OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OFTHE INTERIOR 

U.S. Fish and Wildlife Service Grants 

Awarded to the Commonwealth of 

Pennsylvania, Fish and Boat Commission, 

From July 1, 2016, Through June 30, 2018, 

Under the Wildlife and Sport Fish Restoration 

Program 

AUDIT 

In recognition of Secretarial Order No. 3380, we are providing estimated costs 

associated with certain work products. Applying a formula involving prior salary 

and benefit expenses, we estimate the cost of preparing this report to be $54,000.

Report No.: 2019-WR-006 July 2020 

This is a revised version of the report prepared for public release.
Memorandum 

To: Aurelia Skipwith

Director, U.S. Fish and Wildlife Service 

From: Michael P. Colombo 

Regional Manager, Western Region

Subject: Final Audit Report – U.S. Fish and Wildlife Service Grants Awarded to the 

Commonwealth of Pennsylvania, Fish and Boat Commission, From July 1, 2016, 

Through June 30, 2018, Under the Wildlife and Sport Fish Restoration Program 

Report No. 2019-WR-006 

This final report presents the results of our audit of costs claimed by the Commonwealth

of Pennsylvania’s Fish and Boat Commission (Commission) under grants awarded by the 

U.S. Fish and Wildlife Service (FWS). The FWS provided the grants to the Commonwealth

under the Wildlife and Sport Fish Restoration Program. The audit included claims totaling 

approximately $36 million on 17 grants that were open during the State fiscal years that ended 

June 30, 2017, and June 30, 2018 (see Appendix 1). The audit also covered the Commission’s

compliance with applicable laws, regulations, and FWS guidelines, including those related to 

collecting and using fishing license revenues and reporting program income. 

We found that the Commission was unable to demonstrate that it had adequate support 

for labor costs charged to Program grants because of its inability to reconcile these costs with the 

Commonwealth’s accounting system and its use of estimated values for labor costs. We therefore

question the Federal share of unsupported labor costs and related indirect costs, totaling 

$17,701,030. 

We provided a draft of the report to the FWS. The FWS concurred with our 

recommendations and will work with the Commission to implement corrective actions. In this 

report we summarize the Commission’s and the FWS’ responses to our recommendations, as 

well as our comments on their responses. The full responses from the Commission and the FWS

are included in Appendix 3. We list the status of the recommendations in Appendix 4. 

Please provide us with a corrective action plan based on our recommendations by 

October 28, 2020. The plan should provide information on actions taken or planned to address 

the recommendations, as well as target dates and titles of the officials responsible for 

implementation. Please send your response to aie_reports@doioig.gov. 

If you have any questions regarding this report, please contact me at 916-978-6199. 

Office of Audits, Inspections, and Evaluations | Sacramento, CA
2

The legislation creating the Office of Inspector General requires that we report to 

Congress semiannually on all audit reports issued, actions taken to implement our 

recommendations, and recommendations that have not been implemented.

cc: Colleen E. Sculley, Chief, Division of Wildlife and Sport Fish Restoration, Region 1,

U.S. Fish and Wildlife Service
Table of Contents

Introduction ......................................................................................................................................1

Background...............................................................................................................................1

Objectives.................................................................................................................................1

Scope ........................................................................................................................................1

Methodology.............................................................................................................................2

Prior Audit Coverage ................................................................................................................3

Results of Audit ...............................................................................................................................4

Audit Summary ........................................................................................................................4

Finding and Recommendations ................................................................................................4

Appendix 1 .......................................................................................................................................8

Appendix 2 .......................................................................................................................................9

Appendix 3 .....................................................................................................................................10

Appendix 4 .....................................................................................................................................15
1 

Introduction 

Background

The Pittman-Robertson Wildlife Restoration Act and the Dingell-Johnson Sport Fish Restoration 

Act1 established the Wildlife and Sport Fish Restoration Program. Under the Program, the 

U.S. Fish and Wildlife Service (FWS) provides grants to States to restore, conserve, manage, 

and enhance their wildlife and sport fish resources. The Acts and Federal regulations contain 

provisions and principles on eligible costs and allow the FWS to reimburse States up to 

75 percent of the eligible costs incurred under the grants. The Acts also require that hunting and 

fishing license revenues be used only for the administration of State fish and game agencies. 

