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Provide documentation, or a full and detailed written explanation, of the process Oklahoma used to determine the initiatives it supported with GEER grant funds and the entities it selected to administer the initiatives.

Develop and implement a process to ensure that it documents the criteria and decisions made for awarding future GEER grant funds in accordance with applicable requirements.

Develop and implement internal controls to ensure that it administers current and future GEER grants in accordance with applicable Federal laws and grant requirements, including ensuring that grant subrecipients are provided the proper award documentation; and that any entity that is awarded Federal funds retains records relating to those awards in accordance with Federal requirements.

Perform a 100 percent review, or review a statistical sample, of the Stay in School Fund microgrant recipients to confirm that all students were eligible to receive GEER grant funds.

Develop and implement written policies and procedures to describe the specific circumstances under which deviations from procurement rules are warranted, including procedures about required documentation of such decisions for procurements that do not use competitive bidding but use Federal education funds.

Take appropriate action if the documentation and other information provided by Oklahoma in response to the above recommendations does not support that the State followed applicable requirements.

Return $652,720 to the Department for the unallowable Bridge the Gap expenditures we identified or provide documentation to support that the expenditures were allowable or the items were purchased with personal funds.

Perform a 100-percent review, or review a statistical sample, of the $5,473,894 in Bridge the Gap expenditures that we did not review to determine whether the expenditures were allowable, and if applicable, return the funds for any unallowable expenditures to the Department.

Develop and implement additional internal controls for the Skills to Rebuild, Learn Anywhere Oklahoma, Bridge the Gap, and Stay in School Fund initiatives that include written monitoring procedures for those processes that are already in place, and for additional procedures that include a review of expenditures and supporting documentation, and a review of documentation that supports the information in initiatives’ weekly status reports.

Develop and implement internal controls to ensure that fiscal agents for Federal grant programs obtain an understanding of the rules and regulations surrounding the grant programs they are tasked with overseeing.

Develop and implement controls to ensure that Oklahoma’s State agencies that receive Federal funds have written cash management policies and procedures, including policies for the draw down and disbursement of grant funds in accordance with Federal requirements.

Return to the Department any unexpended GEER grant funds applicable to our audit scope that are being held by GEER grant subrecipients.

Develop and implement internal controls to ensure that fiscal agents for Federal grant programs obtain an understanding of the rules and regulations surrounding the grant programs they are tasked with overseeing.

Require its fiscal agent or State program representative to work closely with the Department to ensure that other GEER grants are administered in compliance with cash management rules and with any actions the Department determines are needed, if warranted.