Audit 326473

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for the subrecipients that received federal funds. Questioned Costs: None noted. Context: The single subrecipient under both ALN 93.044 and 93.045 receiving approximately $418,000 was not evaluated for suspension and debarment. It was noted after subsequent check, that the subrecipient was not suspended or debarred. Identification of Prior Year Finding: 2021-005 Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: For the Unified Government, this is typically included in the contracts, but was not included in the subrecipient contracts for this program and the Unified Government did not have another means of validating suspension and debarment. Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include subrecipients, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step for both suppliers and subrecipients. Downstream, need to evaluate if this language can be added to the contract templates.

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for the subrecipients that received federal funds. Questioned Costs: None noted. Context: The single subrecipient under both ALN 93.044 and 93.045 receiving approximately $418,000 was not evaluated for suspension and debarment. It was noted after subsequent check, that the subrecipient was not suspended or debarred. Identification of Prior Year Finding: 2021-005 Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: For the Unified Government, this is typically included in the contracts, but was not included in the subrecipient contracts for this program and the Unified Government did not have another means of validating suspension and debarment. Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include subrecipients, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step for both suppliers and subrecipients. Downstream, need to evaluate if this language can be added to the contract templates.

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for the subrecipients that received federal funds. Questioned Costs: None noted. Context: The single subrecipient under both ALN 93.044 and 93.045 receiving approximately $418,000 was not evaluated for suspension and debarment. It was noted after subsequent check, that the subrecipient was not suspended or debarred. Identification of Prior Year Finding: 2021-005 Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: For the Unified Government, this is typically included in the contracts, but was not included in the subrecipient contracts for this program and the Unified Government did not have another means of validating suspension and debarment. Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include subrecipients, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step for both suppliers and subrecipients. Downstream, need to evaluate if this language can be added to the contract templates.

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement: Subrecipient Monitoring and Material Weakness Per 2 CFR 200.332, a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and terms and conditions of the subaward as well as monitor the activities of the subrecipient which include reviewing financial and performance reports, obtaining and reviewing subrecipient single audit reports, etc. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: No risk assessment or ongoing formal monitoring of the subrecipient was performed. Questioned Costs: None noted. Context: There is only one subrecipient associated with this program. During 2022, the subrecipient received $418,171 ($104,601 - ALN 93.044, $313,570 - ALN 93.045) from the Unified Government. The subrecipient for this program is a long-time subrecipient that is familiar with federal compliance requirements, but the risk assessment was not done in writing. Additionally, ongoing monitoring including reviewing for single audit filings were not completed. Identification of Prior Year Finding: 2021-007 Effect: Federal funds could be improperly utilized by a subrecipient which does not have an adequate understanding of the requirements or tools to support the program. Cause: The Unified Government has a long-time relationship with this subrecipient and did not formalize the risk assessment process. Further, formalized processes for monitoring subrecipients were not operating effectively. Recommendation: We recommend that the Unified Government develop procedures to perform a risk assessment on all potential subrecipients before entering into an agreement to provide federal funds to that entity and revisit annually thereafter. Additionally, formal policies and procedures should be put in place over the various levels of monitoring that may occur as a result of the risk assessment and should also include a trigger to ensure single audit reports of subrecipients are reviewed. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Aging department is now completing these assessments annually.

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement: Subrecipient Monitoring and Material Weakness Per 2 CFR 200.332, a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and terms and conditions of the subaward as well as monitor the activities of the subrecipient which include reviewing financial and performance reports, obtaining and reviewing subrecipient single audit reports, etc. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: No risk assessment or ongoing formal monitoring of the subrecipient was performed. Questioned Costs: None noted. Context: There is only one subrecipient associated with this program. During 2022, the subrecipient received $418,171 ($104,601 - ALN 93.044, $313,570 - ALN 93.045) from the Unified Government. The subrecipient for this program is a long-time subrecipient that is familiar with federal compliance requirements, but the risk assessment was not done in writing. Additionally, ongoing monitoring including reviewing for single audit filings were not completed. Identification of Prior Year Finding: 2021-007 Effect: Federal funds could be improperly utilized by a subrecipient which does not have an adequate understanding of the requirements or tools to support the program. Cause: The Unified Government has a long-time relationship with this subrecipient and did not formalize the risk assessment process. Further, formalized processes for monitoring subrecipients were not operating effectively. Recommendation: We recommend that the Unified Government develop procedures to perform a risk assessment on all potential subrecipients before entering into an agreement to provide federal funds to that entity and revisit annually thereafter. Additionally, formal policies and procedures should be put in place over the various levels of monitoring that may occur as a result of the risk assessment and should also include a trigger to ensure single audit reports of subrecipients are reviewed. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Aging department is now completing these assessments annually.

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement: Subrecipient Monitoring and Material Weakness Per 2 CFR 200.332, a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and terms and conditions of the subaward as well as monitor the activities of the subrecipient which include reviewing financial and performance reports, obtaining and reviewing subrecipient single audit reports, etc. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: No risk assessment or ongoing formal monitoring of the subrecipient was performed. Questioned Costs: None noted. Context: There is only one subrecipient associated with this program. During 2022, the subrecipient received $418,171 ($104,601 - ALN 93.044, $313,570 - ALN 93.045) from the Unified Government. The subrecipient for this program is a long-time subrecipient that is familiar with federal compliance requirements, but the risk assessment was not done in writing. Additionally, ongoing monitoring including reviewing for single audit filings were not completed. Identification of Prior Year Finding: 2021-007 Effect: Federal funds could be improperly utilized by a subrecipient which does not have an adequate understanding of the requirements or tools to support the program. Cause: The Unified Government has a long-time relationship with this subrecipient and did not formalize the risk assessment process. Further, formalized processes for monitoring subrecipients were not operating effectively. Recommendation: We recommend that the Unified Government develop procedures to perform a risk assessment on all potential subrecipients before entering into an agreement to provide federal funds to that entity and revisit annually thereafter. Additionally, formal policies and procedures should be put in place over the various levels of monitoring that may occur as a result of the risk assessment and should also include a trigger to ensure single audit reports of subrecipients are reviewed. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Aging department is now completing these assessments annually.

