- -

OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

U.S. Fish and Wildlife Service Wildlife and 

Sport Fish Restoration Program Grants 

Awarded to the State of West Virginia, 

Division of Natural Resources, From 

July 1, 2016, Through June 30, 2018 

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 $59,000. 

Report No.: 2019-CR-041 July 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 West Virginia, Division of 

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

Report No. 2019-CR-041 

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

Virginia, Division of Natural Resources, under grants awarded by the U.S. Fish and Wildlife 

Service (FWS). The FWS provided the grants to the State under the Wildlife and Sport Fish 

Restoration Program. The audit included claims totaling approximately $46.2 million on 29 

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 Division’s compliance with applicable laws, 

regulations, and FWS guidelines, including those related to the collection and use of hunting and 

fishing license revenues and the reporting of program income. 

We found that the Division complied, in general, with applicable grant accounting and 

regulatory requirements. The Division, however, did not report barter transactions on the 

financial reports to the FWS as required. In addition, the Division and the FWS did not complete 

a required reconciliation of their respective real property inventories. 

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

recommendations and will work with the Division to implement corrective actions. In this report, 

we summarize the Division’s and FWS Region 5’s responses to our recommendations, as well as 

our comments on their responses. We list the status of the recommendations in Appendix 3. 

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 

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

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

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. 

If you have any questions regarding this report, please contact me at 303-236-9243. 

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

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

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

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

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

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

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

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

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

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

Appendix 1.......................................................................................................................................6 

Appendix 2.......................................................................................................................................8 

Appendix 3.......................................................................................................................................9 
 

 

 

 

 

 

 

 

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 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 West Virginia, Division of Natural 

Resources: 

• 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 $46.2 million on the 29 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 Division headquarters in South Charleston, WV, and visited three district offices, four fish 

hatcheries, five wildlife management areas, three boat ramps, two shooting ranges, and the State 

Wildlife Center (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 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. 

We assessed whether internal control was significant to the audit objective. We determined that 

the Division’s control activities and the following related principles were significant to the audit 

objective: 

• Management should design control activities to achieve objectives and respond to risks.

• Management should design the entity’s information system and related control activities

to achieve objectives and respond to risks.

• Management should implement control activities through policies.

We tested the operation and reliability of internal control over Program activities as related to 

our audit objective. Our tests and procedures included: 

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

Division

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

in-kind contributions, and program income

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

were supportable

• Visiting sites to inspect equipment and other property

• Determining whether the Division used hunting and fishing license revenue solely for the

administration of fish and wildlife program activities

• Determining whether the State passed required legislation assenting to the provisions of

the Acts

• Evaluating State policies and procedures for assessing risk and monitoring subawards

We found deficiencies in internal control resulting in our two findings of unreported barter 

transactions and unreconciled real property. 

Based on the results of our initial assessments, we assigned a level of risk and selected a 

judgmental sample of transactions for testing. The degree of testing performed in each area was 

2 
 

 

based on auditor judgment and considered risk levels relative to other audit work performed. Our 

sample selections were not generated using statistical sampling, and therefore we did not project 

the results of our tests to the total population of transactions. 

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 Division employees who 

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

data. 

Prior Audit Coverage 

On December 17, 2015, we issued U.S. Fish and Wildlife Service Wildlife and Sport Fish 

Restoration Program Grants Awarded to the State of West Virginia, Division of Natural 

Resources, From July 1, 2011, Through June 30, 2013 (Report No. R-GR-FWS-0013-2014). 

We followed up on all recommendations in the report and found that the U.S. Department of the 

Interior, Office of the Assistant Secretary for Policy, Management and Budget considered 14 

recommendations resolved and 1 recommendation related to real property resolved but not 

implemented. 

We reviewed single audit reports for SFYs 2017 and 2018. Neither of these reports contained 

any findings that would directly affect the Program grants. 

3 
 

 

 

 

 

 

 

 

 

 

 

Results of Audit 

Audit Summary 

We found that the Division 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. 

A. Unreported Barter Transactions. The Division did not report barter transactions on the 

financial reports. 

B. Unreconciled Real Property Records. The Division did not reconcile its Program-funded 

real property records with those of the FWS. 

Findings and Recommendations 

A. Unreported Barter Transactions 

The Division annually enters into noncash agreements (i.e., barter agreements) that allow 

farmers to grow crops on State wildlife and game areas in exchange for leaving a percentage of 

the crop to improve and maintain wildlife habitat for a variety of species, which directly relates 

to grant-supported wildlife management activities. The Division provided documentation of 

barter transactions that occurred during our audit period but did not report the barter transactions 

on its Federal Financial Reports (SF-425s) as required. Federal regulations require each State to 

report any barter transactions and what those transactions entail on its SF-425s. Title 

50 C.F.R. § 80.98 details that a State fish and wildlife agency must report the transactions in the 

“Remarks” section of its financial report. Division personnel told us they were not aware that 

barter transactions must be reported on the SF-425s. Because the Division did not report the 

barter transactions, the FWS was unaware that the Division had entered these agreements. 

