Wichita Area Metropolitan Planning Organization

CFDA#20.505: U.S. Department of Transportation, Passed Through Kansas Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research, All Open Grants Condition: Lack of proper approval for reporting. Criteria: Per 2 CFR 200.303(a) 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. Questioned Costs: Unknown. Context: During 2020, management implemented a process to include the monthly progress reports for the Unified Planning Work Program on the consent agenda of the Transportation Policy Board before being sent to the Kansas Department of Transportation. From a sample size of two (2) reports, there was one (1) instance without proper evidence of the review and approval process. This occurred prior to the implementation of the new approval process. Overall, the severity of this deficiency was reduced from the prior year due to implementation of proper approvals over expenditures, cash management and period of performance and the mid-year implementation of approvals for reporting. The sample sizes were determined based upon the guidelines provided by the AICPA which was not a statistically valid sample. Cause: Prior to December 2020, WAMPO had not yet put appropriate internal controls in place to ensure proper review and approval of reporting. Effect: Without proper review and approval there is potential for reporting to be inaccurate. Recommendation: Continue to include the monthly progress reports for the Unified Planning Work Program on the consent agenda of the Transportation Policy Board before being sent to the Kansas Department of Transportation. Management?s Response (Unaudited): An approval process is now in place for the UPWP reports. WAMPO staff determined this approval process by coordinating with KDOT staff. Quarterly UPWP reports will be presented at TPB meeting under Director?s report. These quarterly reports will include a breakdown by monthly activity of tasks that are programmed in UPWP. Contact Person: WAMPO Director Anticipated Correction Date: The new process has been in place for 2021.

Condition: General lack of proper internal controls on the approval process for expenditures, both non-payroll and payroll, cash management, period of performance and reporting. Criteria: Per 2 CFR 200.303(a) 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. Questioned Costs: Unknown. Context: 1) Expenditures: from of a sample size of 60 expenditures (23 non-payroll and 37 payroll), we found ten (10) instances of non-payroll expenditures without proper review and approval. We also found one (1) instance of payroll expenditures without proper review and approval and nine (9) instances where employees personnel files didn?t have support for current pay rate. 2) Cash management: from a sample size of three (3) drawdowns, there was one (1) instance without the proper review and approval for each drawdown before it was sent to the Kansas Department of Transportation. 3) Period of Performance: from a sample size of three (3) manual journal entries and nine (9) expenditure transactions, we identified four (4) instances of expenditures without proper documentation of review and approval. 4) Reporting: per WAMPO the Unified Planning Work Program is approved by the Executive Committee of the Transportation Policy Board before being sent to the Kansas Department of Transportation. From a sample size of 2 reports, there were 2 instances without proper evidence of the review and approval process. The sample sizes were determined based upon the guidelines provided by the AICPA which was not a statistically valid sample. Cause: WAMPO has not put internal controls in place to ensure proper review and approval of expenditures, cash management, period of performance or reporting. Effect: Without proper review and approval there is potential for charges to the federal award for expenditures to be inaccurate, unallowable and improperly allocated. Recommendation: Review internal controls and implement policies and procedures to ensure the proper review and approval over expenditures, cash management, period of performance and reporting. Also implementing procedures to make sure employee personnel files are complete and accurate to support employee master file data. Management?s Response (Unaudited): WAMPO invoices are approved by the Director before payment is submitted. This practice was implemented in late 2019 and will continue. The Director approves payroll prior to submission. Journal entries on behalf of WAMPO were being made by the City of Wichita. Effective September 2019, WAMPO had direct control of journal entries. The Director received verbal approval of UPWP grant funding prior to June 2019. Minutes from the UPWP approval will now be drawn up and signed by an Executive Committee member. Contact Person: WAMPO Director Anticipated Correction Date: The new process has been in place for 2020.

Condition: WAMPO was unable to provide appropriate documentation of the significant history of its procurements, including evidence that the relevant procurement policies were followed. Criteria: 2 CFR Part 200 of the Uniform Guidance requires that entities must use their own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in parts 2 CFR 200.318 through 200.326 of the Uniform Guidance. Questioned Costs: Unknown. Context: From a sample size of seven (7) transactions subject to procurement requirements, there were: ? Seven (7) instances in which contract files documenting the significant history of the procurement, including rational for the method of procurement and basis of contract price, could not be provided. As a result, no evidence that the procurement process provided for full and open competition and no evidence that the organization followed its own procurement policies was available for review. ? Five (5) instances in which evidence that the procurement method utilized was appropriate in the circumstances could not be provided. ? Four (4) instances in which a cost/ price analysis was required, but no evidence that the analysis was performed could be provided. ? Two (2) instances in which a contract was entered into which did not include all of the applicable provisions of Appendix II of 2 CFR 200. In addition, there was one (1) instance in which appropriate approval of the transaction could not be provided. The sample sizes were determined based upon the guidelines provided by the AICPA which was not a statistically valid sample. Effect: Without the appropriate internal controls in place, WAMPO could be in noncompliance of the procurement standards in 2 CFR section 200 of the Uniform Guidance. Recommendation: We recommend that the Board and management review their procurement policies and establish procedures to ensure that WAMPO is in compliance with the procurement standards set out in 2 CFR section 200 of the Uniform Guidance. Management?s Response (Unaudited): WAMPO had several procurements in 2019 where adequate documentation could not be located. Due to staff changes, the parties involved in the procurements were not available to assist in locating any additional documentation that they may have collected via email or other sources. Multiple searches of physical and electronic files did not produce the necessary supporting documents. The Employee and Operations Manual was approved in mid-2020 that further details the procurement process to avoid this issue going forward. With the assistance of a consultant, WAMPO is implementing a detailed process for procurements that includes a flowchart to make sure all requirements are followed. Contact Person: WAMPO Director Anticipated Correction Date: Employee and Operations Manual complete in 2020 and new process is currently being reviewed for final implementation.

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