Audit 297874

Criteria or specific requirement: 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Also, 45 CFR 96.85 requires recipients to meet income eligibility thresholds for the LIHEAP program. Condition: During testing of eligibility, the following items were noted: • Two beneficiaries had income entered incorrectly, causing the benefits to be overstated. • One beneficiary had income entered incorrectly but there was no impact on the benefit. • One beneficiary’s income was not entered for consideration, which caused the beneficiary to be incorrectly labeled as eligible. Questioned costs: $ 512 (Net known questioned costs) Context: Errors were noted in 4 of the 40 beneficiaries (10 percent) tested. Cause: Internal controls did not catch the errors in the input of the income information. Effect: Ineligible participants can lead to questioned costs. Repeat Finding: No. Recommendation: We recommend that KDCF strengthen internal controls in place to mitigate this from happening in the future. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Also, 45 CFR 96.85 requires recipients to meet income eligibility thresholds for the LIHEAP program. Condition: During testing of eligibility, the following items were noted: • Two beneficiaries had income entered incorrectly, causing the benefits to be overstated. • One beneficiary had income entered incorrectly but there was no impact on the benefit. • One beneficiary’s income was not entered for consideration, which caused the beneficiary to be incorrectly labeled as eligible. Questioned costs: $ 512 (Net known questioned costs) Context: Errors were noted in 4 of the 40 beneficiaries (10 percent) tested. Cause: Internal controls did not catch the errors in the input of the income information. Effect: Ineligible participants can lead to questioned costs. Repeat Finding: No. Recommendation: We recommend that KDCF strengthen internal controls in place to mitigate this from happening in the future. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Part 170 requires subawards to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). Condition: During testing of the Federal Funding Accountability and Transparency Act (FFATA) report, it was noted that the one report tested was not filed timely. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 0 1 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $ 5,850,379 $ 0 $ 5,850,379 $ 0 $ 0 Questioned costs: None. Context: While the report was not filed timely, the supporting documentation that was needed to file the report was gathered by KDCF and the filing was actually completed. Cause: KDCF was understaffed during most of the fiscal year which impacted the timeliness. KDCF hired an individual to assist in getting the filings up to date, but it was too late for some reports that were already beyond the due date. Effect: Compliance with the reporting requirement for this program is not being met and the information is not being provided on the public website. Repeat Finding: Yes, Finding 2022-007 Recommendation: We recommend that KDCF continue with the process implemented during the fiscal year, which includes tracking the timely submission of the FFATA reports. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Part 170 requires subawards to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). Condition: During testing of the Federal Funding Accountability and Transparency Act (FFATA) report, it was noted that the one report tested was not filed timely. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 0 1 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $ 5,850,379 $ 0 $ 5,850,379 $ 0 $ 0 Questioned costs: None. Context: While the report was not filed timely, the supporting documentation that was needed to file the report was gathered by KDCF and the filing was actually completed. Cause: KDCF was understaffed during most of the fiscal year which impacted the timeliness. KDCF hired an individual to assist in getting the filings up to date, but it was too late for some reports that were already beyond the due date. Effect: Compliance with the reporting requirement for this program is not being met and the information is not being provided on the public website. Repeat Finding: Yes, Finding 2022-007 Recommendation: We recommend that KDCF continue with the process implemented during the fiscal year, which includes tracking the timely submission of the FFATA reports. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Part 170 requires subawards to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). Condition: During testing of the Federal Funding Accountability and Transparency Act (FFATA) reports, it was noted that the reports were not filed timely or not filed at all for the fiscal year. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 8 1 8 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $ 6,046,626 $ 166,455 $ 6,046,626 $ 0 $ 0 Questioned costs: None. Context: While the reports were not filed timely and one report was not filed as of the audit testing date, the supporting documentation that was needed to file the reports was gathered by KDCF and the filing was actually completed. The report not filed was filed subsequent to the audit testing date. Cause: KDCF was understaffed during most of the fiscal year which impacted the timeliness. KDCF hired an individual to assist in getting the filings up to date, but it was too late for some reports that were already beyond the due date. Effect: Compliance with the reporting requirement for this program is not being met and the information is not being provided on the public website. Repeat Finding: No. Recommendation: We recommend that KDCF continue with the process implemented during the fiscal year, that includes tracking the timely submission of the FFATA reports. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include timely submission to ensure the compliance of all reports submitted to the federal agency. Condition: During our testing of performance reports, we noted five out the five tested reports lacked documentation of review. Questioned costs: None. Context: Out of the five reports tested, all five reports did not have supporting documentation that reports were reviewed by an authorized official. Cause: The agency had staffing turnover during the fiscal year causing lack of evidence of review over the submitted reports. Effect: Reports not being formally reviewed could cause errors to get reported related to the program objectives. Repeat Finding: Yes, Finding 2022 - 011 Recommendation: We recommend the agency implement procedures to ensure reports are properly reviewed as well as increase training efforts on reporting requirements if there is future staffing turnover. Views of responsible officials: Management disagrees with the audit finding. There is review and final approval of these quarterly financial reports by the ELC program director prior to submission. The fiscal analyst at KDHE provides these financial reports to the ELC program manager and the ELC program director. The COVID and CORE ELC data from these reports are manually entered into ELC RedCap (for the years that correspond to this audit) and now ELC CAMP. COVID financial reports are then uploaded into GrantSolutions; the core ELC financial reports do not have to be uploaded to GrantSolutions. There is no mechanism to include a signature on these reports, but submission to ELC CAMP and GrantSolutions indicate the reports have been reviewed. Auditor’s Concluding Remarks: Management’s response did not persuade the auditor to revise the finding. Evidence of review was not able to be provided.

Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include timely submission to ensure the compliance of all reports submitted to the federal agency. Condition: During our testing of performance reports, we noted five out the five tested reports lacked documentation of review. Questioned costs: None. Context: Out of the five reports tested, all five reports did not have supporting documentation that reports were reviewed by an authorized official. Cause: The agency had staffing turnover during the fiscal year causing lack of evidence of review over the submitted reports. Effect: Reports not being formally reviewed could cause errors to get reported related to the program objectives. Repeat Finding: Yes, Finding 2022 - 011 Recommendation: We recommend the agency implement procedures to ensure reports are properly reviewed as well as increase training efforts on reporting requirements if there is future staffing turnover. Views of responsible officials: Management disagrees with the audit finding. There is review and final approval of these quarterly financial reports by the ELC program director prior to submission. The fiscal analyst at KDHE provides these financial reports to the ELC program manager and the ELC program director. The COVID and CORE ELC data from these reports are manually entered into ELC RedCap (for the years that correspond to this audit) and now ELC CAMP. COVID financial reports are then uploaded into GrantSolutions; the core ELC financial reports do not have to be uploaded to GrantSolutions. There is no mechanism to include a signature on these reports, but submission to ELC CAMP and GrantSolutions indicate the reports have been reviewed. Auditor’s Concluding Remarks: Management’s response did not persuade the auditor to revise the finding. Evidence of review was not able to be provided.

Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal control should include procedures to ensure required information is communicated prior to the issuance of the subaward. Per 2 CFR 200.331(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes, federal award identification, subrecipient name, subrecipient’s DUNS or UEI number, federal award identification number (FAIN), federal award date, subaward start and end date, amount of federal funds obligated, total amount of federal award, federal award project description, name of federal awarding agency, Assistance Listing (CFDA) number and name, identification of whether the award is research and development (R&D) and indirect cost rate for federal award. Condition: During our testing, we noted subrecipients had required information omitted from the sub agreements to the subrecipients including Assistance Listing Number (ALN) and title, subrecipient’s DUNS/UEI number, Federal Award Identification Number (FAIN), identification of whether the award is R&D, and indirect cost rate for federal award. Questioned costs: None. Context: Seventeen out of the seventeen subrecipients (100 percent) (with awards totaling $796,482) did not include required information in sub agreements issued to subrecipients. Cause: Lack of sufficient controls in place to ensure that subaward agreements contain all required information. Effect: Failure to communicate required information could result in subrecipients not properly administering the federal programs in accordance with federal regulations. Repeat Finding: Yes, finding 2022 -012 Recommendation: We recommend that the agency review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal control should include procedures to ensure required information is communicated prior to the issuance of the subaward. Per 2 CFR 200.331(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes, federal award identification, subrecipient name, subrecipient’s DUNS or UEI number, federal award identification number (FAIN), federal award date, subaward start and end date, amount of federal funds obligated, total amount of federal award, federal award project description, name of federal awarding agency, Assistance Listing (CFDA) number and name, identification of whether the award is research and development (R&D) and indirect cost rate for federal award. Condition: During our testing, we noted subrecipients had required information omitted from the sub agreements to the subrecipients including Assistance Listing Number (ALN) and title, subrecipient’s DUNS/UEI number, Federal Award Identification Number (FAIN), identification of whether the award is R&D, and indirect cost rate for federal award. Questioned costs: None. Context: Seventeen out of the seventeen subrecipients (100 percent) (with awards totaling $796,482) did not include required information in sub agreements issued to subrecipients. Cause: Lack of sufficient controls in place to ensure that subaward agreements contain all required information. Effect: Failure to communicate required information could result in subrecipients not properly administering the federal programs in accordance with federal regulations. Repeat Finding: Yes, finding 2022 -012 Recommendation: We recommend that the agency review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 180.300 prohibits entities from contracting with or making subawards under “covered transactions” to parties that are suspended or debarred from doing business with the federal government. A contract for goods or services is a covered transaction if awarded as a grant or payment for specified use and if the amount of the contract is expected to equal or exceed $25,000. In order to comply with federal suspension and debarment requirements, the State can perform a search in the federal System of Award Management (SAM) website, which tracks the entities that the federal government has determined are ineligible to receive federal funding; collect a certification from the entity; or add a clause or condition to the contract. Condition: During our testing of twenty-seven covered transactions (twelve vendors and fifteen subrecipients), we noted that management was not able to provide supporting documentation for one vendor that suspension and debarment procedures were performed before the start of the procurement contract. Questioned costs: None. Context: For one of the twelve vendors tested (8.3 percent of vendors), management was not able to provide supporting documentation that suspension and debarment verification procedures were performed before the start of the procurement contract. Cause: Lack of sufficient tracking and monitoring procedures related to tracking of suspension and debarment for vendors and subrecipients. Effect: Failure to obtain the required certifications or perform verification procedures with the SAM website before the procurement of good or services could result in the payment of federal funds to vendors that are suspended or debarred from participation in federal assistance programs, which could lead to questioned costs. Repeat Finding: Yes, Finding 2022 - 014 Recommendation: We recommend the agency either obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on the SAM website. We recommend that the agency have proper procedures in place to ensure that all contractual documentation is maintained and able to be located. Views of responsible officials: Management disagrees with the audit finding. Verification is completed at the time the contract is signed by KDHE so the date of signature corresponds with the date of SAM verification. Auditor’s Concluding Remarks: Management’s response did not persuade the auditor to revise the finding. Evidence of SAM verification occurring prior to or the same time as the contract being signed was not provided.

