10.1 Effective Internal Controls

Lead Agencies must ensure the integrity of the use of CCDF funds through effective fiscal management and must ensure that financial practices are in place. Lead Agencies must have effective fiscal management practices in place for all CCDF expenditures. 10.1.1 Organizational structure to support integrity and internal controls Describe how the Lead Agency’s organizational structure ensures the oversight and implementation of effective internal controls that promote and support program integrity and accountability. Describe: SA 39-708 c(c) authorizes the Department for Children and Families to cooperate with the federal government to qualify for funds. KSA 39-709(b)(16) requires Kansas Department for Children and Families to adopt rules and regulations for the Child Care Subsidy Program. Kansas Department for Children and Families has been designated as the Lead Agency for CCDF funds. KSA 75-5316a authorizes the Secretary to organize the agency and appoint personnel, including division and regional directors. Program and policy activities have been delegated to the Economic and Employment Services (EES) Division. EES established policy regarding the use of CCDF funds including the issuance of Child Care Subsidy benefits. Child Care eligibility workers are located throughout the agency, but eligibility and other policy related to CCDF funding is established at the central administrative level of EES. There is frequent coordination of activities between EES Program personnel and fiscal staff. Budget staff monitors and communicates information regarding federal award allotments, availability of funds, fund balances, expiration of funds, etc. The Grants and Contracts staff work with program staff to establish grants and contract to be awarded ensuring adequate funds and in compliance with federal regulations, approval of invoices for payment, etc. The payables staff work with EES program staff to set up obligations, process payments following program review, reviewing for support documentation, etc. The Federal Reporting Unit prepares and submits required expenditure reports and claiming of funds. Budget staff are included in weekly meetings with EES Leadership. Frequent informal communications occur when determining the availability of funds, etc. Grants and Contracts staff have informal communications related to the receiving and processing of request for payments from contractors and grantees. Other communication is completed as necessary to ensure funds are being spent, spent correctly, to obtain additional information, etc. The processing of administrative expenditures and grant and contract payments are set up to ensure no one person can request, create, and make a payment. Different individuals request and approve payments. Entries are made into the accounting system are made by a different person. Obligations (purchase orders) separately from the person authorizing payments. Expenditure reports from the accounting system are provided no less than monthly and reviewed by budget staff to see what has been paid. As indicated above, duties have been segregated to reduce the risk of potential fraud. Administrative and grant and contract payment requests go through multiple persons before a payment is made. Payments can be questioned at any time during the processes of establishing an obligation (setting up the accounting system for a future payment to be made against), receiving the invoice information, and processing the payments. Additionally, after the fact actions include the review of the expenditures on reports and ledger documents by individuals who do not enter or process payments, such as program and budget staff. Interagency agreements with another state agency, such as KDHE, have the same review process, required support and internal controls as other contracts with external organizations and agencies. The assigned Grant and Contract Specialist works with the Program Manager, staff of the lead agency, to review financial reports submitted to ensure all expenditures are allowable, reasonable, and allocable to program. Line-item budgets are approved and tracked against expenditures throughout the award period. The state agency that has an interagency agreement is responsible for keeping detailed records and receipts for all expenditures and ensuring compliance with federal and state regulations. Payments are made by interfund transfer of funds between agencies which includes the same documentation as a Payables voucher. Payments are made based on actual expenditures submitted by interagency. Interfund payments are approved by both the depositing agency and payables agency to ensure the amount paid matches amount submitted for reimbursement. Interagency transactions are subject to internal audit process. Oversight of the work to be completed and monitoring of the performance indicators is completed by lead agency staff. Include the following elements in your description: 1. Assignment of authority and responsibilities related to program integrity. 2. Delegation of duties. 3. Coordination of activities. 4. Communication between fiscal and program staff. 5. Segregation of duties. 6. Establishment of checks and balances to identify potential fraud risks. 7. Other activities that support program integrity. 