EIN: 731681366
UEI: F3D2BE9EGJU3
Data as of August 25, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on July 24, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by January 24, 2027 (151 days from today).
What is a management decision? →Finding 2025-001: Approval of Disbursement – Significant Deficiency Federal Agency: Department of State Federal Program Title: Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Compliance Requirement: Allowable Costs/Costs Principles Criteria Federal requirements and agency policy require that disbursements under federal awards be properly authorized, supported, and approved prior to payment. Budget owner and/or project manager approval is required to ensure expenditures are allowable, appropriate, and consistent with award terms. Accordingly, disbursements should not be processed without documented supervisory approval. Condition During disbursement testing, one instance was identified where no evidence of required approval was documented. Context Audit testing of 60 disbursement transactions identified one instance where no evidence of required approval from the budget owner or project manager was present in the system approval history prior to disbursement. The payment was processed and released without documentation demonstrating required predisbursement authorization. Cause The staffing turnover within the accounting department restricted the Organization’s ability to follow up on the necessary approval of the disbursement. Effect The lack of required approval prior to disbursement increases the risk that unauthorized or unallowable costs may be charged to the Federal award and that the entity may not be in compliance with applicable federal requirements. This deficiency also indicates ineffective internal controls over federal expenditures, which could result in questioned costs or misuse of federal funds. Questioned costs None. Identification of a repeat finding This is not a repeat finding. Recommendation Management should enhance system controls to prevent disbursements from being processed without documented required approvals, reinforce approval requirements through targeted staff training, and conduct periodic monitoring of approval histories to ensure sustained compliance. Views of responsible officials Management acknowledges the deficiency identified related to the approval of disbursements and takes compliance with federal requirements seriously. The instance noted during testing was isolated in nature and occurred during a period of staffing transition. Management believes that overall controls governing disbursement processing are designed and operating effectively. However, additional emphasis has been placed on ensuring that all required approvals are consistently documented prior to the processing of payments. The Organization will also continue to monitor adherence to these procedures and assess opportunities to strengthen controls,
Show full finding ▾Hide full finding ▴Finding 2025-001: Approval of Disbursement – Significant Deficiency Federal Agency: Department of State Federal Program Title: Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Compliance Requirement: Allowable Costs/Costs Principles Criteria Federal requirements and agency policy require that disbursements under federal awards be properly authorized, supported, and approved prior to payment. Budget owner and/or project manager approval is required to ensure expenditures are allowable, appropriate, and consistent with award terms. Accordingly, disbursements should not be processed without documented supervisory approval. Condition During disbursement testing, one instance was identified where no evidence of required approval was documented. Context Audit testing of 60 disbursement transactions identified one instance where no evidence of required approval from the budget owner or project manager was present in the system approval history prior to disbursement. The payment was processed and released without documentation demonstrating required predisbursement authorization. Cause The staffing turnover within the accounting department restricted the Organization’s ability to follow up on the necessary approval of the disbursement. Effect The lack of required approval prior to disbursement increases the risk that unauthorized or unallowable costs may be charged to the Federal award and that the entity may not be in compliance with applicable federal requirements. This deficiency also indicates ineffective internal controls over federal expenditures, which could result in questioned costs or misuse of federal funds. Questioned costs None. Identification of a repeat finding This is not a repeat finding. Recommendation Management should enhance system controls to prevent disbursements from being processed without documented required approvals, reinforce approval requirements through targeted staff training, and conduct periodic monitoring of approval histories to ensure sustained compliance. Views of responsible officials Management acknowledges the deficiency identified related to the approval of disbursements and takes compliance with federal requirements seriously. The instance noted during testing was isolated in nature and occurred during a period of staffing transition. Management believes that overall controls governing disbursement processing are designed and operating effectively. However, additional emphasis has been placed on ensuring that all required approvals are consistently documented prior to the processing of payments. The Organization will also continue to monitor adherence to these procedures and assess opportunities to strengthen controls,
The Center for Advanced Defense Studies (C4ADS) acknowledges the finding related to disbursement approvals and the instance where required pre-disbursement authorization was not documented in the system. Existing C4ADS policy requires the approval of the budget manager before finance team approval on all credit card transactions — this sequence ensures that someone with operational authority verifies necessity and project relevance before charges are recorded. The accounting manager, as the administrator of the credit card online portal, has the ability to override/approve out of sequence with approval from the Senior Director of Operations. Due to staff turnover, the accounting manager inadvertently approved a charge out of cycle. Divvy does not permit retroactive correction of approval order and the accounting manager failed to appropriately document the event. As a result of this finding, C4ADS has implemented the following corrective actions: ● Strengthen Approval Controls: C4ADS added an additional review step where the Director of Finance and the Senior Director of Operations review all credit card charges to ensure all charges have two approvers. In cases where the charge has one approver, the Director of Finance confirms with the Senior Director of Operations that the final coding is appropriate prior month ending billing and month end reporting. ● Enhance Documentation and Monitoring: To demonstrate review, the Director of Finance communicates any anomalies to the Senior Director of Operations via Monday.com, C4ADS’ online ticket and tracking system. The Senior Director of Operations approval, or rejection, is logged in that system. ● Staff Training and Reinforcement: Additional training has been provided to the accounting department related to the approval override system and the appropriate documentation. These measures have been implemented and incorporated into ongoing financial processes to ensure all disbursements are properly authorized and documented.
FAC accepted this audit on August 28, 2019 — management decision was due February 28, 2020.
GSA_MIGRATION
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GSA_MIGRATION
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