Criteria or specific requirement: 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 180.300 prohibits entities from contracting with or making subawards under “covered transactions” to parties that are suspended or debarred from doing business with the federal government. A contract for goods or services is a covered transaction if awarded as a grant or payment for specified use and if the amount of the contract is expected to equal or exceed $25,000. In order to comply with federal suspension and debarment requirements, the State can perform a search in the federal System of Award Management (SAM) website, which tracks the entities that the federal government has determined are ineligible to receive federal funding; collect a certification from the entity; or add a clause or condition to the contract. Condition: During our testing of twenty-seven covered transactions (twelve vendors and fifteen subrecipients), we noted that management was not able to provide supporting documentation for one vendor that suspension and debarment procedures were performed before the start of the procurement contract. Questioned costs: None. Context: For one of the twelve vendors tested (8.3 percent of vendors), management was not able to provide supporting documentation that suspension and debarment verification procedures were performed before the start of the procurement contract. Cause: Lack of sufficient tracking and monitoring procedures related to tracking of suspension and debarment for vendors and subrecipients. Effect: Failure to obtain the required certifications or perform verification procedures with the SAM website before the procurement of good or services could result in the payment of federal funds to vendors that are suspended or debarred from participation in federal assistance programs, which could lead to questioned costs. Repeat Finding: Yes, Finding 2022 - 014 Recommendation: We recommend the agency either obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on the SAM website. We recommend that the agency have proper procedures in place to ensure that all contractual documentation is maintained and able to be located. Views of responsible officials: Management disagrees with the audit finding. Verification is completed at the time the contract is signed by KDHE so the date of signature corresponds with the date of SAM verification. Auditor’s Concluding Remarks: Management’s response did not persuade the auditor to revise the finding. Evidence of SAM verification occurring prior to or the same time as the contract being signed was not provided.

Criteria or specific requirement: 2 CFR Part 170 requires subaward to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing it was discovered that management did not document the review of the submitted reports. Also, we noted that the State also has submitted FFATA Reports to FSRS for vendors when this reporting is not required for vendors. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 0 0 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $41,680 0 0 0 0 Questioned costs: None. Context: No evidence of review was noted for the one FFATA report tested. The agency also submitted information for vendors when it wasn’t applicable to them. Cause: Management has no documented process for review of reports and no documented process to ensure only subawards are submitted to FSRS. Effect: FFATA reports could contain errors that a review would normally identify. Also, vendor contracts can be incorrectly represented as subawards to FSRS. Repeat Finding: No Recommendation: We recommend that the agency implement controls to ensure reports are reviewed before submission and that a process is implemented to ensure only subawards are reported to FSRS. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 170 requires subaward to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing it was discovered that management did not document the review of the submitted reports. Also, we noted that the State also has submitted FFATA Reports to FSRS for vendors when this reporting is not required for vendors. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 0 0 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $41,680 0 0 0 0 Questioned costs: None. Context: No evidence of review was noted for the one FFATA report tested. The agency also submitted information for vendors when it wasn’t applicable to them. Cause: Management has no documented process for review of reports and no documented process to ensure only subawards are submitted to FSRS. Effect: FFATA reports could contain errors that a review would normally identify. Also, vendor contracts can be incorrectly represented as subawards to FSRS. Repeat Finding: No Recommendation: We recommend that the agency implement controls to ensure reports are reviewed before submission and that a process is implemented to ensure only subawards are reported to FSRS. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 170 requires subawards to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing, we noted that FFATA reports were not submitted timely and there was not a documented review of the submitted reports. Also, we noted that the State also has submitted FFATA Reports to FSRS for vendors when this reporting is not required for vendors. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 6 0 6 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,291,464 $0 $2,291,464 0 0 Questioned costs: None. Context: For six of the six FFATA reports tested (100 percent), a lack of timely submission was noted and no evidence of review was noted. The agency submitted information for vendors when it wasn’t applicable to them. Cause: Management has no documented process for the review of FFATA reports and no documented process to ensure that only subawards are submitted to FSRS. Effect: FFATA reports could contain errors that a review would normally identify. Also, vendor contracts can be incorrectly represented as subawards to FSRS. Repeat Finding: No Recommendation: We recommend that the agency implement controls to ensure reports are reviewed before submission, that a process is updated to ensure that reports are submitted timely, and that a process is implemented to ensure only subawards are reported to FSRS. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 170 requires subawards to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing, we noted that FFATA reports were not submitted timely and there was not a documented review of the submitted reports. Also, we noted that the State also has submitted FFATA Reports to FSRS for vendors when this reporting is not required for vendors. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 6 0 6 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,291,464 $0 $2,291,464 0 0 Questioned costs: None. Context: For six of the six FFATA reports tested (100 percent), a lack of timely submission was noted and no evidence of review was noted. The agency submitted information for vendors when it wasn’t applicable to them. Cause: Management has no documented process for the review of FFATA reports and no documented process to ensure that only subawards are submitted to FSRS. Effect: FFATA reports could contain errors that a review would normally identify. Also, vendor contracts can be incorrectly represented as subawards to FSRS. Repeat Finding: No Recommendation: We recommend that the agency implement controls to ensure reports are reviewed before submission, that a process is updated to ensure that reports are submitted timely, and that a process is implemented to ensure only subawards are reported to FSRS. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 170 requires subawards be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing, we noted that FFATA reports were not submitted timely, FFATA reports were not submitted at all, and there was not a documented review of the submitted reports Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 33 14 33 14 not reported 14 not reported Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,775,992 $961,031 $2,775,992 $961,031 Not Reported $961,031 Not Reported Questioned costs: None. Context: Thirty-three of the thirty-three FFATA reports tested (100 percent) were not submitted timely, 14 of 33 FFATA reports tested were not able to be provided, and for thirty-three of the thirty-three reports tested lacked evidence of review. Cause: Management could not obtain UEI numbers for the subawards for the reports not submitted and lacked a control process to ensure reports are submitted timely and formally reviewed. Effect: Compliance with the reporting requirement for this program is not being met and FFATA reports could contain errors that a review would normally identify. Repeat Finding: Yes, Finding 2022 - 008 Recommendation: We recommend that the agency implement controls to ensure subrecipients provide a UEI number before the subaward is entered into and implement procedures to ensure reports are submitted timely and formally reviewed. