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Reports
Oklahoma’s Administration of the Governor’s Emergency Education Relief Fund Grant
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.
Processing of Recovery Rebate Credit Claims During the 2021 Filing Season
On June 15, 2021, we alerted IRS management of our concerns with the systemic calculation of the allowable RRC amount. We recommended that IRS management review the returns we identified and provide us with any corrective actions they intended to take.
Conduct analysis of Tax Year 2020 tax returns processed after May 27, 2021, to identify additional individuals who received an RRC for a qualifying child for which the IRS has already paid an EIP or an RRC to someone else and take the actions needed to recover RRC payments that are determined to be erroneous.
Review the 7,022 individuals identified in which the IRS issued multiple RRCs for a qualifying child who was claimed on more than one tax return and take the actions needed to recover payments that are determined to be erroneous.
Conduct analysis of Tax Year 2020 tax returns processed after May 27, 2021, to identify additional individuals who received an RRC for a qualifying child who was claimed on more than one tax return and take the actions needed to recover payments that are determined to be erroneous.
Review the 75,594 tax returns identified in which the individual is potentially a nonresident alien and take the actions needed to recover the RRC payments that are determined to be erroneous.
Perform analysis of Tax Year 2020 tax returns filed after May 27, 2021, to identify additional tax returns with the same characteristics as those the IRS determined were filed by a nonresident alien and take the actions needed to recover erroneous RRC payments.
The Commissioner, Wage and Investment Division, should coordinate with the Territories to confirm and recover erroneous RRCs.
Review the nearly 6.9 million potentially eligible individuals we provided to the IRS who had not filed a Tax Year 2020 tax return as of May 27, 2021, and send a letter to those individuals who still have not filed a Tax Year 2020 return to encourage them to file a return and claim the RRC if eligible.
Review the 3.1 million eligible individuals we identified who filed a Tax Year 2020 return and proactively issue these taxpayers their credit.
Conduct additional analysis to identify tax returns filed after May 27, 2021, in which an individual is eligible for the RRC based on their Tax Year 2020 tax return and did not claim the credit, and proactively issue the taxpayer their credit.
If IRS management does not proactively issue the RRC to individuals who filed a return and did not claim the credit, the IRS should notify these individuals that they are eligible to claim the RRC and should file an amended tax return to claim the credit.
On March 19, 2021, we alerted IRS management of our concerns that an incorrect amount of advance payments was being used to calculate the RRC for some taxpayers. We recommended that IRS management review the returns we identified and provide us with any corrective actions they intended to take.
Work with the BFS to ensure that individuals who were denied the RRC and have still not activated their EIP1 or EIP2 debit card as of December 31, 2021, have EIPs reversed in their tax account and are issued their RRC. These processes should include notifying Metabank that the debit cards in question are to be cancelled.
Work with the BFS to obtain recurring data during Processing Year 2022 to identify individuals who have not activated their advance ARPA RRC debit card at the time a return is filed and implement processes to reverse the advance payment so these individuals can receive the RRC on their Tax Year 2021 tax return.
We alerted the Commissioner, Wage and Investment Division, of our concerns that the IRS was unnecessarily burdening taxpayers whose RRC claims were identified for manual ERS review. We recommended the IRS develop processes to systemically adjust RRC claims using the computer-generated RRC calculation.
On April 6, 2021, we alerted IRS management of our concerns regarding ERS tax examiners incorrectly computing the RRC (see management’s action in response to Recommendation 1). We recommended the IRS review the returns we identified and take the actions necessary to ensure that these taxpayers receive the amount of the RRC
they are entitled to receive.
On March 12, 2021, we alerted IRS management of our concerns that some tax returns were not being identified by fraud filters. We recommended IRS management review the returns we identified and associated fraud filters to identify why these returns were not selected and make programming changes as necessary to ensure proper
identification of returns with potentially questionable claims.
Conduct analysis to identify Tax Year 2020 RRC claims processed after May 27, 2021, to identify other returns in which ERS tax examiners incorrectly calculated the number of allowable dependents and returns that were not reprocessed per IRS guidance after programming was corrected, and ensure that these taxpayers receive the correct amount of the RRC.
