (FFATA) reporting requirements and in accordance with Section 15011 of the CARES Act, as amended and interpreted in Treasury’s reporting and compliance guidance on Treasury.gov.
Expenditures reported on the ERAl and ERA2 were reported to the best of the knowledge we had at the time of reporting. These figures were generally sourced from the third-party administrator. The US Treasury did not allow for corrections to be made to previously submitted reports within their online portal. When corrections were made known, adjustments would be made in the following quarter's report. Going forward, these reports can now be requested to be re-opened for corrections within that auarter.
Lack of Internal Controls and Noncompliance with Compliance Requirements - Activities Allowed or Unallowed and Allowable Costs/Cost - Coronavirus State and Local Fiscal Recovery Funds FEDERAL AGENCY: U.S. Department of the Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2022 CONTROL CATEGORY: Activities Allowed or Unallowed and Allowable Costs/Cost Principles QUESTIONED COSTS: $0 Condition: OSAI tested twenty-four (24) expenditures from the various projects of the County’s Coronavirus State and Local Fiscal Recovery Funds (SLFRF) totaling $12,574,117. Testwork indicated that although the County’s CARES/ARP Committee and BOCC documented approval of the various SLFRF projects individually and noted the total award for each SLFRF project, there was insufficient documentation to show that the BOCC approved of the specific method and timing of payments. Project awards were approved by the County in total but the beneficiaries/subrecipients did not receive a one-time payment for the total award. Beneficiaries/subrecipients received partial payments during the fiscal year. Partial payments do not appear to be approved independently and were only supported by documentation titled “invoices” prepared by the County’s Budget Department and presented to the County Clerk’s office for payment. Ten (10) expenditures totaling $9,218,384, from eight different projects noted below, were not supported by written agreements that: o were approved prior to the issuance of payments to the beneficiaries/subrecipients, o detailed how much funding the beneficiaries/subrecipients were to receive, and o provided for the method and timing of the payments. Cause of Condition: Policies and procedures have not been designed and implemented to ensure all payments to beneficiaries/subrecipients are supported by adequate documentation and are reviewed and approved by the BOCC. Effect of Condition: These conditions resulted in noncompliance with federal requirements and could result in unrecorded transactions, misstated reports, undetected errors, and misappropriation of assets and funds. Recommendation: OSAI recommends the County design and implement policies and procedures to ensure adequate supporting documentation exists to demonstrate all expenditures to beneficiaries/subrecipients have been reviewed and approved by the BOCC. Management Response: Board of County Commissioners Chairman: Tulsa County made sizeable awards to dozens of organizations in Tulsa County through the American Recovery Plan Act (ARPA). As these conversations occurred in the ARPA Committee and through deliberation of the BOCC, project cashflow and program needs were analyzed, and the County Clerk’s Office Budget Division agreed to provide disbursements according to those discussions. It was determined that many projects would be awarded in installments and that was put into practice by the Budget Division. The awards of funds were always approved in open, public meetings. The County Clerk’s Office will create a policy and procedure for future programs with written guidelines including items related to project cashflow, agreement status and other needed provisions. Auditor Response: Partial payments should be independently approved by the BOCC and supported by draw down requests/invoices prepared/provided by the subrecipients. County Clerk: Tulsa County made sizeable awards to dozens of organizations in Tulsa County through ARPA. As these conversations occurred in the ARPA Committee and through deliberation of the BOCC, project cashflow and program needs were analyzed, and the County Clerk’s Office Budget Division agreed to provide disbursements according to those discussions. It was determined that many projects would be awarded in installments and that was put into practice by the Budget Division. The County Clerk’s Office will create a policy and procedure for future programs with written guidelines including items related to project cashflow, agreement status and other needed provisions. Criteria: 2 CFR § 200.303(a) Internal Controls reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing 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 or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR § 200.403 - Factors affecting allowability costs states in part, Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. Additionally, GAO Standards – Section 2 – Establishing an Effective Internal Control System – OV2.23 states in part: Objectives of an Entity – Compliance Objectives Management conducts activities in accordance with applicable laws and regulations. As part of specifying compliance objectives, the entity determines which laws and regulations apply to the entity. Management is expected to set objectives that incorporate these requirements. Finally, Principle 10 – Segregation of Duties, states in part: 10.10 – Management may design a variety of transaction control activities for operational processes, which may include verifications, reconciliations, authorizations and approvals, physical control activities, and supervisory control activities.
