Follow Up Audit: Reviewing Agencies’ Implementation of Selected Performance Audit Recommendations

Introduction

The Legislative Post Audit Committee’s rules include a process to check on prior audit recommendations. That process has two primary components. First, the Post Auditor is required to follow up with each agency twice a year and have officials self-report on their progress in implementing recommendations. Second, the Post Auditor is required to prepare an audit proposal each year that lists “previous audit recommendations for which follow up audit work is necessary to independently ascertain whether such agency or other entity has implemented audit recommendations.”

On April 24, 2024, the Legislative Post Audit Committee approved the proposal staff prepared for that purpose. The proposal included 6 recommendations from 3 of our prior audits. The recommendations were for the Kansas Department for Children and Families, the Department for Aging and Disability Services, and the Kansas State Department of Education.

Objectives, Scope, & Methodology

Our audit objective was to answer the following question:

1. To what extent have agencies implemented selected audit recommendations from performance audits issued in recent years?

To determine if the agencies implemented the recommendations, we reviewed original audit work, interviewed agency officials, and requested and reviewed agency documentation of implemented changes. Documentation included written policies and procedures, contracts, reporting forms, internal agency correspondence, and case reviews conducted by agency staff.

We only did what was necessary to evaluate whether the agencies implemented the recommendations. We did not reevaluate the programs or problems found in the original audit. We also did not evaluate the effectiveness of the changes. For example, we reviewed whether an agency developed written guidance, but we did not evaluate how well the agency implemented the guidance or whether it produced the intended result. Therefore, a finding that a recommendation was implemented does not mean that the agencies completely fixed any underlying problems.

More specific details about the scope of our work and the methods we used are included throughout the report as appropriate.

Important Disclosures

We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. Overall, we believe the evidence obtained provides a reasonable basis for our findings and conclusions based on those audit objectives.

The 3 agencies implemented 3 of the 6 recommendations we reviewed for this audit.

The Kansas Department for Children and Families (DCF) and Department for Aging and Disability Services (KDADS) implemented 2 of the 4 recommendations from our 2022 audit of foster care services.

In March 2022, we published an audit evaluating the adequacy of DCF’s policies and procedures for ensuring the safety of children in foster care and whether case management providers had the capacity to provide necessary services.

• The audit, Reviewing Foster Care Services for the Health and Safety of Children found that although DCF generally had adequate written policies, DCF and case management providers’ practices were not adequate to ensure the safety of children in foster care in several areas. The audit also found that the state does not have the capacity to provide services to all children in foster care, especially those with specialized service needs. Several findings contributed to these conclusions, including:

• To address these findings, we made 4 recommendations that we followed up on in this audit. 3 of these recommendations were directed at DCF and one recommendation was directed at both DCF and KDADS. We had a fifth recommendation for DCF to consider conducting a staffing study to determine caseloads, but we did not follow up on that recommendation in this audit. That’s because DCF reported they had sufficient guidance on caseloads from national accrediting organizations and therefore did not need to conduct a separate staffing study.

As of April 2025, DCF and KDADS implemented 2 of the 4 recommendations.

• We spoke with agency staff and requested and reviewed documentation to verify DCF’s and KDADS’s implementation of the 4 recommendations from our 2022 audit. Those documents included written policies and procedures, contracts with case management providers, and copies of training presentations for DCF, KDADS, community mental health center, and case management provider staff. It also included reviewing inter-agency correspondence and planning documents, statewide performance assessments, and quality assurance reports. We also spoke with DCF officials to further understand how to interpret the documentation provided.

• Figure 1 shows our results.