Finally, Federal regulations and FWS guidance require States to account for any income they 

earn using grant funds. 

Objectives

In June 2016, we entered into an intra-agency agreement with the FWS to conduct audits of State 

agencies receiving grant funds under the Wildlife and Sport Fish Restoration Program. These 

audits fulfill the FWS’ statutory responsibility to audit State agencies’ use of these grant funds. 

We conducted this audit to determine whether the Commonwealth of Pennsylvania’s Fish and 

Boat Commission (Commission): 

• Claimed the costs incurred under the Program grants in accordance with the Acts and

related regulations, FWS guidelines, and grant agreements

• Used Commonwealth hunting and fishing license revenues solely for fish and wildlife

program activities

• Reported and used program income in accordance with Federal regulations

Scope

Audit work included claims totaling approximately $36 million on the 17 grants open during the 

State fiscal years (SFYs) that ended June 30, 2017, and June 30, 2018 (see Appendix 1). We 

report only on those conditions that existed during this audit period. We performed our audit at 

the Commission’s headquarters office in Harrisburg, PA, and visited two regional offices, six

fish hatcheries, and five boating access sites (see Appendix 2). 

We performed this audit to supplement—not replace—the audits required by the Single Audit 

Act. 

1 16 U.S.C. §§ 669 and 777, as amended, respectively.
2

Methodology

We conducted this performance audit in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions 

based on our audit objectives. We believe that the evidence obtained provides a reasonable basis 

for our findings and conclusions based on our audit objectives.

Our tests and procedures included:

• Examining the evidence that supports selected expenditures charged to the grants by the

Commission

• Reviewing transactions related to purchases, direct costs, drawdowns of reimbursements, 

in-kind contributions, and program income

• Interviewing Commission employees to ensure that personnel costs charged to the grants 

were supportable

• Conducting site visits to inspect equipment and other property

• Determining whether the Commission used fishing license revenues solely for the 

administration of fish and wildlife program activities

• Determining whether the Commonwealth passed required legislation assenting to the 

provisions of the Acts

We also identified the internal controls over transactions recorded in the labor and license-fee 

accounting systems and tested their operation and reliability. Based on the results of initial 

assessments, we assigned a level of risk to these systems and selected a judgmental sample of 

transactions for testing. We did not project the results of the tests to the total population of 

recorded transactions or evaluate the economy, efficiency, or effectiveness of the Commission’s

operations. 

We relied on computer-generated data for other direct costs and personnel costs to the extent that 

we used these data to select Program costs for testing. Based on our test results, we either 

accepted the data or performed additional testing. For other direct costs, we took samples of 

costs and verified them against source documents such as purchase orders, invoices, receiving 

reports, and payment documentation. For personnel costs, we selected Commission employees 

who charged time to Program grants and verified their hours against timesheets and other 

supporting data.
3

Prior Audit Coverage

On July 24, 2015, we issued U.S. Fish and Wildlife Service Wildlife and Sport Fish Restoration 

Program Grants Awarded to the Commonwealth of Pennsylvania, Fish and Boat Commission, 

From July 1, 2011, Through June 30, 2013 (Report No. R-GR-FWS-0005-2014). 

We followed up on the recommendation in the report (related to license certification) and found 

that it was resolved and implemented prior to issuance of the final report.

We also reviewed the Commonwealth’s single audit reports for SFYs 2016 and 2017. Neither

report contained any findings directly affecting the Program grants.
4 

Results of Audit

Audit Summary

We found that the Commission was unable to demonstrate adequate support for labor costs 

charged to Program grants because of its inability to reconcile these costs with the 

Commonwealth’s accounting system and its use of estimated values for labor costs. We question 

a total of $17,701,030, the Federal share of unsupported labor costs and related indirect costs. 