Project awards were approved by the County in total but were disbursed in two (or sometimes three) tranches. This was an internal policy to provide the receiving entity with only a portion of their award. The entity then had to provide all supporting documentation of their expenses of the first tranche before requesting the remaining portions. The administrator of the funds corresponded with the receiving entities regarding their payment schedule and outlined to them what they would be initially receiving and the process to request the remaining funds.
Lack of Internal Controls and Noncompliance Over Subrecipient Monitoring - Coronavirus State and Local Fiscal Recovery Funds FEDERAL AGENCY: U.S. Department of the Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2022 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Condition: While performing testwork to determine that Tulsa County met subrecipient monitoring requirements, OSAI noted the County did not obtain the required subrecipient’s single audit from Tulsa Community Foundation (TCF) for the periods ending December 31, 2021 and December 31, 2022 and has not established procedures to ensure compliance with the subrecipient monitoring requirements. Cause of Condition: Policies and procedures have not been designed and implemented to ensure the County complies with federal laws and regulations. Effect of Condition: This condition resulted in noncompliance with federal requirements and increases the risk of unrecorded transactions, misstated reports, undetected errors, and misappropriation of assets and funds. Recommendation: OSAI recommends the County implement policies and procedures to monitor whether the subrecipient obtains a required Single Audit and takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient by the County. Management Response: Board of County Commissioners Chairman: Tulsa County awarded significant funds to the Tulsa Community Foundation through ARPA. We will work with the leadership of the Tulsa Community Foundation to ensure the requirement for the single audit is understood moving forward. County Clerk: Tulsa County awarded significant funds to the Tulsa Community Foundation through ARPA. We will work with the leadership of the Tulsa Community Foundation to ensure the requirement for the single audit is understood moving forward. Criteria: Part 3 of the July 2022 Compliance Requirements read, in relevant part, as follows: A pass-through entity (PTE) must: Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 4. Reviewing financial and programmatic (performance and special reports) required by the PTE. 5. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 6. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. 2 CFR § 501(a) Audit requirements reads as follows: Audit required. A non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part. 2 CFR § 200.331(c) Subrecipient and contractor determinations reads as follows: Use of judgment in making determination. In determining whether an agreement between a pass-through entity and another non-Federal entity casts the latter as a subrecipient or a contractor, the substance of the relationship is more important than the form of the agreement. All of the characteristics listed above may not be present in all cases, and the pass-through entity must use judgment in classifying each agreement as a subaward or a procurement contract. 2 CFR § 200.303(a) Internal Controls reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing 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 or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Additionally, GAO Standards – Section 2 – Establishing an Effective Internal Control System – OV2.23 states in part: Objectives of an Entity – Compliance Objectives Management conducts activities in accordance with applicable laws and regulations. As part of specifying compliance objectives, the entity determines which laws and regulations apply to the entity. Management is expected to set objectives that incorporate these requirements.
Tulsa Community Foundation continues to state that they were not subject to a Single Audit for their FY2 l and FY22 years. However, after further discussion with them, a FY23 single audit will be performed. The County will also work more closely with subrecipients to ensure they understand when a Single Audit is necessary.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 4, 2022. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by April 4, 2023, which was (1235 days ago).