Figure 1. DCF and KDADS implemented 2 of the 4 recommendations and DCF partially implemented the other 2.
Recommendation	Status	Summary
DCF, KDADS, and other partners should develop clear protocols and guidance for services, including timeliness standards for assessments and communication with service providers.	Implemented	DCF added a “mental health service workflow” to their policy manual and KDADS added it to their contracts with community mental health centers. This workflow includes who to contact, when, and what the next steps are when a mental health or behavioral health need is identified.
		KDADS and DCF developed a form that tracks dates of community mental health center services and assessments administered that they told us is shared between agencies.
		Finally, DCF and KDADS amended community mental health center contracts to require that children in need of care must be contacted and receive an initial evaluation within one business day and be scheduled to receive the services identified through that evaluation within 10 business days. They designated separate phone lines and email addresses for each community mental health center that foster care stakeholders use when seeking community mental health services.
DCF should consider conducting a service capacity study to determine what services are most needed in the system and how best to increase capacity.	Implemented	DCF considered assessing service capacity needs through its pre-existing case review process to meet federal requirements.
		The case reviews addressed some of the capacity concerns LPA raised in our 2022 audit. For example, DCF’s case reviews included an assessment of the array of services available to children and families in the foster care system including things like mental health, behavioral health, and substance use services. They also covered areas of improvement (e.g., caseworker turnover or long waitlists for services) and plans for how to improve those areas.
DCF should establish clear oversight expectations with their case management providers. This includes corrective actions and using performance data to identify systemic issues.	Partially Implemented	DCF conducted quality assurance checks by interviewing children and placement providers about their experiences with case managers. DCF used this to compile accountability reports and help identify systemic issues.
		However, DCF’s oversight expectations for case management providers, including their established corrective actions, have not substantively changed since our 2022 review.
DCF should ensure the Comprehensive Child Welfare Case Management System they are developing has several key features, including a robust comprehensive case management system; the ability to track services children need and are receiving; provide direct access to case management staff; a way to uniformly access customer service complaints and resolutions; and have clear data quality control measures.	Partially Implemented	DCF’s Comprehensive Child Welfare Information System (CCWIS) is not yet developed. Officials told us development begins when a contract is awarded to a vendor. They said they couldn’t provide the estimated timeline for this implementation because it’s currently going through the state’s RFP process.
		However, DCF provided documentation of plans that detail what current reporting looks like, their associated problems, and how they intend to address those problems through the CCWIS. The features outlined in DCF’s plans include many of the items suggested in LPA’s recommendation.
Source: LPA review of relevant documents
Kansas Legislative Division of Post Audit

The Kansas State Department of Education (KSDE) implemented the recommendation from our 2022 limited-scope audit of social workers employed by school districts.

In April 2022, we published a limited-scope audit evaluating trends in social workers employed by school districts.

• The audit, Trends in Social Workers Employed by School Districts, evaluated how the number of social workers employed by school districts had changed since the establishment of the Mental Health Intervention Team Program. The audit found that the number of licensed social workers employed by school districts in Kansas had increased since the program’s establishment from school year 2019 to 2022.

• However, the 5 school districts we reviewed in the audit didn’t report social worker FTE consistently to KSDE. Specifically, we found 2 main issues with how districts reported their staff:

1. Some school districts reported their social worker staff FTE based on license, while others reported based on role. For example, if a licensed social worker held a position as a school counselor, some districts reported this staff FTE as a licensed social worker, while others reported them as a counselor.
2. Some of the districts we talked to during the 2022 audit said the data we used to evaluate social worker trends did not include all the licensed social workers they employed.

• To address our findings concerning data inconsistencies, we made one recommendation to KSDE.

As of April 2025, KSDE implemented the recommendation.

• We requested and reviewed documentation from KSDE to verify they implemented the recommendation. Those documents included the most recent versions of the Superintendent Organization Report User Guide, the Educator Data Collection System and Licensed Personnel Report User Manual, the Licensed Personnel Guide, and copies of district training presentations. We also spoke with KSDE officials to further understand how to interpret the guidance and how districts are made aware of these reporting changes.

• Figure 2 shows the results of our evaluation.

Figure 2. KSDE implemented the recommendation.
Recommendation	Status	Summary
KSDE should develop and distribute guidance to districts on how to report their licensed mental health staff including how to define staff FTE for each category (social workers, psychologists, and counselors).	Implemented	KSDE has 3 guidance documents publicly available on their website that direct school districts on how to report their licensed mental health staff and define their FTE, depending on what KSDE report the information is for.
		The guidance documents direct school districts to report all licensed and unlicensed mental health staff (i.e., social workers, school counselors, and school psychologists) in the Superintendent’s Organization Report. The instructions make it clear that districts should report staff FTE by role, not license.
		The guidance documents further direct school districts to report certain mental health staff that are licensed by KSDE (i.e., school counselors and school psychologists) in the Educator Data Collection System. The instructions make it clear that districts should exclude social workers from this system because they’re not licensed by KSDE.
		Finally, KSDE officials told us school districts are no longer responsible for reporting school liaisons who are part of the Mental Health Intervention Team. They said KDADS is responsible for reporting those staff.
Source: LPA review of relevant documents
Kansas Legislative Division of Post Audit

KSDE partially implemented the recommendation from our 2022 limited-scope audit of scholarship granting organizations (SGOs).

