OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OFTHE INTERIOR 

U.S. Fish and Wildlife Service Grants 

Awarded to the State of Wisconsin, 

Department of Natural Resources, 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 $159,000. 

Report No.: 2019-CR-023 September 2020 
 

 

 

 

 

 

 

 

OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

Memorandum 

To: Aurelia Skipwith 

Director, U.S. Fish and Wildlife Service 

From: Amy R. Billings 

Regional Manager, Central Region 

Subject: Final Audit Report – U.S. Fish and Wildlife Service Wildlife and Sport Fish 

Restoration Program Grants Awarded to the State of Wisconsin, Department of 

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

Report No. 2019-CR-023 

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

Wisconsin, Department of Natural Resources (Department), under grants awarded by the U.S. 

Fish and Wildlife Service (FWS) through the Wildlife and Sport Fish Restoration Program 

(Program). We conducted this audit to determine whether the Department used grant funds and 

State hunting and fishing license revenue for allowable fish and wildlife activities and complied 

with applicable laws and regulations, FWS guidelines, and grant agreements. The audit period 

included claims totaling $103 million on 27 grants that were open during the State fiscal years 

that ended June 30, 2017, and June 30, 2018. 

We found that the Department generally ensured that grant funds and hunting and fishing 

license revenue were used for allowable fish and wildlife activities and complied with applicable 

laws and regulations, FWS guidelines, and grant agreements. We noted, however, issues with 

real property reconciliations, equipment inventory and program income estimations. We 

questioned $103,235 ($77,426 Federal share) in payroll charges and a potential diversion of 

($112,639) in license revenue. 

We provided a draft of this report to the FWS. The FWS concurred with all nine 

recommendations, including the repeat recommendations, and will work with the Department to 

implement corrective actions. The full responses from the Department and the FWS are included 

in Appendix 4. We list the status of the recommendations in Appendix 5. 

Please provide us with a corrective action plan based on our recommendations by December 21, 

2020. The plan should provide information on actions taken or planned to address each 

recommendation, 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 303-236-9243. 

Office of Audits, Inspections, and Evaluations | Lakewood, CO 
 

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. 

2 
 

 

 

 

 

 

 

 

Table of Contents 

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

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

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

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

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

Prior Audit Coverage .................................................................................................................2 

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

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

Findings and Recommendations................................................................................................4 

Appendix 1: Grants Open During the Audit Period...................................................................... 14 

Appendix 2: Sites Visited ............................................................................................................. 16 

Appendix 3: Monetary Impact...................................................................................................... 17 

Appendix 4: Responses to Draft Report ....................................................................................... 18 

Appendix 5: Status of Recommendations..................................................................................... 23 
 

 

 

 

 

 

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 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 the States’ 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 if the State of Wisconsin, Department of Natural 

Resources (Department): 

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

related regulations, FWS guidelines, and grant agreements

• Used State 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 $103 million on the 27 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 Department’s headquarters office in Madison, WI, and visited 3 

fish hatcheries, 4 service centers, 2 satellite centers, 10 subawardee locations, 1 wildlife 

management area, and 2 other locations (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. 

1 
 

 

 

 

 

 

Methodology 

We conducted this 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

Department

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

in-kind contributions, and program income

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

were supportable

• Conducting site visits to inspect equipment and other property

• Determining whether the Department used hunting and fishing license revenues solely for

the administration of fish and wildlife program activities

• Determining whether the State 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 Department’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 Department 

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

other supporting data. 

Prior Audit Coverage 

On September 15, 2014 we issued the audit report, U.S. Fish and Wildlife Service Wildlife and 

Sport Fish Restoration Program Grants Awarded to the State of Wisconsin, Department of 

2 
 

 

 

 

 

 

 

Natural Resources, From July 1, 2011, Through June 30, 2013 (Report No. R-GR-FWS-0006-

2014). 

We followed up on all three recommendations from our prior report and found that the U.S. 

Department of the Interior, Office of the Assistant Secretary for Policy Management and Budget 

(PMB) considered two recommendations as resolved and implemented and one recommendation 

as resolved but not yet implemented. 

Additionally, we followed up on one unimplemented recommendation from our report, U.S. Fish 

and Wildlife Service Wildlife and Sport Fish Restoration Program Grants Awarded to the State 

of Wisconsin, Department of Natural Resources, From July 1, 2007, Through June 30, 2009 

(Report No. R-GR-FWS-0011-2010), issued on November 22, 2010. As discussed in the 

“Findings and Recommendations” section of this report, we are repeating two unimplemented 

recommendations, which deal with the inadequate control of real property (unreconciled real 

property, Report No. R-GR-FWS-0011-2010, and noncertified grant funded real property as 

being used for its intended purposes, Report No. R-GR-FWS-0006-2014) and we will continue 

tracking the unimplemented recommendations with the prior audit reports. 