Finding and Recommendations

Inadequate Financial Management—Questioned Costs of $17,701,030

The Commission uses two systems to account for grant expenditures: System Analysis and 

Program Development (SAP) and Microsoft Excel. SAP, the Commonwealth’s official 

accounting system, accounts for all nonlabor direct costs and can provide reports of actual 

expenditures coded to grants. The Commission does not use the SAP system to account for labor 

expenditures charged to grants. Instead, the Commission uses a separate grants accounting 

process reliant upon Microsoft Excel to track labor hours recorded on employee timesheets. 

These labor hours are valued according to a composite labor rate computed by the Commission. 

This process produces an estimated value of the labor costs associated with grants rather than 

actual labor expenditures. The two systems do not interface, and the labor costs recorded in the 

Excel workbooks are not reconciled with the Commonwealth’s official accounting system 

(SAP). In addition, the Excel records are not audited or evaluated as part of the Commonwealth’s 

single audit. 

Further, the records of labor hours are manually input into the Excel system by one employee, 

and this employee’s work is only spot-checked for accuracy. Thus, there are not adequate 

internal controls in place to ensure that the hours and related costs recorded are accurate.

Because of the Commission’s use of an unreconciled and unofficial system to support its grant 

labor expenditures, we classified all labor costs ($22,618,822) and related indirect costs

($3,491,192) claimed by the Commission for grants open during our audit period as unsupported. 

These costs total $26,110,014, with a Federal share of $17,701,030, as summarized in Figure 1 

below. 
5 

Figure 1. Federal Share of Unsupported Labor Costs and 

Related Indirect Costs, by Grant

Grant No.

Unsupported 

Labor 

Costs ($)

Unsupported 

Indirect 

Costs ($)

Questioned

Labor

Costs ($)

Questioned

Indirect 

Costs ($)

Total

Questioned 

Costs ($)

F16AF00090 417,331 69,778 267,029 46,375 313,404

F16AF00091 3,923,567 656,162 2,942,675 492,121 3,434,796

F16AF00101 1,022,559 170,715 758,637 126,957 885,594

F16AF00105 1,147,197 191,789 860,398 143,842 1,004,240

F16FA00625 201,078 33,439 150,808 25,079 175,887

F16AF00768 15,875 2,640 11,907 1,980 13,887

F17AF00084 1,490,106 229,863 1,117,580 172,038 1,289,618

F17AF00085 4,235,287 654,740 2,837,340 446,723 3,284,063

F17AF00086 1,153,735 177,711 806,578 125,896 932,474

F17AF00087 560,643 86,575 256,595 44,899 301,494

F17AF00731 270,864 38,842 192,785 27,734 220,519

F17AF00903 55,951 8,023 41,964 6,018 47,982

F18AF00116 1,330,028 191,745 997,521 143,272 1,140,793

F18AF00122 721,991 104,076 255,417 44,337 299,754

F18AF00123 1,268,189 182,744 756,036 115,340 871,376

F18AF00159 4,804,422 692,350 3,036,621 448,528 3,485,149

Total $22,618,822 $3,491,192 $15,289,891 $2,411,139 $17,701,030

Federal regulations (2 C.F.R. § 200.302(a)) require that a State’s financial management system 

be sufficient to permit the tracing of funds to a level of expenditures adequate to establish that 

such funds have been used according to Federal statutes, regulations, and the terms and 

conditions of the Federal award. The Commission’s Excel-based financial management process 

does not permit such tracing because the labor costs claimed do not represent actual 

expenditures, but rather are estimated values based on a composite labor rate. 

Further, Federal regulations (2 C.F.R. § 200.302(b)(1)) require that the financial management 

system of each grant recipient provide for identification, in its accounts, of all Federal awards 

received and expended.

In addition, Federal regulations (2 C.F.R. § 200.430(i)) require that records of charges to Federal 

awards for salaries and wages be supported by a system of internal controls that provides 

reasonable assurance that the charges are accurate, allowable, and properly allocated, and that 

they are incorporated in the State’s official records.
6

Commission officials told us this labor accounting process has been in place in some form for 

decades. It is based on a legacy system of handwritten ledgers that was later adapted to Excel.

Officials also told us that they are highly confident the records they rely on are accurate. Without 

sufficient internal controls or efforts to reconcile labor costs, however, the continued use of this 

process as-is prevents the Commission from complying with Federal grant regulations.

