Finding 498910 (2022-002)

Significant Deficiency Repeat Finding
Requirement
C
Questioned Costs
-
Year
2022
Accepted
2024-09-27
Audit: 321740
Organization: Panthera Corporation (NY)

AI Summary

  • Core Issue: Panthera Corporation failed to formally review quarterly expenditure files before reimbursement requests, violating internal control requirements.
  • Impacted Requirements: This finding repeats a prior issue, indicating ongoing non-compliance with 2 CFR Part 200.303(a) regarding effective internal controls over federal awards.
  • Recommended Follow-Up: Implement a formal written approval process for quarterly expenditure files to ensure compliance and prevent improper cash drawdowns.

Finding Text

Repeat of Prior Audit Finding 2021-002 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 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 two 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.

Corrective Action Plan

Panthera implemented an approval workflow in Chrome River, but we will also ensure a formal written approval is issued on quarterly expenditure reports going forward.

Categories

Cash Management

Other Findings in this Audit

  • 498911 2022-004
    Significant Deficiency Repeat
  • 498912 2022-005
    Significant Deficiency Repeat
  • 498913 2022-001
    Material Weakness Repeat
  • 498914 2022-003
    Significant Deficiency Repeat
  • 1075352 2022-002
    Significant Deficiency Repeat
  • 1075353 2022-004
    Significant Deficiency Repeat
  • 1075354 2022-005
    Significant Deficiency Repeat
  • 1075355 2022-001
    Material Weakness Repeat
  • 1075356 2022-003
    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