What is a management decision? →Finding 2021-011 - Lack of Internal Controls Over Noncompliance with Compliance Requirements ? Subrecipient Monitoring FEDERAL AGENCY: U.S. Department of the Treasury ASSISTANCE LISTING: 21.019 FEDERAL PROGRAM NAME: Coronavirus Relief Fund FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2021CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Condition: In reviewing the County?s expenditures and the nature of the products/services provided, it was determined the County had three subrecipients for the fiscal year ended June 30, 2021: ? Tulsa Economic Development Corporation (TEDC) ? Tulsa Housing Authority (THA) ? Tulsa Community Foundation (TCF) In reviewing the County?s procedures for subrecipient monitoring, OSAI found that the County had not established effective internal control processes for determining subrecipients and the monitoring of subrecipients. Additionally, the following deficiencies related to compliance were noted: Regarding TEDC: ? Although the County did review and approve the applicant submissions by TEDC for payments to small businesses and non-profits, certain documentation that would have been necessary to establish allowable costs were retained by TEDC but not reviewed by the County. ? The County did not evaluate each subrecipient?s risk of noncompliance for purposes of determining appropriate monitoring procedures. ? While TEDC would make available supporting documentation upon request, it does not appear the County established or performed procedures to examine such documentation. ? The County did not request audit reports or follow-up on audit findings for each subrecipient. Regarding THA and TCF: ? The County had not identified these entities as subrecipients. ? The County did not clearly identify the award as a subaward or requirements imposed on the subrecipients so that the federal award would be used in accordance with federal requirements. ? The County did not evaluate each subrecipient?s risk of noncompliance for purposes of determining appropriate monitoring procedures. ? While supporting documentation was readily available at the County, there is no evidence anyone at the County reviewed documentation beyond the spreadsheets detailing the recipients of rental and utility assistance at THA and TCF, respectively. ? The County did not request audit reports or follow-up on audit findings for each subrecipient. Cause of Condition: The County has not designed and implemented policies and procedures to ensure the County correctly identifies subrecipient or beneficiary relationships. Additionally, policies and procedures have not been designed and implemented to ensure compliance with subrecipient monitoring requirements. Effect of Condition: These conditions resulted in noncompliance with federal requirements and could result in unrecorded transactions, misstated reports, undetected errors, and misappropriation of assets and funds. Additionally, these conditions could lead to the loss of federal funds to the County.Recommendation: OSAI recommends the County implement the following procedures: Subrecipient Identification: ? Review County expenditures to other entities for potential subrecipient relationships. ? Evaluate whether a subrecipient relationship exists with all or a portion of the expenditures to other entities. ? Document the evaluation. Subrecipient Communication: ? Enter into a written agreement with the subrecipient which: o Clearly identifies to all subrecipients the award as a subaward by providing the information described in 2 CFR section 200.331(a)(1). o Communicates all requirements imposed by the County so that the federal award is used in accordance with federal requirements. o Notifies the subrecipient that the expenditure of federal awards over $750,000 will require a single audit. Subrecipient Risk Assessment: ? Evaluate each subrecipient?s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. ? Document the subrecipient?s prior experience with the same or similar subawards, the results of previous audits including whether or not the subrecipient receives a single audit, and the extent to which the same or similar subaward has been audited as a major program. ? Document the subrecipient?s procedures for ensuring compliance with program requirements. ? Document any other considerations in evaluating risk. Subrecipient Monitoring: ? Perform monitoring procedures as appropriate to the assessed risk of each subrecipient. ? Examine all or a sample of expenditures of the subrecipients and trace to adequate supporting documentation to verify allowable costs. ? Ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award. ? Document monitoring procedures, including the individuals who performed the procedures and the supporting documentation they reviewed. Subrecipient Audits: ? Inquire of each subrecipient whether they are required to obtain a single audit and request copies once it is complete. ? Examine audit reports for instances of findings related to the federal award. ? Issue a management decision for audit findings pertaining to the federal award provided to the subrecipient as required by 2 CFR section 200.521. Management Response: Chairman of the BOCC: I agree with the County Clerk?s responses and the County Commissioners will work with the County Clerk?s office to ensure adherence to their corrective action plan as noted in the County Clerk?s response. County Clerk: The Tulsa County Clerk?s Office will continue to improve our analysis of subrecipients including procedures for additional test work to ensure monitoring compliance. Our procedures moving forward will ensure that additional monitoring occurs. Criteria: Part 3 of the July 2021 Compliance Requirements read, in relevant part, as follows: A pass-through entity (PTE) must: ? Identify the Award and Applicable Requirements ? Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). ? Evaluate Risk ? Evaluate each subrecipient?s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient?s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). ? Monitor ? Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.Management Response: Chairman of the BOCC: I agree with the County Clerk?s responses and the County Commissioners will work with the County Clerk?s office to ensure adherence to their corrective action plan as noted in the County Clerk?s response. County Clerk: The Tulsa County Clerk?s Office will continue to improve our analysis of subrecipients including procedures for additional test work to ensure monitoring compliance. Our procedures moving forward will ensure that additional monitoring occurs. Criteria: Part 3 of the July 2021 Compliance Requirements read, in relevant part, as follows: A pass-through entity (PTE) must: ? Identify the Award and Applicable Requirements ? Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). ? Evaluate Risk ? Evaluate each subrecipient?s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient?s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). ? Monitor ? Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.Management Response: Chairman of the BOCC: I agree with the County Clerk?s responses and the County Commissioners will work with the County Clerk?s office to ensure adherence to their corrective action plan as noted in the County Clerk?s response. County Clerk: The Tulsa County Clerk?s Office will continue to improve our analysis of subrecipients including procedures for additional test work to ensure monitoring compliance. Our procedures moving forward will ensure that additional monitoring occurs. Criteria: Part 3 of the July 2021 Compliance Requirements read, in relevant part, as follows: A pass-through entity (PTE) must: ? Identify the Award and Applicable Requirements ? Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). ? Evaluate Risk ? Evaluate each subrecipient?s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient?s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). ? Monitor ? Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means.3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. 2 CFR ? 200.331(c) Subrecipient and contractor determinations reads as follows: Use of judgment in making determination. In determining whether an agreement between a pass-through entity and another non- Federal entity casts the latter as a subrecipient or a contractor, the substance of the relationship is more important than the form of the agreement. All of the characteristics listed above may not be present in all cases, and the pass-through entity must use judgment in classifying each agreement as a subaward or a procurement contract. 2 CFR ? 200.303(a) Internal Controls reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing 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 or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Additionally, GAO Standards ? Section 2 ? Establishing an Effective Internal Control System ? OV2.23 states in part: Objectives of an Entity ? Compliance Objectives Management conducts activities in accordance with applicable laws and regulations. As part of specifying compliance objectives, the entity determines which laws and regulations apply to the entity. Management is expected to set objectives that incorporate these requirements.
The Tulsa County Clerk's Office will continue to improve our analysis of subrecipients including procedures for additional test work to ensure monitoring compliance. Our procedures moving forward will ensure that additional monitoring occurs.