10.1.2 Fiscal management practices Describe how the Lead Agency ensures effective fiscal management practices for all CCDF expenditures, including: a. Fiscal oversight of CCDF funds, including grants and contracts. Describe: The Procurement Services Unit within the Operations Division with Kansas Department for Children and Families, the lead agency, coordinates and processes the procuring of goods and services through contracts and grants. They are responsible for making payments for all encumbered contracts and grants and ensuring they comply for all applicable statues, regulations, and policies. Prior to entering written agreements, the Lead Agency verifies the subrecipients' tax clearance, debarment status and FFATA (Federal Funding Accountability and Transparency Act) information. The specific work required by a grant must be completed in accordance with the scope of work specified in the notification of grant award and all required reports must be submitted to a designated Kansas Department for Children and Families staff member as agreed on. Written agreements include scope of work; services to be provided; performance measures; deliverables and reporting requirements. The status report, budget transaction report and budget itemization reports are reviewed by multiple Kansas Department for Children and Families staff for completeness and allowability. In addition to monthly financial reports, subrecipients are required to submit quarterly performance goals reports, quarterly outcome reports and annual quality performance reports. Site visits may occur by assigned Kansas Department for Children and Families staff and/or the Kansas Department for Children and Families internal audit services unit to ensure appropriate fiscal practices are being followed. Desk reviews, monthly calls and email communications are examples of other methods used for grant/contract oversight and monitoring. The grantee is responsible for obtaining an independent audit of any grant awarded by Kansas Department for Children and Families. All grantees are subject to federal and state audits. CCDF childcare benefits are authorized by Economic and Employment Services (EES) childcare staff via the KEES system. Workers identify whether authorized benefits are for TANF or non-TANF beneficiaries. Authorized benefits are loaded into the EBT system and beneficiaries are issued an EBT card, which the beneficiary then uses to expend the benefits. DCF receives daily reports detailing how the authorized benefits have been expended; benefits for TANF beneficiaries and non-TANF benefits are recorded in the SMART system with different program codes. At the beginning of each fiscal year, fiscal staff do estimates to determine how to fund TANF and Income Eligible Employed to hit the MOE, Match, and CCDF targets as closely as possible. TANF Childcare is funded state only at the beginning of the state fiscal year and applied to the MOE requirement; funding is changed to CCDF later in the state fiscal year after the MOE target is met. The funding for Income Eligible Employed Childcare is estimated to meet the required State Match, SSBG, CCDF Mandatory, and CCDF Discretionary Targets. Fiscal staff monitor the funding of Childcare benefits throughout the year to ensure progress toward these targets; funding will be changed if adjustments are needed to meet the targets. Finally, fiscal staff will process journal vouchers to make final adjustments needed to meet the targets. b. Tracking systems that ensure reasonable and allowable costs and allow for tracing of funds to a level of expenditure adequate to establish that such funds have not been used in violation of the provision of this part. Describe: Each grant/contract has its own file where copies of all payments processed, budget balances, the grant or agreement, and any important correspondence is stored. All grants/contracts are in an Access database. The database tracks Payments and purchase order balances are reconciled on a regular basis and then reconciled with our accounting system, SMART. Each agreement is tracked and monitored by fiscal year, specific information regarding the length of the term of the grant/contract, if there is a renewal option and address information. The use of various codes in the accounting system provide data for tracking expenditures applicable to CCDF funds. These include: program codes which identify a specific cost pool with like costs that are distributed and claimed in the same manner; fund and budget unit codes which identify a specific grant; account codes utilized by the state accounting system which identify the type of expenditure (i.e. salaries, benefits, travel, consumables, grants, assistance, equipment, etc.); department codes which link the program code to a specific agency unit responsible for oversight of the grant and related activity. Data from the state accounting system is accumulated on a quarterly basis for processing through the Cost Allocation Plan database. Various statistics are used to allocate the expenditures of program codes based on the approved Cost Allocation Plan. All costs are allocated to final receivers (i.e. federal grants or state-funded programs ￿ also described as cost objectives) for claiming purposes. Staff in the Federal Reporting unit utilize reports from the Cost Allocation Plan database to develop quarterly reports which are available to budget analysts and/or program staff responsible for a given program. CCDF funds are tracked by funds and budget units, but program codes are the primary mechanism through which expenditures are charged to funds and budget units. Each program code has funding assigned to it; as expenditures are recorded to program codes, expenditures are also recorded to funds and budget units, which triggers draws from the Federal award accounts. For example, the program code forChildcare Quality, is funded 100% with CCDF Discretionary Funds; expenditures recorded to the code will be included in a future draw from the Federal draw account for award 2x01KSCCDD. This same process is also true for program codes that aren’t 100% CCDF. For example, program code for Information Technology Services General, is funded 1.62% with CCDF Discretionary, which means that $1.62 of every $100 of expenditures is charged to CCDF Discretionary and will also be included in a future draw from the CCDF Discretionary award. To be clear, the 1.62% for IT is an estimate; each quarter we distribute the expenditures applying the actual time study and other stats that determine the results for the quarter, which calculates the actual CCDF Discretionary share. We then compare the actual share to the amount recorded as expenditures based on the 1.62% estimate and process a journal voucher to true up the expenditures and draws. DCF has used this same process for many years. Program codes are also the sources of expenditures input to the public assistance cost allocation plan application. Expenditures at program code level are pulled from SMART, the State accounting system, and input to the Cost Allocation Plan Access program. Each program code is assigned an allocation base in the CAP. For example, the allocation method for program code forChildcare Quality, is Direct to CCDF Discretionary 935750522.01. 