EIN: 043783861
UEI: GF2KNMH55CJ6
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 13, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by April 13, 2026 (136 days ago).
What is a management decision? →2023-001 Financial Reporting on Indirect Costs Criteria: According to 2 CFR Part 200, a cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. The Organization recorded audit fees as direct and indirect costs. The Organization lacks controls and segregation of duties over the financial reporting of indirect costs. Condition and Context: The Organization listed the single audit fees on the final grant reports as direct costs. The single audit fees were recorded as indirect costs and not as direct costs to the grants in the Organization’s financial system, which resulted in an overallocation of audit fees as direct and indirect costs. With the audit fees included in direct costs, the Organization does not have enough indirect costs to cover what was claimed on their grant reports resulting in the Organization receiving more in federal funds than the Organization’s expenses. Cause: Indirect cost allocations were not reviewed for compliance and accuracy. Effect: The Organization did not have enough indirect costs to substantiate what was claimed on the grant reports as indirect costs. The granting agency subsequently approved the carryforward of the unused money to a future period. Recommendation: The Organization should develop a process to record indirect costs appropriately in the Organization’s financial system to avoid duplication and develop a review process for indirect costs to ensure sufficient expenses and accurate reporting. Management Response: Management agrees with finding. Procedures are being implemented to ensure an appropriate review process as well as a proper way of recording indirect costs, see attached corrective action plan.
Show full finding ▾Hide full finding ▴2023-001 Financial Reporting on Indirect Costs Criteria: According to 2 CFR Part 200, a cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. The Organization recorded audit fees as direct and indirect costs. The Organization lacks controls and segregation of duties over the financial reporting of indirect costs. Condition and Context: The Organization listed the single audit fees on the final grant reports as direct costs. The single audit fees were recorded as indirect costs and not as direct costs to the grants in the Organization’s financial system, which resulted in an overallocation of audit fees as direct and indirect costs. With the audit fees included in direct costs, the Organization does not have enough indirect costs to cover what was claimed on their grant reports resulting in the Organization receiving more in federal funds than the Organization’s expenses. Cause: Indirect cost allocations were not reviewed for compliance and accuracy. Effect: The Organization did not have enough indirect costs to substantiate what was claimed on the grant reports as indirect costs. The granting agency subsequently approved the carryforward of the unused money to a future period. Recommendation: The Organization should develop a process to record indirect costs appropriately in the Organization’s financial system to avoid duplication and develop a review process for indirect costs to ensure sufficient expenses and accurate reporting. Management Response: Management agrees with finding. Procedures are being implemented to ensure an appropriate review process as well as a proper way of recording indirect costs, see attached corrective action plan.
2023-001: Financial Reporting on Indirect Costs Responsible Party: Libby Albers, Executive Director Implementation Date: 1/29/2025 1. The KAWS WRAPS grants are multi-year grants. To date, KAWS has reported a flat indirect rate on each affidavit split evently across the reporting periods of the grant. With the additional reimbursement of the audit expenses in 2023, and loss of Assistant Director position, 2023 closed out with less administrative expenses than had been budgeted. 2. The Executive Director requested and received written acknowledgement from the Kansas Department of Health and Environment that the unexpected adminstrative income from 2023 could be applied to expenses incurred in 2024.
2023-002 Oversight over the Revenue Process Criteria: The Organization lacks controls and segregation of duties over the deposit process. Condition and Context: The deposits are primarily handled by one person with little oversight. Timing differences may occur between receipt of payment and deposit into the financial institution. Cause: There is not currently a review and/or reconciliation of the bank statement in comparison to the deposit log. Effect: Receipts could potentially be misappropriated. The financial records may not reflect the correct revenue and/or receivables for the period due to timing differences. Repeat Finding: Repeat finding of 2022-001. Recommendation: We recommend routine review and reconciliation of the bank statement to ensure all receipts are included and activity through the bank accounts appear to be in accordance with the activities of the Organization. Management Response: Management agrees with finding. Procedures are being implemented to ensure an appropriate review process, see attached corrective action plan.
Show full finding ▾Hide full finding ▴2023-002 Oversight over the Revenue Process Criteria: The Organization lacks controls and segregation of duties over the deposit process. Condition and Context: The deposits are primarily handled by one person with little oversight. Timing differences may occur between receipt of payment and deposit into the financial institution. Cause: There is not currently a review and/or reconciliation of the bank statement in comparison to the deposit log. Effect: Receipts could potentially be misappropriated. The financial records may not reflect the correct revenue and/or receivables for the period due to timing differences. Repeat Finding: Repeat finding of 2022-001. Recommendation: We recommend routine review and reconciliation of the bank statement to ensure all receipts are included and activity through the bank accounts appear to be in accordance with the activities of the Organization. Management Response: Management agrees with finding. Procedures are being implemented to ensure an appropriate review process, see attached corrective action plan.