Finding 2021-012 - Lack of Internal Controls and Noncompliance with Requirements ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles PASS-THROUGH GRANTOR: N/A FEDERAL AGENCY: U.S. Department of the Treasury ASSISTANCE LISTING: 21.019 FEDERAL PROGRAM NAME: Coronavirus Relief Fund FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Activities Allowed or Unallowed, and Allowable Costs/Costs Principles, QUESTIONED COSTS: $2,612 Condition: During our review of a sample of (60) sixty of the 98,656 rental assistance payments administered by the THA, a subrecipient of the County, it was noted that (3) three of the (60) sixty payments were not supported by lease agreements. Therefore, allowability could not be determined. This resulted in known questioned costs of $2,612 and likely questioned costs of $147,324. In accordance with 2 CFR 200.516, known questioned costs must be reported in the schedule of findings and questioned costs when likely questioned costs are greater than $25,000. Cause of Condition: Policies and procedures have not been designed and implemented to ensure compliance with Activities Allowed of Unallowed and Allowable Costs. Effect of Condition: This condition resulted in noncompliance with federal requirements and could result in unrecorded transactions, misstated reports, undetected errors, and misappropriation of assets and funds. Recommendation: OSAI recommends the County perform monitoring procedures as appropriate to ensure adequate supporting documentation exists to establish the allowability of costs. Management Response: Chairman of the BOCC: I agree with the County Clerk?s responses and the County Commissioners will work with the County Clerk?s office to ensure adherence to their corrective action plan as noted in the County Clerk?s response. County Clerk: Out of $5.6 million provided to Housing Authority, the $147 thousand represents approximately 0.25% of total funds received. Tulsa County relied on the documentation provided by Housing Authority?s 3rd party system and while we believe the documentation for the missing applications does exist, we will continue to improve our subrecipient monitoring procedures in order to ensure complete compliance with uniform guidance and federal regulations. Auditor Response: While the lease agreements may exist in the 3rd party system, the County could not provide them to OSAI. Criteria: 2 CFR ? 200.303(a) Internal Controls reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing 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 or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR ? 200.516(a)(3) Audit Findings reads as follows: Known questioned costs that are greater than $25,000 for a type of compliance requirement for a major program.Known questioned costs are those specifically identified by the auditor. In evaluating the effect of questioned costs on the opinion on compliance, the auditor considers the best estimate of total costs questioned (likely questioned costs), not just the questioned costs specifically identified (known questioned costs). The auditor must also report known questioned costs when likely questioned costs are greater than $25,000 for a type of compliance requirement for a major program. In reporting questioned costs, the auditor must include information to provide proper perspective for judging the prevalence and consequences of the questioned costs. Additionally, GAO Standards ? Section 2 ? Establishing an Effective Internal Control System ? OV2.23 states in part: Objectives of an Entity ? Compliance Objectives Management conducts activities in accordance with applicable laws and regulations. As part of specifying compliance objectives, the entity determines which laws and regulations apply to the entity. Management is expected to set objectives that incorporate these requirements.
Out of $5.6 million provided to Housing Authority, the $147 thousand represents approximately 0.25% of total funds received. Tulsa County relied on the documentation provided by Housing Authority?s 3rd party system and while we believe the documentation for the missing applications does exist, we will continue to improve our subrecipient monitoring procedures in order to ensure complete compliance with uniform guidance and federal regulations.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 27, 2021. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by April 27, 2022, which was (1577 days ago).
What is a management decision? →Condition: Of the fifteen (15) expenditures tested, seven (7) were not supported by signed documentation indicating TAEMA?s Executive Director approval. Additionally, multiple variances found in the equipment rates used highway equipment charges resulted in overcharges of $780 for Federal Emergency Management Agency (FEMA) reimbursements. Cause of Condition: Policies and procedures have not been designed and implemented to ensure the expenditure of federal funds are allowable and accurate. Effect of Condition: These conditions resulted in noncompliance with federal requirements. Further, these conditions could result in unrecorded transactions, undetected errors, misappropriation of federal funds, and inaccurate records. Recommendation: OSAI recommends internal control procedures be designed and implemented to ensure expenditures are reviewed for allowability and accuracy and proof of review is documented.
TAEMA agrees with the findings related to signatures needing to be hand signed by the Director prior to submission through FEMA and has altered internal procedures to require that all submitted force account documentation supplied to FEMA must first have written approval by the TAEMA Director of their designee.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 26, 2020. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 26, 2020, which was (2125 days ago).
What is a management decision? →GSA_MIGRATION
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Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 12, 2017. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 12, 2017, which was (3235 days ago).
What is a management decision? →GSA_MIGRATION
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