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM Criteria or Specific Requirement – Earmarking and Significant Deficiency As described in the Older American Acts (OAA) Field Manual, Section 8.1.6.A.5 of the Kansas Department for Aging and Disability Services, the Unified Government is required to perform earmarking to ensure that no more than 120% of the budgeted amount of each category is spent and reimbursed. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: While performing procedures over the Aging Cluster, the Unified Government did not comply with the earmarking requirements as set forth by the grant. Questioned Costs – $22,234 (In home services expenses which exceeded budgeted amounts by more than 20% for ALN 93.044 - 2201KSOASS and 2201KSOACM) Context: We reviewed the budget to actual comparison for the grant period ended September 30, 2022, which is associated with the awards year end. We noted in home services expenses exceeded the budgeted threshold of 120% by $22,234. Identification of Prior Year Finding: N/A Effect: Compliance with earmarking is not being met. Cause: The Unified Government's controls to follow the earmarking requirement did not operate effectively. Recommendation: We recommend that the Unified Government put in place processes/controls to monitor earmarking requirement for compliance. Views of Responsible Official and Planned Corrective Actions: Management will put controls and processes in place to ensure earmarking is being monitored for compliance.

U.S. Department of Agriculture Passed through the Kansas Department of Health and Environment Special Supplemental Nutrition Program for Women, Infants, and Children - 10.557 - Award number 202222W100643 Criteria or Specific Requirement – Allowable Costs/Cost Principles and Significant Deficiency Per 2 CFR 200.412 costs may be classified as direct or indirect costs and the charging of indirect costs are further governed by 2 CFR 200.414. The Unified Government has not elected to use the De Minimus indirect cost rate as allowed under the regulations nor do they have a federally negotiated indirect cost rate agreement. Per the WIC Policy and Procedures Manual, Expenses Section, 15.b., the Unified Government should negotiate a rate with the State Agency (SA) annually. As part of the negotiation, the Local Agency (LA) must submit an Indirect Cost Rate (ICR) proposal, including all documents and calculations used to determine the ICR, to the SA with the annual budget. The rate negotiated by the SA will be equal to or less than the indirect rate approved by the U.S. Dept. of Health and Human Services for KDHE. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: For the Unified Government's Special Supplemental Nutrition Program for Women, Infants, and Children grant, for specific indirect cost rate was negotiated and approved by the Kansas Department of Health for the period July 1, 2021 through June 30, 2022. The Unified Government was unable to find a subsequent renewal or change in the negotiated rate governing such charges to the award. Questioned Costs – $37,931 related to the award number 202222W100643 for the grant period of October 1, 2021 through September 30, 2022. An approved indirect cost rate was not available for the period of July 1, 2022 through September 30, 2022. Context: In the absence of an updated agreement, the Unified Government used the indirect cost rate from its most recent agreement, which covered the period of July 2021 to June 2022 for periods outside of the agreed upon time (July 2022 through September 2022). Given an updated agreement was not present, it was uncertain if such charges were allowable or accurately charged to the award. Identification of Prior Year Finding: N/A Effect: Inappropriate indirect costs may be charged to the award based on unapproved agreements. Cause: The Unified Government does not have proper controls in place to monitor indirect costs and timing of when new negotiations may be required to support ongoing indirect costs. Recommendation: We recommend the Unified Government appropriately store records where department personnel can access them when needed. Views of Responsible Official and Planned Corrective Actions: Management will work internally to complete the annual calculation of the indirect rate and develop a solution, a shared document solution to provide indirect rate information to departments in a consistent and timely manner.

U.S. Department of Treasury COVID 19 - Coronavirus State and Local Fiscal Recovery Funds - 21.027 Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: For vendor contracts, suspension and debarment checks were not performed. Questioned Costs - None noted. Context: For 21.027, there were 15 vendors receiving a total of $1,382,977 subject to suspension and debarment requirements. Of those 15, a sample of 3 vendors receiving a total of $324,205 were selected for testing and none of the three were verified by the Unified Government for Suspension and Debarment. A subsequent check was completed and none of the associated three vendors selected for testing were suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: 2021-002 Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: Expenditures for these programs were identified after many of these purchases had taken place. Departments performing their own procurement processes may not have been familiar with federal requirements or known at the time of purchase that this would be reimbursed with federal funds and did not complete the required suspension and debarment checks. Recommendation: We recommend that the Unified Government communicate to all departments that purchases using federal funds have suspension and debarment checks completed prior to purchase and the procurement department provide training on the requirements to properly document that suspension and debarment checks are completed. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step.

U.S. Department of Treasury COVID 19 - Coronavirus State and Local Fiscal Recovery Funds - 21.027 Criteria or Specific Requirement – Reporting and Significant Deficiency Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per the Coronavirus State and Local Fiscal Recovery Funds Guidance on Recipient Compliance and Reporting Responsibilities, metropolitan cities and counties with a population below 250,000 residents that are allocated more than $10,000,000 in SLFRF are required to submit quarterly project and expenditure reports. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our test work over the Coronavirus State and Local Fiscal Recovery grant, we noted the Unified Government did not timely file required reports. Questioned Costs – None noted. Context: One out of the two quarterly reports selected for testing was submitted on August 18, 2022 rather than the Department of Treasury's due date of July 31, 2022. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect: Required reports are not being submitted timely. Cause: The Unified Government's controls to ensure reports are filed timely were not operating effectively. Recommendation: We recommend that the Unified Government implement a process that includes tracking the timely submission of reports. Views of Responsible Official and Planned Corrective Actions: In concert with our ARPA consultant, we were able to combine the City & County on the portal and report timely quarterly since this initial issue in the reporting portal.