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 2 CFR 200.331(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes, federal award identification, subrecipient name, subrecipient’s DUNS/UEI number, federal award identification number (FAIN), federal award date, subaward start and end date, amount of federal funds obligated, total amount of federal award, federal award project description, name of federal awarding agency, Assistance Listing Number (ALN) and name, identification of whether the award is R&D and indirect cost rate for federal award. 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Subaward agreements with subrecipients, including Assistance Listing Number (ALN) and title, subrecipient’s DUNS/UEI number, Federal Award Identification Number (FAIN), identification of whether the award is research and development, and indirect cost rate for federal award, were not included. Questioned costs: None. Context: Sixty out of the sixty subrecipients (100 percent) tested did not have required information in the applicable subawards. Cause: Lack of sufficient internal controls to ensure subawards include required information. Effect: Failure to communicate required information could result in subrecipients not properly administering the federal programs in accordance with federal regulations. Repeat Finding: Yes, Finding 2022 - 009 Recommendation: We recommend that the agency review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200, Subpart F requires the pass-through entity to verify that subrecipients expected to be audited, met this requirement. 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Management did not track, determine or monitor the audit verification requirement for any subrecipients. Questioned costs: None Context: Sixty out of the sixty subrecipients (100 percent) were not monitored related to the audit verification requirement. Cause: Lack of sufficient tracking and monitoring procedures related to subrecipient audit verification. Effect: Failure to verify and review subrecipient audits could result in subrecipients lacking required audits or audit findings that directly impact the program’s compliance requirements. Repeat Finding: Yes, Finding 2022 - 010 Recommendation: We recommend that the agency review its procedures for monitoring of annual audits for subrecipients. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 42 CFR part 442, providers must meet the prescribed health and safety standards for hospitals, nursing facilities, and ICF/IID. 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: From a sample of sixty providers, nine of the providers did not have a recertification survey completed within the required timeframe which is used to meet the provider health and safety standards. Questioned costs: None. Context: Nine of the sixty providers sampled received payments from the State without meeting the prescribed health and safety standards, which is an error rate of 15%. A non-statistical sampling method was used to select the sample. Cause: Due to staffing shortages and a focus on completing Tier One workload requirements, KDHE has not been able to conduct all of the recertification surveys timely. Effect: Compliance with the prescribed health and safety standards for this program is not being met. Providers who are not meeting the health and safety standards, are still able to receive payments. Repeat Finding: Yes, Finding 2022-003 Recommendation: We recommend the State train all staff members to properly verify providers are meeting the prescribed health and safety standards before making payments to those providers. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 42 CFR part 442, providers must meet the prescribed health and safety standards for hospitals, nursing facilities, and ICF/IID. 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: From a sample of sixty providers, nine of the providers did not have a recertification survey completed within the required timeframe which is used to meet the provider health and safety standards. Questioned costs: None. Context: Nine of the sixty providers sampled received payments from the State without meeting the prescribed health and safety standards, which is an error rate of 15%. A non-statistical sampling method was used to select the sample. Cause: Due to staffing shortages and a focus on completing Tier One workload requirements, KDHE has not been able to conduct all of the recertification surveys timely. Effect: Compliance with the prescribed health and safety standards for this program is not being met. Providers who are not meeting the health and safety standards, are still able to receive payments. Repeat Finding: Yes, Finding 2022-003 Recommendation: We recommend the State train all staff members to properly verify providers are meeting the prescribed health and safety standards before making payments to those providers. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 42 CFR part 442, providers must meet the prescribed health and safety standards for hospitals, nursing facilities, and ICF/IID. 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: From a sample of sixty providers, nine of the providers did not have a recertification survey completed within the required timeframe which is used to meet the provider health and safety standards. Questioned costs: None. Context: Nine of the sixty providers sampled received payments from the State without meeting the prescribed health and safety standards, which is an error rate of 15%. A non-statistical sampling method was used to select the sample. Cause: Due to staffing shortages and a focus on completing Tier One workload requirements, KDHE has not been able to conduct all of the recertification surveys timely. Effect: Compliance with the prescribed health and safety standards for this program is not being met. Providers who are not meeting the health and safety standards, are still able to receive payments. Repeat Finding: Yes, Finding 2022-003 Recommendation: We recommend the State train all staff members to properly verify providers are meeting the prescribed health and safety standards before making payments to those providers. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 42 CFR part 442, providers must meet the prescribed health and safety standards for hospitals, nursing facilities, and ICF/IID. 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: From a sample of sixty providers, nine of the providers did not have a recertification survey completed within the required timeframe which is used to meet the provider health and safety standards. Questioned costs: None. Context: Nine of the sixty providers sampled received payments from the State without meeting the prescribed health and safety standards, which is an error rate of 15%. A non-statistical sampling method was used to select the sample. Cause: Due to staffing shortages and a focus on completing Tier One workload requirements, KDHE has not been able to conduct all of the recertification surveys timely. Effect: Compliance with the prescribed health and safety standards for this program is not being met. Providers who are not meeting the health and safety standards, are still able to receive payments. Repeat Finding: Yes, Finding 2022-003 Recommendation: We recommend the State train all staff members to properly verify providers are meeting the prescribed health and safety standards before making payments to those providers. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 42 CFR part 442, providers must meet the prescribed health and safety standards for hospitals, nursing facilities, and ICF/IID. 