Finding Text
Federal Program: Trans-National Crime
Federal Agency: 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 two 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.