We reviewed single audit reports for SFYs 2017 and 2018. None of these reports contained any 

findings that would directly affect the Program grants. 

3 
 

 

 

 

 

 

 

 

 

 

 

 

 

Results of Audit 

Audit Summary 

We found that the Department complied, in general, with applicable grant agreement provisions 

and requirements of the Acts, regulations, and FWS guidance. We identified, however, the 

following conditions that resulted in our findings including questioned costs totaling $103,235. 

A. Questioned Costs $103,235 ($77,426 Federal share) – Unsupported Payroll

Expenditures. We questioned $103,235 as unsupported payroll expenditures. The

Department could not reconcile its payroll costs to the State Comptroller’s general ledger

cost.

B. Potential Diversion of License Revenue – $112,639. The Department used license

revenue funds to purchase equipment that was used within a State park or State forest

campground instead of for the administration of the program.

C. Inadequate Equipment Inventory. The Department implemented a new Asset

Management System in October 2015 but has yet to conduct a physical equipment

inventory verification since that time.

D. Lack of Documentation on Grant Applications. The Department failed to document

estimated program income on SF-424s when submitting its grant applications.

E. Repeat Finding – Inadequate Control of Real Property Records. The Division has not

reconciled its Program-funded real property records with the FWS.

Findings and Recommendations 

A. Questioned Costs $103,235 ($77,426 Federal share) Unsupported Payroll

Expenditures

The Department’s Human Capital Management (HCM) data did not reconcile to the 

Department’s general ledger data, resulting in questioned costs of $103,235 ($77,426 Federal 

share). The Department implemented State Transforming Agency Resources (STAR), a new 

accounting system, in SFY 2016. 

STAR connects more than 120 of the State’s IT software and systems into one comprehensive 

system. STAR’s Accounting Solution contains the general ledger data, and the HCM Solution 

contains all of the time and labor, benefits, and payroll data. 

We identified multiple variances in the pay period data downloads received from both the HCM 

and the Department’s general ledger for SFYs 2017 and 2018. The Department appeared to 

overstate the payroll expenses by $72,464 ($54,348 Federal share) for SFY 2017, and $30,771 

($23,078 Federal share) for SFY 2018. These overstatements are outlined in Figure 1. 

4 
 

 

Figure 1: Overstatements of Payroll Expenses for SFYs 2017 and 2018 

State Fiscal Year 2017 State Fiscal Year 2018 

Pay General Variance General Variance 

Period Ledger ($) HCM ($) ($) Ledger ($) HCM ($) ($) 

1 7,900,653 7,900,655 -2 7,863,827 7,863,826 1 

2 7,997,193 7,997,390 -197 7,817,863 7,817,863 – 

3 7,965,880 7,965,899 -19 8,032,843 8,032,843 – 

4 7,961,521 7,959,061 2,460 8,139,850 8,139,850 – 

5 7,959,171 7,958,251 920 8,035,619 8,036,289 -670

6 7,904,508 7,904,506 2 8,119,472 8,119,472 – 

7 6,503,005 6,502,987 18 6,707,376 6,714,219 -6,843

8 8,061,891 8,061,891 – 8,310,562 8,310,179 383

9 8,262,246 8,262,246 – 8,179,487 8,182,972 -3,485

10 8,150,147 8,150,614 -467 8,420,570 8,420,555 15 

11 9,357,079 9,354,806 2,273 8,742,345 8,742,345 – 

12 8,398,268 8,362,786 35,482 9,891,670 9,891,670 – 

13 8,487,171 8,487,900 -729 8,764,187 8,769,855 -5,668

14 8,384,338 8,367,343 16,995 8,652,580 8,650,486 2,094

15 8,503,162 8,501,566 1,596 8,462,001 8,464,201 -2,200

16 8,372,454 8,370,074 2,380 8,420,037 8,413,800 6,237

17 8,472,637 8,472,870 -233 8,475,941 8,455,878 20,063 

18 8,347,721 8,346,353 1,368 7,099,713 7,089,871 9,842 

19 8,331,662 8,329,719 1,943 8,469,273 8,469,272 1 

20 6,766,161 6,759,572 6,589 8,262,324 8,262,324 – 

21 8,145,240 8,147,431 -2,191 8,318,836 8,318,687 149 

22 8,086,511 8,086,511 – 8,150,477 8,150,477 – 

23 8,026,910 8,026,910 – 8,126,307 8,126,307 – 

24 8,005,539 8,006,249 -710 7,928,366 7,928,366 – 

25 8,196,370 8,194,988 1,382 7,957,192 7,957,192 – 

26 8,528,401 8,524,797 3,604 8,385,234 8,374,382 10,852 

5 
 

 