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: From a sample of sixty providers, nine of the providers did not have a recertification survey completed within the required timeframe which is used to meet the provider health and safety standards. Questioned costs: None. Context: Nine of the sixty providers sampled received payments from the State without meeting the prescribed health and safety standards, which is an error rate of 15%. A non-statistical sampling method was used to select the sample. Cause: Due to staffing shortages and a focus on completing Tier One workload requirements, KDHE has not been able to conduct all of the recertification surveys timely. Effect: Compliance with the prescribed health and safety standards for this program is not being met. Providers who are not meeting the health and safety standards, are still able to receive payments. Repeat Finding: Yes, Finding 2022-003 Recommendation: We recommend the State train all staff members to properly verify providers are meeting the prescribed health and safety standards before making payments to those providers. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Also, 45 CFR 96.85 requires recipients to meet income eligibility thresholds for the LIHEAP program. Condition: During testing of eligibility, the following items were noted: • Two beneficiaries had income entered incorrectly, causing the benefits to be overstated. • One beneficiary had income entered incorrectly but there was no impact on the benefit. • One beneficiary’s income was not entered for consideration, which caused the beneficiary to be incorrectly labeled as eligible. Questioned costs: $ 512 (Net known questioned costs) Context: Errors were noted in 4 of the 40 beneficiaries (10 percent) tested. Cause: Internal controls did not catch the errors in the input of the income information. Effect: Ineligible participants can lead to questioned costs. Repeat Finding: No. Recommendation: We recommend that KDCF strengthen internal controls in place to mitigate this from happening in the future. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Also, 45 CFR 96.85 requires recipients to meet income eligibility thresholds for the LIHEAP program. Condition: During testing of eligibility, the following items were noted: • Two beneficiaries had income entered incorrectly, causing the benefits to be overstated. • One beneficiary had income entered incorrectly but there was no impact on the benefit. • One beneficiary’s income was not entered for consideration, which caused the beneficiary to be incorrectly labeled as eligible. Questioned costs: $ 512 (Net known questioned costs) Context: Errors were noted in 4 of the 40 beneficiaries (10 percent) tested. Cause: Internal controls did not catch the errors in the input of the income information. Effect: Ineligible participants can lead to questioned costs. Repeat Finding: No. Recommendation: We recommend that KDCF strengthen internal controls in place to mitigate this from happening in the future. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Part 170 requires subawards to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). Condition: During testing of the Federal Funding Accountability and Transparency Act (FFATA) report, it was noted that the one report tested was not filed timely. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 0 1 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $ 5,850,379 $ 0 $ 5,850,379 $ 0 $ 0 Questioned costs: None. Context: While the report was not filed timely, the supporting documentation that was needed to file the report was gathered by KDCF and the filing was actually completed. Cause: KDCF was understaffed during most of the fiscal year which impacted the timeliness. KDCF hired an individual to assist in getting the filings up to date, but it was too late for some reports that were already beyond the due date. Effect: Compliance with the reporting requirement for this program is not being met and the information is not being provided on the public website. Repeat Finding: Yes, Finding 2022-007 Recommendation: We recommend that KDCF continue with the process implemented during the fiscal year, which includes tracking the timely submission of the FFATA reports. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Part 170 requires subawards to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). Condition: During testing of the Federal Funding Accountability and Transparency Act (FFATA) report, it was noted that the one report tested was not filed timely. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 0 1 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $ 5,850,379 $ 0 $ 5,850,379 $ 0 $ 0 Questioned costs: None. Context: While the report was not filed timely, the supporting documentation that was needed to file the report was gathered by KDCF and the filing was actually completed. Cause: KDCF was understaffed during most of the fiscal year which impacted the timeliness. KDCF hired an individual to assist in getting the filings up to date, but it was too late for some reports that were already beyond the due date. Effect: Compliance with the reporting requirement for this program is not being met and the information is not being provided on the public website. Repeat Finding: Yes, Finding 2022-007 Recommendation: We recommend that KDCF continue with the process implemented during the fiscal year, which includes tracking the timely submission of the FFATA reports. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Part 170 requires subawards to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). Condition: During testing of the Federal Funding Accountability and Transparency Act (FFATA) reports, it was noted that the reports were not filed timely or not filed at all for the fiscal year. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 8 1 8 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $ 6,046,626 $ 166,455 $ 6,046,626 $ 0 $ 0 Questioned costs: None. Context: While the reports were not filed timely and one report was not filed as of the audit testing date, the supporting documentation that was needed to file the reports was gathered by KDCF and the filing was actually completed. The report not filed was filed subsequent to the audit testing date. Cause: KDCF was understaffed during most of the fiscal year which impacted the timeliness. KDCF hired an individual to assist in getting the filings up to date, but it was too late for some reports that were already beyond the due date. Effect: Compliance with the reporting requirement for this program is not being met and the information is not being provided on the public website. Repeat Finding: No. Recommendation: We recommend that KDCF continue with the process implemented during the fiscal year, that includes tracking the timely submission of the FFATA reports. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include timely submission to ensure the compliance of all reports submitted to the federal agency. Condition: During our testing of performance reports, we noted five out the five tested reports lacked documentation of review. Questioned costs: None. Context: Out of the five reports tested, all five reports did not have supporting documentation that reports were reviewed by an authorized official. Cause: The agency had staffing turnover during the fiscal year causing lack of evidence of review over the submitted reports. Effect: Reports not being formally reviewed could cause errors to get reported related to the program objectives. Repeat Finding: Yes, Finding 2022 - 011 Recommendation: We recommend the agency implement procedures to ensure reports are properly reviewed as well as increase training efforts on reporting requirements if there is future staffing turnover. Views of responsible officials: Management disagrees with the audit finding. There is review and final approval of these quarterly financial reports by the ELC program director prior to submission. The fiscal analyst at KDHE provides these financial reports to the ELC program manager and the ELC program director. The COVID and CORE ELC data from these reports are manually entered into ELC RedCap (for the years that correspond to this audit) and now ELC CAMP. COVID financial reports are then uploaded into GrantSolutions; the core ELC financial reports do not have to be uploaded to GrantSolutions. There is no mechanism to include a signature on these reports, but submission to ELC CAMP and GrantSolutions indicate the reports have been reviewed. Auditor’s Concluding Remarks: Management’s response did not persuade the auditor to revise the finding. Evidence of review was not able to be provided.

Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include timely submission to ensure the compliance of all reports submitted to the federal agency. Condition: During our testing of performance reports, we noted five out the five tested reports lacked documentation of review. Questioned costs: None. Context: Out of the five reports tested, all five reports did not have supporting documentation that reports were reviewed by an authorized official. Cause: The agency had staffing turnover during the fiscal year causing lack of evidence of review over the submitted reports. Effect: Reports not being formally reviewed could cause errors to get reported related to the program objectives. Repeat Finding: Yes, Finding 2022 - 011 Recommendation: We recommend the agency implement procedures to ensure reports are properly reviewed as well as increase training efforts on reporting requirements if there is future staffing turnover. Views of responsible officials: Management disagrees with the audit finding. There is review and final approval of these quarterly financial reports by the ELC program director prior to submission. The fiscal analyst at KDHE provides these financial reports to the ELC program manager and the ELC program director. The COVID and CORE ELC data from these reports are manually entered into ELC RedCap (for the years that correspond to this audit) and now ELC CAMP. COVID financial reports are then uploaded into GrantSolutions; the core ELC financial reports do not have to be uploaded to GrantSolutions. There is no mechanism to include a signature on these reports, but submission to ELC CAMP and GrantSolutions indicate the reports have been reviewed. Auditor’s Concluding Remarks: Management’s response did not persuade the auditor to revise the finding. Evidence of review was not able to be provided.

Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal control should include procedures to ensure required information is communicated prior to the issuance of the subaward. Per 2 CFR 200.331(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes, federal award identification, subrecipient name, subrecipient’s DUNS or UEI number, federal award identification number (FAIN), federal award date, subaward start and end date, amount of federal funds obligated, total amount of federal award, federal award project description, name of federal awarding agency, Assistance Listing (CFDA) number and name, identification of whether the award is research and development (R&D) and indirect cost rate for federal award. Condition: During our testing, we noted subrecipients had required information omitted from the sub agreements to the subrecipients including Assistance Listing Number (ALN) and title, subrecipient’s DUNS/UEI number, Federal Award Identification Number (FAIN), identification of whether the award is R&D, and indirect cost rate for federal award. Questioned costs: None. Context: Seventeen out of the seventeen subrecipients (100 percent) (with awards totaling $796,482) did not include required information in sub agreements issued to subrecipients. Cause: Lack of sufficient controls in place to ensure that subaward agreements contain all required information. Effect: Failure to communicate required information could result in subrecipients not properly administering the federal programs in accordance with federal regulations. Repeat Finding: Yes, finding 2022 -012 Recommendation: We recommend that the agency review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal control should include procedures to ensure required information is communicated prior to the issuance of the subaward. Per 2 CFR 200.331(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes, federal award identification, subrecipient name, subrecipient’s DUNS or UEI number, federal award identification number (FAIN), federal award date, subaward start and end date, amount of federal funds obligated, total amount of federal award, federal award project description, name of federal awarding agency, Assistance Listing (CFDA) number and name, identification of whether the award is research and development (R&D) and indirect cost rate for federal award. Condition: During our testing, we noted subrecipients had required information omitted from the sub agreements to the subrecipients including Assistance Listing Number (ALN) and title, subrecipient’s DUNS/UEI number, Federal Award Identification Number (FAIN), identification of whether the award is R&D, and indirect cost rate for federal award. Questioned costs: None. Context: Seventeen out of the seventeen subrecipients (100 percent) (with awards totaling $796,482) did not include required information in sub agreements issued to subrecipients. Cause: Lack of sufficient controls in place to ensure that subaward agreements contain all required information. Effect: Failure to communicate required information could result in subrecipients not properly administering the federal programs in accordance with federal regulations. Repeat Finding: Yes, finding 2022 -012 Recommendation: We recommend that the agency review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 180.300 prohibits entities from contracting with or making subawards under “covered transactions” to parties that are suspended or debarred from doing business with the federal government. A contract for goods or services is a covered transaction if awarded as a grant or payment for specified use and if the amount of the contract is expected to equal or exceed $25,000. In order to comply with federal suspension and debarment requirements, the State can perform a search in the federal System of Award Management (SAM) website, which tracks the entities that the federal government has determined are ineligible to receive federal funding; collect a certification from the entity; or add a clause or condition to the contract. Condition: During our testing of twenty-seven covered transactions (twelve vendors and fifteen subrecipients), we noted that management was not able to provide supporting documentation for one vendor that suspension and debarment procedures were performed before the start of the procurement contract. Questioned costs: None. Context: For one of the twelve vendors tested (8.3 percent of vendors), management was not able to provide supporting documentation that suspension and debarment verification procedures were performed before the start of the procurement contract. Cause: Lack of sufficient tracking and monitoring procedures related to tracking of suspension and debarment for vendors and subrecipients. Effect: Failure to obtain the required certifications or perform verification procedures with the SAM website before the procurement of good or services could result in the payment of federal funds to vendors that are suspended or debarred from participation in federal assistance programs, which could lead to questioned costs. Repeat Finding: Yes, Finding 2022 - 014 Recommendation: We recommend the agency either obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on the SAM website. We recommend that the agency have proper procedures in place to ensure that all contractual documentation is maintained and able to be located. Views of responsible officials: Management disagrees with the audit finding. Verification is completed at the time the contract is signed by KDHE so the date of signature corresponds with the date of SAM verification. Auditor’s Concluding Remarks: Management’s response did not persuade the auditor to revise the finding. Evidence of SAM verification occurring prior to or the same time as the contract being signed was not provided.