Therefore, the FWS did not have the opportunity to review any barter transactions that occurred 

on Division-managed property that received Program funds to ensure that the agreements were 

equitable, which impacts the FWS’s ability to effectively monitor program grants. 

Recommendations 

We recommend that the FWS work with the Division to: 

1. Ensure all barter transactions are recorded on its SF-425s 

2. Develop policies and procedures for reporting barter transactions on its 

SF-425s in accordance with regulations 

4 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Division Response 

The Division concurred with the finding and recommendations. 

FWS Response 

The FWS concurred with the finding and recommendations and will work with the Division on a 

corrective action plan. 

OIG Comment 

Based on the Division and FWS responses, we consider the recommendations resolved but not 

implemented (see Appendix 3). 

B. Unreconciled Real Property Records 

We found the Division and the FWS did not reconcile the real property records of land 

purchased with Program grant funds. The Division should reconcile its land records with the 

FWS to ensure that its database of real property purchased with Program funds is accurate and 

complete and that Program grant-funded real property continues to serve the purpose for 

which it was acquired. Both the FWS and the Division agreed that they had not completed 

the required land record reconciliation. Federal regulation, 2 C.F.R. § 200.311(b), requires 

that the Division use assets acquired under Program grants for the originally authorized 

purpose. In order to do so, it must have a comprehensive list of real property that was 

purchased with grant funds. In addition, 2 C.F.R. § 200.329 states that if the Federal interest in 

real property extends 15 years or longer, the State must report the status of the property to the 

FWS at least every 5 years. The Division and the FWS did not commit sufficient resources to 

complete the reconciliation, and therefore cannot ensure that lands acquired under the 

Program are being used for their intended purposes. 

Recommendation 

We recommend that the FWS work with the Division to: 

3. Reconcile their respective records of lands purchased with Program funds 

and resolve any identified acreage and cost differences 

Division Response 

The Division concurred with the finding and recommendation. 

FWS Response 

The FWS concurred with the finding and recommendation and will work with the Division on a 

corrective action plan. 

OIG Comment 

Based on the Division and FWS responses, we consider the recommendation resolved but not 

implemented (see Appendix 3). 

5 
 

 

Appendix 1 

State of West Virginia 

Division of Natural Resources 

Grants Open During the Audit Period 

July 1, 2016, Through June 30, 2018 

FBMS Grant Grant Claimed 

Number Amount ($) Costs ($) 

F13AF01144 530,000 6,268 

F13AF01145 465,000 431,467 

F14AF01267 25,343 18,738 

F15AF00121 840,000 896,920 

F15AF00123 30,000 11,025 

F15AF00824 4,544,200 4,330,596 

F15AF00840 570,500 626,901 

F15AF00841 635,357 511,145 

F15AF00997 22,736,333 16,453,000 

F16AF00142 75,000 9,477 

F16AF00143 560,000 178,987 

F16AF00144 660,000 892,686 

F16AF00840 350,000 324,675 

F16AF00849 1,322,900 1,400,202 

F16AF00864 3,602,126 2,914,790 

F16AF00897 1,197,272 818,220 

F16AF01230 1,357,300 1,352,075 

F16AF01268 1,336,000 143,328 

F17AF00124 1,283,594 826,255 

F17AF00125 610,000 166,897 

6 
FBMS Grant Grant Claimed 

Number Amount ($) Costs ($) 

F17AF00126 10,175,163 6,298,921 

F17AF00127 550,000 740,802 

F17AF00644 544,606 249,675 

F17AF00679 98,375 37,647 

F17AF00810 1,538,724 897,071 

F17AF00811 2,779,394 1,445,453 

F17AF00855 6,547,908 3,211,861 

F18AF00140 412,006 118,670 

F18AF00142 775,000 853,221 

Total $66,152,100 $46,166,973 

7 
 

Appendix 2 

State of West Virginia 

Division of Natural Resources 

Sites Visited 

Headquarters 

South Charleston, WV 

District Offices 

Beckley, WV 

French Creek, WV 

Romney, WV 

Fish Hatcheries 

Bowden 

Reeds Creek 

Spring Run 

Tate Lohr 

Wildlife Management Areas 

Bluestone Lake 

Plum Orchard Lake 

Stonewall Jackson Lake 

Tate Lohr 

Wardensville 

Boat Ramps 

Buffalo 

Palatine 

Warden Lake 

Shooting Ranges 

Plum Orchard 

Stonewall Jackson 

Other 

State Wildlife Center 

8 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Appendix 3 

State of West Virginia 

Division of Natural Resources 

Status of Recommendations 

Recommendation Status Action Required 

Resolved but not 

implemented: 

U.S. Fish and Wildlife Service 

(FWS) regional officials 

concurred with these 1 – 3 recommendations and will 

work with staff from the West 

Virginia Division 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 October 28, 

2020) to the Assistant 

Secretary for Policy, 

Management and Budget to 

track implementation. 

9 
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