935750522.01 is the final receiver (or cost objective); 93575 is the CCDF Discretionary CFDA (or ALN), 0522 is the budget unit, and .01 is an expander if needed (expanders are used for IV-E foster care, for example, to separately identify placement costs from administration costs). Constructing the final receivers in this fashion is the way we link the Cost Allocation Plan to SMART and to the Federal program. Because the allocation method for 25710 is direct to CCDF Discretionary, the Cost Allocation Plan will assign every dollar recorded in it to CCDF Discretionary, 935750522.01. The Cost Allocation Plan will also assign the CCDF Discretionary share of IT costs in program code 01351 to 935750522.01 based on the quarterly distribution. The PACAP reports enable us to track expenditures back to the program code where expenditures were recorded. This is true for expenditures assigned directly to CCDF Discretionary as 25710 is, or distributed to multiple Federal and State grants as 01351 is. c. Processes and procedures to prepare and submit required state and federal fiscal reporting. Describe: Federal funds are assigned a fund and budget unit identifying number based on the related CFDA number. Program codes are established to help identify revenue and expenditures by cost center. Program codes are funded by the applicable fund and budget unit. All expenditures are processed quarterly through the cost allocation plan based on the cost center (i.e. program code). Every program code has a cost allocation method to assign those costs to one or more ￿final receivers￿ which for federal funds is typically the grant award. Every grant has an excel file which contains quarterly updates based on the cost allocation reports. The file has various tabs as needed which step through the cost’s allocation reports to the federal and/or grant report. Reports are submitted quarterly or annually as required and in the applicable federal system or to the applicable awarding entity. d. Other. Describe: 10.1.3 Effectiveness of fiscal management practices Describe how the Lead Agency knows there are effective fiscal management practices in place for all CCDF expenditures, including: a. How the Lead Agency defines effective fiscal management practices. Describe: Kansas Department for Children and Families follows the fiscal management practices adopted by the State of Kansas which has governance over the agency. Fiscal management practices include having standard operating procedures and internal controls for accounting, financial reporting, budgeting, and other financial related activities. Kansas Department for Children and Families has internal policies and procedures that reference the State of Kansas procedures and enforce any federal regulations. These policies and procedures are in place and supported by management. b. How the Lead Agency measures and tracks results of their fiscal management practices. Describe: Program and Fiscal staff regularly monitor reports for each program including reports submitted by subrecipients to ensure compliance requirements are being met. There is management level review at significant trigger points throughout all programs such as applying penalties or terminating benefits for recipients. Periodic site visits may be performed, and audits are conducted. Any deficiencies within prescribed time frames identified in the audit are documented and corrective action plans developed if needed. c. How the results inform implementation. Describe: The results from audits and monitoring activities provide support of the effectiveness of these fiscal management practices and identify areas where additional efforts are needed. Implementation of any changes will be reviewed and then determined if additional modifications are needed by management. Results from monitoring activities have implemented the practice of requiring more supporting documentation for expenditures such as detailed general ledger transactions, copies of invoices, payroll reports and timesheets depending on award. Requiring supporting documentation has created a closer review from the grantee or contractor as well as Program Manager and Grant Contract Specialist. The ability to crosscheck between the manual reports submitted by grantee or contractor for reimbursement with the actual transactions posted to accounting system has provided more accurate reports since implementation. The detailed transactions allow reviewers to evaluate individual expenditures posted to request additional documentation if needed. d. Other. Describe: 10.1.4 Identifying risk Describe the processes the Lead Agency uses to identify risk in the CCDF program including: a. Each process used by the Lead Agency to identify risk (including entities responsible for implementing each process). Describe: Kansas Department for Children and Families has established Program Management, Operation, and Support departments to separate functions of the program to ensure checks and balances are in place to support the policies and procedures for the program. There are various processes Kansas Department for Children and Families has in place with regards to conducting risk assessment of our policies and procedures. The program management, operations, and support departments work independently and together to identify and assess areas at risk in their departments. Each department has a role in evaluating the issues they encounter within the program and presenting the issues in regular meetings which discuss and are related to program integrity and accountability with regards to any systems or software issues, training issues, cross program communications, collections, and procedures and process with regards to eligibility determinations and fraud. Various employees from each department attend groups which