Barton County, Kansas

SIGNIFICANT DEFICIENCY 2024-001 10.855 – Distance Learning and Telemedicine Loans and Grants – Procurement, Suspension, and Debarment Criteria or specific requirement Procurement methods should follow the requirements laid out at 2 CFR 200.320. Noncompetitive procurement methods should only be used if one of the following circumstances applies: the aggregate amount of the procurement transaction does not exceed the micro-purchase threshold; the procurement transaction can only be fulfilled by a single source; the public exigency or emergency for the requirement will not permit a delay resulting from providing public notice of a competitive solicitation; the recipient or subrecipient requests in writing to use a noncompetitive procurement method, and the Federal agency or pass-through entity provides written approval; or, after soliciting several sources, competition is deemed inadequate. Condition The County used a noncompetitive procurement method without receiving written approval or meeting one of the other allowable circumstances for a procurement that was greater than a micro-purchase but less than the simplified acquisition threshold. Context The County’s procurement policy allows for noncompetitive procurements in specified circumstances, including when the procurement is for services from a provider with unique knowledge, skill, or ability not available from other sources; when the procurement is for goods and services where standardization is beneficial for reasons including maintenance, repair, training, and inoperability; and when the procurement is for goods and services where continuity of providers’ efficiency or critical knowledge is preferable and other providers of the goods and services cannot provide similar efficiency or critical knowledge. County staff felt that they had sufficiently met these three circumstances, and they used that justification to proceed with a noncompetitive procurement. Cause The County was following its procurement policy and did not note that there were some key differences between it and when noncompetitive procurements are allowable when using federal funding. Effect The County did not allow for full and open competition. Recommendation Whenever possible, we recommend that the County request written permission from the awarding agency if it seeks to use noncompetitive procurement methods for grants. We also recommend that the County consider updating its procurement policy to make it clear that the circumstances in which noncompetitive procurements can be used with federal assistance differ from normal circumstances. Views of responsible officials See corrective action plan.

2022-001 Federal program Coronavirus State and Local Fiscal Recovery Funds ? 21.027 Compliance requirements Activities allowed or unallowed, allowable costs/cost principles Criteria or specific requirement Internal controls should be in place to ensure that payroll amounts reimbursed by federal programs are properly calculated. Condition During testing, we identified errors in the calculation of the payroll amounts that were reimbursed by program funding. Context Two employees had the employer portion of their taxes and KPERS double-counted and reimbursed related to the premium pay that they received. An additional three employees showed minor variances between the amounts reimbursed and the actual amounts paid, due to data entry errors. Cause Errors stemmed either from human error during data entry or from mistakenly double-counting the employer portion of taxes and KPERS related to premium pay made using program funds. Effect In total, the program reimbursed other funds in error for $156. Recommendation We recommend the County review its controls to ensure that mistakes made during the calculation of expenditures for federal program reimbursement are caught and corrected in a timely manner. Views of responsible officials See Corrective Action Plan.

Federal program Coronavirus State and Local Fiscal Recovery Funds ? 21.027 Compliance requirements Reporting Criteria or specific requirement Internal controls should be in place to ensure that reports are completed accurately and submitted timely. Condition During review of the annual program reporting, it was noted that expenditures incurred and obligated projects were not properly noted. Context The Projects section of the report was not properly utilized to report all activities that the County had planned or undertaken throughout the reporting period. Cause Turnover occurred around the time of the reporting period, and as a result, there was some confusion about the reporting requirements. Effect Incorrect current period and total cumulative obligations and expenditures were reported to the Treasury. Recommendation We recommend the County review its grant reporting procedures and implement controls to ensure that grant reports are completed accurately and submitted timely. Views of responsible officials See Corrective Action Plan.

Federal program Epidemiology and Laboratory Capacity for Infectious Diseases - (ELC) 93.323 Compliance requirements Activities allowed or unallowed, allowable costs/cost principles Criteria or specific requirement Internal controls should be in place to ensure that payroll expenditures are properly calculated and paid out. Condition During testing, we identified errors in the calculation of the payroll hours paid out to the health department for payroll periods throughout the year. Of the 20 employees tested, 7 were improperly paid for a pay period tested, resulting in an overpayment of $1,053. Context When compared to the total population of applicable health department payroll expenses, the estimated overpayment is $5,230. Cause The health department requested that certain overtime hours be recorded as COVID-19 overtime hours for grant tracking purposes. However, those hours were mistakenly added instead of being reclassified. Effect The payroll amounts used to calculate the allocations between programs were incorrect, which resulted in an incorrect amount being reported to the awarding agency. Recommendation We recommend the County review its payroll controls to ensure that hours worked are properly paid out to employees. Views of responsible officials See Corrective Action Plan.

Federal program Epidemiology and Laboratory Capacity for Infectious Diseases - (ELC) 93.323 Compliance requirements Activities allowed or unallowed, allowable costs/cost principles, reporting Criteria or specific requirement Internal controls should be in place to ensure that grant expenditures are properly calculated and reports completed accurately. Condition During testing, we identified errors in the calculation of the payroll allocations for the health department grants. Of the 14 employees tested, 6 had entry errors either within the allocation calculation or within the report submitted to the awarding agency. There were both errors that resulted in too much being reported and errors that resulted in too little being reported, and the cumulative effect was $1,027 of program expenditures that were not claimed that could have been. Context Applicable employee payroll amounts are entered into a spreadsheet maintained by the health department, and that spreadsheet is used to calculate the amounts reported to the awarding agency. Any entry errors within the spreadsheet or within the reports submitted will result in an incorrect amount of funding being claimed. When compared to the total population of applicable health department payroll expenses, the estimated overpayment is $2,867. Cause Entry errors were the result of typos or an incorrect number being used. Effect Incorrect payroll expenditure amounts were reported to the awarding agency. Recommendation We recommend the County review its grant reporting controls to ensure that correct amounts are submitted. Views of responsible officials See Corrective Action Plan.

Criteria or specific requirement Internal controls should be in place to ensure that only allowable expenditures which are incurred during the period of performance are charged to the program. Condition During our fieldwork, we identified an error in the calculation of the payroll expenditure journal entry that was utilized to allocate payroll expenditures to the Coronavirus Relief Fund. Internal controls were not in place to prevent unallowable expenditures to be charged to the program. Context The County allocated payroll expenditures to the Coronavirus Relief Fund through two journal entries which were manually calculated using an Excel spreadsheet and various reports from the payroll system. Cause There was confusion on the County?s side regarding how this funding could be utilized due to lack of timeliness of information provided by the Treasury. Effect The allocation performed utilized data that included payroll expenditures incurred before the period of performance. Additionally, certain longevity wages were backed out of the calculation for determining the wage amount to record to CRF, but the related taxes were not backed out. Questioned costs The amount of unallowable expenditures is $65,100. Recommendation We recommend the County earmark allowable CRF expenditures incurred prior to March 1, 2021 to cover the unallowable expenditures reported in 2020. Views of responsible officials See Corrective Action Plan.