Because of its inability to reconcile its grant claims with actual labor costs recorded in its 

accounting system, the Commission cannot provide assurance that grant claims for labor costs 

are accurate, allowable, and properly allocated.

Recommendations

We recommend that the FWS:

1. Resolve questioned costs of $17,701,030

2. Require the Commission to implement a financial management system with 

sufficient internal controls to provide for a reconciliation of all grant claims to 

actual expenditures recorded in the Commonwealth’s System Analysis and 

Program Development (SAP) accounting system

Commission Response

The Commission did not concur with our finding, stating that it does not offer an accurate 

representation of the Commission’s accounting for and internal controls over Federal grant 

reporting. Specifically, the Commission believes that it maintained sufficient and appropriate 

evidence to support the audit’s questioned costs and that its financial management system for 

labor costs charged to grants complies with Federal grant management and internal control 

requirements. The Commission, however, is committed to working with the FWS to resolve the 

questioned costs and explore options to improve its financial management system. See 

Appendix 3 for the Commission’s full response.

FWS Response

The FWS concurred with our finding and recommendations and will work with the Commission 

to resolve the questioned costs and develop a corrective action plan. See Appendix 3 for the 

FWS’ full response.

OIG Comment

We disagree with the Commission’s contention that it was able to support the allocation of labor 

costs among specific Federal awards in sufficient detail to fulfill Federal requirements. In 

addition, the Commission was unable to demonstrate that it deployed sufficient control activities 

through established policies and procedures to permit corroboration of management’s assertions 
7 

over internal controls. Further, we gave the Commission ample opportunity to thoroughly 

explain its grant reporting process. 

To provide support for questioned costs, the Commission has agreed to crosswalk information 

from the SAP system to its grant accounting subledgers. Specifically, the Commission will

recalculate a compensation and fringe rate for each employee, based on the costs for each pay 

period, and apply that rate against the actual hours recorded on the grants for all reporting 

periods in question. The Commission’s target date for resolving all questioned costs is 

December 31, 2020. 

In addition, to improve its financial management system, the Commission will explore methods 

for identifying grant-related personnel expenses in SAP to provide a clearer link to these costs in 

its subledgers. The Commission will provide these data to the FWS to demonstrate that grant 

claims can be reconciled to actual expenditures. The Commission proposes to have an enhanced 

financial management system in place no later than December 31, 2024. 

Based on the Commission’s and the FWS’ responses, we consider Recommendations 1 and 2 

resolved but not implemented (see Appendix 4). 
8 

Appendix 1

Commonwealth of Pennsylvania

Fish and Boat Commission 

Grants Open During the Audit Period

July 1, 2016, Through June 30, 2018 

Grant No.

Grant 

Amount ($)

Claimed 

Costs ($)

Questioned

Costs ($)

F10AF00430 4,706,400 4,684,889 0

F16AF00090 538,864 608,102 313,404

F16AF00091 5,411,641 5,388,094 3,434,796

F16AF00101 1,470,000 1,481,059 885,594

F16AF00105 2,400,000 1,670,624 1,004,240

F16FA00625 308,032 269,082 175,887

F16AF00768 730,500 21,334 13,887

F17AF00084 2,448,000 2,119,869 1,289,618

F17AF00085 5,152,030 5,663,306 3,284,063

F17AF00086 1,502,340 1,590,486 932,474

F17AF00087 549,642 794,868 301,494

F17AF00731 311,112 326,793 220,519

F17AF00903 1,912,000 131,238 47,982

F18AF00116 2,496,960 1,959,224 1,140,793

F18AF00122 560,635 987,030 299,754

F18AF00123 1,535,391 1,824,488 871,376

F18AF00159 5,389,289 6,239,195 3,485,149

Totals $37,422,836 $35,759,681 $17,701,030
9 

Appendix 2

Commonwealth of Pennsylvania

Fish and Boat Commission 

Sites Visited

Headquarters

Harrisburg, PA 

Regional Offices

Central Region

Northwest Region 

Fish Hatcheries

Benner Spring 

Fairview

Huntsdale 

Linesville

Reynoldsdale 

Union City 

Boating Access

Elk Creek

Kyle Lake

Lake LeBoeuf

Tamarack Lake

Walnut Creek
10 

Appendix 3

Commonwealth of Pennsylvania

Fish and Boat Commission 

Responses to Draft Report

The Commonwealth of Pennsylvania’s Fish and Boat Commission’s response to our draft report 