meet regularly to discuss, review, and revise such policies and processes related to program integrity and accountability. These groups include the Policy Planning Team, IPT, KAG, & PA Meeting. All these groups include elements of program integrity and accountability during discussions and are regular steps in the process of reviewing and revising policy. An additional step in policy revision includes KEESM Implementation calls. Policy changes can be initiated in many ways and there is process used to develop policy. As part of this process, the changes are discussed in various work groups and then there is an internal approval process. The Business Process Management team meets regularly to discuss process and procedural changes or possible improvements. The Child Care Provider Integrity Education and Support Unit attends the KEESM implementation calls for updates on policy revisions. In addition, the Child Care Provider Integrity Education Support Unit has regular monthly meetings to discuss any program issues and to share ideas for potential policy revision and changes related to program integrity and accountability. This unit also meets with the Child Care Enrollment Unit, Foster Care Child Care and Fraud Supervisors regularly, once a month to identify and discuss any policy or procedural issues to collaborate as well as to discuss any changes and updates which may affect their work and process with regards to program integrity and accountability. Various employees across the department in the units referenced receive the notifications regarding regulatory changes. Individuals overseeing these areas are knowledgeable of the program and the appropriate supervisions are in place to ensure Kansas Department for Children and Families is in compliance with applicable requirements. In addition, regular case reviews performed within the program at the eligibility level and audits of Kansas Department for Children and Families enrolled providers conducted by the Child Care Provider Integrity Education Support unit further detects potential risks. The identification of any process, policy or procedural issues are presented to the appropriate departments to further discuss prevention. The concurrence process is a review process that is used to assess for risk for grants and contracts. During the initiation of the award or Request for Proposal, a determination, using the Federal Funding Accountability and Transparency Act is made to classify the relationship with the lead agency as a vendor or subrecipient. The lead agency’s program staff makes the initial determination on the form. The lead agency’s audit team reviews the content of the agreement to make the determination of subrecipient or vendor. If program and audits agree, the agreement continues to proceed through the process until finalized. Another process to assess for risk is a certified public accountant review. For subrecipients only, they are tracked to ensure they submit an independent audit and associated management letters yearly. Once received, the lead agency’s audit team reviews these documents to determine any concerns which may impact lead agency or related funds. These concerns are communicated to the provider in writing and the lead agency regions, program staff, fiscal staff, and budget staff are all notified. If needed, a corrective action is required to include a written response. The lead agency also has a risk assessment process. These are completed yearly, and the final results are communicated with the lead agency program staff to include monitoring recommendations. Desk audits are completed on selected providers by the lead agency audit department. b. The frequency of each risk assessment. Describe: The program management, operations, and support departments work independently and together to identify and assess areas at risk in their departments. Each department has a role in evaluating the issues they encounter within the program and presenting the issues in regular meetings which discuss and are related to program integrity and accountability with regards to any systems or software issues, training issues, cross program communications, collections, and procedures and process with regards to eligibility determinations and fraud. The Data Analysts under Management Support reviews system generated data to identify any concerns or problematic inconsistencies. System generated data reports are sent regularly, monthly to the Kansas Department for Children and Families program managers to further assess any potential risks identified from these reports. The Child Care Provider Integrity Education Support Unit as well as the Child Care Enrollment unit receives regular reports from the Data Analyst team to review for any irregularities and potential fraud risks. In addition, the Child Care Provider Integrity Education and Support Unit attends the KEESM implementation calls for updates on policy revisions. The Child Care Provider Integrity Education Support Unit has regular monthly meetings to discuss any program issues and to share ideas for potential policy revision and changes related to program integrity and accountability. This unit also meets with the Child Care Enrollment Unit, Foster Care Child Care and Fraud Supervisors regularly, once a month to identify and discuss any policy or procedural issues to collaborate as well as to discuss any changes and updates which may affect their work and process with regards to program integrity and accountability. Various employees from each department attend groups which meet regularly to discuss, review, and revise such policies and processes related to program integrity and accountability. These groups include the Policy Planning Team, IPT, KAG, & PA Meeting. All these groups include elements of program integrity and accountability during discussions and are regular steps in the process of reviewing and revising policy. The Business Process Management team meets regularly to discuss process and procedural changes or possible improvements. In addition, regular case reviews performed within the program at the eligibility level and audits of