U.S. Department of Homeland Security Staffing for Adequate Fire and Emergency Response (SAFER) - 97.083, Award number EMW-2019-FF-0819 Criteria or Specific Requirement – Material Weakness Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: It is the Unified Government's policy that no funding received through the Staffing for Adequate Fire and Emergency Response (SAFER) grant is to be utilized for overtime pay even when it is allowed under the grant. During testing of allowable costs, we identified instances in which funding was used for overtime pay. Question Costs: None noted Context: We selected a sample of 40 charges to the SAFER grant of which, all were salaries and benefits expenditures. Within our sample, we noted 10 of the selections were overtime and were charged and allocated to the grant. These were determined to be allowable under the grant as it was for overtime that the fire department routinely pays as a part of the firefighter’s regularly scheduled and contracted shift hours to comply with the Fair Labor Standards Act (FLSA). This sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect: The Unified Government's control surrounding overtime pay was not operating effectively and overtime was applied against the grant despite their internal policies and controls. Cause: The Unified Government's controls to not charge overtime did not operate effectively. Recommendation: We recommend that the Unified Government review it's control structure surrounding the SAFER award document and ensure they are designed around compliance requirements and that they are operating effectively. Views of Responsible Official and Planned Corrective Actions: Management will work with stakeholders so that only the allowed costs are used as the basis of the reimbursement packet. We have also created fencing around allowed costs and period of performance in our new ERP system.

U.S. Department of Homeland Security Staffing for Adequate Fire and Emergency Response (SAFER) - 97.083, Award number EMW-2019-FF-0819 Criteria or Specific Requirement – Reporting and Significant Deficiency Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per The Department of Homeland Security (DHS) Notice of Funding Opportunity (NOFO) FY 2019 Staffing for Adequate Fire and Emergency Response (SAFER), quarterly performance reports which include a summary of project expenditures are required to be submitted. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our test work over the Staffing for Adequate Fire and Emergency Response (SAFER) grant, we noted the Unified Government was not able to supply support to evidence that a quarterly performance report selected for testing was properly completed and filed. Questioned Costs – None noted. Context: One out of the two quarterly reports selected for testing was unable to be supplied. This sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect: Required reports may not be submitted and/or submitted timely. Cause: The Unified Government's controls to ensure quarterly reports were submitted did not operate effectively. Recommendation: We recommend that the Unified Government implement a process that includes tracking the timely submission of reports. Views of Responsible Official and Planned Corrective Actions: Management has begun the process of centralizing documents related to reporting, monitoring and compliance.

U.S. Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-20-0001 Criteria or Specific Requirement – Matching and Material Weakness Per 24 CFR 576.201, ESG, recipients, other than states and territories, must match the funding provided by HUD under its ESG program in an amount that equals the recipient's fiscal year grant from sources other than those provided under the ESG program. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our test work over the Emergency Solutions grant, we noted that the Unified Government did not meet the matching requirements during the year ended December 31, 2022. Questioned Costs – $166,876, which are the total expenditures under the grant award number E-22-MC-20-0001. The entire amount is considered a questioned costs as no match was made for the related expenditures. Context: The Unified Government did not comply with matching requirement as set forth by the U.S. Department of Housing and Urban Development. The award agreement is for a total of $195,473 and the period of performance does extend until November 2, 2024; therefore, a match could still be met, but it will not be within the same fiscal year as when the funds were spent. Identification of Prior Year Finding: N/A Effect: Compliance with the matching requirements for this program is not being met. Cause: The Unified Government controls to ensure matching requirements are met was not operating effectively. Recommendation: We recommend that the Unified Government implement a process that includes tracking the matching requirements to ensure compliance. Views of Responsible Official and Planned Corrective Actions: With our new ERP system, in the grant/award module, the Unified Government of Wyandotte County & Kansas City KS are working with departments to establish match components and trackable spend items to enhance compliance with award terms.

U.S. Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-20-0001 Criteria or Specific Requirement – Special Tests - Obligation, Expenditure and Payment Requirements and Material Weakness Per 24 CFR Section 576.203(b), all of the recipient’s grant must be expended for eligible activity costs within 24 months after the date HUD signs the grant agreement with the recipient. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Various expenditures were dated outside of the applicable expenditure periods. Questioned Costs – $166,028 Context: Based on the expenditure listing provided by the Unified Government, a total of $166,028 of expenditures were outside of the period of performance on the award. The expenses were incurred from December 2021 through October 2022, but the award did not begin until November 2022. Identification of Prior Year Finding: N/A Effect: Compliance with the expenditure requirements is not being met. Cause: The Unified Government's controls to follow expenditure requirements did not operate effectively. Recommendation: We recommend that the Unified Government ensure that costs allocated to federal programs are incurred during the period of performance. Views of Responsible Official and Planned Corrective Actions: With the aid of technology available through our new ERP system, management plans to enhance operations by having training documents and processes for various awards so as personnel attrition occurs there is continuity in processes.

U.S. Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-0001 COVID-19 Emergency Solutions Grant Program - 14.231, Award number E-20-MW-20-0001 Criteria or Specific Requirement – Special Tests: Obligation, Expenditure and Payment Requirements and Material Weakness According to 24 CFR section 576.203, a recipient must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient's complete payment request. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: While performing testing over the Emergency Solutions Grant, we noted the Unified Government did not pay three subrecipients within the 30 days of receiving the subrecipients completed payment request. Questioned Costs – None noted. Context: There were 74 payments made to subrecipients receiving a total of $1,013,942. Of those 74 payments, a sample of eight payments totaling $143,908 were selected for testing. Out of the eight payments, three payments totaling $96,853 were made past the 30 day requirement (ranged from 39 to 77 days for payment). This sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect: Payments to subrecipients are not being made within 30 days of the payment request. Cause: The Unified Government's controls to ensure timely payment did not operate effectively. Recommendation: We recommend that the Unified Government put in place processes/controls to ensure payment requests received from subrecipients within 30 days of receipt. Views of Responsible Official and Planned Corrective Actions: Departmental stakeholders should work with central accounting to be sure payments are made in time and develop solutions where there could potentially be a shortfall.

