Audit 393917

Criteria or specific requirement: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. Per 2 CFR Part 170, “subaward” has the meaning given in 2 CFR 200.1 and means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $25,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§ 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) 2 CFR 200.303 requires that non-federal entities receiving federal awards establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During testing of the Federal Funding Accountability and Transparency Act (FFATA) report, it was noted that the Kansas Division of Emergency Management (KDEM) did not timely report certain subawards to FSRS for the fiscal year. Questioned costs: None. Context: Twenty-eight subawards were selected for testing, totaling $39,668,267. Eighteen of the twenty-eight subawards (64%), totaling $39,594,211, were not submitted timely and reviewed timely prior to being submitted to FSRS as summarized below. While the reports were not filed timely, the supporting documentation that was needed to file the reports was gathered by KDEM and the filing was completed before SFYE 6/30/2025. Transactions Tested Report not timely 28 18 Dollar Amount of Tested Transactions Report not timely $39,668,267 $39,594,211 Cause: KDEM was understaffed during the current and prior fiscal years and had not fully implemented its corrective action plan from the prior year audit during SFY 2025 to ensure that the subawards were reported timely and reviewed timely prior to submitted to FSRS. Effect: Management is not in compliance with FFATA reporting requirements. Repeat Finding: Yes, Finding 2024-010. Recommendation: We recommend that KDEM continue to implement its corrective action plan from the prior year. Management should continue to enhance its procedures and internal controls to ensure that subawards are accurate, reported timely and reviewed timely to FSRS. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 2 CFR 200.332, all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information listed in 2 CFR 200.332(a)(1) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Per 2 CFR 200.332(b), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes required award information. A pass-through entity must provide the best available information when some of the information below is unavailable. A pass-through entity must provide the unavailable information when it is obtained. Required information includes: Subrecipient's name, Subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), Federal Award Date, Subaward Period of Performance Start and End Date, Subaward Budget Period Start and End Date, Amount of Federal Funds Obligated in the subaward, Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity, including the current financial obligation, Total Amount of the Federal Award committed to the subrecipient by the pass-through entity, Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA), Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity, Assistance Listings title and number, Identification of whether the Federal award is for research and development, Indirect cost rate for the Federal award (including if the de minimis rate is used. Per 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing of subrecipient monitoring, we noted that for certain subawards the Kansas Division of Emergency Management (KDEM) did not timely issue the subaward letter to the subrecipients, which should have been communicated within 30 days of subaward being obligated or before subaward payments were made. Questioned costs: None. Context: For eleven of twenty-eight subrecipients selected for testing, KDEM did not issue subaward letters to the subrecipient timely when the funds were approved and obligated. Further for six of the eleven subrecipients tested, KDEM did not maintain documentation from a previously utilized portal that they no longer have access to. Cause: 2 CFR 200.332(a) requires subawards to include certain required information to be communicated to subrecipients at the time of the subaward being awarded. The subawards were made prior to KDEM fully implementing their corrective action plan. For six of the transactions, KDEM no longer has access to the portal in which the subaward documentation is maintained. Effect: Failure to issue subawards timely and to include required federal award information could result in subrecipients not properly administering the federal program in accordance with federal regulations. Repeat Finding: Yes, Finding 2024-011. Recommendation: We recommend that KDEM continues to implement its corrective action plan from prior year and continue to enhance its internal controls and procedures to ensure that the subaward letter is issued to subrecipients timely to ensure all required federal award information is communicated to the subrecipient at the time of the subaward. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. Per 2 CFR Part 170, “subaward” has the meaning given in 2 CFR 200.1 and means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $25,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§ 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During the audit period, the entity did not submit required FFATA reports for certain first‑tier subawards subject to FFATA reporting requirements. As a result, required information was not reported in SAM.gov by the last day of the month following the month in which the subaward obligation occurred. Questioned costs: None. Context: Fourteen of the fourteen new subawards tested during the current year were not reported to the FSRS to comply with the Federal Funding and Accountability Act (FFATA). Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 14 14 14 14 14 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 651,008 $651,008 $651,008 $651,008 $651,008 Cause: The noncompliance occurred because the entity did not have adequate internal controls in place to identify federal awards and subawards subject to FFATA reporting requirements. Specifically, management did not maintain a formal process to track FFATA‑reportable awards, monitor reporting deadlines, or ensure staff responsible for grant administration were sufficiently trained on FFATA reporting requirements. Effect: As a result of this noncompliance, required FFATA information related to federal subawards was not publicly reported in a timely and complete manner, reducing transparency over the use of federal funds. Failure to comply with FFATA reporting requirements may result in increased oversight by federal awarding agencies and could impact the entity’s ability to receive future federal funding. Repeat Finding: No Recommendation: We recommend that management implement policies and procedures to ensure compliance with FFATA reporting requirements. This should include identifying all federal awards and subawards subject to FFATA, establishing a process to track reporting deadlines, and providing training to personnel responsible for grant administration to ensure FFATA reports are submitted timely and accurately in SAM.gov. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 2 CFR 200.332, all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information listed in 2 CFR 200.332(a)(1) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: Subrecipient's name, Subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), Federal Award Date, Subaward Period of Performance Start and End Date, Subaward Budget Period Start and End Date, Amount of Federal Funds Obligated in the subaward, Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity, including the current financial obligation, Total Amount of the Federal Award committed to the subrecipient by the pass-through entity, Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA), Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity, Assistance Listings title and number, Identification of whether the Federal award is for research and development, Indirect cost rate for the Federal award (including if the de minimis rate is used). Per 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.332(f) pass-through entities must verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Per 2 CFR 200.332(e)(2), a pass-through entity must following-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. Single Audit findings referenced above are those resulting from audits required under 2 CFR 200.501. Condition: Subawards issued by the Kansas Department of Health and Environment (Department) did not include all required subaward information and failed to obtain the Unique Identity ID for all subawards. The Department did not obtain the required audit information (Single Audit or another applicable audit) from its subrecipient during the audit period. Questioned costs: None. Context: Twenty-five of thirty-four subawards selected for testing, totaling $11,685,599, did not include all required federal award information. Specifically, the following was omitted: • Subrecipient’s Unique Identifier - (Twenty-five of Thirty-four subawards) • Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity, including the current financial obligation – (Twenty-five of thirty-four subawards) • Identification of whether the award is research and development - (Twenty-five of Thirty-four subawards) • Indirect cost rate for federal award - (twenty-five of Thirty-four subawards) For two of the thirty-four subawards the Department failed to provide evidence that the Unique Entity ID was obtained. We were not provided with an audit report for one of the thirty-four subawards tested, totaling $680,010. Cause: The Department’s procedures were not sufficient to ensure that subawards included all required federal award information and obtain the required Unique Entity ID. Internal controls did not prevent or detect the errors. The Department did not have adequate procedures in place, or did not consistently implement existing procedures, to request, obtain, and track required subrecipient audit reports as part of its subrecipient monitoring process. Effect: Excluding the required federal award information at the time of subaward issuance could result in subrecipients not properly administering the federal programs in accordance with federal regulations. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports when all federal award information is not provided to them. Failure to obtain the subrecipient’s UEI resulted in incomplete subaward identification and increases the risk of ineffective subrecipient monitoring. Without obtaining and reviewing the subrecipient’s audit, the Department lacked reasonable assurance that audit findings, questioned costs, or instances of noncompliance affecting the subaward were identified and addressed. This increased the risk that Federal funds were not administered in accordance with applicable requirements. Repeat Finding: Yes, finding 2024-006. Recommendation: We recommend that the Department revise the subaward templates to include all required federal award information and update its procedures and internal controls to ensure that all required federal award information is included in subawards at the time of issuance. The Department should establish and implement formal subrecipient monitoring procedures to ensure required audit reports are requested, obtained, and reviewed in a timely manner. The Department should document its review of audit results and perform appropriate follow‑up on any identified deficiencies to ensure compliance with Federal requirements. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR 200.214 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person 2 CFR 200.303 requires that non-federal entities receiving federal awards establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Kansas Department of Health and Environment (Department) was unable to provide supporting documentation that it had performed suspension and debarment verification procedures before the start of procurement contracts. Questioned costs: None. Context: Sixty transactions were selected for testing which included twenty-five contracts and thirty-five subawards. For twenty-five of twenty-five contracts (100%), the Department was unable to provide documentation supporting when it had verified the contractors’ suspension and debarment status. The Department provided auditors with documentation that the contractors were not suspended or debarred, however, auditors were not able to verify that the status was documented prior to the start of the contracts. No exceptions were noted for the thirty-five subawards tested. Cause: The Department’s procedures and internal controls are not sufficient to ensure that it verifies and properly documents contractors’ suspension and debarment status prior to the execution of contracts. Effect: Failure to perform suspension and debarment verification procedures before the procurement of good or services could result in the payment of federal funds to contractors that are ineligible to participate in federal assistance programs. Repeat Finding: Yes, Finding 2024 - 007 Recommendation: We recommend that the Department enhances its procedures and internal controls to ensure that it verifies and maintains documentation of its contractors’ suspension and debarment status prior to the execution of all contracts. Verification can be performed by either checking SAM exclusions and maintaining documentation when the verification occurred, collecting a signed certification from the contractor prior to contract execution, or adding a clause or condition to the contract. We further recommend that documentation is readily available for audit. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 42 CFR part 442, providers must meet the prescribed health and safety standards for hospitals, nursing facilities, and ICF/IID. 2 CFR 200.303 requires that non-federal entities receiving federal awards establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Kansas Department of Health and Environment (Department) was unable to provide supporting documentation that it had performed recertification surveys within the required timeframe which is used to meet the provider health and safety standards. Questioned costs: Unable to determine. Context: Out of sixty providers selected for testing, the Department was unable to provide the recertification surveys for 26 providers. As such, we were unable to ensure that those 26 providers met the prescribed health and safety standards prior to the Department making payments to those providers. These exceptions resulted in an error rate of 43%. Cause: The Department’s procedures and internal controls were not operating effectively to ensure that recertification surveys were maintained by the Department. The Department had not completed implementation of its corrective action plan from the prior year. Effect: Compliance with the prescribed health and safety standards for this program is not being met. Providers who are not meeting the health and safety standards are still able to receive payments. Repeat Finding: Yes, Finding 2024-009. Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior year. We recommend the Department train all staff members to properly verify providers are meeting the prescribed health and safety standards before making payments to those providers and maintain all records of these verifications. Views of responsible officials: There is no disagreement with the audit finding. KDHE/Bureau of Facilities and Licensing (BFL) recognizes that documentation for twenty-six of the sixty providers was not provided. KDHE BFL operates as the State Survey Agency (SSA) under agreement with the Centers for Medicare and Medicaid Services pursuant to Section 1864 of the Social Security Act. Survey frequency and workload prioritization are governed by the annual CMS Mission and Priority Document (MPD), not by Medicaid payment cycles. KDHE BFL does not authorize, approve, or suspend Medicaid payments and does not function as a pre-payment verification entity. Health and safety oversight is accomplished through federally directed recertification surveys, complaint investigations, and CMS approved accreditation processes, consistent with the MPD and federal survey requirements. The MPD establishes a mandatory prioritization framework requiring SSA to complete Tier 1 and Tier 2 workload before initiating Tier 3 and Tier 4 activities. During the award period in question, the SSA allocated available survey resources in accordance with MPD directives, prioritizing Immediate Jeopardy investigations, high-priority complaints, enforcement follow-up, and other time-sensitive certification actions. Recertification surveys fall lower within lower-tier workload categories and may be deferred when higher-tier federally mandated priorities require resource allocations. The SSA’s survey scheduling decisions during the audit period were consistent with CMS directed workload prioritization requirements. During a recent internal review, the SSA identified several historical recertification surveys that remain in open status with the ASPEN/ACO system. In some instances, the surveys were completed and follow-up actions addressed; however, final administrative closure steps do not appear to have been fully finalized in the system. Other findings included revisit linkage or enforcement tracking was not fully reconciled or provider terminations or Change of Ownership (CHOW) process were not fully reconciled.