follows on page 11. The U.S. Fish and Wildlife Service’s response to our draft report follows 

on page 14. 
Pennsylvania Fish & Boat Commission 

established 1866 

OFFICE OF ADMINISTRATION 

P.O. Box 67000 

H ARRlSBURG, PA 17106-7000 

1111111111111 FAX: (717) 705-7802 

@P.\ .GO\' 

March 11, 2020 

, Grants Fiscal Officer 

Wildlife and Sport Fish Restoration Program 

U.S. Fish and Wildlife Service 

300 Westgate Center Drive 

Hadley, MA 01035 

The Pennsylvania Fish & Boat Commission (Commission) has reviewed the Draft Audit 

Report-US. Fish and Wildlife Service Wildlife and Sport Fish Restoration Program Grants 

Awarded to the Commonwealth of Pennsylvania, Fish and Boat Commission, From July 1, 2016, 

Through June 3 0, 2018 Report and appreciates the opportunity to provide comments. Since 

Generally Accepted Government Auditing Standards state that the purpose of providing a draft 

report with findings for review and comment by the audited entity is to help the auditors develop a 

report that is fair, complete, and objective, these written comments will primarily serve to 

demonstrate why the Commission firmly believes this audit finding does not offer an accurate 

representation of its accounting for and internal controls over Federal grant reporting. 

In accordance with 2 C.F.R. §200.302(a), the Commission is required to use the 

Commonwealth's SAP system to record all revenues and expenditures - including total 

compensation and fringe benefit costs; and therefore, these costs are not only incorporated into the 

official records of the State, but also comply with the State's established accounting policies and 

practices. Additionally, the Commission is able to produce reports indicating that it maintains 

accurate records for the identification of all federal awards in sufficient detail to fulfill the 

requirements of2 C.F.R. §200.302(b)(l). However, in an effort to properly support the distribution 

of an employee's salary or wages among specific Federal activities, the Commission allocates the 

compensation costs from SAP in a separate sub-ledger (i.e. Excel). Notably, all the information 

used to prepare the grant requests is derived from the SAP system, and the costs are traceable from 

the (1) Grant Funding request to the (2) Sub-ledger, and back to the (3) Time and Activity reports; 

and all of this information can be traced to the SAP system through SAP payroll reports. 

According to 2 C.F.R. §200.430(i)(iv) these records must "encompass both federally 

assisted and all other activities compensated by the non-Federal entity on an integrated basis, 

but may include the use of subsidiary records as defined in the non-Federal entity's written 

Our Mission: www.fishandboat.com 

To protect, conserve and enhance the Commonwealths aquatic resources and provide fishing and boating opportunities. 

11 
Ms.­ March 11 , 2020 

Page 2 

policy. " Thus, the Commission affim1s that this audit conclusion does not appear to be 

substantiated, and arguably conflicts with the applicable statutes. To comply with Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, the 

Commission has made a concerted effort to ensure that its allocated costs are reasonable, 

consistent, and that they conform to established written policies. Additionally, charges to federal 

awards for salaries and wages must be based on records that accurately reflect the work 

performed. Therefore, to be in compliance with time and effort requirements, employees of the 

Commission submit bi-weekly Time and Activity Reports, which are duly authorized, reviewed 

and approved, and clearly detail the exact number of hours worked on all grant and non-grant 

activity. Since most employees work on more than one federally funded grant or project, all 

hours are supported by these detailed personal activity reports and they serve as the basis for 

allocating all direct compensation and fringe benefit costs. The Commission takes great 

measures to ensure that the hours on the Time and Activity Reports are properly recorded, as 

evidenced by its strong system of internal controls. An internal audit process is performed after 

the reports are reviewed and approved by an employee's supervisor, and importantly, prior to 

any drawdown or funding requests being charged against a grant. 

