Repeat of Prior Audit Finding 2021-001 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance require all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. In addition, 2 CFR section 200.405 requires federal awards be expended only for allowable activities. Condition/Context: Panthera Corporation was unable to provide a signed contract, payment information, invoice or reconciliation to evidence allowability of the expenditures or documentation of review and approval for the following: ? For 34 out of 80 selections, no evidence of approval of the invoice or approval of signed contract could be provided (control) ? For 63 out of 80 selections, no evidence of approval of payment could be provided (control) ? For 46 out of 80 selections, no evidence of signed contract or payment support could be provided (compliance) This was not a statistically valid sample. Questioned Costs: Questioned costs were approximately $65,341. Cause: Panthera Corporation did not retain/could not retrieve the signed contract or any related support for the disbursements due to poor document retention and staffing turnover and did not follow its internal control procedures by including formal, written review of disbursement payments. Effect: Panthera Corporation has not complied with the specific requirements for activities allowed or unallowed and allowable costs/cost principles as described in the Uniform Guidance. Unallowable costs may have been charged to the federal program. Recommendation: We recommend that Panthera Corporation review its process and implement procedures that would allow management to properly maintain all required documentation on its federal expenditures. Views of Responsible Officials: Management acknowledges the finding and is in the process of attaining the proper systems to adequately track and maintain documentation including the review and approval process.
Repeat of Prior Audit Finding 2021-002 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance require all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that a non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Condition/Context: Panthera Corporation prepares and reviews a quarterly expenditure file to track and compile quarterly costs to be submitted for reimbursement to the funding agency. For the selection of 2 quarterly expenditure files, we were unable to verify that the file was formally reviewed prior to requesting reimbursement. This was not a statistically valid sample. Questioned Costs: None Cause: Panthera Corporation developed written cash management procedures, however, did not follow such procedures by including formal, written review of quarterly expenditure files. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is appropriately managing the cash management compliance requirement of the Uniform Guidance. Improper cash drawdowns could occur. Recommendation: We recommend that Panthera Corporation implement written approval on their quarterly expenditure files. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process within Chrome River.
Repeat of Prior Audit Finding 2021-003 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance requires all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that a non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. 2 CFR Part 200.306 of the Uniform Guidance requires shared costs or matching funds be accepted as part of the non-Federal entity's cost sharing or matching when they are verifiable, necessary and reasonable and are allowable. Condition/Context: Panthera Corporation prepares and reviews a quarterly expenditure file to track and compile quarterly costs and calculate the cost-sharing component to be submitted for reimbursement to the funding agency. For the selection of 2 quarterly expenditure files, we were unable to verify that the file was formally reviewed. This was not a statistically valid sample. Questioned Costs: None Cause: Panthera Corporation developed written matching procedures, however, did not follow such procedures by including formal, written review of quarterly expenditure files. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the matching compliance requirement of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation implement documented approval on their quarterly expenditure files. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process within Chrome River.
Repeat of Prior Audit Finding 2021-004 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200 Subpart D Section 200.320 identifies small purchases as purchases greater than the micro-purchase threshold but not exceeding the simplified acquisition threshold. For small purchases, rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. 2 CFR Part 200 Subpart D Section 200.320 (c) of the Uniform Guidance establishes specific circumstances in which noncompetitive procurement can be used. Condition/Context: For the selection of 2 subcontractors which was utilized by Panthera Corporation during the year that received federal expenditures greater than the micro-purchase threshold, but did not exceed the simplified acquisition threshold, this purchase did not go through a procurement process. Management asserted that one subcontractor came highly recommended and the other was due to space limitations for an event, however, Panthera Corporation did not document these rationales at the time the contract was awarded, nor were they able to provide documentation that the subcontractors satisfied the specific circumstances for which noncompetitive procurement can be used. This was not a statistically valid sample. Questioned Costs: Not determinable Cause: Panthera Corporation developed written procurement procedures, however, did not follow such procedures in obtaining competitive bids or maintaining documentation to support why competitive bids could not be obtained. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the procurement compliance requirement of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation follow its policies and procedures by ensuring that purchases requiring procurement go through the appropriate procurement process as well as maintaining documentation to allow for an audit trail. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process.
Repeat of Prior Audit Finding 2021-005 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200, Subpart D Section 200.332 of the Uniform Guidance require all non-Federal entities to assess subrecipients' risk, as well as monitor sub-awards passed through. All requirements imposed by the pass-through entity on the subrecipient are to ensure that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. Condition/Context: For the selection of 2 subrecipients, we were unable to verify that the respective subaward agreements contained accurate award information, such as the identification of the funding being U.S. federal funds, the federal Assistance Listing Number and the requirements that the subrecipients would need to comply with the Uniform Guidance. In addition, for 2 other subrecipients, we could not determine the quarterly programmatic and financial reports were reviewed or approved by Panthera Corporation as there was no evidence of formal review and approval. There was also no evidence that those subrecipients had been audited or monitored under appropriate local government regulations. This was not a statistically valid sample. Questioned Costs: Not determinable Cause: Panthera Corporation's procedures did not ensure the required written subrecipient monitoring policies were implemented in accordance with the Uniform Guidance. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the subrecipient monitoring requirements of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation clearly identify in each agreement with subrecipients the reference to the applicable federal Assistance Listing Number and request audited reports from subrecipients when applicable. We further recommend that Panthera Corporation follow its policies and procedures by ensuring that subrecipient quarterly reports are subject to the appropriate process as well as maintaining documentation to allow for an audit trail. View of Responsible Officials: Management acknowledges the finding and will be retaining support and updating subrecipient agreements to include the relevant award information and the Uniform Guidance compliance requirements for subrecipients.