 

 

 

 

 

 

 

 

 

 

State Fiscal Year 2017 State Fiscal Year 2018 

Pay 

Period 

General 

Ledger ($) HCM ($) 

Variance 

($) 

General 

Ledger ($) HCM ($) 

Variance 

($) 

Total Variance $72,464 $30,771 

SFYs 2017 and 2018 Total Variance $103,235 

($77,426 Federal share) 

The Department told us that it brought this to the attention of the State Comptroller 3 different 

times, each at state fiscal year end, since the new financial system has been in place (October 

2015). The State Comptroller told the Department that there were no variances in its data and 

that no further action was needed. 

According to 2 C.F.R. § 200.430(i)(1), Federal awards for salaries and wages must be based on 

records that accurately reflect the work performed. In addition, 2 C.F.R. § 225, Appendix A, C 

(1)(j) states that costs must be adequately documented in order to be allowable under Federal 

awards. 

Without adequate controls and reconciliations, the Department may have been reimbursed for 

payroll costs totaling $103,235 ($77,426 Federal share) that did not represent the actual number 

of hours employees worked on Program grants. 

Recommendations 

We recommend that the FWS work with the Department to: 

1. Resolve the unsupported questioned costs of $103,235 ($77,426 Federal

share)

2. Develop and implement a process that ensures payroll expenses reconcile

with personnel activity reports reflecting actual time worked

Department Response 

In response to recommendation 1, the Department stated that it provided a complete 

reconciliation of the payroll for SFY 2018 on January 7, 2020. Further, the Department stated it 

was waiting to proceed with the reconciliation for SFY 2017 until the OIG auditors confirmed 

that the SFY 2018 reconciliation was sufficient. The Department concurred with 

recommendation two and is working with the State Comptroller’s Office to obtain the necessary 

reports to complete its reconciliation. 

FWS Response 

The FWS concurred with our recommendations and will work with the Department on a 

corrective action plan. 

6 
 

 

 

 

 

 

 

 

 

 

 

 

 

OIG Comment 

We received the Department’s reconciliation for SFY 2018 on January 7, 2020; however, the 

information was provided after the end of our fieldwork and therefore we did not verify the 

information. We will defer to the FWS to determine if the reconciliation is sufficient. Based on 

the Department and FWS responses, we consider the recommendations resolved but not 

implemented (See Appendix 5). 

B. Potential Diversion of License Revenue – $112,639

The Department potentially diverted $112,639 in license revenue funds by using equipment 

partially purchased with license revenue for purposes other than the administration of the State 

fish and wildlife agency. Specifically, we found a copy machine, storage shed, and a tractor 

being used at a state forest campground and a skid-steer used at a state park, all partially paid for 

by license revenue funds. None of these items were being used for the administration of the State 

fish and wildlife agency. 

The potential diversion of license revenue jeopardizes the State’s continued participation in the 

Program and brings into question whether fish and wildlife resources appropriately benefitted 

from the funds. See Figure 2 for a breakdown of the costs associated with the potential diversion. 

Figure 2: Equipment Identified as Potential Diversion 

Equipment Cost ($) 

Copier 3,827 

Skid-steer 33,410 

Unheated storage shed 4,999 

Terrain cut mower 70,403 

Total $112,639 

According to Federal regulation, 50 C.F.R. § 80.11, a State becomes ineligible under the 

Program if it diverts hunting and fishing license revenues for purposes other than the 

administration of the State fish and wildlife agency. Further, 50 C.F.R. § 80.10(c)(2) also 

explains that only the functions required to manage and administer the State’s fish and wildlife 

resources may be supported with license revenue. 

The Department uses an allocation formula when purchasing equipment for the Fish, Wildlife 

and Parks Division and Forestry Division. This allocation formula includes the use of license 

revenue funds to purchase equipment items for use in the state parks and state forest areas 

resulting in a potential diversion issue. 