In April 2022, we published a limited-scope audit evaluating SGOs’ compliance with disbursement requirements for the Tax Credit for Low Income Students Scholarship Program.

• The audit, Evaluating Disbursements for the Tax Credit for Low Income Students Scholarship Program, evaluated whether SGOs had disbursed at least 90% of the contributions they received for student scholarships within 36 months, as required by state law. The audit found that from 2015-2021, 2 of the 8 SGOs did not meet the 90% distribution requirement.

• However, LPA staff were only able to calculate SGOs’ contributions and distributions by year, rather than a more detailed analysis based on month of receipt. This was because state law only requires KSDE to collect annual contribution and disbursement data from SGOs by school year. Without more detailed monthly data, we could not be precise in evaluating whether disbursements were made within 36 months.

• To address our findings concerning a lack of detailed data, we made one recommendation to KSDE.

As of April 2025, KSDE has partially implemented the recommendation.

• We requested and reviewed documentation from KSDE to verify they implemented the recommendation. Those documents included the SGO annual report form from the 2023-2024 school year and the draft of the upcoming SGO annual report form for the 2024-2025 school year. We also spoke with KSDE staff to further understand what types of data they received from SGOs and what they do with it.

• Figure 3 shows the results of our evaluation.

Figure 3. KSDE partally implemented the recommendation.
Recommendation	Status	Summary
KSDE staff should request and analyze monthly contributions and disbursement data needed to monitor SGOs’ compliance with the 90% distribution requirement in state law.	Partially Implemented	KSDE now requires SGOs to include how much they received in monthly contributions in their annual reports to the department. They also require SGOs to report disbursements for each student in their annual reports, but do not ask what they disbursed per month. KSDE officials told us if SGOs reported what they disbursed per student, KSDE could independently calculate what was disbursed each month. However, officials told us SGOs do not consistently report on a per-student basis.
		Therefore, KSDE officials told us they do not currently analyze SGO contribution and disbursement data to monitor their compliance with the 90% distribution requirement in state law. Officials told us this is because they lack the 36 months of historical data needed (reliable monthly contribution and disbursement data) to conduct such analyses.
		KSDE plans to require SGOs to report their monthly disbursements in their annual reports to the department starting with the 2024-2025 school year. KSDE also plans to request monthly contribution and disbursement data for the previous 3 years, which would allow KSDE to annually evaluate SGOs’ compliance with state law moving forward. KSDE will send SGOs data requests for the annual report for the 2024-2025 school year in May 2025 and such data will be due to KSDE by June 1, 2025.
Source: LPA review of relevant documents
Kansas Legislative Division of Post Audit

Recommendations

We did not make any recommendations for this audit.

Agency Response

On April 28, 2025 we provided the draft audit report to the Kansas Department for Children and Families, the Department for Aging and Disability Services, and the Kansas State Department of Education. Because we did not make any recommendations, written responses from DCF, KDADS, and KSDE were optional.

DCF and KDADS chose not to submit a response. KSDE’s response is below. Agency officials generally agreed with our findings and conclusions.

KSDE Response:

Dear Ms. Clarke,

The Kansas State Department of Education (KSDE) appreciates the opportunity to provide a response to the Follow Up Audit on the ‘Evaluating Disbursements for the Tax Credit for Low Income Student Scholarship Program (TCLISSP)’ originally conducted in 2022.

As part of the 2022 TCLISSP audit, LPA recommend that KSDE collect donation and scholarship distribution information on a monthly basis as part of each Scholarship Granting Organization’s (SGO) annual report. LPA also recommended that KSDE use this information to determine if each SGO was meeting the statutory requirement to disburse 90% of their contributions within 36 months.

KSDE began requiring the monthly breakdown of contributions as part of the 2022-2023 annual report that was due by June 1, 2023. KSDE will not have received 36 months of monthly contribution data until June 1, 2025. After each of the SGOs have submitted their 2024-2025 annual report in the required format, KSDE will conduct the analysis recommended by LPA.

KSDE does agree that these recommendations have been partially implemented. However, it was not possible to fully implement the recommendation before the Follow Up Audit was conducted. KSDE will continue the process described above to determine SGO compliance.

Respectfully submitted,

Dr. Frank Harwood

Deputy Commissioner

Appendix A – Cited References

This appendix lists the major publications we relied on for this report.