U.S. Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-0001 COVID-19 Emergency Solutions Grant Program - 14.231, Award number E-20-MW-20-0001 Criteria or Specific Requirement – Special Tests: Obligation, Expenditure and Payment Requirements and Material Weakness According to 24 CFR section 576.203, a recipient must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient's complete payment request. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: While performing testing over the Emergency Solutions Grant, we noted the Unified Government did not pay three subrecipients within the 30 days of receiving the subrecipients completed payment request. Questioned Costs – None noted. Context: There were 74 payments made to subrecipients receiving a total of $1,013,942. Of those 74 payments, a sample of eight payments totaling $143,908 were selected for testing. Out of the eight payments, three payments totaling $96,853 were made past the 30 day requirement (ranged from 39 to 77 days for payment). This sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect: Payments to subrecipients are not being made within 30 days of the payment request. Cause: The Unified Government's controls to ensure timely payment did not operate effectively. Recommendation: We recommend that the Unified Government put in place processes/controls to ensure payment requests received from subrecipients within 30 days of receipt. Views of Responsible Official and Planned Corrective Actions: Departmental stakeholders should work with central accounting to be sure payments are made in time and develop solutions where there could potentially be a shortfall.

U.S. Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-0001 COVID-19 Emergency Solutions Grant Program - 14.231, Award number E-20-MW-20-0001 Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for the subrecipients that received federal funds. Questioned Costs - None noted. Context: For 14.231, there were seven subrecipients receiving a total of $1,013,942 subject to suspension and debarment requirements. Of those seven, a sample of two subrecipients receiving a total of $469,455 were selected for testing and none of the two were verified by the Unified Government for Suspension and Debarment. A subsequent check was completed and none of the associated two subrecipients selected for testing were suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: For the Unified Government, this is typically included in the contracts, but was not included in the subrecipient contracts for this program and the Unified Government did not have another means of validating suspension and debarment. Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include subrecipients, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step.

U.S. Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-0001 COVID-19 Emergency Solutions Grant Program - 14.231, Award number E-20-MW-20-0001 Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for the subrecipients that received federal funds. Questioned Costs - None noted. Context: For 14.231, there were seven subrecipients receiving a total of $1,013,942 subject to suspension and debarment requirements. Of those seven, a sample of two subrecipients receiving a total of $469,455 were selected for testing and none of the two were verified by the Unified Government for Suspension and Debarment. A subsequent check was completed and none of the associated two subrecipients selected for testing were suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: For the Unified Government, this is typically included in the contracts, but was not included in the subrecipient contracts for this program and the Unified Government did not have another means of validating suspension and debarment. Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include subrecipients, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step.

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement – Allowable Costs/Cost Principles and Material Weakness Federal regulations state that “charges to federal awards for salaries and wages, must be based on records that accurately reflect the work performed.” The regulations also state that “the records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and property allocated” and “budget estimates alone do not qualify as support for charges to federal awards” (2 CFR 200.430(i)). Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e ., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – During our test work over the ALN 93.045 grant, we noted the the Unified Government did not have time and activity records with sufficient detail per federal regulations document to support its compensation and fringe benefit expenses. Questioned Costs – Total questioned costs of $2,332 were identified as a result of lack of proper documentation to support the charge and allocation to the grant. Context – We selected a sample of 40 charges totaling $16,402 to the Aging Cluster grants of which 28 were salaries and benefits expenditures with a value of $2,332. Within our sample, none of the 28 selections had proper documentation to support allocation to the grant. Per discussions with management and further review, the amounts charged to the grant were based on the approved budget for the position and the internal allocation performed each payroll period. Salaries and benefits charged to the entire cluster in the audit period totaled $306,658 and represented 16% of the total grant expenditures for the period. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect – Based on testing completed, the the Unified Government did not have sufficient procedures to allocate salaries and fringe benefits activity related to Aging Cluster throughout fiscal year 2022. Cause – Management indicated that this was attributed to a misunderstanding of the requirements and the inability to rely on budgeted estimates alone. Recommendation – We recommend that management utilize a time and activity method which meets the requirements of federal regulations. We also recommend employees and their supervisors are provided training on the requirements. Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement – Allowable Costs/Cost Principles and Material Weakness Federal regulations state that “charges to federal awards for salaries and wages, must be based on records that accurately reflect the work performed.” The regulations also state that “the records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and property allocated” and “budget estimates alone do not qualify as support for charges to federal awards” (2 CFR 200.430(i)). Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e ., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – During our test work over the ALN 93.045 grant, we noted the the Unified Government did not have time and activity records with sufficient detail per federal regulations document to support its compensation and fringe benefit expenses. Questioned Costs – Total questioned costs of $2,332 were identified as a result of lack of proper documentation to support the charge and allocation to the grant. Context – We selected a sample of 40 charges totaling $16,402 to the Aging Cluster grants of which 28 were salaries and benefits expenditures with a value of $2,332. Within our sample, none of the 28 selections had proper documentation to support allocation to the grant. Per discussions with management and further review, the amounts charged to the grant were based on the approved budget for the position and the internal allocation performed each payroll period. Salaries and benefits charged to the entire cluster in the audit period totaled $306,658 and represented 16% of the total grant expenditures for the period. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect – Based on testing completed, the the Unified Government did not have sufficient procedures to allocate salaries and fringe benefits activity related to Aging Cluster throughout fiscal year 2022. Cause – Management indicated that this was attributed to a misunderstanding of the requirements and the inability to rely on budgeted estimates alone. Recommendation – We recommend that management utilize a time and activity method which meets the requirements of federal regulations. We also recommend employees and their supervisors are provided training on the requirements. Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for the subrecipients that received federal funds. Questioned Costs: None noted. Context: The single subrecipient under both ALN 93.044 and 93.045 receiving approximately $418,000 was not evaluated for suspension and debarment. It was noted after subsequent check, that the subrecipient was not suspended or debarred. Identification of Prior Year Finding: 2021-005 Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: For the Unified Government, this is typically included in the contracts, but was not included in the subrecipient contracts for this program and the Unified Government did not have another means of validating suspension and debarment. Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include subrecipients, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step for both suppliers and subrecipients. Downstream, need to evaluate if this language can be added to the contract templates.