7 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Recommendations 

We recommend that the FWS work with the Department to: 

3. Verify that expenditures ($112,639) paid with license revenue and fees are

eligible and appropriate

4. Establish policies and procedures to ensure that license revenues are used

solely for the administration of the State’s fish and wildlife program activity

Department Response 

The Department did not concur with these recommendations. It considered the $112,639 in 

expenses partially paid with license revenue and fees to be appropriate and consistent with the 

cost allocation process established by the Department. In addition, the Department stated that its 

policies and procedures protect license revenue. 

FWS Response 

The FWS concurs with our recommendations and will work with the Department on a corrective 

action plan. 

OIG Comment 

As stated in our finding, we found equipment that was partially purchased with license revenue 

funds; however, that equipment was not being used for the administration of the State fish and 

wildlife agency, as required by regulation. Based on the Department’s response, we consider this 

recommendation unresolved (see Appendix 5). 

C. Inadequate Equipment Inventory

The Department did not verify personal property (equipment) after converting to the finance and 

procurement modules of PeopleSoft. 

The asset management system, part of the procurement module, went active in October 2015. 

Since then, the Department has failed to develop policies and procedures that would require 

physical verification of all equipment—including all hunter education firearms—every 2 years. 

Since October 2015, the headquarters has not physically verified equipment and the Department 

has not required its equipment custodians to verify equipment. 

We identified multiple verification issues that could have been avoided if the Department had 

implemented an asset verification program after converting its equipment inventory to the new 

system. For example, out of the 65 items tested, we found: 

• Two instances where the serial number was recorded incorrectly

• Three instances where the custodian changed

8 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

• One instance where the cost of an item in the inventory was actually the total cost of

multiple items purchased at the same time

• One instance where the cost of the item was overstated by $137,786

In addition, the Department does not have a comprehensive list of hunter education firearms (live 

fire and nonfiring) to include locations and property custodians. A Department official told us 

that only the firearms verified before the conversion were part of the new inventory. Because the 

Department does not have a comprehensive list, we do not know how many unverified firearms 

the Department owns. 

In addition, the Department has not conducted an asset verification since the conversion to the 

new asset management system in October 2015. We also found that the Department’s 

headquarters has not conducted a physical inventory of equipment. Of the 11 employees we 

interviewed who stated they were equipment custodians, 10 stated that no one from headquarters 

or the region had conducted physical inventory of the equipment since converting to the asset 

management system in SFY 2016. The one remaining employee was uncertain of when the last 

physical inventory occurred. 

According to 2 C.F.R. § 200.313(d), organizations must: 

1. Maintain property records including a description of the property; a serial number or

other identification number; the source of funding for the property; the Federal Aid

Identification number; who holds title; the acquisition date; the cost of the property; the

percentage of Federal participation in the project costs for the Federal award under which

the property was acquired; and the location, use, and condition of the property

2. Conduct a physical inventory of the property and reconcile the results with the property

records at least once every 2 years

3. Develop a control system to adequately safeguard against loss, damage, or theft of the

property

The Department did not require a physical equipment verification after the conversion to ensure 

all equipment was appropriately transferred into the new system or to identity what equipment 

was not transferred into the new system. Only verified equipment was converted into the new 

system, but the Department did not follow up on the status of unverified equipment. Further, the 

Department did not have a program in place to require physical equipment verification of its 

equipment inventory items in the asset management system. Without proper physical equipment 

verification, equipment purchased with Program funds and license revenue are at risk of loss, 

theft, or mismanagement. 

9 
 

 

 

 

 

 

 

 

 

 

 

Recommendations 

We recommend that the FWS work with the Department to: 

5. Conduct a physical equipment verification, including hunter education

firearms, and ensure records are complete and accurate

6. Establish policies and procedures to address equipment verification

requirements to include maintaining accurate equipment records and

conducting physical inventories at least every 2 years

Department Response 

The Department concurred with these recommendations and is developing a process to conduct a 

physical inventory of all equipment records at least every 2 years. 

FWS Response 

The FWS concurs with our recommendations and will work with the Department on a corrective 

action plan. 

OIG Comment 

Based on the Department and FWS’ responses, we consider the recommendations resolved but 

not implemented (see Appendix 5). 

D. Lack of Documentation on Grant Applications

The Department did not always include estimated program income on the initial SF-424, 

Application for Federal Assistance, nor did the Department request approval to change its 

method of reporting program income from deductive (default method) to the additive method, as 

required. 