Repeat of Prior Audit Finding 2021-001 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance require all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. In addition, 2 CFR section 200.405 requires federal awards be expended only for allowable activities. Condition/Context: Panthera Corporation was unable to provide a signed contract, payment information, invoice or reconciliation to evidence allowability of the expenditures or documentation of review and approval for the following: ? For 34 out of 80 selections, no evidence of approval of the invoice or approval of signed contract could be provided (control) ? For 63 out of 80 selections, no evidence of approval of payment could be provided (control) ? For 46 out of 80 selections, no evidence of signed contract or payment support could be provided (compliance) This was not a statistically valid sample. Questioned Costs: Questioned costs were approximately $65,341. Cause: Panthera Corporation did not retain/could not retrieve the signed contract or any related support for the disbursements due to poor document retention and staffing turnover and did not follow its internal control procedures by including formal, written review of disbursement payments. Effect: Panthera Corporation has not complied with the specific requirements for activities allowed or unallowed and allowable costs/cost principles as described in the Uniform Guidance. Unallowable costs may have been charged to the federal program. Recommendation: We recommend that Panthera Corporation review its process and implement procedures that would allow management to properly maintain all required documentation on its federal expenditures. Views of Responsible Officials: Management acknowledges the finding and is in the process of attaining the proper systems to adequately track and maintain documentation including the review and approval process.
Repeat of Prior Audit Finding 2021-002 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance require all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that a non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Condition/Context: Panthera Corporation prepares and reviews a quarterly expenditure file to track and compile quarterly costs to be submitted for reimbursement to the funding agency. For the selection of 2 quarterly expenditure files, we were unable to verify that the file was formally reviewed prior to requesting reimbursement. This was not a statistically valid sample. Questioned Costs: None Cause: Panthera Corporation developed written cash management procedures, however, did not follow such procedures by including formal, written review of quarterly expenditure files. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is appropriately managing the cash management compliance requirement of the Uniform Guidance. Improper cash drawdowns could occur. Recommendation: We recommend that Panthera Corporation implement written approval on their quarterly expenditure files. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process within Chrome River.
Repeat of Prior Audit Finding 2021-003 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance requires all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that a non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. 2 CFR Part 200.306 of the Uniform Guidance requires shared costs or matching funds be accepted as part of the non-Federal entity's cost sharing or matching when they are verifiable, necessary and reasonable and are allowable. Condition/Context: Panthera Corporation prepares and reviews a quarterly expenditure file to track and compile quarterly costs and calculate the cost-sharing component to be submitted for reimbursement to the funding agency. For the selection of 2 quarterly expenditure files, we were unable to verify that the file was formally reviewed. This was not a statistically valid sample. Questioned Costs: None Cause: Panthera Corporation developed written matching procedures, however, did not follow such procedures by including formal, written review of quarterly expenditure files. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the matching compliance requirement of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation implement documented approval on their quarterly expenditure files. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process within Chrome River.
Repeat of Prior Audit Finding 2021-004 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200 Subpart D Section 200.320 identifies small purchases as purchases greater than the micro-purchase threshold but not exceeding the simplified acquisition threshold. For small purchases, rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. 2 CFR Part 200 Subpart D Section 200.320 (c) of the Uniform Guidance establishes specific circumstances in which noncompetitive procurement can be used. Condition/Context: For the selection of 2 subcontractors which was utilized by Panthera Corporation during the year that received federal expenditures greater than the micro-purchase threshold, but did not exceed the simplified acquisition threshold, this purchase did not go through a procurement process. Management asserted that one subcontractor came highly recommended and the other was due to space limitations for an event, however, Panthera Corporation did not document these rationales at the time the contract was awarded, nor were they able to provide documentation that the subcontractors satisfied the specific circumstances for which noncompetitive procurement can be used. This was not a statistically valid sample. Questioned Costs: Not determinable Cause: Panthera Corporation developed written procurement procedures, however, did not follow such procedures in obtaining competitive bids or maintaining documentation to support why competitive bids could not be obtained. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the procurement compliance requirement of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation follow its policies and procedures by ensuring that purchases requiring procurement go through the appropriate procurement process as well as maintaining documentation to allow for an audit trail. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process.
Repeat of Prior Audit Finding 2021-005 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200, Subpart D Section 200.332 of the Uniform Guidance require all non-Federal entities to assess subrecipients' risk, as well as monitor sub-awards passed through. All requirements imposed by the pass-through entity on the subrecipient are to ensure that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. Condition/Context: For the selection of 2 subrecipients, we were unable to verify that the respective subaward agreements contained accurate award information, such as the identification of the funding being U.S. federal funds, the federal Assistance Listing Number and the requirements that the subrecipients would need to comply with the Uniform Guidance. In addition, for 2 other subrecipients, we could not determine the quarterly programmatic and financial reports were reviewed or approved by Panthera Corporation as there was no evidence of formal review and approval. There was also no evidence that those subrecipients had been audited or monitored under appropriate local government regulations. This was not a statistically valid sample. Questioned Costs: Not determinable Cause: Panthera Corporation's procedures did not ensure the required written subrecipient monitoring policies were implemented in accordance with the Uniform Guidance. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the subrecipient monitoring requirements of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation clearly identify in each agreement with subrecipients the reference to the applicable federal Assistance Listing Number and request audited reports from subrecipients when applicable. We further recommend that Panthera Corporation follow its policies and procedures by ensuring that subrecipient quarterly reports are subject to the appropriate process as well as maintaining documentation to allow for an audit trail. View of Responsible Officials: Management acknowledges the finding and will be retaining support and updating subrecipient agreements to include the relevant award information and the Uniform Guidance compliance requirements for subrecipients.