2023-002: Oversight over the Revenue Process Responsible Party: Libby Albers, Executive Director Implementation Date: Originally 2/15/2024, revised to retroactively begin with the 1/1/2025 statement 1. KAWS Executive Director will continue to log deposits and deposit documentation in an internal spreadsheet and reporting each deposit to the KAWS accountant via email. The Conservation Easement Specialists will check the deposit spreadsheet against the monthly bank statement to ensure that all deposits are present. This extra reviewer of bank statements is independent of any of the parties handling the deposits. 2. The Executive Director will request a monthly reconciliation report from the independent accountant and the Conservation Easement Specialist will compare the data against the expense reporting platforms, payment requests, and bank statements. The Conservation Easement Specialists will provide an email response upon completion of the review of the statements.
2022-001
2023-003 Allowable Costs of Indirect Costs U.S. Environment Protection Agency Pass-Through from Kansas Department of Health and Environment No. 66.460 - 319 Program: Nonpoint Source Implementation Grants John Redmond Reservoir WRAPS Implementation SFY20-22, Milford WRAPS Implementation SFY20-22, and Upper Wakarusa WRAPS Implementation SFY20-22 Grant Period Year Ended December 31, 2023 Type of Finding: Internal Control/Noncompliance Criteria: According to 2 CFR Part 200, a cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. The Organization recorded audit fees as direct and indirect costs. Condition and Context: The Organization listed the single audit fees on the final grant reports as direct costs. The single audit fees were recorded as indirect costs and not as direct osts to the grants in the Organization’s financial system, which resulted in an overallocation of audit fees as direct and indirect costs. With the audit fees included in direct costs, the Organization does not have enough indirect costs to cover what was claimed on their grant reports resulting in the Organization receiving more in federal funds than the Organization’s expenses. Cause: Indirect cost allocations were not reviewed for compliance and accuracy. Effect: The Organization did not have enough indirect costs to substantiate what was claimed on the grant reports as indirect costs. The granting agency subsequently approved the carryforward of the unused money to a future period. Questioned Costs: The Organization recorded audit fees of $40,952 as direct and indirect costs to three federal grants. There is estimated additional over-allocated indirect costs of $8,800 that are not part of the major program. The reversal of the duplicate audit fees expenses were reversed and included in the audit journal entries. Recommendation: The Organization should develop a process to record indirect costs appropriately in the Organization’s financial system to avoid duplication and develop a review process for indirect costs to ensure sufficient expenses and accurate reporting. Management Response: Management agrees with finding. Procedures are being implemented to ensure an appropriate review process as well as a proper way of recording indirect costs, see attached corrective action plan.
Show full finding ▾Hide full finding ▴2023-003 Allowable Costs of Indirect Costs U.S. Environment Protection Agency Pass-Through from Kansas Department of Health and Environment No. 66.460 - 319 Program: Nonpoint Source Implementation Grants John Redmond Reservoir WRAPS Implementation SFY20-22, Milford WRAPS Implementation SFY20-22, and Upper Wakarusa WRAPS Implementation SFY20-22 Grant Period Year Ended December 31, 2023 Type of Finding: Internal Control/Noncompliance Criteria: According to 2 CFR Part 200, a cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. The Organization recorded audit fees as direct and indirect costs. Condition and Context: The Organization listed the single audit fees on the final grant reports as direct costs. The single audit fees were recorded as indirect costs and not as direct osts to the grants in the Organization’s financial system, which resulted in an overallocation of audit fees as direct and indirect costs. With the audit fees included in direct costs, the Organization does not have enough indirect costs to cover what was claimed on their grant reports resulting in the Organization receiving more in federal funds than the Organization’s expenses. Cause: Indirect cost allocations were not reviewed for compliance and accuracy. Effect: The Organization did not have enough indirect costs to substantiate what was claimed on the grant reports as indirect costs. The granting agency subsequently approved the carryforward of the unused money to a future period. Questioned Costs: The Organization recorded audit fees of $40,952 as direct and indirect costs to three federal grants. There is estimated additional over-allocated indirect costs of $8,800 that are not part of the major program. The reversal of the duplicate audit fees expenses were reversed and included in the audit journal entries. Recommendation: The Organization should develop a process to record indirect costs appropriately in the Organization’s financial system to avoid duplication and develop a review process for indirect costs to ensure sufficient expenses and accurate reporting. Management Response: Management agrees with finding. Procedures are being implemented to ensure an appropriate review process as well as a proper way of recording indirect costs, see attached corrective action plan.