For example, the Department did not include the estimated program income on the initial SF-424 

for Grant No. F17AF00565. The first modification for this grant, however, showed an estimated 

program income amount but did not indicate that the method of reporting program income would 

change from the default method. Neither the FWS nor the Department indicated a change in the 

reporting method. However, when the Department submitted the Federal Financial Report (SF425) at the end of the grant period, the method in reporting the program income changed from

deductive to additive without documented approval from the FWS.

The FWS acknowledged the estimated program income but did not note a change in the 

reporting method. This was also true for Grant Nos. F17AF00568 and F16AF00822. For Grant 

No. F17AF00568, when the Department asked for an updated award letter to show that the 

additive method was requested for reporting program income, the FWS informed the Department 

that an updated letter was not necessary. 

Federal regulation, 50 C.F.R. § 80.82 (c) (8) (i) (ii) (iii), requires that State fish and wildlife 

agencies include the estimated amount of program income that the project is likely to generate on 

10 
 

 

 

 

 

 

 

 

 

 

 

 

the SF-424, indicate the method of applying the program income to Federal and non-Federal 

outlays, and request the Regional Director’s approval for the matching method. 

Further, 2 C.F.R. § 200.307 (e) (1) (2) states that program income must be deducted from total 

allowable costs to determine the net allowable costs and must be used for current costs unless the 

Federal awarding agency authorizes otherwise. Program income that the non-Federal entity did 

not anticipate at the time of the Federal award must be used to reduce the Federal award and nonFederal entity contributions rather than to increase the funds committed to the project. With prior 

approval from the Federal awarding agency, program income may be added to the Federal 

award. 

The Department had no policies and procedures to ensure that SF-424s were submitted with 

proper information for estimated program income and its reporting method. In addition, the FWS 

did not always inform the Department when it found errors and did not require additional or 

corrected documents. 

Without the estimated program income on the initial grant application—the SF-424—the FWS 

cannot accurately address and anticipate proper administration of the Program grant funds. This 

will be of greater importance as the FWS implements the cost sharing method of reporting its 

program income. 

Recommendation 

We recommend that the FWS work with the Department to: 

7. Establish policies and procedures that will address:

(a) required documentation when submitting the initial SF-424

(b) a proper process for changing the program income reporting methods

Department Response 

The Department concurred with this recommendation. The Department implemented new 

procedures and modified the project/budget narrative template to include anticipated program 

income. If the Department identifies program income that was not anticipated or if it needs to 

change the program income calculation method, it will request an administrative 

amendment/modification through the WSFR standard process. 

FWS Response 

The FWS concurs with our recommendation and will work with the Department on a corrective 

action plan. 

OIG Comment 

Based on the Department and FWS’ responses, we consider the recommendations resolved but 

not implemented (see Appendix 5). 

11 
 

 

 

 

 

 

 

 

 

 

 

E. Repeat Finding – Inadequate Control of Real Property Records

In our prior report (Report No. R-GR-FWS-0011-2010), we noted that the Department had not 

reconciled its Program-funded, real property records with the FWS. We recommended that the 

FWS ensure that the Department reconciles its real property records with FWS’ records. This 

recommendation was still open at the time of our audit. Also, in another prior report (Report No. 

R-GR-FWS-0006-2014) we found that the Department had not certified that its grant-funded real

property is being used for its intended purposes.

According to 50 C.F.R. § 80.90(b)(2) and 50 C.F.R. § 80.90(f), respectively, a State fish and 

wildlife agency, as a grantee, is responsible for maintaining records and control of all assets 

acquired under the grant to ensure that the grants serve the intended purpose 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 Department must report the status of the property to the FWS at least 

every 5 years. 

Until the Department and the FWS complete a reconciliation of real property records, neither 

party can fully ensure that lands acquired under the Program are being used for their intended 

purposes. We are therefore repeating the recommendations from our prior audit reports. The 

FWS should submit any documentation to the PMB to track implementation under the prior 

audits. 

Repeat Recommendation (Tracked Under Report No. R-GR-FWS-0011-2010, 

Recommended No. B) 

We recommend that the FWS ensure the Department reconciles its real property 

records with FWS’ records. 

Department Response 

The Department reconciled its real property records with the FWS’ records as of May 25, 2020. 

FWS Response 

The FWS has received, reviewed, and accepted the supporting documentation from the 

Department and considers this recommendation resolved and implemented. 

OIG Comment 

Based on the Policy, Management and Budget Disposition of Finding B of Report No. R-GRFWS-0006-2014, we consider the recommendation resolved and implemented (see Appendix 5). 

