- -

OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

U.S. Fish and Wildlife Service Grants 

AUDIT

Awarded to the State of Kansas, Department 

of Wildlife, Parks and Tourism, From July 1, 

2016, Through June 30, 2018, Under the 

Wildlife and Sport Fish Restoration Program

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 $141,000. 

Report No.: 2019-CR-047 August 2020
 

 

 

 

 

 

 

OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OFTHE 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 Grants Awarded to the State 

of Kansas, Department of Wildlife, Parks and Tourism, From July 1, 2016, 

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

Report No. 2019-CR-047 

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

Department of Wildlife, Parks and Tourism (Department) under grants awarded by the U.S. Fish 

and Wildlife Service (FWS) through the Wildlife and Sport Fish Restoration 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 $49.3 million on 69 grants that were open during the State fiscal years 

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

We found that the State 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 

indirect costs, subawards, and equipment management. We questioned $139,087 ($103,191 

Federal share) as ineligible. We recorded a potential diversion of $30,728 in license revenue. We 

also found control deficiencies with the Department’s subaward reporting policies, and we 

repeated a finding on real property. 

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

recommendations and 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 

November 23, 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 
Contents 

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

Objective ....................................................................................................................................1 

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

Results of Audit ...............................................................................................................................2 

Questioned Costs—$103,191 (Federal Share)...........................................................................3 

Potential Diversion of License Revenue—$30,728...................................................................5 

Control Deficiencies ..................................................................................................................6 

Finding Repeated From Previous Audit ....................................................................................7 

Recommendations Summary ...........................................................................................................8 

Appendix 1: Scope and Methodology..............................................................................................9 

Appendix 2: Sites Visited ..............................................................................................................12 

Appendix 3: Monetary Impact .......................................................................................................13 

Appendix 4: Responses to Draft Report ........................................................................................15 

Appendix 5: Status of Recommendations......................................................................................20 
 

 

 

 

 

Introduction 

Objective 

In June 2016, we entered into an intra-agency agreement with the U.S. Fish and Wildlife Service 

(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 Kansas Department of Wildlife, Parks and 

Tourism (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. See Appendix 1 for details about our scope and methodology. 

See Appendix 2 for sites we visited. 

Background 

The FWS provides grants to States1 through its Wildlife and Sport Fish Restoration Program 

(WSFR) for the conservation, restoration, and management of wildlife and sport fish resources. 

WSFR was established by the Pittman-Robertson Wildlife Restoration Act and the DingellJohnson Sport Fish Restoration Act.

2 The Acts and related Federal regulations allow the FWS to 

reimburse grantees a portion of eligible costs incurred under WSFR grants—up to 75 percent for 

States and up to 100 percent for the District of Columbia, Puerto Rico, the U.S. Virgin Islands, 

Guam, American Samoa, and the Northern Mariana Islands. The reimbursement amount is called 

the Federal share. The Acts require that hunting and fishing license revenue be used only for the 

administration of State fish and wildlife agencies. In addition, Federal regulations require States 

to account for any income earned from grant-funded activities and to spend this income before 

requesting grant reimbursements. 

1 The Wildlife and Sport Fish Restoration Program defines the term “State” to include the District of Columbia, the 

Commonwealth of Puerto Rico, the U.S. Virgin Islands, Guam, American Samoa, and the Commonwealth of the Northern 

Mariana Islands. 

2 Formally known, respectively, as the Federal Aid in Wildlife Restoration Act, 16 U.S.C. § 669, as amended, and the Federal 

Aid in Sport Fish Restoration Act, 16 U.S.C. § 777, as amended. 

1 
 

Results of Audit 

We determined that the State generally ensured that grant funds and State 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 

indirect costs, subawards, and equipment management. We are also repeating a finding on real 

property from our 2015 report. 

We found the following: 

• Questioned Costs. We questioned $139,087 ($103,191 Federal share) as ineligible (see

Figure 1). These questioned costs arose due to ineligible indirect costs and subawards.

• Potential Diversion of License Revenue. The Department potentially diverted license

revenue totaling $30,728 by allowing the use of vehicles for purposes that were not

related to fish and wildlife activities.

• Control Deficiencies. We found an opportunity to improve controls in the reporting of

subawards of $25,000 or more.

• Repeat Finding. We previously reported on inaccurate and unreconciled real property

and found that the recommendations were resolved but not implemented.

Figure 1: Summary of Ineligible Costs (Federal Share) 

Ineligible 

Issue Costs ($) 

Indirect costs 64,409 

Subaward payments 38,782 

Total $103,191 

See Appendix 3 for a statement of monetary impact and a summary of potential diversion of 

license revenue. 

We provided a draft of this report to the FWS for review. The FWS concurred with all six 

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

implement corrective actions. See Appendix 4 for the full text of the Department’s and the FWS’ 

responses; Appendix 5 lists the status of each recommendation. 