Kansas Department for Children and Families enrolled providers conducted by the Child Care Provider Integrity Education Support unit further detects potential risks. The identification of any process, policy or procedural issues are presented to the appropriate departments to further discuss prevention. The concurrence process is a review process that is used to assess for risk for grants and contracts. It is completed during the initiation of the award or Request for Proposal and includes a determination, using the Federal Funding Accountability and Transparency Act, to classify the relationship with the lead agency as a vendor or subrecipient The certified public accountant review for subrecipients must be completed yearly. The lead agency’s formal risk assessment process is completed yearly. c. How the Lead Agency uses risk assessment results to inform program improvement. Describe: Supervisory case reviews are used to assess error trends and determine additional training needs. Supervisors and program improvement staff complete and record the results of case reads in the Case Review System (CARES), The data is available at the worker, unit, regional, or state level. The eligibility system, KEES, contains edits that prevent the authorization of excessive hours, prevent the overlap of plans for the same child at the same time, determines the hours to be authorized when schedules are entered to prevent and reduce errors. Warnings are also created when the system recognizes something that requires a closer look by the eligibility worker, like child care plans being created for a provider who is almost at capacity or when a child is on another child care program. Provider rates are automated to prevent incorrect rates from being entered on the child care plan. System rules streamline the application of many of the child care policies based on data that is entered by eligibility workers. Data matches are used with Kansas wage and unemployment compensation and Social Security Administration to assist with verifying or identifying income. Eligibility workers also verify various child care eligibility factors, such as employment, income, citizenship, age, residency, etc.) through access to child support services, vital statistics, food assistance program information, Cash Assistance program information, the work number, and the Systematic Alien Verification for Entitlements Program. Fraud Navigator is a tool accessed through the EBT system to monitor real- time transactions including child care payments for suspicious payment activity, such as excessive transaction amounts. Discussions regarding error trends and discrepancies are discussed during the Policy Planning Team, IPT, KAG, & PA Meeting. All these groups include elements of program integrity and accountability during discussions. In addition, if policy changes are necessary for program improvement, the discussion is had within KEESM Implementation calls. Policy changes can be initiated in many ways and there is process used to develop policy. As part of this process, the changes are discussed in various work groups and then there is an internal approval process. The Business Process Management team meets regularly to discuss process and procedural changes or possible improvements. The Child Care Provider Integrity Education and Support Unit attends the KEESM implementation calls for updates on policy revisions. In addition, the Child Care Provider Integrity Education Support Unit has regular monthly meetings to discuss any program issues and to share ideas for potential policy revision and changes related to program integrity and accountability. This unit also meets with the Child Care Enrollment Unit, Foster Care Child Care and Fraud Supervisors regularly, once a month to identify and discuss any policy or procedural issues to collaborate as well as to discuss any changes and updates which may affect their work and process with regards to program integrity and accountability. Various employees across the department in the units referenced receive the notifications regarding regulatory changes. Individuals overseeing these areas are knowledgeable of the program and the appropriate supervisions are in place to ensure Kansas Department for Children and Families is in compliance with applicable requirements. In addition, case reviews performed within the program at the eligibility level and audits of Kansas Department for Children and Families enrolled providers conducted by the Child Care Provider Integrity Education Support unit further detects potential risks. The identification of any process, policy or procedural issues are presented to the appropriate departments to further discuss prevention. Risk assessments are completed yearly, and the results are communicated to the program director. It identifies those which are high, medium and low risk and provides guidance on additional monitoring for those rated in each of these categories, respectively. DCF Audits may identify those which are high or upper medium risk for possible desk audit. If a desk audit is found to be necessary, DCF Audits completes the desk audit on the provider. If a risk is identified, it is presented to the appropriate department program director. There is no more follow-up once those are submitted to each program director. If the program director finds it necessary, they would bring the discovered issue for discussion at one of the many groups developed to review, discuss and revise policies and/or processes related to program integrity and accountability. d. How the Lead Agency knows that the risk assessment processes utilized are effective. Describe: Regular supervisory case reviews are used to assess error trends and determine additional training needs. Supervisors and program improvement staff complete and record the results of case reads in the Case Review System (CARES), The data is available at the worker, unit, regional, or state level. In addition, the Child Care Provider Integrity Education Support unit reviews child care eligibility cases when conducting a child care provider audit. The Child Care Provider Integrity