2023-003: Allowable Costs of Indirect Costs Responsible Party: Libby Albers, Executive Director Implementation Date: 11/1/2025 The KAWS Executive Director requested reimbursements of audit expenses that included contractual invoices and billing for direct hours spent on the effort. However, the Director neglected to follow up with the independent account to transfer reimbursement of the personnel hours out of the grant and into the administrative project code. The KAWS Executive Director will request a P&L by job report from the accountant on an annual basis and again when a grant is closing to ensure that any costs recorded as direct or indirect administrative expenses have been moved to the administrative project code and out of the grant.
2023-004 Internal Control over Cash Management and Matching U.S. Environment Protection Agency Pass-Through from Kansas Department of Health and Environment No. 66.460 - 319 Program: Nonpoint Source Implementation Grants John Redmond Reservoir WRAPS Implementation 2022-2025, Fall River/Toronto WRAPS Implementation 2022-2025, R Michael Rhoades Community Wetlands Project, and Land and Water Preservation Through Conservation Easements Grant Period Year Ended December 31, 2023 Type of Finding: Internal Control Criteria: The Organization lacked consistent use of internal control procedures over cash management and matching. Condition and Context: The Organization had ten different WRAPS grants included in the major program during the year ended December 31, 2023. The Organization files Financial Status Reports quarterly for each grant. Two of the four quarterly WRAPS reports were tested for each grant open during the year. Of the ten WRAPS grants, two grants were not reviewed prior to submission to the granting agency for the third quarter. Two additional grants under the assistance listing number had no control over matching. Cause: Internal control procedures were not documented and applied consistently to ensure accurate reporting. Effect: Internal controls were lacking on four of the twelve grants, which could lead to improper reporting of grant expenses. Recommendation: The Organization should develop a written policy that includes an internal review of grant matching expenses and reports filed along with the related supporting documentation. Proper segregation of duties includes a person performing the process with oversight from another person. We recommend that another person review the expenses being claimed as matching expenses and review the reports prior to being filed with the state. Management Response: Management agrees with finding. Procedures are being implemented to ensure an appropriate review process, see attached corrective action plan.
Show full finding ▾Hide full finding ▴2023-004 Internal Control over Cash Management and Matching U.S. Environment Protection Agency Pass-Through from Kansas Department of Health and Environment No. 66.460 - 319 Program: Nonpoint Source Implementation Grants John Redmond Reservoir WRAPS Implementation 2022-2025, Fall River/Toronto WRAPS Implementation 2022-2025, R Michael Rhoades Community Wetlands Project, and Land and Water Preservation Through Conservation Easements Grant Period Year Ended December 31, 2023 Type of Finding: Internal Control Criteria: The Organization lacked consistent use of internal control procedures over cash management and matching. Condition and Context: The Organization had ten different WRAPS grants included in the major program during the year ended December 31, 2023. The Organization files Financial Status Reports quarterly for each grant. Two of the four quarterly WRAPS reports were tested for each grant open during the year. Of the ten WRAPS grants, two grants were not reviewed prior to submission to the granting agency for the third quarter. Two additional grants under the assistance listing number had no control over matching. Cause: Internal control procedures were not documented and applied consistently to ensure accurate reporting. Effect: Internal controls were lacking on four of the twelve grants, which could lead to improper reporting of grant expenses. Recommendation: The Organization should develop a written policy that includes an internal review of grant matching expenses and reports filed along with the related supporting documentation. Proper segregation of duties includes a person performing the process with oversight from another person. We recommend that another person review the expenses being claimed as matching expenses and review the reports prior to being filed with the state. Management Response: Management agrees with finding. Procedures are being implemented to ensure an appropriate review process, see attached corrective action plan.
2023-004: Internal Control over Cash Management and Matching Responsible Party: Libby Albers, Executive Director Implementation Date: 1/21/2025 The KAWS Executive Director sends drafts of every affidavit to six of the staff funded by EPA 31 grants. As additional grant projects came onboard, this effective review approach was not carried over through the new grants. This oversight was discussed during the audit and the same affidavit review process was applied to the other EPA 319 grant.
FAC accepted this audit on February 20, 2024 — management decision was due August 20, 2024.