Review the 14,508 individuals identified in which the IRS issued an RRC to an individual who was claimed as a dependent on someone else’s tax return but did not check the dependent box and take the actions needed to recover payments that are determined to be erroneous.
Conduct analysis of Tax Year 2020 tax returns processed after May 27, 2021, to identify additional individuals who received an RRC and were also claimed as a dependent on someone else’s tax return but did not check the dependent box, and take the actions needed to recover the RRC payments that are determined to be erroneous.
Review the 238,680 individuals under the age of 25 identified as potential dependents and take the actions needed to recover payments that are determined to be erroneous.
Review the 15,741 individuals identified in which the individual incorrectly received an RRC and an EIP for the same qualifying child and take the actions needed to recover RRC payments that are determined to be erroneous.
The Child Tax Credit Update Portal Was Successfully Deployed, but Security and Process Improvements Are Needed
Program and Organizational Changes Are Needed to Address the Continued Inadequate Tax Account Assistance Provided to Taxpayers
On September 20, 2021, we notified the Director, Accounts Management, that the Austin site was not requiring Accounts Management screeners to come into the office to perform their duties, resulting in a significant backlog and delays in inventory being routed to Accounts Management to be worked. We recommended that the IRS establish consistent guidance and clarification on when resources can be directed to the office to help with screening inventory, to ensure that sufficient staff is available to screen documents in a timely manner, and establish processes to monitor the progress,
The Commissioner, Wage and Investment Division, should update existing scanning software or obtain a new scanning software to
address document capacity concerns.
The Commissioner, Wage and Investment Division, should ensure that programming is updated to systemically reject electronic
submissions of Forms 2848 and 8821 when missing one of the five essential elements (name, address, signature, etc.) without manually mailing a rejection letter.
The Commissioner, Wage and Investment Division, should ensure that the rejection letter used for Forms 2848 and 8821 is updated
to include language that a revised form can be submitted electronically via an IRS Tax Pro Account25 or through Taxpayer Digital Communication.
The Commissioner, Wage and Investment Division, should develop an action plan to prioritize the continued expansion of documents that can be sent in via electronic fax and converted into a Correspondence Imaging System (CIS) image.
Develop an action plan to prioritize the continued expansion of documents that can be sent in via electronic fax and converted into a CIS image.
The Commissioner, Wage and Investment Division, should Identify priority work that needs to be expedited by the Image Control Team (ICT) and assess the feasibility of creating an electronic fax number to receive this inventory.
On July 12, 2021, TiGTA notified the Director, Accounts Management, of concerns regarding inaccuracies as it related to the compiling and reporting of the Accounts Management Inventory Report (AMIR). TIGTA recommended that the IRS perform a reconciliation of each Accounts Management site’s AMIR to the source reports to identify inventory inconsistencies and reporting errors by site
The Commissioner, Wage and Investment Division, should complete the inventory reconciliations for the four remaining Accounts
Management site’s to identify and correct inventory inaccuracies and inconsistencies and implement processes to provide oversight by periodically performing reconciliations for each site so that any future inconsistencies and errors are identified and corrected in a timely manner.
The Commissioner, Wage and Investment Division, should develop specific and detailed instructions for preparing the Accounts Management Inventory Report (AMIR), including how controlled and uncontrolled inventory should be captured
The Commissioner, Wage and Investment Division, should develop a process to systemically pull all controlled inventory for each
Accounts Management site for the Accounts Management Inventory Report (AMIR) to ensure consistency, reduce human error, and
increase efficiencies
The Commissioner, Wage and Investment Division, should modify Accounts Management inventory reporting to report unassigned
controlled inventory separately on the nationwide Accounts Management Inventory Report (AMIR) and limit the site-specific AMIRs to only
the inventory assigned to be worked in each site.
The Commissioner, Wage and Investment Division, should evaluate directing taxpayers to send tax account correspondence and
replies intended for Accounts Management directly to Campus Support Sites for processing to reduce backlogs at Tax Processing Centers and improve services to taxpayers.