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for the subrecipients that received federal funds. Questioned Costs: None noted. Context: The single subrecipient under both ALN 93.044 and 93.045 receiving approximately $418,000 was not evaluated for suspension and debarment. It was noted after subsequent check, that the subrecipient was not suspended or debarred. Identification of Prior Year Finding: 2021-005 Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: For the Unified Government, this is typically included in the contracts, but was not included in the subrecipient contracts for this program and the Unified Government did not have another means of validating suspension and debarment. Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include subrecipients, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step for both suppliers and subrecipients. Downstream, need to evaluate if this language can be added to the contract templates.

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for the subrecipients that received federal funds. Questioned Costs: None noted. Context: The single subrecipient under both ALN 93.044 and 93.045 receiving approximately $418,000 was not evaluated for suspension and debarment. It was noted after subsequent check, that the subrecipient was not suspended or debarred. Identification of Prior Year Finding: 2021-005 Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: For the Unified Government, this is typically included in the contracts, but was not included in the subrecipient contracts for this program and the Unified Government did not have another means of validating suspension and debarment. Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include subrecipients, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step for both suppliers and subrecipients. Downstream, need to evaluate if this language can be added to the contract templates.

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement: Subrecipient Monitoring and Material Weakness Per 2 CFR 200.332, a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and terms and conditions of the subaward as well as monitor the activities of the subrecipient which include reviewing financial and performance reports, obtaining and reviewing subrecipient single audit reports, etc. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: No risk assessment or ongoing formal monitoring of the subrecipient was performed. Questioned Costs: None noted. Context: There is only one subrecipient associated with this program. During 2022, the subrecipient received $418,171 ($104,601 - ALN 93.044, $313,570 - ALN 93.045) from the Unified Government. The subrecipient for this program is a long-time subrecipient that is familiar with federal compliance requirements, but the risk assessment was not done in writing. Additionally, ongoing monitoring including reviewing for single audit filings were not completed. Identification of Prior Year Finding: 2021-007 Effect: Federal funds could be improperly utilized by a subrecipient which does not have an adequate understanding of the requirements or tools to support the program. Cause: The Unified Government has a long-time relationship with this subrecipient and did not formalize the risk assessment process. Further, formalized processes for monitoring subrecipients were not operating effectively. Recommendation: We recommend that the Unified Government develop procedures to perform a risk assessment on all potential subrecipients before entering into an agreement to provide federal funds to that entity and revisit annually thereafter. Additionally, formal policies and procedures should be put in place over the various levels of monitoring that may occur as a result of the risk assessment and should also include a trigger to ensure single audit reports of subrecipients are reviewed. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Aging department is now completing these assessments annually.

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement: Subrecipient Monitoring and Material Weakness Per 2 CFR 200.332, a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and terms and conditions of the subaward as well as monitor the activities of the subrecipient which include reviewing financial and performance reports, obtaining and reviewing subrecipient single audit reports, etc. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: No risk assessment or ongoing formal monitoring of the subrecipient was performed. Questioned Costs: None noted. Context: There is only one subrecipient associated with this program. During 2022, the subrecipient received $418,171 ($104,601 - ALN 93.044, $313,570 - ALN 93.045) from the Unified Government. The subrecipient for this program is a long-time subrecipient that is familiar with federal compliance requirements, but the risk assessment was not done in writing. Additionally, ongoing monitoring including reviewing for single audit filings were not completed. Identification of Prior Year Finding: 2021-007 Effect: Federal funds could be improperly utilized by a subrecipient which does not have an adequate understanding of the requirements or tools to support the program. Cause: The Unified Government has a long-time relationship with this subrecipient and did not formalize the risk assessment process. Further, formalized processes for monitoring subrecipients were not operating effectively. Recommendation: We recommend that the Unified Government develop procedures to perform a risk assessment on all potential subrecipients before entering into an agreement to provide federal funds to that entity and revisit annually thereafter. Additionally, formal policies and procedures should be put in place over the various levels of monitoring that may occur as a result of the risk assessment and should also include a trigger to ensure single audit reports of subrecipients are reviewed. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Aging department is now completing these assessments annually.

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement: Subrecipient Monitoring and Material Weakness Per 2 CFR 200.332, a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and terms and conditions of the subaward as well as monitor the activities of the subrecipient which include reviewing financial and performance reports, obtaining and reviewing subrecipient single audit reports, etc. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: No risk assessment or ongoing formal monitoring of the subrecipient was performed. Questioned Costs: None noted. Context: There is only one subrecipient associated with this program. During 2022, the subrecipient received $418,171 ($104,601 - ALN 93.044, $313,570 - ALN 93.045) from the Unified Government. The subrecipient for this program is a long-time subrecipient that is familiar with federal compliance requirements, but the risk assessment was not done in writing. Additionally, ongoing monitoring including reviewing for single audit filings were not completed. Identification of Prior Year Finding: 2021-007 Effect: Federal funds could be improperly utilized by a subrecipient which does not have an adequate understanding of the requirements or tools to support the program. Cause: The Unified Government has a long-time relationship with this subrecipient and did not formalize the risk assessment process. Further, formalized processes for monitoring subrecipients were not operating effectively. Recommendation: We recommend that the Unified Government develop procedures to perform a risk assessment on all potential subrecipients before entering into an agreement to provide federal funds to that entity and revisit annually thereafter. Additionally, formal policies and procedures should be put in place over the various levels of monitoring that may occur as a result of the risk assessment and should also include a trigger to ensure single audit reports of subrecipients are reviewed. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Aging department is now completing these assessments annually.