Education Support unit identifies any error trends or inconsistencies and reports them to the child care program and policy managers for prevention and further discussions for training or program improvements. These case reviews performed within the program at the eligibility level and the audits of Kansas Department for Children and Families enrolled providers not only assist in detecting potential risks and assisting with the discussion for prevention, but they also allow the state to identify areas of potential weaknesses to allow further discussions for training or program improvements. Risk assessments are completed yearly, and the results are communicated to the program director. It identifies those which are high, medium, and low risk and provides guidance on additional monitoring for those rated in each of these categories, respectively. DCF Audits may identify those which are high or upper medium risk for possible desk audit. If a desk audit is found to be necessary, DCF Audits completes the desk audit on the provider. If a risk is identified, it is presented to the appropriate department program director. There is no more follow-up once those are submitted to each program director. If the program director finds it necessary, they would bring the discovered issue for discussion at one of the many groups developed to review, discuss and revise policies and/or processes related to program integrity and accountability. The Program Director oversees the Program Administrators, Performance Improvement and Eligibility staff to ensure regular case reviews are completed to continue assessing trends to identify whether processes and policies implemented are effective in deterring risk. e. Other. Describe: 10.1.5 Processes to train about CCDF requirements and program integrity Describe the processes the Lead Agency uses to train staff of the Lead Agency and other agencies engaged in the administration of CCDF, and child care providers about program requirements and integrity. a. Describe how the Lead Agency ensures that all staff who administer the CCDF program (including through MOUs, grants, and contracts) are informed and trained regarding program requirements and integrity. i. Describe the training provided to staff members around CCDF program requirements and program integrity: Each time a policy change takes place, the new information is posted in the Kansas Economic & Employment Services Manual that is available to both agency staff and the general public on the agency’s web sites. Summaries of all policy changes made are also posted on the web page that houses the manual. That manual can be viewed at http://content.dcf.ks.gov/EES/KEESM/Keesm.htm. Prior to the effective date of the changes, that information is shared with the lead agency’s eligibility staff via the summaries of changes, implementation memos and training calls. Depending on the policy that is being changed, there may be a press release or other announcement made. If it is expected that a policy change could have a significant impact on them, a letter could be sent to providers and others. When needed, information about the changes are shared with our partners at various meetings that are attended by agency staff. Information may also be posted on the Kansas Department for Children and Families Website of the CCDF Consumer Education Website, Child Care in Kansas. The Child Care Provider Integrity Education and Support Unit is also kept up to date on child care policies. They have regular monthly meetings to discuss policy changes, program issues and to share ideas for potential policy revision and changes related to program integrity and accountability. This unit also meets with the Child Care Enrollment Unit, the Foster Care Child Care Unit and the fraud unit on a regular basis to discuss any changes and updates in policies or process which may affect their work and process with regards to program integrity and accountability. The Child Care Provider Integrity Education and Support Unit staff are required to take the following trainings which include, but are not limited to, KEES overview training, the child care training course, EBT edge system and process, as well as various trainings on tools and techniques for audit interviewing, interviewing, documentation, fraud. They are also required to take the KCCTO training on the Kansas Department for Children and Families Child Care Subsidy Program. The Child Care Provider Integrity Education and Support Unit also take interviewing, fraud trainings, financial investigation trainings from (NW3C) National White-Collar Crime Center which provides a nationwide support system for law enforcement and regulatory agencies tasked with the prevention, investigation, and prosecution of economic and high-tech crime. The unit also continuously seeks and takes relevant trainings or courses offered by outside agencies, including investigation, welfare fraud or Anti-Fraud agencies to further educate them on federal policies with regards to welfare, fraud, and investigations. Agencies and organizations receiving funds through grants or contracts with the lead agency are provided links to sites within their award document. A representative of Grantee must complete the lead agency’s mandatory grant training before agency submits first reimbursement request. One person from Grantee, preferably the Project Director (person managing the grant), must review the Grantee Resources found at http://www.dcf.ks.gov/Agency/Operations/Pages/Grantee-Resources.aspx and complete the online training found at https://www.surveymonkey.com/s/2JHMZXX. The training certificate received at completion of the training must be submitted along with the Grantee Agencies and organizations first submitted Budget Transaction, Budget Itemization and Status reports. Grant and Contract Specialist works with Program Manager to provide one-on-one training for grantee or contractor. ii. Describe how staff training is evaluated for effectiveness: When information is shared with the lead agency’s eligibility staff via the summaries of changes, implementation memos and training calls, there