Finding 34786 (2022-003)

Significant Deficiency Repeat Finding
Requirement
G
Questioned Costs
-
Year
2022
Accepted
2023-09-28
Audit: 34492
Organization: Panthera Corporation (NY)

AI Summary

  • Core Issue: Panthera Corporation failed to formally review quarterly expenditure files, which is a repeat finding from 2021.
  • Impacted Requirements: This impacts compliance with 2 CFR Part 200.303(a) and 2 CFR Part 200.306 regarding internal controls and matching funds.
  • Recommended Follow-Up: Implement a documented approval process for quarterly expenditure files to ensure compliance.

Finding Text

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.

Corrective Action Plan

We already implemented a formal review and approval process in 2023 and anticipate this finding to be resolved on our next year audit. We will also ensure the review and approval is properly documented.

Categories

Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 34784 2022-001
    Material Weakness Repeat
  • 34785 2022-002
    Significant Deficiency Repeat
  • 34787 2022-004
    Significant Deficiency Repeat
  • 34788 2022-005
    Significant Deficiency Repeat
  • 611226 2022-001
    Material Weakness Repeat
  • 611227 2022-002
    Significant Deficiency Repeat
  • 611228 2022-003
    Significant Deficiency Repeat
  • 611229 2022-004
    Significant Deficiency Repeat
  • 611230 2022-005
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
19.705 Trans-National Crime $1.59M
15.619 Rhinoceros and Tiger Conservation Fund $119,613
15.640 Latin America and Caribbean Regional $31,845
15.679 Combating Wildlife Trafficking $19,118