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM Criteria or Specific Requirement – Earmarking and Significant Deficiency As described in the Older American Acts (OAA) Field Manual, Section 8.1.6.A.5 of the Kansas Department for Aging and Disability Services, the Unified Government is required to perform earmarking to ensure that no more than 120% of the budgeted amount of each category is spent and reimbursed. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: While performing procedures over the Aging Cluster, the Unified Government did not comply with the earmarking requirements as set forth by the grant. Questioned Costs – $22,234 (In home services expenses which exceeded budgeted amounts by more than 20% for ALN 93.044 - 2201KSOASS and 2201KSOACM) Context: We reviewed the budget to actual comparison for the grant period ended September 30, 2022, which is associated with the awards year end. We noted in home services expenses exceeded the budgeted threshold of 120% by $22,234. Identification of Prior Year Finding: N/A Effect: Compliance with earmarking is not being met. Cause: The Unified Government's controls to follow the earmarking requirement did not operate effectively. Recommendation: We recommend that the Unified Government put in place processes/controls to monitor earmarking requirement for compliance. Views of Responsible Official and Planned Corrective Actions: Management will put controls and processes in place to ensure earmarking is being monitored for compliance.

U.S. Department of Agriculture Passed through the Kansas Department of Health and Environment Special Supplemental Nutrition Program for Women, Infants, and Children - 10.557 - Award number 202222W100643 Criteria or Specific Requirement – Allowable Costs/Cost Principles and Significant Deficiency Per 2 CFR 200.412 costs may be classified as direct or indirect costs and the charging of indirect costs are further governed by 2 CFR 200.414. The Unified Government has not elected to use the De Minimus indirect cost rate as allowed under the regulations nor do they have a federally negotiated indirect cost rate agreement. Per the WIC Policy and Procedures Manual, Expenses Section, 15.b., the Unified Government should negotiate a rate with the State Agency (SA) annually. As part of the negotiation, the Local Agency (LA) must submit an Indirect Cost Rate (ICR) proposal, including all documents and calculations used to determine the ICR, to the SA with the annual budget. The rate negotiated by the SA will be equal to or less than the indirect rate approved by the U.S. Dept. of Health and Human Services for KDHE. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: For the Unified Government's Special Supplemental Nutrition Program for Women, Infants, and Children grant, for specific indirect cost rate was negotiated and approved by the Kansas Department of Health for the period July 1, 2021 through June 30, 2022. The Unified Government was unable to find a subsequent renewal or change in the negotiated rate governing such charges to the award. Questioned Costs – $37,931 related to the award number 202222W100643 for the grant period of October 1, 2021 through September 30, 2022. An approved indirect cost rate was not available for the period of July 1, 2022 through September 30, 2022. Context: In the absence of an updated agreement, the Unified Government used the indirect cost rate from its most recent agreement, which covered the period of July 2021 to June 2022 for periods outside of the agreed upon time (July 2022 through September 2022). Given an updated agreement was not present, it was uncertain if such charges were allowable or accurately charged to the award. Identification of Prior Year Finding: N/A Effect: Inappropriate indirect costs may be charged to the award based on unapproved agreements. Cause: The Unified Government does not have proper controls in place to monitor indirect costs and timing of when new negotiations may be required to support ongoing indirect costs. Recommendation: We recommend the Unified Government appropriately store records where department personnel can access them when needed. Views of Responsible Official and Planned Corrective Actions: Management will work internally to complete the annual calculation of the indirect rate and develop a solution, a shared document solution to provide indirect rate information to departments in a consistent and timely manner.

U.S. Department of Treasury COVID 19 - Coronavirus State and Local Fiscal Recovery Funds - 21.027 Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: For vendor contracts, suspension and debarment checks were not performed. Questioned Costs - None noted. Context: For 21.027, there were 15 vendors receiving a total of $1,382,977 subject to suspension and debarment requirements. Of those 15, a sample of 3 vendors receiving a total of $324,205 were selected for testing and none of the three were verified by the Unified Government for Suspension and Debarment. A subsequent check was completed and none of the associated three vendors selected for testing were suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: 2021-002 Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: Expenditures for these programs were identified after many of these purchases had taken place. Departments performing their own procurement processes may not have been familiar with federal requirements or known at the time of purchase that this would be reimbursed with federal funds and did not complete the required suspension and debarment checks. Recommendation: We recommend that the Unified Government communicate to all departments that purchases using federal funds have suspension and debarment checks completed prior to purchase and the procurement department provide training on the requirements to properly document that suspension and debarment checks are completed. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step.

U.S. Department of Treasury COVID 19 - Coronavirus State and Local Fiscal Recovery Funds - 21.027 Criteria or Specific Requirement – Reporting and Significant Deficiency Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per the Coronavirus State and Local Fiscal Recovery Funds Guidance on Recipient Compliance and Reporting Responsibilities, metropolitan cities and counties with a population below 250,000 residents that are allocated more than $10,000,000 in SLFRF are required to submit quarterly project and expenditure reports. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our test work over the Coronavirus State and Local Fiscal Recovery grant, we noted the Unified Government did not timely file required reports. Questioned Costs – None noted. Context: One out of the two quarterly reports selected for testing was submitted on August 18, 2022 rather than the Department of Treasury's due date of July 31, 2022. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect: Required reports are not being submitted timely. Cause: The Unified Government's controls to ensure reports are filed timely were not operating effectively. Recommendation: We recommend that the Unified Government implement a process that includes tracking the timely submission of reports. Views of Responsible Official and Planned Corrective Actions: In concert with our ARPA consultant, we were able to combine the City & County on the portal and report timely quarterly since this initial issue in the reporting portal.

