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Kansas Legislative Division of Post Audit

Agency Responses to Audit Recommendations

Previous Audit Recommendations Agency Updates as of April 2025
Audit Report ID Recommendation Current Status Description of Current Status
Secretary of State
Reviewing Kansas’s Procedures for Election Security, Part 1 (2023) 1 The Secretary of State should more proactively hold county election officers accountable for reviewing annual training, which may include requiring and tracking session attendance. Will Not Implement In the agency’s audit response, the agency agreed that county election officers (CEOs) should receive annual training, but expressed concerns with the attendance tracking recommendation for the following reasons:
  • Clerks are independent, elected officials and state law does not authorize the Secretary of State’s Office (SOS) to exercise enforcement authority over county clerks in their role as county election officials (CEOs).
  • State law requires the SOS to provide annual in-person training but does not compel CEOs to attend. The SOS works with CEOs to ensure those unable to attend in-person training receive and understand the material that is presented. Therefore, tracking in-person training session attendance is not an indicator of whether training was received.
Therefore, the SOS will continue its current practice of proactively working with all CEOs to ensure they receive annual training without imposing an unenforceable requirement on these elected officials to receive training. The SOS is also working to enhance training delivery to provide additional options to receive annual training.

The SOS also has implemented a certification training program to provide enhanced training to county election officers. This training, where attendance is taken, requires participants to complete a series of classes covering many aspects of election administration, including voter registration list maintenance, security of election systems, ballot preparation, and poll worker training. Once a CEO has taken all the required courses, a CEO will achieve a certified election official designation. To date more than 150 CEOs have received certification training.
Reviewing Kansas’s Procedures for Election Security, Part 2 (2023) 1 The Secretary of State’s office should create example election security policies and standardized forms to offer to county election officers to use at their discretion. The Secretary of State’s office should consider working with officials from counties with stronger practices to adapt these practices for all counties to use. In Progress The agency has worked with different groups of county election officials (CEOs) to create and provide templates to all 105 county election officials (CEOs) for a series of forms and procedures. These include, but are not limited to, ballot chain of custody on Election Day, receiving ballots from the postal service and retrieving ballots from drop boxes, checklists for supervising judges for the opening and closing of polls, and logic and accuracy testing procedures. Additional instruction was provided on the security and signature review of advance ballot envelopes, The agency has also create templates for other election activities including petitions, candidate declarations of intent, write-in candidates, and post-election audit reporting. The agency anticipates that form development and updating will be an ongoing process as laws, regulations and best practices are reviewed after this election year and evolve. The agency is also evaluating how best to standardize election security forms with respect to county’s annual security procedure review, in addition to those forms referenced above.
2 The Secretary of State’s office should use county election officers’ annual training or new certification program to train them in the importance, proper implementation, and effective oversight of election security statutes and best practices. This would include guidance on which security best practices counties should implement as a baseline. Have Implemented The Secretary of State’s office has used annual training over multiple years to provide security training, which has included presentations from security officials and private security specialists. Ensuring election security is an ongoing process that occurs throughout the year, therefore, providing training, information, and best practices is not limited to annual training.
3 The Secretary of State’s office should provide guidance to county election officers on what materials to seal in ballot containers and what materials should not be sealed so they are available for public review. Have Implemented The Secretary of State’s office routinely reminds counties of the requirements of KSA 25-3008 both prior to and following each election. This reminder occurs both verbally and in writing, Further, during certification training, counties are instructed on ballot security measures and retention laws, with emphasis on what should and should not be included in sealed ballot containers. This guidance is also provided in the election standards.
Ground Water Management District #1
Evaluating Groundwater Management Districts’ Efforts to Conserve Water (2023) 1 Groundwater management districts should develop written policies that describe when and how they will revise their management programs Have Implemented On November 9th 2023 the GMD1 Board of Directors passed an official policy titled the Official Management Program Revision Policy, which has been attached to this submission for your review. The Policy requires that the GMD1 Board of Directors review the Management Program on an annual basis, during the Regular August Board Meeting to assess the need to revise or reaffirm the Management Program. The Management Program will then be presented at the District’s Annual Meeting.
Ground Water Management District #2
Evaluating Groundwater Management Districts’ Efforts to Conserve Water (2023) 1 Groundwater management districts should develop written policies that describe when and how they will revise their management programs Have Implemented The Equus Beds GMD2 Board of Directors approved a formal District Standard and Policy on December 21, 2023, that sets forth the procedure and time schedule for reviewing and revising the District’s management program. We provided a copy of the approved District Standard and Policy to the Kansas Legislative Division of Post Audit on January 22, 2024.
Ground Water Management District #3
Evaluating Groundwater Management Districts’ Efforts to Conserve Water (2023) 1 Groundwater management districts should develop written policies that describe when and how they will revise their management programs Have Implemented The GMD3 Board of Directors passed resolution 2023-5 adopting the Official Management Program Revision Policy dated October 31, 2023, that is intended to be applied so as to be consistent with the provisions of K.S.A. 82a-1029 of the GMD Act.
Ground Water Management District #4
Evaluating Groundwater Management Districts’ Efforts to Conserve Water (2023) 1 Groundwater management districts should develop written policies that describe when and how they will revise their management programs Have Implemented We implemented the policy during the regular scheduled board meeting in conjunction with our annual meeting.  The management program is currently being updated.
Ground Water Management District #5
Evaluating Groundwater Management Districts’ Efforts to Conserve Water (2023) 1 Groundwater management districts should develop written policies that describe when and how they will revise their management programs Have Implemented In December 2023, the District board approved and adopted an administrative policy to guide the District in reviewing and amending the management program of the District. This policy may be amended as necessary in the future as the District begins implementing it in 2024.
Kansas Department of Education