Criteria: The QuickBooks file is maintained by an external accountant; a copy of the QuickBooks file is not provided to the Organization. The external accountant compiles the financial statements on a monthly basis for management. A breakout of the grants is not included in the compiled financial statements. Job reports are provided to management on an interim basis from QuickBooks for management to complete grant reporting. The Organization also lacks controls and segregation of duties over the deposit process. Condition and Context: While material variances were not ultimately noted during testing, discrepancies were found on multiple awards between the QuickBooks file and the filed reports. The QuickBooks data appears to have been changed subsequent to the reports being provided to management for grant reporting. The deposits are primarily handled by one person with little oversight. Timing differences may occur between receipt of payment and deposit into the financial institution. Effect: The grant reports filed did not match the expenses in QuickBooks, which could lead to incorrect filings and requests for reimbursement. Receipts could potentially be misappropriated. The financial records may not reflect the correct revenue and/or receivables for the period due to timing differences. Cause: Expenses were changed after a report was given to the Organization and amended grant reports were not filed. The QuickBooks data is not being reviewed by the Organization once a grant report is filed. The information provided to the Organization is only for the current period grant report. There is not currently a review and/or reconciliation of the bank statement in comparison to the deposit log. Recommendation: The Organization should review the information posted in QuickBooks for accurate reporting, which could include a Profit and Loss by Job report. Implementation of procedures to ensure the Organization is reviewing the QuickBooks data and looking over revenue and expenses for each grant. The QuickBooks file could be locked after month-end close to mitigate changes subsequent to information being provided to management. We recommend routine review and reconciliation of the bank statement to ensure all receipts are included and activity through the bank accounts appear to be in accordance with the activities of the Organization. Management Response: Management agrees with finding. Procedures are being implemented to ensure an appropriate review process, see attached corrective action plan.
Show full finding ▾Hide full finding ▴Criteria: The QuickBooks file is maintained by an external accountant; a copy of the QuickBooks file is not provided to the Organization. The external accountant compiles the financial statements on a monthly basis for management. A breakout of the grants is not included in the compiled financial statements. Job reports are provided to management on an interim basis from QuickBooks for management to complete grant reporting. The Organization also lacks controls and segregation of duties over the deposit process. Condition and Context: While material variances were not ultimately noted during testing, discrepancies were found on multiple awards between the QuickBooks file and the filed reports. The QuickBooks data appears to have been changed subsequent to the reports being provided to management for grant reporting. The deposits are primarily handled by one person with little oversight. Timing differences may occur between receipt of payment and deposit into the financial institution. Effect: The grant reports filed did not match the expenses in QuickBooks, which could lead to incorrect filings and requests for reimbursement. Receipts could potentially be misappropriated. The financial records may not reflect the correct revenue and/or receivables for the period due to timing differences. Cause: Expenses were changed after a report was given to the Organization and amended grant reports were not filed. The QuickBooks data is not being reviewed by the Organization once a grant report is filed. The information provided to the Organization is only for the current period grant report. There is not currently a review and/or reconciliation of the bank statement in comparison to the deposit log. Recommendation: The Organization should review the information posted in QuickBooks for accurate reporting, which could include a Profit and Loss by Job report. Implementation of procedures to ensure the Organization is reviewing the QuickBooks data and looking over revenue and expenses for each grant. The QuickBooks file could be locked after month-end close to mitigate changes subsequent to information being provided to management. We recommend routine review and reconciliation of the bank statement to ensure all receipts are included and activity through the bank accounts appear to be in accordance with the activities of the Organization. Management Response: Management agrees with finding. Procedures are being implemented to ensure an appropriate review process, see attached corrective action plan.
2022-001 Financial Reporting Oversight Responsible Party: Libby Albers, Executive Director Implementation Date: 2/15/2024 1. KAWS Executive Director, will continue to log deposits and deposit documentation in an internal spreadsheet and reporting each deposit to the KAWS Accountant via email. The Conservation Easement Specialist will check the deposit spreadsheet against the monthly bank statements to ensure that all deposits are present. This extra reviewer of bank statements is independent of any of the parties handling the deposits. 2. Executive Director will request quarterly Profit and Loss and Transaction reports by Job from the outsourced accountant, and compare the data against the expense reporting platforms, payment requests, and bank statements. 3. Executive Director will discuss the issue of reallocation of expenses being changed after quarterly reports have been provided and request that the outsourced accountant locks the Quickbooks data at the end of each month’s reconciliation. Should the data need to be unlocked the outsourced accountant will notify the Executive Director. Although this still places Quickbooks control with the accountant, it will create additional steps required of the accountant.
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