Finding Text
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.