Criteria or specific requirement: 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 180.300 prohibits entities from contracting with or making subawards under “covered transactions” to parties that are suspended or debarred from doing business with the federal government. A contract for goods or services is a covered transaction if awarded as a grant or payment for specified use and if the amount of the contract is expected to equal or exceed $25,000. In order to comply with federal suspension and debarment requirements, the State can perform a search in the federal System of Award Management (SAM) website, which tracks the entities that the federal government has determined are ineligible to receive federal funding; collect a certification from the entity; or add a clause or condition to the contract. Condition: During our testing of twenty-seven covered transactions (twelve vendors and fifteen subrecipients), we noted that management was not able to provide supporting documentation for one vendor that suspension and debarment procedures were performed before the start of the procurement contract. Questioned costs: None. Context: For one of the twelve vendors tested (8.3 percent of vendors), management was not able to provide supporting documentation that suspension and debarment verification procedures were performed before the start of the procurement contract. Cause: Lack of sufficient tracking and monitoring procedures related to tracking of suspension and debarment for vendors and subrecipients. Effect: Failure to obtain the required certifications or perform verification procedures with the SAM website before the procurement of good or services could result in the payment of federal funds to vendors that are suspended or debarred from participation in federal assistance programs, which could lead to questioned costs. Repeat Finding: Yes, Finding 2022 - 014 Recommendation: We recommend the agency either obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on the SAM website. We recommend that the agency have proper procedures in place to ensure that all contractual documentation is maintained and able to be located. Views of responsible officials: Management disagrees with the audit finding. Verification is completed at the time the contract is signed by KDHE so the date of signature corresponds with the date of SAM verification. Auditor’s Concluding Remarks: Management’s response did not persuade the auditor to revise the finding. Evidence of SAM verification occurring prior to or the same time as the contract being signed was not provided.

Criteria or specific requirement: 2 CFR Part 170 requires subaward to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing it was discovered that management did not document the review of the submitted reports. Also, we noted that the State also has submitted FFATA Reports to FSRS for vendors when this reporting is not required for vendors. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 0 0 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $41,680 0 0 0 0 Questioned costs: None. Context: No evidence of review was noted for the one FFATA report tested. The agency also submitted information for vendors when it wasn’t applicable to them. Cause: Management has no documented process for review of reports and no documented process to ensure only subawards are submitted to FSRS. Effect: FFATA reports could contain errors that a review would normally identify. Also, vendor contracts can be incorrectly represented as subawards to FSRS. Repeat Finding: No Recommendation: We recommend that the agency implement controls to ensure reports are reviewed before submission and that a process is implemented to ensure only subawards are reported to FSRS. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 170 requires subaward to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing it was discovered that management did not document the review of the submitted reports. Also, we noted that the State also has submitted FFATA Reports to FSRS for vendors when this reporting is not required for vendors. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 0 0 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $41,680 0 0 0 0 Questioned costs: None. Context: No evidence of review was noted for the one FFATA report tested. The agency also submitted information for vendors when it wasn’t applicable to them. Cause: Management has no documented process for review of reports and no documented process to ensure only subawards are submitted to FSRS. Effect: FFATA reports could contain errors that a review would normally identify. Also, vendor contracts can be incorrectly represented as subawards to FSRS. Repeat Finding: No Recommendation: We recommend that the agency implement controls to ensure reports are reviewed before submission and that a process is implemented to ensure only subawards are reported to FSRS. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 170 requires subawards to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing, we noted that FFATA reports were not submitted timely and there was not a documented review of the submitted reports. Also, we noted that the State also has submitted FFATA Reports to FSRS for vendors when this reporting is not required for vendors. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 6 0 6 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,291,464 $0 $2,291,464 0 0 Questioned costs: None. Context: For six of the six FFATA reports tested (100 percent), a lack of timely submission was noted and no evidence of review was noted. The agency submitted information for vendors when it wasn’t applicable to them. Cause: Management has no documented process for the review of FFATA reports and no documented process to ensure that only subawards are submitted to FSRS. Effect: FFATA reports could contain errors that a review would normally identify. Also, vendor contracts can be incorrectly represented as subawards to FSRS. Repeat Finding: No Recommendation: We recommend that the agency implement controls to ensure reports are reviewed before submission, that a process is updated to ensure that reports are submitted timely, and that a process is implemented to ensure only subawards are reported to FSRS. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 170 requires subawards to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing, we noted that FFATA reports were not submitted timely and there was not a documented review of the submitted reports. Also, we noted that the State also has submitted FFATA Reports to FSRS for vendors when this reporting is not required for vendors. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 6 0 6 0 0 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,291,464 $0 $2,291,464 0 0 Questioned costs: None. Context: For six of the six FFATA reports tested (100 percent), a lack of timely submission was noted and no evidence of review was noted. The agency submitted information for vendors when it wasn’t applicable to them. Cause: Management has no documented process for the review of FFATA reports and no documented process to ensure that only subawards are submitted to FSRS. Effect: FFATA reports could contain errors that a review would normally identify. Also, vendor contracts can be incorrectly represented as subawards to FSRS. Repeat Finding: No Recommendation: We recommend that the agency implement controls to ensure reports are reviewed before submission, that a process is updated to ensure that reports are submitted timely, and that a process is implemented to ensure only subawards are reported to FSRS. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 170 requires subawards be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing, we noted that FFATA reports were not submitted timely, FFATA reports were not submitted at all, and there was not a documented review of the submitted reports Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 33 14 33 14 not reported 14 not reported Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,775,992 $961,031 $2,775,992 $961,031 Not Reported $961,031 Not Reported Questioned costs: None. Context: Thirty-three of the thirty-three FFATA reports tested (100 percent) were not submitted timely, 14 of 33 FFATA reports tested were not able to be provided, and for thirty-three of the thirty-three reports tested lacked evidence of review. Cause: Management could not obtain UEI numbers for the subawards for the reports not submitted and lacked a control process to ensure reports are submitted timely and formally reviewed. Effect: Compliance with the reporting requirement for this program is not being met and FFATA reports could contain errors that a review would normally identify. Repeat Finding: Yes, Finding 2022 - 008 Recommendation: We recommend that the agency implement controls to ensure subrecipients provide a UEI number before the subaward is entered into and implement procedures to ensure reports are submitted timely and formally reviewed. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 2 CFR 200.331(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes, federal award identification, subrecipient name, subrecipient’s DUNS/UEI number, federal award identification number (FAIN), federal award date, subaward start and end date, amount of federal funds obligated, total amount of federal award, federal award project description, name of federal awarding agency, Assistance Listing Number (ALN) and name, identification of whether the award is R&D and indirect cost rate for federal award. 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Subaward agreements with subrecipients, including Assistance Listing Number (ALN) and title, subrecipient’s DUNS/UEI number, Federal Award Identification Number (FAIN), identification of whether the award is research and development, and indirect cost rate for federal award, were not included. Questioned costs: None. Context: Sixty out of the sixty subrecipients (100 percent) tested did not have required information in the applicable subawards. Cause: Lack of sufficient internal controls to ensure subawards include required information. Effect: Failure to communicate required information could result in subrecipients not properly administering the federal programs in accordance with federal regulations. Repeat Finding: Yes, Finding 2022 - 009 Recommendation: We recommend that the agency review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200, Subpart F requires the pass-through entity to verify that subrecipients expected to be audited, met this requirement. 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Management did not track, determine or monitor the audit verification requirement for any subrecipients. Questioned costs: None Context: Sixty out of the sixty subrecipients (100 percent) were not monitored related to the audit verification requirement. Cause: Lack of sufficient tracking and monitoring procedures related to subrecipient audit verification. Effect: Failure to verify and review subrecipient audits could result in subrecipients lacking required audits or audit findings that directly impact the program’s compliance requirements. Repeat Finding: Yes, Finding 2022 - 010 Recommendation: We recommend that the agency review its procedures for monitoring of annual audits for subrecipients. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 42 CFR part 442, providers must meet the prescribed health and safety standards for hospitals, nursing facilities, and ICF/IID. 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: From a sample of sixty providers, nine of the providers did not have a recertification survey completed within the required timeframe which is used to meet the provider health and safety standards. Questioned costs: None. Context: Nine of the sixty providers sampled received payments from the State without meeting the prescribed health and safety standards, which is an error rate of 15%. A non-statistical sampling method was used to select the sample. Cause: Due to staffing shortages and a focus on completing Tier One workload requirements, KDHE has not been able to conduct all of the recertification surveys timely. Effect: Compliance with the prescribed health and safety standards for this program is not being met. Providers who are not meeting the health and safety standards, are still able to receive payments. Repeat Finding: Yes, Finding 2022-003 Recommendation: We recommend the State train all staff members to properly verify providers are meeting the prescribed health and safety standards before making payments to those providers. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 42 CFR part 442, providers must meet the prescribed health and safety standards for hospitals, nursing facilities, and ICF/IID. 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: From a sample of sixty providers, nine of the providers did not have a recertification survey completed within the required timeframe which is used to meet the provider health and safety standards. Questioned costs: None. Context: Nine of the sixty providers sampled received payments from the State without meeting the prescribed health and safety standards, which is an error rate of 15%. A non-statistical sampling method was used to select the sample. Cause: Due to staffing shortages and a focus on completing Tier One workload requirements, KDHE has not been able to conduct all of the recertification surveys timely. Effect: Compliance with the prescribed health and safety standards for this program is not being met. Providers who are not meeting the health and safety standards, are still able to receive payments. Repeat Finding: Yes, Finding 2022-003 Recommendation: We recommend the State train all staff members to properly verify providers are meeting the prescribed health and safety standards before making payments to those providers. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 42 CFR part 442, providers must meet the prescribed health and safety standards for hospitals, nursing facilities, and ICF/IID. 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: From a sample of sixty providers, nine of the providers did not have a recertification survey completed within the required timeframe which is used to meet the provider health and safety standards. Questioned costs: None. Context: Nine of the sixty providers sampled received payments from the State without meeting the prescribed health and safety standards, which is an error rate of 15%. A non-statistical sampling method was used to select the sample. Cause: Due to staffing shortages and a focus on completing Tier One workload requirements, KDHE has not been able to conduct all of the recertification surveys timely. Effect: Compliance with the prescribed health and safety standards for this program is not being met. Providers who are not meeting the health and safety standards, are still able to receive payments. Repeat Finding: Yes, Finding 2022-003 Recommendation: We recommend the State train all staff members to properly verify providers are meeting the prescribed health and safety standards before making payments to those providers. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 42 CFR part 442, providers must meet the prescribed health and safety standards for hospitals, nursing facilities, and ICF/IID. 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: From a sample of sixty providers, nine of the providers did not have a recertification survey completed within the required timeframe which is used to meet the provider health and safety standards. Questioned costs: None. Context: Nine of the sixty providers sampled received payments from the State without meeting the prescribed health and safety standards, which is an error rate of 15%. A non-statistical sampling method was used to select the sample. Cause: Due to staffing shortages and a focus on completing Tier One workload requirements, KDHE has not been able to conduct all of the recertification surveys timely. Effect: Compliance with the prescribed health and safety standards for this program is not being met. Providers who are not meeting the health and safety standards, are still able to receive payments. Repeat Finding: Yes, Finding 2022-003 Recommendation: We recommend the State train all staff members to properly verify providers are meeting the prescribed health and safety standards before making payments to those providers. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 42 CFR part 442, providers must meet the prescribed health and safety standards for hospitals, nursing facilities, and ICF/IID. 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: From a sample of sixty providers, nine of the providers did not have a recertification survey completed within the required timeframe which is used to meet the provider health and safety standards. Questioned costs: None. Context: Nine of the sixty providers sampled received payments from the State without meeting the prescribed health and safety standards, which is an error rate of 15%. A non-statistical sampling method was used to select the sample. Cause: Due to staffing shortages and a focus on completing Tier One workload requirements, KDHE has not been able to conduct all of the recertification surveys timely. Effect: Compliance with the prescribed health and safety standards for this program is not being met. Providers who are not meeting the health and safety standards, are still able to receive payments. Repeat Finding: Yes, Finding 2022-003 Recommendation: We recommend the State train all staff members to properly verify providers are meeting the prescribed health and safety standards before making payments to those providers. Views of responsible officials: There is no disagreement with the audit finding.