Repeat Recommendation (Tracked Under Report No. R-GR-FWS-0006-2014, 

Recommended No. B) 

We recommend that the FWS require the Department to certify that grant-funded real 

property is being used for its intended purposes. 

12 
 

 

Department Response 

The Department certified that its grant-funded real property is being used for its intended 

purposes. 

FWS Response 

The FWS has received, reviewed, and accepted the supporting documentation from the 

Department and considers this recommendation resolved and implemented. 

OIG Comment 

Based on the Policy, Management and Budget Disposition of Finding B of Report No. R-GRFWS-0006-2014, we consider the recommendation resolved and implemented (see Appendix 5). 

13 
 

 

 

Grant No. Grant Amount ($) Claimed Costs ($) 

F13AF00212 871,211 $882,564 

F13AF00610/F13AF01159 11,791,880 9,122,063 

F13AF01116 1,469,776 1,227,799 

F14AF00464 759,011 491,804 

F14AF00470 602,842 254,106 

F14AF00474 548,200 580,824 

F14AF01334 198,166 186,216 

F14AF01368 723,851 553,169 

F15AF00417 1,184,382 322,787 

F15AF00420 1,470,715 897,757 

F15AF00762 265,308 265,308 

F15AF00828 147,539 147,539 

F15AF01111 790,556 490,646 

F16AF00822 19,667,727 22,067,746 

F16AF00823 19,000,369 19,621,333 

F16AF01147 146,739 2,746,993 

F16AF01150 344,957 302,520 

F17AF00160 1,343,830 0 

F17AF00182 962,168 0 

F17AF00565 19,765,827 19,257,114 

F17AF00568 22,330,547 23,603,868 

F17AF00651 147,539 -1,940

F17AF00668 344,957 0 

F17AF01133 4,433,030 7,563 

F18AF00085 1,333,334 0 

F18AF00293 100,000 0 

Appendix 1: Grants Open During the 

Audit Period 

State of Wisconsin 

Department of Natural Resources 

Grants Open During the Audit Period 

July 1, 2016, Through June 30, 2018 

14 
Grant No. Grant Amount ($) Claimed Costs ($) 

F18AF00691 843,947 0 

Total $111,588,407 $103,027,779 

15 
 

 

 

 

 

Appendix 2: Sites Visited 

State of Wisconsin 

Department of Natural Resources 

Sites Visited 

Headquarters 

Madison, WI 

Fish Hatcheries 

Nevin 

Osceola 

St. Croix Falls 

Service Centers 

Eau Claire 

Fitchburg 

Green Bay 

Oshkosh 

Satellite Centers 

Black River Falls 

Plymouth 

Subawardee Locations 

Barron Co. Maple Plains Shooting Range 

Boulder Junction Shooting Range 

City of Rhinelander - Boyce Drive Boat Landing 

Florence Co. Menominee River Boat Launch and Access Road 

Hudson Rod, Gun and Archery Club 

Izaak Walton League of America, Indoor Range 

Machickanee Forest Shooting Range Renovations 

North Freedom Boat Launch 

Osceola Rod and Gun Club 

Rice Lake Archery Park 

Wildlife Management Area 

Muddy Creek 

Other 

Black River State Forest Castle Mound Campground 

Interstate Park 

16 
Finding Area Amount ($) 

Unsupported Payroll Expenditures 103,235 

Total $103,235 

Monetary Impact: Potential Diversion of License Revenue 

Finding Area Amount ($) 

Personal Property (Equipment) 112,639 

Total $112,639 

Appendix 3: Monetary Impact 

Monetary Impact: Questioned Costs 

17 
 

 

 

Appendix 4: Responses to Draft Report 

The U.S. Fish and Wildlife Service’s response to our draft report follows on page 19. The 

Wisconsin Department of Natural Resources response to our draft report follows on page 20.

18 
 

 

 

U.S. FISH & WILDLIFE SERVICE 

United States Department of the Interior 

FISH AND WILDLIFE SERVICE 

Wildlife and Sport Fish Restoration Programs 

5600 American Boulevard West, Suite 990 

Bloomington, Minnesota 55437-1458 

IN REPLY REFER TO: 

FWS/R3/WSFR 

Memorandum 

To: Central Region Manager for Audits, Inspections, and Evaluations, Office of Inspector General 

From: Chief, Wildlife and Sport Fish Restoration Program 

Subject: Response to the Office of Inspector General’s Memorandum dated June 22, 2020 containing the 

OIG’s Draft Audit Report NO.: 2019-CR-023 on U.S. Fish and Wildlife Service Wildlife and 

Sport Fish Restoration grants administered by the State of Wisconsin, Department of Natural 

Resources 

Attached is a copy of the Wisconsin Department of Natural Resources response to the draft Office of 

Inspector General (OIG) audit report (see attachments). 