Time and Activity Reports for each pay period are submitted from the various field 

offices every two weeks. These reports summarize hours worked on applicable projects, 

including any federally funded grant project. Once approved by the responsible supervisor or 

manager, the data is recorded in the Commonwealth's accounting system (SAP) by timekeepers 

for each bi-weekly payroll. Copies of these Time and Activity Reports are then forwarded to the 

Federal Aid Section for subsequent review by the Grant Accounting Specialist. This internal 

audit function is designed to offer objective assurance that the employees' time and activity is 

properly recorded. Once the Grant Accounting Specialist is satisfied that the time recorded is 

eligible to be charged to each project, she posts the hours, by employee, to the appropriate 

project accounting file in a subsidiary ledger. Care is also taken to ensure that the postings are 

applicable to the respective grant period and that all records are properly retained. Once all the 

information is summarized by project, the Federal Program Manager reviews all charges and 

then prepares scheduled, semi-annual or periodic Grant Funding request. As a result, the 

Commission maintains that its control activities contribute to the mitigation of risk ( especially as 

it pertains to federal grant requests). The Commission also believes that it deploys control 

activities through established policies which put the procedures into action. Considering the 

auditors should be able to corroborate management's assertions over its internal controls, the 

audit report should be modified accordingly. 

The Commission does acknowledge that a composite rate has been used to systematically 

and rationally allocate allowable fringe benefit costs. Nonetheless, 2 C.F.R. §200.43l(d) states 

the following: "Fringe benefits may be assigned to cost objectives ... by allocating on the basis of 

entity wide salaries and wages of the employees receiving the benefits, " and the Commission is 

able to demonstrate that these costs in relationship to the salaries and wages do not differ 

significantly for different groups of its employees. The Commission further recognizes that the 

fringe benefit component of the composite rate calculation was based upon the prior year's actual 

costs, though it adamantly refutes the audit report's claim that the composite rate is a mere 

estimate. Unfortunately, this undermines the reality that the use of prior year's cost is predicated 

on the expectation that benefit costs are likely to increase the following year, thus creating a 

12 
March 11, 2020 

Page 3 

conservative approach for the Commission to charge Federal grants. And, despite the fact that 

Uniform Guidance was intended to ease the administrative burden on Federal award recipients, 

the Commission believes that it has consistently applied the general meaning of the law. But be 

that as it may, the Commission agrees, in an effort to support total questioned costs, it will take 

whatsoever steps that are necessary to substantiate the direct costs (and the indirect costs). 

Notwithstanding our disagreement with the audit findings, to the satisfaction of the U.S. 

Fish and Wildlife Service, the Commission fully intends to resolve the questioned costs and, in 

an attempt to reduce the chance of receiving any future audit findings, will also explore all 

available options to more fully utilize the Commonwealth's SAP accounting system. The 

Commission believes that it maintained sufficient and appropriate evidence to support the 

$17,701 ,030 in questioned costs and emphasizes its position that if the Commission had been 

afforded the opportunity to adequately explain its grant reporting processes thoroughly, the 

auditors likely would have disabused themselves of at least some of their notions. As such, the 

Commission will crosswalk information from the SAP system to its grant accounting subledgers. This will be accomplished by re-calculating a compensation and fringe rate for each 

employee, based on the costs for each pay period, and applying that factor against the actual 

hours previously recorded on the grants for all grant reporting periods in question. The 

Commission is unequivocally confident that the results will confirm and prove that its charges to 

the Wildlife and Sport Fish Restoration Program grants were fully supported. 

Federal Program Manager for the Commission, will conduct a full 

review of the grants identified in the audit finding. Given the number of grants to be examined 

and the volume of personnel charging to each grant, the process will be lengthy; however, the 

Commission's target date for resolving all questioned costs is December 31 , 2020. 