Evaluating At-Risk Expenditures and Statutory Compliance (2023) 1 The department should ensure that its guidance document accurately reflects the at-risk related statutes. Have Implemented The guidance documents have been updated for 2024-2025 and 2025-2026. Guidance will continue to be reviewed and updated with the implementation of changes to KSA 72-3574 and KSA 72-5153.
2 The department should re-review all currently approved programs to ensure that approved programs meet all the requirements described in state law. Have Implemented KSDE has reviewed each item on the Evidence-Based Programs and Practices list and the Kansas State Board of Education has approved the list for 2024-2025. KSDE will provide updates for State Board approval on an annual basis in compliance with KSA 72-5153.
3 Districts should review K.S.A. 72-5153, which specifies allowable uses for spending from the at-risk fund, and ensure that their policies, training, and guidance are in alignment with those laws. Have Implemented As part of the 2024 KSDE Budget Workshops, districts were provided with updated guidance for the expenditure of at-risk funds. Currently, thirteen districts are participating in a pilot to develop new procedures for at-risk expenditure reporting in accordance with KSA 72-3574. In 2026-2027, all districts will receive updated guidance and training for implementation of the requirements of KSA 72-3574.
The African American Affairs Commission
Reviewing the African American Affairs Commission’s Statutory Compliance and Expenditures (2023) 1 The executive director should ensure the commission holds an annual vote for Chair and Secretary positions in accordance with state law. Have Implemented The commission held elections on July 7, 2023, re-electing Mark McCormick as chair and Jonathan McRoy as vice-chair. The next election will be at the last meeting before the end of the next fiscal year.
2 The executive director should ensure the commission elects several members to each of the standing committees included in the commission’s bylaws. Have Implemented During the August 11, 2023 meeting, each commission member volunteered for each of the standing committees. Currently, there is at least one commissioner on each of the standing committees. Standing committee membership will be finalized once the bylaw review is complete.
3 The executive director should get written approval from the Governor’s Office for all non-routine expenses to ensure there’s documentation of the purpose and planned amount before proceeding with the activity. Have Implemented KAAAC Commissioners continue to maintain access to the commission’s financials. That said, the commission is currently updating the bylaws to formalize how this information can be more easily shared in the future. This may involve restructuring the committees to add a finance or budget committee or adding a treasurer position to the commission.
4 The executive director should share the commission’s budget details and financial transactions (in detail or summary) with the commission periodically and on request. Have Implemented The bylaws were completed at the November 2024 KAAAC meeting. There is a budget committee that shares oversight on the budget with the executive director. The committee must have one member from all political parties represented on KAAAC at the time.
5 The executive director should provide training to commissioners to clarify what travel expenses are reimbursable, and inform members of the process to claim and submit such expenditures. Have Implemented The Director of Finance and Office Management for the Governor’s Office provided such training at the December meeting. This would have happened earlier but the bylaws took much more time than anticipated.
The Department of Revenue
Evaluating the Rural Opportunity Zones Program (2023) 1 Commerce and Revenue should develop a way to identify individuals participating in both parts of the ROZ program to enhance the quality of future program evaluations. Have Implemented As part of the application process for the student loan repayment assistance program, the Department of Commerce has begun collecting social security numbers (SSN’s) from the individuals that have applied for and been approved for the program. The Department of Commerce will share pertinent information (including the SSN’s) from the student loan repayment assistance program with the Department of Revenue. The Department of Revenue will match the student loan repayment assistance data with the individuals that are claiming the rural opportunity zone income tax credit and have it available for future program evaluations.
The Department of Commerce
Evaluating the Rural Opportunity Zones Program (2023) 1 Commerce and Revenue should develop a way to identify individuals participating in both parts of the ROZ program to enhance the quality of future program evaluations. In Progress Annually, KDC will send a report to KDOR in January listing all participants who received ROZ payments in the year prior in order for KDOR to be able to cross check for individuals who are participating in both the student loan repayment assistance program and also receiving the tax credit. This will allow KDOR and Commerce to report back to the legislature on the number of individuals that are utilizing each portion of the ROZ program, and how many are using both.
Evaluating the Angel Investor Tax Credit Program (2024) 1 The Department of Commerce should develop processes to regularly and systematically review its Angel Investor Tax Credit program data and correct inaccuracies. In Progress Commerce has assigned the AITC to a new unit which is reviewing policies and procedures to improve processes and accuracy. This process will be ongoing and result in regular reviews and stronger effort to insure data accuracy.
2 Commerce should continue with its plan to make its monitoring processes more efficient. This may include the new survey process Commerce officials described to us. After implementing its plan, Commerce should evaluate whether it helped them provide all the oversight functions required by state law. In Progress The initiative to make the AITC monitoring process more consistent and comprehensive is ongoing. The team managing this program is reviewing options and best practices. Our goal is more regular and accurate oversight.
Louisburg School District
Reviewing the Louisburg School District’s Expenditures (2024) 1 The district should take steps to ensure that all expenditures within their internal accounting system are coded correctly at both the function and object level. Have Implemented The district has takend steps to ensure all expendtures are coded correctly. These expenditures are currently coded at the function and object level.
2 The district should review state law regarding at-risk expenditures and ensure that their spending is in alignment with those laws. Have Implemented The district has reviewed state law regarding at-risk expenditures. All at-risk expenditures are in alignment with current at-risk laws.
3 The district should review KSDE guidance regarding capital outlay equipment and ensure their spending is in alignment with that guidance. Have Implemented The district has reviewed KSDE guidance regarding capital outlay equipment. All capital outlay expendictures fall under the current capital outlay statute.
Department of Revenue
Reviewing the Department of Revenue’s Procedures to Ensure Correct Payment of Sales and Compensating Use Taxes on Motor Vehicle Sales (2024) 1 KDOR should create and implement the missing procedures we pointed out under the heading “ KDOR was missing 2 procedures related to the monitoring and enforcement of counties.“ Have Implemented Beginning in April 2024, a report has been generated on the 10th of every month that is distributed to the individuals in the positions listed in the response. This report enables the Department to contact those local governments that may be delinquent in filing sales tax returns or in submitting payments and to work with these local governments to ensure compliance with statutory sales tax reporting requirements.