The Service concurs with OIG report recommendations. The Wisconsin Department of Natural 

Resources’ response to implement the recommendations will be considered in the corrective action plan. 

Attachments: 

as 

cc: USFWS, WO WSFR Compliance Branch (Mr. Ord Bargerstock) 

19
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Tony Evers, Governor

Preston D. Cole, Secretary 

Telephone 608-266-2621 

Toll Free 1-888-936-7463 

TTY Access via relay - 711 

 

State of Wisconsin 

DEPARTMENT OF NATURAL RESOURCES 

101 S. Webster Street 

Box 7921 

Madison WI 53707-7921 

Vllisconsin.gov Naturally WISCONSIN O .o~:NTED 

()('JG'COYCiFr. 

.''}f'iCli 

July 24, 2020 

Mr. James Hodgson, Chief 

Wildlife and Sport Fish Restoration Programs 

5600 American Boulevard West 

Suite 990 

Bloomington, MN 55437-1458 

Dear Mr. Hodgson: 

Thank you for providing the draft audit report from the Office of the Inspector General (OIG). We appreciate the 

feedback as well as the opportunity to respond to the report and provide additional information regarding the audit 

findings. 

There are 9 audit recommendations, with the WI DNR responses, as follows: 

1. Resolve the unsupported questioned costs of $103,235.

WI DNR Response: WI DNR supplied the auditors with a complete reconciliation of payroll for State Fiscal

Year 2018. This documentation was provided to the OIG auditors on January 7, 2020. WI DNR did not

receive any feedback or response to this information regarding whether the reconciliation was sufficient or if

any further action was needed. We have been awaiting a response from OIG before proceeding with the

reconciliation for FY 2017. Attached are the e-mails with the payroll reconciliation sent to the OIG auditors.

2. Develop and implement a process that ensures payroll expenses reconcile with personnel activity reports

reflecting actual time worked.

WI DNR Response: WI DNR concurs with this recommendation and is working with the WI State

Controller’s Office to obtain the necessary reports for WI DNR to complete this reconciliation for each

payroll.

3. Verify that expenditures ($112,639) paid with license revenue and fees are eligible and appropriate

WI DNR Response: WI DNR considers the expenses of $112,639 partially paid with license revenue and

fees to be appropriate and consistent with the cost allocation process established by the WI DNR. As such,

WI DNR does not concur with this recommendation.

The assets in question were purchased to support wildlife, fishing, parks, forestry and law enforcement

programs in the Department; therefore, the funding source for the assets is a blend of fish and wildlife

licensure revenue, parks revenue, and forestry revenue that is allocated based on acreage or staff activity

codes. Allocation formulas are reviewed and adjusted each year, as needed.

4. Establish policies and procedures to ensure that license revenues are used solely for the administration of

the State’s fish and wildlife program activity

WI DNR Response: As noted in item 3, policies and procedures within WI DNR do protect license revenue.

As such, WDNR does not concur with this finding. WDNR manages a wide variety of properties to provide

high quality outdoor recreation experiences and achieve natural resource management goals. WDNRowned properties include state parks, wildlife areas, fisheries areas, forests, natural areas, flowages,
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

trails, recreation areas, scenic areas, and more. Visitors seek quality experiences and robust populations 

of fish and wildlife, regardless of the formal property type. Just as wildlife and fishery areas are open for 

hiking, bird watching, and other types of non-consumptive recreation, hunting and fishing opportunities 

exist on many DNR properties not officially designated as “wildlife areas” or “fishery areas.” 

Of the ~1100 properties owned and managed by WDNR, more than 70% provide hunting access. These 

properties include traditional wildlife areas, but also state natural areas, state parks, fishery areas, state 

forests, state trails, and other property types. Fishing is allowed on nearly all WDNR properties with 

stream, river, or lake frontage. The OIG audit report identified two specific property types that were of 

concern relative to possible diversion of license revenue: state parks and state forests. More than 85% of 

Wisconsin State Parks provide hunting opportunities (including Interstate State Park) and more than 

80% provide fishing access (WDNR Bureau of Parks and Recreation, 7/16/20). Further, 100% of 

Wisconsin State Forests (including Black River State Forest) are open for hunting, fishing, and trapping 

during state-designated seasons (WDNR Division of Forestry, 7/16/20). 