are opportunities for questions to be asked and clarification is given. These changes are also frequently shared by the field during meetings they have in the mornings and staff can ask clarifying questions at that time, which are answered by the field administration or by centralized policy staff. Verbal feedback is requested for any grantee trainings. There are no formal written evaluation of grantee trainings. iii. Describe how the Lead Agency uses program integrity data (e.g., error rate results, risk assessment data) to inform ongoing staff training needs: Supervisory case reviews are used to assess error trends and determine additional training needs. Supervisors and program improvement staff complete and record the results of case reads in the Case Review System (CARES), The data is available at the worker, unit, regional, or state level. Regular case reads determine whether eligibility and provider enrollment cases are processed accurately. Case Reads are completed by using the CARES system which assists supervisor and management staff conduct payment and case management/process errors. This CARES system keeps track of the errors and corrections for management staff. Random audits and red flag audits are completed for child care providers are completed to ensure they are complying with policies and if further education is necessary for the provider or whether additional training is required for staff. In addition, the Child Care Provider Integrity Education Support unit reviews child care eligibility cases when conducting a child care provider audit. The Child Care Provider Integrity Education Support unit identifies any error trends or inconsistencies and reports them to the child care program and policy managers for prevention and further discussions for training or program improvements. The Child Care Provider Integrity Education Support unit utilizes the ACF403 as a guide when identifying errors and trends to further assist the program with training needs. b. Describe how the Lead Agency ensures all providers for children receiving CCDF funds are informed and trained regarding CCDF program requirements and program integrity: i. Describe the training for providers around CCDF program requirements and program integrity: Regular case reads determine whether eligibility and provider enrollment cases are processed accurately. Case Reads are completed by using the CARES system which assists supervisor and management staff conduct payment and case management/process errors. This CARES system keeps track of the errors and corrections for management staff. Child Care providers enrolling with Kansas Department for Children and Families are required to complete the ￿Supporting Kansas Families: Kansas Department for Children and Families Child Care Subsidy Program￿ through the Kansas Child Care Training Opportunities as an initial part of their application process. This program provides education with regards to program requirements. Child care providers are given access to the Kansas Department for Children and Families Child Care handbook to review and are required to sign off prior to their enrollment they had reviewed and understood the program policies and regulations. Random audits and red flag audits are completed for child care providers are completed to ensure they are complying with policies and if further education is necessary for the provider or whether additional training is required for staff. The Child Care Provider Integrity Education and Support unit completes facility site visits to enrolled providers to further provide education and understanding of program requirements and program integrity. During a site visit, the Child Care Provider Integrity Education and Support unit reviews the providers business records and procedures to ensure they are in compliance with Kansas Department for Children and Families provider policies. The Child Care Provider Integrity Education and Support unit provides education, support and assistance with regards to questions and issues surrounding program integrity, procedures, policies and regulations. ii. Describe how provider training is evaluated for effectiveness: The Child Care Provider Integrity Education and Support Unit completes facility site visits to review provider records and procedures to ensure they are complying. After the initial site visit, the Child Care Provider Integrity Education Support unit completes a follow up site visit to ensure any discrepancies identified at the initial visit have been corrected. If further support and education is required, Child Care Provider Integrity Education Support continues to provide follow up and education until discrepancies are no longer discovered. During the site visit education is provided regarding best practices for business records and program integrity is discussed. Effectiveness of this education is evaluated by the increased volume of contact Child Care Provider Integrity Education Support unit receives from the providers requesting further clarification or assistance on policies, procedures, and education. Furthermore, the increased amount of provider refunds being sent in validate the effectiveness from the education; enrolled providers voluntarily returning subsidies that are not owed to them to return to the parent and/or Kansas Department for Children and Families. In addition, regular case reads determine whether eligibility and provider enrollment cases are processed accurately. Case Reads are completed by using the CARES system which assists supervisor and management staff conduct payment and case management/process errors. This CARES system keeps track of the errors and corrections for management staff. Random audits and red flag audits are completed for child care providers are completed to ensure they are complying with policies and if further education is necessary for the provider or whether additional training is required for staff. iii. Describe how the Lead Agency uses program integrity data (e.g., error rate results, risk assessment data) to inform ongoing provider training needs: Program Integrity data not only consists of the data reports consists of case reviews from facility site visits, the triennial error rate review as well as child care eligibility and child care enrollment supervisory case reviews utilizing the CARES system; these data identify error trends or inconsistencies for prevention and further discussions for training or program improvements. 