The Commissioner, Wage and Investment Division, should prioritize the development and implementation of tools that will enable
taxpayers seeking assistance or responding to Accounts Management to correspond with the IRS electronically, including the ability to directly upload documents into Accounts Management’s inventory.
The Chief Taxpayer Experience Officer, in conjunction with the Director, IRS NEXT Office, should evaluate establishing two distinct IRS programs as part of the IRS reorganization under the Taxpayer First Act – one dedicated to answering toll-free telephone calls and one dedicated to working Accounts Management inventory – with adequate staffing to provide appropriate service to taxpayers using each channel.
On June 9, 2021, we notified the Director, Customer Account Services, that Submission Processing requested resources from Accounts Management to assist with clearing the Image Control Team (ICT) backlog and was told by Campus Support management that no resources could be made available to assist with reducing the ICT backlog. We recommended that the IRS assess the availability of Campus Support’s ICT staffing or other resources that could be made available to assist with clearing the ICT backlogs at Tax Processing Centers.
On September 3, 2021, we notified the Director, Accounts Management, of concerns relating to the newly stood-up Fresno Campus Support Site, including scanners not being used to the full extent possible. We recommended that IRS management provide us with it plans to address our concerns identified with the new Fresno Campus Support Site, including additional staffing to assist Image Control Team (ICT).
The Commissioner, Wage and Investment Division, should complete a strategic review of all 10 Image Control Team (ICT) sites to determine what contributes to the ICT’s inability to timely scan and validate documents. Based on the results of this review, initiate steps to address the concerns identified. This should include the development of an action plan to ensure that the high-capacity ICT scanners and staffing are realigned to the appropriate sites based on actual or expected inventory levels and that responsibility of the ICT operations are consolidated under the appropriate function.
The Commissioner, Wage and Investment Division, should cross-train additional mail clerks at Campus Support Sites to work Image Control Team (ICT) validations, freeing up additional resources in sites with higher inventories needing to be scanned, or consider shipping inventory to sites with less inventory to be scanned.
The Commissioner, Wage and Investment Division, should develop specific instructions and a common template for all 10 Image Control Team (ICT) sites to consistently capture ICT inventory information.
Remington College’s Use of Higher Education Emergency Relief Fund Student Aid and Institutional Grants
Require Remington College to return to the Department the $80,121 in Institutional grant funds spent beyond the supplemental Institutional grant period or reallocate the funds to other allowable costs.
Clarify whether the costs that Remington College initially charged to its Institutional grant for student computers were allowable under the law and existing guidance, and determine whether Remington College’s subsequent reallocation of costs for other expenses in the amount of $64,985 (corrective actions) was appropriate.
Determine whether the $639,400 that Remington College charged to its Institutional grant for contracts awarded without a competitive procurement process was reasonable when compared to the quality and costs of suitable alternatives, and if not, require appropriate corrective actions.
Require Remington College to incorporate in its policies and procedures for managing HEERF grant funds the Federal requirements related to charging only allowable costs during the grant performance period, using competitive processes for selecting vendors when purchases are over $10,000, obtaining price or rate quotations from an adequate number of qualified vendors for purchases between $10,000 and $250,000, and using formal procurement methods for purchases over $250,000.
Require Remington College to ensure that school officials responsible for making purchasing decisions receive sufficient training on Federal rules and regulations related to grant administration and management.
Require Remington College to incorporate in its policies and procedures for managing Institutional grant funds the Federal cash management requirements related to minimizing the time between drawing down and spending Federal grant funds, including HEERF funds; maintaining the funds in an interest-bearing account; and remitting interest earned in excess of $500 in accordance with 2 C.F.R. § 200.305(b).
Require Remington College to incorporate in its policies and procedures for managing Student Aid grant funds the Federal cash management requirements related to maintaining the funds in an interest-bearing account and remitting interest earned in excess of $500 in accordance with 2 C.F.R. § 200.305(b).
Determine whether Remington College accurately calculated interest and ensure that the correct amount of interest is returned to the Federal government in accordance with 2 C.F.R. § 200.305(b)(9).