Finding Text
Repeat of Prior Audit Finding 2021-001
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 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.