The Department is exploring the possibility of utilizing the county registration data to identify questionable sales prices or tax exemptions. It is currently beginning a pilot project by reviewing commercial vehicle transactions and whether exemption certificates that have been presented are valid or appropriate. Once, this project is completed, staff will explore the utilization of county data for personal vehicle transactions to determine the feasibility of verifying the validity of sales prices and exemptions.
2 KDOR should develop and implement a process to improve the accuracy of existing and ongoing vehicle registration data submitted through MOVRS. In Progress The Department is working with current IT resources to capture more accurately the information for the vehicle Registration report. The Department has been meeting with county treasurers for months to identify much needed MOVRS system enhancements to facilitate the data capture. MOVRS system upgrades have been elevated as part of the Department’s overall IT strategic plan.
3 KDOR should provide the current, up-to-date sales tax guidance document to the dealership portal. They should also provide tax guidance updates in the portal as those are made. They should consider if there are points in time where they should offer dealerships a chance to retake KDOR training. Have Implemented The link to Publication KS-1526, Business Taxes for Motor Vehicle Transactions was added to the Dealer Portal on April 5, 2024. Additionally, the Department has published to the Dealer Portal, notification for any dealer needing additional training on sales tax to contact the Department. The Dealer Portal also now provides reminders that sales tax returns are due on the 25th day of each month. As guidance is developed or updated, the Department will publish to the Dealer Portal. As way of example, the Department recently published the following to the Dealer Portal: Notice 24-19, Used Motor Vehicle Sales Transactions; Frequently Asked Questions About the Sale of a Used Motor Vehicle within 120 Days of the Purchase of a New or Used Motor Vehicle; and Form ST-21VT, Request for Sales Tax Refund of a Motor Vehicle Sold within 120 Days of a New or Used Motor Vehicle Purchase. These three documents were developed based on legislation (2024 House Bill 2098) passed during the 2024 legislative session.
4 KDOR should formally document all existing and new procedures related to motor vehicle training, guidance, monitoring, and enforcement. Have Implemented The Sales Tax area within the Department has a PowerPoint document on the processes for verifying and processing returns of all county sales tax/compensating use tax accounts. Enforcement procedures in place for all sales tax/compensating use tax accounts may be imposed for county accounts if needed.

The dealer sales tax/compensating use tax accounts are not treated any differently than any other sales tax/compensating use tax accounts. There are multiple documents for training, guidance, monitoring and enforcement for these accounts. These documents are updated with any legislative, policy or procedural changes as soon as reasonably possible.