Three main goals must be achieved in order to provide quality hunting/fishing experiences: 

1) Healthy harvestable fish/wildlife populations

2) Public access (e.g. land)

3) Supporting infrastructure (e.g. roads, parking lots, trails, restrooms, property maps, etc.)

Projects that achieve these goals do support administration of DNR’s fish and wildlife programs, 

regardless of the type of property on which the project occurs or other activities that may also be 

allowed on the property. 

5. Conduct a physical equipment verification, including hunter education firearms, and ensure records are

complete and accurate

WI DNR Response: WI DNR concurs with this recommendation and is developing a process to conduct a

physical inventory of all equipment records at least every 2 years.

6. Establish policies and procedures to address equipment verification requirements to include maintaining

accurate equipment records and conducting physical inventories at least every 2 years

WI DNR Response: WI DNR concurs with this recommendation and is developing a process to conduct a

physical inventory of all equipment records at least every 2 years.

7. Establish policies and procedures that will address: (a) required documentation when submitting the initial SF424 (b) a proper process for changing the program income reporting methods

WI DNR Response: WI DNR concurs with this recommendation. SF424 forms for grants F19AF00440 and

F19AF00441 were updated in September 2019 to reflect anticipated program income (PI). For all new grant

applications submitted since that time, DNR included anticipated PI for the proposed grant activities in

Section 18f of the SF424. DNR also modified the project/budget narrative template to include a section that

specifically identifies if PI is anticipated, the basis of the PI estimate, and the method through which PI will

be incorporated into the grant budget (additive, cost-share, or deductive). This narrative is submitted with

new WSFR grant applications.

During the period-of-performance, if DNR identifies PI that was not anticipated at the time of application or

identifies a need to change the PI calculation method, DNR will submit a request for administrative

amendment/modification through the standard processes identified by USFWS WSFR staff. The

administrative amendment/modification will serve as formal documentation of the PI addition or change.

21
 

 

8. We recommend that FWS ensure the Department reconciles its real property records with FWS’ records.

WI DNR Response: This audit finding was resolved and closed by FWS on 5/25/20.

9. We recommend that the FWS require the Department to certify that grant-funded real property is being

used for its intended purposes.

WI DNR Response: This audit finding was resolved and closed by FWS on 5/25/20.

Sincerely, 

Karen Van Schoonhoven 

Karen Van Schoonhoven, CPA 

Finance Director, WI Department of Natural Resources 

cc: Donna Zanger, WSFR R3 Fiscal Branch Chief 

U.S. Fish and Wildlife Service 

22
Recommendation Status Action Required 

1, 2, 5, 6, 7 

Resolved but not 

implemented: 

U.S. Fish and Wildlife 

Service (FWS) regional 

officials concurred with 

these recommendations 

and will work with staff 

from the Wisconsin 

Department of Natural 

Resources to develop 

and implement a 

corrective action plan. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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 the actions 

the State has taken or planned. 

We will refer the recommendations 

not implemented at the end of 90 

days (after December 21, 2020) to 

the Assistant Secretary for Policy, 

Management and Budget to track 

implementation. 

3,4 

Unresolved: 

FWS regional officials 

concurred with these 

recommendations and 

will work with staff from 

the Wisconsin 

Department of Natural 

Resources to develop 

and implement a 

corrective action plan. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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 the actions 

the State has taken or planned. 

We will refer the recommendations 

not implemented at the end of 90 

days (after December 21, 2020) to 

the Assistant Secretary for Policy, 

Management and Budget to track 

implementation. 

Repeat Recommendation 

B (Report No. R-GRFWS-0011-2010) 

Repeat Recommendation 

B (Report No. R-GRResolved and 

implemented No action is required. 

FWS-0006-2014) 

Appendix 5: Status of Recommendations 

23 
Report Fraud, Waste,

and Mismanagement

Fraud, waste, and mismanagement in

Government concern everyone: Office 

of Inspector General staff, departmental 

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.

 By Internet: www.doioig.gov

 By Phone: 24-Hour Toll Free: 800-424-5081

Washington Metro Area: 202-208-5300

 By Fax: 703-487-5402

 By Mail: U.S. Department of the Interior

Office of Inspector General

Mail Stop 4428 MIB

1849 C Street, NW.

Washington, DC 20240