U.S. Department of Homeland Security Staffing for Adequate Fire and Emergency Response (SAFER) - 97.083, Award number EMW-2019-FF-0819 Criteria or Specific Requirement – Material Weakness Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: It is the Unified Government's policy that no funding received through the Staffing for Adequate Fire and Emergency Response (SAFER) grant is to be utilized for overtime pay even when it is allowed under the grant. During testing of allowable costs, we identified instances in which funding was used for overtime pay. Question Costs: None noted Context: We selected a sample of 40 charges to the SAFER grant of which, all were salaries and benefits expenditures. Within our sample, we noted 10 of the selections were overtime and were charged and allocated to the grant. These were determined to be allowable under the grant as it was for overtime that the fire department routinely pays as a part of the firefighter’s regularly scheduled and contracted shift hours to comply with the Fair Labor Standards Act (FLSA). This sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect: The Unified Government's control surrounding overtime pay was not operating effectively and overtime was applied against the grant despite their internal policies and controls. Cause: The Unified Government's controls to not charge overtime did not operate effectively. Recommendation: We recommend that the Unified Government review it's control structure surrounding the SAFER award document and ensure they are designed around compliance requirements and that they are operating effectively. Views of Responsible Official and Planned Corrective Actions: Management will work with stakeholders so that only the allowed costs are used as the basis of the reimbursement packet. We have also created fencing around allowed costs and period of performance in our new ERP system.

U.S. Department of Homeland Security Staffing for Adequate Fire and Emergency Response (SAFER) - 97.083, Award number EMW-2019-FF-0819 Criteria or Specific Requirement – Reporting and Significant Deficiency Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per The Department of Homeland Security (DHS) Notice of Funding Opportunity (NOFO) FY 2019 Staffing for Adequate Fire and Emergency Response (SAFER), quarterly performance reports which include a summary of project expenditures are required to be submitted. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our test work over the Staffing for Adequate Fire and Emergency Response (SAFER) grant, we noted the Unified Government was not able to supply support to evidence that a quarterly performance report selected for testing was properly completed and filed. Questioned Costs – None noted. Context: One out of the two quarterly reports selected for testing was unable to be supplied. This sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect: Required reports may not be submitted and/or submitted timely. Cause: The Unified Government's controls to ensure quarterly reports were submitted did not operate effectively. Recommendation: We recommend that the Unified Government implement a process that includes tracking the timely submission of reports. Views of Responsible Official and Planned Corrective Actions: Management has begun the process of centralizing documents related to reporting, monitoring and compliance.

U.S. Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-20-0001 Criteria or Specific Requirement – Matching and Material Weakness Per 24 CFR 576.201, ESG, recipients, other than states and territories, must match the funding provided by HUD under its ESG program in an amount that equals the recipient's fiscal year grant from sources other than those provided under the ESG program. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our test work over the Emergency Solutions grant, we noted that the Unified Government did not meet the matching requirements during the year ended December 31, 2022. Questioned Costs – $166,876, which are the total expenditures under the grant award number E-22-MC-20-0001. The entire amount is considered a questioned costs as no match was made for the related expenditures. Context: The Unified Government did not comply with matching requirement as set forth by the U.S. Department of Housing and Urban Development. The award agreement is for a total of $195,473 and the period of performance does extend until November 2, 2024; therefore, a match could still be met, but it will not be within the same fiscal year as when the funds were spent. Identification of Prior Year Finding: N/A Effect: Compliance with the matching requirements for this program is not being met. Cause: The Unified Government controls to ensure matching requirements are met was not operating effectively. Recommendation: We recommend that the Unified Government implement a process that includes tracking the matching requirements to ensure compliance. Views of Responsible Official and Planned Corrective Actions: With our new ERP system, in the grant/award module, the Unified Government of Wyandotte County & Kansas City KS are working with departments to establish match components and trackable spend items to enhance compliance with award terms.

U.S. Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-20-0001 Criteria or Specific Requirement – Special Tests - Obligation, Expenditure and Payment Requirements and Material Weakness Per 24 CFR Section 576.203(b), all of the recipient’s grant must be expended for eligible activity costs within 24 months after the date HUD signs the grant agreement with the recipient. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Various expenditures were dated outside of the applicable expenditure periods. Questioned Costs – $166,028 Context: Based on the expenditure listing provided by the Unified Government, a total of $166,028 of expenditures were outside of the period of performance on the award. The expenses were incurred from December 2021 through October 2022, but the award did not begin until November 2022. Identification of Prior Year Finding: N/A Effect: Compliance with the expenditure requirements is not being met. Cause: The Unified Government's controls to follow expenditure requirements did not operate effectively. Recommendation: We recommend that the Unified Government ensure that costs allocated to federal programs are incurred during the period of performance. Views of Responsible Official and Planned Corrective Actions: With the aid of technology available through our new ERP system, management plans to enhance operations by having training documents and processes for various awards so as personnel attrition occurs there is continuity in processes.

U.S. Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-0001 COVID-19 Emergency Solutions Grant Program - 14.231, Award number E-20-MW-20-0001 Criteria or Specific Requirement – Special Tests: Obligation, Expenditure and Payment Requirements and Material Weakness According to 24 CFR section 576.203, a recipient must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient's complete payment request. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: While performing testing over the Emergency Solutions Grant, we noted the Unified Government did not pay three subrecipients within the 30 days of receiving the subrecipients completed payment request. Questioned Costs – None noted. Context: There were 74 payments made to subrecipients receiving a total of $1,013,942. Of those 74 payments, a sample of eight payments totaling $143,908 were selected for testing. Out of the eight payments, three payments totaling $96,853 were made past the 30 day requirement (ranged from 39 to 77 days for payment). This sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect: Payments to subrecipients are not being made within 30 days of the payment request. Cause: The Unified Government's controls to ensure timely payment did not operate effectively. Recommendation: We recommend that the Unified Government put in place processes/controls to ensure payment requests received from subrecipients within 30 days of receipt. Views of Responsible Official and Planned Corrective Actions: Departmental stakeholders should work with central accounting to be sure payments are made in time and develop solutions where there could potentially be a shortfall.