10.1.6 Evaluate internal control activities Describe how the Lead Agency uses the following to regularly evaluate the effectiveness of Lead Agency internal control activities for all CCDF expenditures. a. Error rate review triennial report results (if applicable). Describe who this information is shared with and how the Lead Agency uses the information to evaluate the effectiveness of its internal controls: The triennial report is completed by the Child Care Provider Integrity Education Support unit. The information is shared with the Office of Child Care as well as the Kansas Department for Children and Families Child care program and policy manager as well as Kansas Department for Children and Families leadership. Random case reviews are conducted to review child care eligibility cases as well as child care enrollment provider files to determine whether the cases are processed accurately with regards to the elements and factors as given by the Office of Child Care. The reviews assist in identifying any error trends within program eligibility and child care enrollment. These trends are shared with program staff as well as the program and policy manager. If internal errors are discovered, child care program and policy manager is notified to further assess for corrections or additional training. In addition, the Child Care Provider Integrity Education Support unit utilizes the ACF403 as a guide when identifying errors and trends to further assist the program with training needs. b. Audit results. Describe who this information is shared with and how the Lead Agency uses the information to evaluate the effectiveness of its internal controls: Internal controls consist of Supervisors and management staff conducting random, regular case reads for the child care program to determine whether eligibility and provider enrollment cases are processed accurately. Case Reads are completed by using the CARES system which assists supervisor and management staff conduct payment and case management/process errors. This CARES system keeps track of the errors and corrections for management staff. Random audits for child care providers are completed to ensure they are complying with policies. The Child Care Provider Integrity, Education and Integrity Support Unit conducts site visits on red flag providers to ensure they are complying with all Kansas Department for Children and Families policies and assess the provider for any questionable activity or fraud for further investigation. When an audit is completed, provider enrollment files are reviewed first by staff to ensure all of the information gathered at application/review for the providers is accurate and up to date. Child Care Provider Integrity staff also reviews child care recipient cases when they audit providers to ensure plans are processed and written correctly by eligibility staff. During the audit, if internal errors are discovered than the supervisor/staff is notified to further assess the errors for corrections. The Child Care Provider Integrity Education Support unit utilizes the ACF403 as a guide when identifying errors and trends to further assist the program with training needs. In addition, the agency has a Kansas Department for Children and Families Audit department for internal controls pertaining to subrecipients and compliance. Kansas Department for Children and Families Audits may identify those which are high or upper medium risk for possible desk audit. If a desk audit is found to be necessary, Kansas Department for Children and Families Audits completes the desk audit on the provider. If a risk is identified, it is presented to the appropriate department program director. There is no more follow-up once those are submitted to each program director. If the program director finds it necessary, they would bring the discovered issue for discussion at one of the many groups developed to review, discuss and revise policies and/or processes related to program integrity and accountability. c. Other. Describe who this information is shared with and how the Lead Agency uses the information to evaluate the effectiveness of its internal controls: 10.1.7 Identified weaknesses in internal controls Has the Lead Agency or other entity identified any weaknesses in its internal controls? a. [ ] No. If no, describe when and how it was most recently determined that there were no weaknesses in the Lead Agency’s internal controls. b. [x] Yes. If yes, what were the indicators? How did you use the information to strengthen your internal controls? No internal weaknesses were identified as part of the financial audits and audits of the agreements relating to the use of CCDF funding in the SFY2023 Single Audit. Based on the triennial report results, inconsistencies were found in processing child care eligibility cases. It was discovered there were various interpretations with regards to process and policy knowledge. With regards to child care eligibility cases, supervisory case reviews will be completed on a more regular basis, utilizing the Case Action Review system (CAREs) to discover these inconsistencies. Kansas is in the process of upgrading the CARE system to include the elements used in the triennial report to assist in identifying weaknesses. The agency will continue to do the policy meetings/trainings, review reports and results of case reads, and analyzing for any additional training needs for staff. With regards to system identified weaknesses; when reviewing these Kansas Eligibility Enforcement System (KEES) generated reports, system defects may be discovered, which need to be fixed or errors are found which result in further investigation to determine whether additional staff training is necessary, or if changes in the system are necessary to support policy changes.