Criteria or specific requirement: Per 2 CFR 200.332, all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information listed in 2 CFR 200.332(a)(1) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Per 2 CFR 200.332(b), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes required award information. A pass-through entity must provide the best available information when some of the information below is unavailable. A pass-through entity must provide the unavailable information when it is obtained. Required information includes: Subrecipient's name, Subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), Federal Award Date, Subaward Period of Performance Start and End Date, Subaward Budget Period Start and End Date, Amount of Federal Funds Obligated in the subaward, Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity, including the current financial obligation, Total Amount of the Federal Award committed to the subrecipient by the pass-through entity, Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA), Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity, Assistance Listings title and number, Identification of whether the Federal award is for research and development, Indirect cost rate for the Federal award (including if the de minimis rate is used. Per 2 CFR 200.332(a), a pass-through entity must verify that the subrecipient is not excluded or disqualified in accordance with § 180.300. Verification methods are provided in § 180.300, which include confirming in SAM.gov that a potential subrecipient is not suspended, debarred, or otherwise excluded from receiving Federal funds. Per 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Subawards issued by the Kansas Department of Education and Kansas Department of Children and Families (Departments) did not include all required subaward information. Subawards underwent suspension and debarment verification from sam.gov but this process was not formally documented. Questioned costs: None. Context: Eleven of nineteen subawards selected for testing, totaling $991,788, did not include all required federal award information. Specifically, the following was omitted: • Federal Award Identification Number (FAIN) • Name of the Federal agency and contact information for awarding official of the pass-through entity • Assistance Listing Number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement • Identification of whether the award is research and development • In addition, for eleven of the eleven subawards tested, the Department did not maintain documentation evidencing that suspension and debarment verification was performed prior to issuing the subawards. Cause: The Department’s procedures were not sufficient to ensure that subawards included all required federal award information and that suspension and debarment verification was documented. Internal controls did not prevent or detect the errors. Effect: Excluding the required federal award information at the time of subaward issuance could result in subrecipients not properly administering the federal programs in accordance with federal regulations. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports when all federal award information is not provided to them. As a result of this condition, the federal awarding agency lacks full assurance that program funds were administered in compliance with federal requirements, including requirements related to vendor suspension and debarment. This condition limits the government’s ability to ensure proper oversight and stewardship of federal funds. Repeat Finding: No Recommendation: We recommend that the Departments develop a subaward template that includes all required federal award information and update its procedures and internal controls to ensure that all required federal award information is included in subawards at the time of issuance. We recommend that management enhance its procurement procedures to require and retain documented evidence that vendors are verified as not suspended or debarred prior to the award of contracts or payment of federal funds. Maintaining this documentation will help ensure compliance with federal requirements and support the government’s assurance that federal funds are expended only with eligible vendors. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. Per 2 CFR Part 170, “subaward” has the meaning given in 2 CFR 200.1 and means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $25,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§ 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Kansas Department of Children and Families (Department) was unable to provide FFATA reports for various subawards. Questioned costs: None. Context: During Reporting – FFATA testing the Department was unable to provide submitted FFATA reports for four of the 12 subaward transactions tested. Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 12 4 4 4 4 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 377,770 $377,770 $377,770 $377,770 $377,770 Cause: The Kansas Department of Children and Families (DCF) passed a portion of the award to the Kansas Department of Education (KSDE). The Kansas Department of Education (KSDE) passed the awards to other subrecipients located outside of the State of Kansas. At the time these subawards were issued, DCF was not aware that the subawards were subject to the Federal Funding Accountability and Transparency Act (FFATA) reporting requirements. As a result, DCF did not submit the required FFATA reports for the subawards passed through to these subrecipients. Effect: As a result of not submitting the required FFATA reports for subawards passed through to the Kansas Department of Education and other subrecipients located outside of the State of Kansas, the federal awarding agency did not receive complete and timely information regarding the use of federal funds. This resulted in noncompliance with FFATA reporting requirements and reduced transparency over federal subaward activity, which could limit federal oversight and monitoring of the program. Repeat Finding: No Recommendation: We recommend that the Kansas Department of Children and Families implement procedures to identify all subawards subject to Federal Funding Accountability and Transparency Act (FFATA) reporting requirements, including subawards passed through to both in‑state and out‑of‑state subrecipients. DCF should provide training to relevant staff on FFATA requirements and establish a review process to ensure required FFATA reports are submitted accurately and timely for all applicable subaward. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The entity did not have a documented control in place to evidence an independent review of the ACF‑199 TANF Data Report for accuracy and completeness prior to submission to the federal awarding agency. The report was generated from system data and submitted without documented supervisory review or approval before transmission. Questioned costs: None. Context: For two of the four ACF‑199 reports tested, the auditors were unable to obtain evidence that a documented review or approval of the report occurred prior to submission. No errors were identified in the reports tested, and the reports were system‑generated; however, the absence of documented review for a portion of the population tested indicates that the review control was not consistently applied. Cause: Management relied on the fact that the ACF‑199 report is generated from system‑based data extracts and did not implement a formalized review or approval process prior to submission. As a result, a specific control to review and approve the report before submission was not designed or documented. Effect: Without a documented pre‑submission review, there is an increased risk that errors or omissions in the ACF‑199 TANF Data Report may not be detected timely, which could result in the submission of inaccurate or incomplete information to the federal awarding agency. Repeat Finding: No Recommendation: We recommend that management design and implement a documented review and approval control over the ACF‑199 TANF Data Report prior to submission to the federal awarding agency. The control should include evidence of review to verify the accuracy and completeness of the report, such as documented supervisory sign‑off, electronic approval, or retention of review documentation. Implementing a consistent pre‑submission review process will strengthen internal controls over federal reporting and provide reasonable assurance of compliance with reporting requirements. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During test work of Activities Allowed or Unallowed & Allowable Costs/Cost Principles, one transaction was identified that lacked evidence that the transaction was reviewed. Questioned costs: None. Context: One of the forty transactions selected for testing, totaling $7,300, lacked evidence that the transaction was properly reviewed and approved. Cause: The Department was under a transition period between the legacy UI system and newly implemented system when this transaction occurred. The process of reviewing at the time had not been fully implemented within the new system. Effect: Not reviewing a transaction related to a federal expenditure increases the risk that the entity may be unaware of noncompliance with federal program requirements, such as unallowable costs or improper use of funds. This can result in questioned costs, the need to repay federal funds, or increased scrutiny from oversight agencies. Additionally, unresolved issues may affect the entity’s eligibility for future federal funding and require additional time and resources to address corrective actions, monitoring, or remediation efforts. Repeat Finding: No Recommendation: We recommend that the Department strengthen its review and monitoring procedures over federal expenditures to ensure that all transactions are appropriately reviewed for compliance with applicable federal program requirements. Management should implement controls to ensure transactions are adequately supported, reviewed in a timely manner, and documented, including supervisory review of expenditures charged to federal programs. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing of ETA – 191, Financial Status of UCFE/UCX one of the two reports tested lacked documentation that the report was reviewed prior to submission. Questioned costs: None. Context: One of the two ETA – 191, Financial Status of ECFE/UCX reports tested lacked documentation that the report was reviewed prior to submission. Cause: The Department lacked proper controls around the report to ensure that documentation was maintained to support that the report was reviewed for accuracy prior to submission. Effect: When evidence of review is not maintained, the Department lacks support that key oversight and approval controls were effectively performed. This increases the risk that errors, omissions, or noncompliance issues are not identified or addressed in a timely manner. In the absence of documented review, the Department may be unable to demonstrate compliance with internal control expectations to oversight agencies, which could result in increased scrutiny, additional monitoring requirements, or the need for corrective action. Repeat Finding: No Recommendation: We recommend that the Department formalize its review procedures by maintaining documented evidence of reviews for key reports related to federal programs. Management should establish clear documentation standards, such as reviewer sign‑off, date of review, and evidence of follow‑up on identified issues, to demonstrate that oversight controls are consistently performed. Views of responsible officials: There is no disagreement with the finding.

Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). States are required to submit periodic reporting to evaluate the performance of the state UI program. This includes the following reports: ETA 9050 – Time Lapse of All First Payments Except Workshare, ETA 9052 – Nonmonetary Determination Time Lapse Detections and the ETA 9055 – Appeals Case Aging – Lower and Higher Authority Appeals. Condition: During the audit period, the Department did not submit the ETA 9050, ETA 9052, and ETA 9055 reports accurately. Testing identified discrepancies between the data reported to the U.S. Department of Labor and the supporting underlying records, including variances within validation samples used to support reported figures. As a result, the reported information did not fully and accurately reflect program activity for the audit period. Questioned costs: None. Context: The U.S. Department of Labor requires states to submit accurate and complete Unemployment Insurance (UI) reports, including ETA 9050, ETA 9052, and ETA 9055. As part of the audit, eight ETA reports were tested, and discrepancies were identified in all eight reports tested. Cause: The condition occurred because the Department was in the process of implementing a new information system during the current year, which required the migration of historical and current‑year data. Management is continuing to identify and resolve data integrity issues associated with the system conversion, including differences within validation samples used to prepare the ETA reports. As a result, the Department is still working through data reconciliation and validation challenges related to the new system environment. Effect: As a result of the inaccurate submission of the ETA 9050, ETA 9052, and ETA 9055 reports, the U.S. Department of Labor may not have reliable information to assess the Department’s compliance with federal UI program requirements, including the timeliness and quality of nonmonetary determinations. Continued inaccuracies in required reporting could result in increased federal oversight and may impact future program evaluations or funding decisions. Repeat Finding: No Recommendation: We recommend that the Department continue efforts to strengthen controls over the preparation and review of ETA reports, including completing data reconciliation procedures related to the new system implementation. This should include validating migrated data, resolving discrepancies identified within validation samples, and implementing review procedures to ensure reported information is accurate, complete, and supported prior to submission to the U.S. Department of Labor. Views of responsible officials: There is no disagreement with the finding.

Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Kansas Department of Health and Environment (Department) submits quarterly workplan milestone progress reports; however, the reports provided are cumulative in nature and prior quarterly versions are not retained. As a result, auditors were unable to review progress and supporting information for each individual quarter, as only the most recent cumulative report was available. We were also unable to verify the dates that the quarterly performance reports were submitted. The Department prepares and submits quarterly workplan milestone progress reports and annual performance reports; however, documented evidence of supervisory or management review and approval of these reports prior to submission was not consistently maintained. As a result, the Department was unable to provide documentation demonstrating that the reports were reviewed for accuracy, completeness, or compliance with reporting requirements. Questioned costs: None. Context: During the audit, twenty-one quarterly workplan milestone progress reports were selected for testing; however, because the reports provided were cumulative and prior quarterly versions were not retained, we were able to test only four of the twenty-one reports and were unable to test the remaining twenty‑one reports. During the audit, twenty-one quarterly workplan milestone progress reports were selected for testing, and none included documentation evidencing review prior to submission. Additionally, five annual performance reports were tested; although the reports were available and appeared complete, the Department was unable to provide documentation demonstrating that they were formally reviewed prior to submission. Cause: The Department does not save or retain copies of the quarterly progress reports at the time they are submitted. Instead, reports are updated cumulatively each quarter, resulting in the loss of historical quarterly information. The Department does not have formalized procedures requiring documentation of supervisory or management review and approval for quarterly workplan milestone progress reports or annual performance reports. Although reports may be reviewed informally, the absence of standardized review and documentation procedures resulted in a lack of verifiable evidence that reports were reviewed prior to submission. Effect: Because individual quarterly reports were not retained, we were unable to verify progress, milestones, and reported information on a quarterly basis, which limits the ability to demonstrate compliance with reporting requirements and increases the risk that errors, omissions, or delays in milestone completion may not be detected timely. We were unable to verify whether the quarterly performance reports were submitted timely. Additionally, the absence of documented supervisory or management review for quarterly and annual performance reports limits the Department’s ability to demonstrate appropriate oversight and effective internal controls over performance reporting. Repeat Finding: No Recommendation: We recommend that the Department implement procedures to retain copies of each quarterly workplan milestone progress report at the time of submission. Maintaining discrete quarterly reports will improve documentation, support compliance with program requirements, and allow for effective monitoring and audit review of progress throughout the reporting period. In addition, we recommend that the Department implement formal procedures to document the review and approval of the quarterly and annual performance reports prior to submission. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: In accordance with 2 CFR §200.303, non-Federal entities must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is complying with Federal statutes, regulations, and the terms and conditions of Federal awards. In addition, the Adoption Assistance Title IV‑E program allows payment of nonrecurring adoption expenses on behalf of an eligible child. Program records must include adequate supporting documentation to substantiate the allowability and eligibility of such costs. Condition: During testing of eligibility requirements, it was noted that three participants out of forty tested did not have supporting documentation in their case files for nonrecurring adoption expenses paid on their behalf. Questioned costs: None. Context: The participants tested were determined to be eligible for the program; however, their case files did not contain complete documentation supporting the nonrecurring expenses component. Cause: Internal controls were not sufficient to identify and correct missing documentation for nonrecurring expenses prior to payment. Effect: Without adequate supporting documentation, nonrecurring expenses paid may have included costs that were not eligible under program requirements. Repeat Finding: No. Recommendation: We recommend that KDCF strengthen internal controls to ensure that supporting documentation for nonrecurring adoption expenses is obtained, reviewed, and retained prior to payment to mitigate the risk of noncompliance in the future. Views of responsible officials: There is no disagreement with the audit finding.