- will also be the team lead to improve the Commission's financial 

management system. Methods for identifying grant-related personnel expenses in SAP will be 

explored to provide a clearer link to these costs in Commission sub-ledgers. Upon 

implementation of suitable improvements, grant costs will be accrued for a minimum of 12 

months; this data will be provided to WSFR to demonstrate grant claims can be reconciled to 

actual expenditures. To ensure sufficient testing of available SAP options, allow adequate time 

to capture costs using improved methods, and review of the dataset by WSFR staff, the 

Commission proposes to have an enhanced financial management system in place by no later 

than December 31, 2024. 

Thank you for the opportunity to provide comment on the draft audit report. We 

respectfully request that our response be published in its entirety in the Office of Inspector 

General's final audit report. 

Sinc~ely, 

~'=J!zl(__J(_.R_~>--- Brian P. Barner 

Deputy Executive Director 

13 
 -

U.S. 

PJSHst~LIFH 

~~·o.,-r,,t', 

, -

' 

United States Department of the Interior 

FISH AND WILDLIFE SERVICE 

300 Westgate Center Drive 

Hadley, MA 01035-9589 

March 18, 2020 

In Reply Refer To: 

FWS/Region 5/WSFR 

Michael P. Colombo, Regional Manager, Western Region 

Office of Inspector General 

U.S. Department of the Interior 

2800 Cottage Way, Suite 

Sacramento, California 95825 

Dear Mr. Colombo: 

Attached is the Commonwealth of Pennsylvania’s Fish and Boat Commission’s (Commission), 

response to the Office of Inspector General’s Draft Audit Report No. 2019-WR-006. The Service 

has confirmed with the State these are the only comments they have on this Draft Report. 

The Service concurs with the auditors recommendations and has reviewed and accepted the 

State’s response. The Service fully anticipates that the Commission will be able to demonstrate 

adequate support to resolve the all of the questioned costs ($17,701.030) related to labor and 

indirect charges. 

The Service will work closely with the Commission staff in developing and implementing a 

corrective action plan that will resolve all of the findings and recommendations. 

Details on each recommendation: 

The Service is working with the Commission to demonstrate adequate support for labor 

costs charged to Program grants by reviewing labor hours and actual labor expenditures 

to verify that labor costs and related indirect costs are accurate, allowable and properly 

allocated to resolve the question costs. The official responsible for implementing these 

actions is Charlene Seifert, Federal Program Manager for the Commission. Target date 

for implementation is December 31, 2020. 

The Commission is exploring ways to improve their financial management system. This 

includes exploring methods to identify grant-related personnel expenses in the 

Commonwealth’s System Analysis and Program Development (SAP) accounting system 

in order to reconcile this information with Commission sub-ledgers. 

14
 

 

 

 

Upon implementation of improvements the Commission will demonstrate to the Service 

that they can reconcile grant claims to actual expenditures recorded in the SAP. The 

official responsible for leading the team to improve the Commissions financial 

management system is Charlene Seifert. Target date for implementation is December 31, 

2024. 

We note that the Commission, in their response to the draft audit report, requested that 

their full response be included in the final audit report. We respectfully ask that this 

request be met. 

Sincerely,

Colleen E. Sculley 

Chief, Division of Wildlife

 and Sport Fish Restoration 

Attachment 

15
16

Appendix 4 

Commonwealth of Pennsylvania

Fish and Boat Commission 

Status of Audit Recommendations

Recommendations Status Action Required

1 – 2 

We consider the 

recommendations resolved 

but not implemented.

U.S. Fish and Wildlife 

Service (FWS) regional 

officials concurred with the

recommendations and will 

work with the 

Pennsylvania Fish and 

Boat Commission to 

develop and implement a 

corrective action plan for 

these recommendations.

Complete a corrective action plan that

includes information on actions taken

or planned to address the

recommendations, target dates and

titles of the officials responsible for 

implementation, and verification that

FWS headquarters officials reviewed

and approved of the actions taken or 

planned by the State. 

We will refer the recommendations

not implemented at the end of 

90 days (after October 28, 2020) to 

the Assistant Secretary for Policy,

Management and Budget to track

implementation.
Report Fraud, Waste,

and Mismanagement

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employees, and the general public. We 

actively solicit allegations of any 

inefficient and wasteful practices, fraud, 

and mismanagement related to 

departmental or Insular Area programs 

and operations. You can report 

allegations to us in several ways.

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