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OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

U.S. Fish and Wildlife Service Wildlife and

Sport Fish Restoration Program

Issues Identified with State Land Reconciliation for Wildlife and 

Sport Fish Restoration Program Grants 

MANAGEMENT ADVISORY

Report No.: 2019-CR-015 April 2020
 

 

 

 

 

OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OFTHE INTERIOR 

Memorandum 

To: Aurelia Skipwith 

Director, U.S. Fish and Wildlife Service 

From: Melanie L. Sorenson 

Deputy Assistant Inspector General 

Office of Audits, Inspections, and Evaluations 

Subject: Management Advisory – Issues Identified with State Land Reconciliation for 

Wildlife and Sport Fish Restoration Program Grants 

Report No. 2019-CR-015 

The U.S. Fish and Wildlife Service (FWS) annually awards approximately $1 billion in 

grants to State fish and wildlife agencies through its Wildlife and Sport Fish Restoration 

Program, under the provisions of the Pittman-Robertson Wildlife Restoration Act and the 

Dingell-Johnson Sport Fish Restoration Act.1 Under the Program, States are required to maintain 

control of all assets and report the status of real property to the FWS at least every 5 years. 

According to FWS guidance, the States should reconcile their land records with the FWS to 

ensure that the States’ databases of real property purchased with Program funds are accurate and 

complete. 

During our audits of the grants awarded under the Program, we identified numerous 

instances in which the States had not completed the required land reconciliation as of 

October 2019.2 These States cannot ensure that the lands acquired under the Program are being 

used for their intended purposes (e.g., hunting and fishing) until they reconcile their records with 

the FWS’ land records. 

We identified 15 States that have not reconciled their real property records with the FWS’ 

records as required (see attached list).

3 Federal regulation, 50 C.F.R. § 80.90(f), requires that the 

State maintains control of all assets acquired under Program grants to ensure that they serve the 

purpose for which they were acquired throughout their useful life. Further, 2 C.F.R. § 200.329 

states that if the Federal interest in real property extends 15 years or longer, the State must report 

1 In this report, we use the term “State” to refer generally to any of the primary funding recipients, to include States, 

Commonwealths, Territories, or the District of Columbia. 2 The Wildlife and Sport Fish Restoration Programs Improvement Act of 2000 requires that recipients of Program grants be 

audited once every 5 years. We have an interagency agreement with the FWS to audit States receiving Program grants. We 

typically conduct more than 60 audits of Program grants during a 5-year period per this agreement. 3 Real property means land, including land improvements, structures and appurtenances thereto, but excludes moveable 

machinery and equipment according to 2 C.F.R. § 200.85. 

Office of Audits, Inspections, and Evaluations | Washington, DC 
 

 

 

 

 

 

 

 

 

the status of the property to the FWS at least every 5 years. According to information the FWS 

provided, 11 States have not completed a reconciliation in the past 5 years. Additionally, nine 

States have open recommendations on incomplete land reconciliations. 

The States must ensure that their databases of real property acquired with Program grant 

funds are accurate, complete, and reconciled with land records the FWS maintains. Otherwise, 

lands may be at risk of impacts such as encroachment or trespass from nearby landowners, or 

loss of control to other State agencies (e.g., another State division using the land for recreation 

rather than fish and wildlife purposes). 

Some of the States that do not have a current completed land reconciliation indicated that 

they have provided information to the FWS, but FWS has not completed its review. For the 

remaining States, both the FWS and the States need to finish additional work to complete the 

land reconciliation. States cannot ensure that lands are being used appropriately if they are not 

aware of or do not have concurrence from the FWS on which real property must be used to 

support the Program. 

We recommend the FWS: 

1. Develop and implement an action plan to require States that have not reconciled their 

records of lands purchased with Program funds for more than 5 years to do so by a 

specific date 

2. Establish and implement controls and timelines to ensure real property records are 

reconciled in a timely manner 

Please provide us with your written response by May 8, 2020. The response should 

provide information on the actions you have taken or planned to address the recommendations, 

as well as target dates and titles of the officials responsible for implementing these actions. 

Please send your response to aie_reports@doioig.gov. 

The information in this management advisory will be included in our semiannual report 

to Congress and posted on our website no later than 3 days from the date we issue it to you. 

Please contact Amy Billings at 303-236-9243, or me at 202-208-5745, if you have any questions. 

Attachment 

2 
 

 

 

 

 

 

Attachment: States Without Reconciled Real 

Property Records 

Reconciliation Open 

State Older Than 5 Years Recommendations 

Colorado* Yes 

Connecticut Yes 

Illinois Yes 

Kansas* Yes 

Minnesota Yes Yes 

Missouri Yes 

Montana* Yes 

Nebraska Yes Yes 

New York* Yes 

Rhode Island Yes 

South Dakota Yes Yes 

Utah Yes Yes 

West Virginia Yes 

Wisconsin Yes 

Wyoming Yes Yes 

Total 11 9 

*The U.S. Fish and Wildlife Service told us that these States 

completed their inventory. We, however, have no record of 

these States completing the inventory in the past 5 years. We 

determined that the States do not currently have a completed 

land reconciliation and still have open recommendations. 

Source: U.S. Fish and Wildlife Service and Office of Inspector 

General records. 

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