U.S. Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-0001 COVID-19 Emergency Solutions Grant Program - 14.231, Award number E-20-MW-20-0001 Criteria or Specific Requirement – Special Tests: Obligation, Expenditure and Payment Requirements and Material Weakness According to 24 CFR section 576.203, a recipient must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient's complete payment request. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: While performing testing over the Emergency Solutions Grant, we noted the Unified Government did not pay three subrecipients within the 30 days of receiving the subrecipients completed payment request. Questioned Costs – None noted. Context: There were 74 payments made to subrecipients receiving a total of $1,013,942. Of those 74 payments, a sample of eight payments totaling $143,908 were selected for testing. Out of the eight payments, three payments totaling $96,853 were made past the 30 day requirement (ranged from 39 to 77 days for payment). This sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect: Payments to subrecipients are not being made within 30 days of the payment request. Cause: The Unified Government's controls to ensure timely payment did not operate effectively. Recommendation: We recommend that the Unified Government put in place processes/controls to ensure payment requests received from subrecipients within 30 days of receipt. Views of Responsible Official and Planned Corrective Actions: Departmental stakeholders should work with central accounting to be sure payments are made in time and develop solutions where there could potentially be a shortfall.

U.S. Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-0001 COVID-19 Emergency Solutions Grant Program - 14.231, Award number E-20-MW-20-0001 Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for the subrecipients that received federal funds. Questioned Costs - None noted. Context: For 14.231, there were seven subrecipients receiving a total of $1,013,942 subject to suspension and debarment requirements. Of those seven, a sample of two subrecipients receiving a total of $469,455 were selected for testing and none of the two were verified by the Unified Government for Suspension and Debarment. A subsequent check was completed and none of the associated two subrecipients selected for testing were suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: For the Unified Government, this is typically included in the contracts, but was not included in the subrecipient contracts for this program and the Unified Government did not have another means of validating suspension and debarment. Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include subrecipients, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step.

U.S. Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-0001 COVID-19 Emergency Solutions Grant Program - 14.231, Award number E-20-MW-20-0001 Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for the subrecipients that received federal funds. Questioned Costs - None noted. Context: For 14.231, there were seven subrecipients receiving a total of $1,013,942 subject to suspension and debarment requirements. Of those seven, a sample of two subrecipients receiving a total of $469,455 were selected for testing and none of the two were verified by the Unified Government for Suspension and Debarment. A subsequent check was completed and none of the associated two subrecipients selected for testing were suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: For the Unified Government, this is typically included in the contracts, but was not included in the subrecipient contracts for this program and the Unified Government did not have another means of validating suspension and debarment. Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include subrecipients, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step.

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement – Allowable Costs/Cost Principles and Material Weakness Federal regulations state that “charges to federal awards for salaries and wages, must be based on records that accurately reflect the work performed.” The regulations also state that “the records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and property allocated” and “budget estimates alone do not qualify as support for charges to federal awards” (2 CFR 200.430(i)). Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e ., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – During our test work over the ALN 93.045 grant, we noted the the Unified Government did not have time and activity records with sufficient detail per federal regulations document to support its compensation and fringe benefit expenses. Questioned Costs – Total questioned costs of $2,332 were identified as a result of lack of proper documentation to support the charge and allocation to the grant. Context – We selected a sample of 40 charges totaling $16,402 to the Aging Cluster grants of which 28 were salaries and benefits expenditures with a value of $2,332. Within our sample, none of the 28 selections had proper documentation to support allocation to the grant. Per discussions with management and further review, the amounts charged to the grant were based on the approved budget for the position and the internal allocation performed each payroll period. Salaries and benefits charged to the entire cluster in the audit period totaled $306,658 and represented 16% of the total grant expenditures for the period. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect – Based on testing completed, the the Unified Government did not have sufficient procedures to allocate salaries and fringe benefits activity related to Aging Cluster throughout fiscal year 2022. Cause – Management indicated that this was attributed to a misunderstanding of the requirements and the inability to rely on budgeted estimates alone. Recommendation – We recommend that management utilize a time and activity method which meets the requirements of federal regulations. We also recommend employees and their supervisors are provided training on the requirements. Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement – Allowable Costs/Cost Principles and Material Weakness Federal regulations state that “charges to federal awards for salaries and wages, must be based on records that accurately reflect the work performed.” The regulations also state that “the records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and property allocated” and “budget estimates alone do not qualify as support for charges to federal awards” (2 CFR 200.430(i)). Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e ., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – During our test work over the ALN 93.045 grant, we noted the the Unified Government did not have time and activity records with sufficient detail per federal regulations document to support its compensation and fringe benefit expenses. Questioned Costs – Total questioned costs of $2,332 were identified as a result of lack of proper documentation to support the charge and allocation to the grant. Context – We selected a sample of 40 charges totaling $16,402 to the Aging Cluster grants of which 28 were salaries and benefits expenditures with a value of $2,332. Within our sample, none of the 28 selections had proper documentation to support allocation to the grant. Per discussions with management and further review, the amounts charged to the grant were based on the approved budget for the position and the internal allocation performed each payroll period. Salaries and benefits charged to the entire cluster in the audit period totaled $306,658 and represented 16% of the total grant expenditures for the period. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect – Based on testing completed, the the Unified Government did not have sufficient procedures to allocate salaries and fringe benefits activity related to Aging Cluster throughout fiscal year 2022. Cause – Management indicated that this was attributed to a misunderstanding of the requirements and the inability to rely on budgeted estimates alone. Recommendation – We recommend that management utilize a time and activity method which meets the requirements of federal regulations. We also recommend employees and their supervisors are provided training on the requirements. Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.