2 
Questioned Costs—$103,191 (Federal Share) 

Ineligible Indirect Costs—Questioned Costs of $64,409 

We found that the Department overcharged the FWS for indirect costs claimed under four of its 

WSFR grants. To determine the indirect costs attributable to each grant, the Department 

multiplied bases consisting of select direct costs by federally approved indirect cost rates. 

The Department did not report the correct direct cost bases on four of the seven grants we tested. 

We found that the Department did not remove passthrough funds from the direct cost bases on 

two of these grants: F17AF00226 and F17AF00359. The Department also did not apply the 

correct indirect cost rates to the other two WSFR grants when the grants extended across two 

fiscal years: F16AF00651 and F16AF00668. 

The Code of Federal Regulations (2 C.F.R. § 200, Appendix VII(B)(1)) specifies that the base 

used for the computation of indirect costs is the accumulated direct costs. Normally, the base 

includes either total direct salaries and wages or total direct costs, exclusive of any extraordinary 

or distorting expenditures. The direct cost base used should result in fair and reasonable 

distribution of indirect costs among each Federal award. 

In addition, 2 C.F.R. § 200, Appendix VII(D)(1)(a) and (d) state that a grantee wishing to claim 

indirect costs must submit an indirect cost rate proposal to its cognizant Federal agency upon 

request. The Federal agency then reviews the proposal and negotiates an indirect cost with the 

grantee, and the results of the negotiation are required to be formalized in a written agreement 

between the two parties (2 C.F.R. § 200, Appendix VII(E)(1) and (3)). Accordingly, the 

Department’s indirect cost negotiation agreements for State fiscal years 2017 and 2018 note that 

passthrough funds may not be included in the base used to calculate indirect costs for Federal 

grants. 

This issue occurred because the Department did not have policies and procedures outlining the 

process for determining indirect cost expenditures. Having policies and procedures in place 

would have provided guidance to staff to ensure they were calculating indirect costs within 

applicable criteria. 

Without policies and procedures outlining the process for determining indirect cost expenditures, 

the Department claimed an excess of indirect costs under the four grants we tested. As a result, 

we question $64,409 of Federal share in ineligible costs (see Figure 2). 

3 
 

 

 

 

 

 

 

Figure 2: Questioned Costs Related to Indirect Costs 

Questioned Costs ($) 

(Federal Share) 

Grant No. Grant Title Ineligible 

F16AF00651 Hunting Access to Private Lands 653 

F16AF00668 Wildlife Research and Surveys 103 

F17AF00226 Assessment of Lesser Prairie 

Chicken Response to Translocation 22,461 

Survival Rates, Habitat Selection, 

F17AF00359 and Movement of Sympatric Mule 

Deer and White-Tailed Deer in 41,192 

Kansas 

Total $64,409 

Recommendations 

We recommend that the FWS work with the Department to: 

1. Resolve the ineligible questioned costs related to indirect costs totaling

$64,409 (Federal share)

2. Ensure the Department establishes policies and procedures outlining the

process for determining indirect cost expenditures

Ineligible Subaward Costs—Questioned Costs of $38,782 

The Department entered into a subaward agreement with the University of Tennessee, National 

Bobwhite Conservation Initiative (NBCI) for Grant No. F16AF01229. The NBCI provides 

similar services detailed under the grant to other “member” States and external partners. Some of 

these external partners, including nonprofit nongovernmental organizations, provide funding to 

the NBCI using non-Federal funds. During a site visit to the NBCI, we determined that the NBCI 

did not properly allocate expenditures among all benefiting members. The NBCI did not have a 

policy or a sound and reasonable methodology to determine and allocate assignable expenditures 

among all benefiting members in proportion to the received benefits. 

Instead, NBCI officials described their funding as one “pot” of money from which to pay for 

expenses that benefited all members and external partners. This practice does not ensure 

expenditures are properly allocated to a specific Federal grant. 

Federal regulations at 2 C.F.R. § 200.403 state that costs must be allocable to the Federal award 

for them to be allowable. Under 2 C.F.R. § 200.405, a cost is allocable to a particular award if 

the goods and services involved are chargeable or assignable to that Federal award in accordance 

4 
 

 

 

 

 

with the relative benefits received. Costs are also allocable if, when such costs benefit both the 

Federal award and other work of the non-Federal entity, they are distributed in proportions that 

may be approximated using reasonable methods. Part (d) of the regulation states that if a cost 

benefits two or more projects or activities in proportions that can be determined without undue 

effort or cost, the cost must be allocated to the projects based on the proportional benefit. 

The NBCI did not have adequate accounting methodologies that allowed for proper allocation of 

expenditures among benefiting member accounts. Because the NBCI did not properly allocate 

the expenditures among all benefiting members in proportion to the received benefits, and 

because the NBCI did not distribute the costs using a reasonable methodology, the expenditures 

are considered unallocable to Federal awards. Therefore, these costs are ineligible to be charged 

to WSFR grants. 

The Department paid $38,782 claimed by the NBCI on Grant No. F16AF01229 for unallocable 

expenditures (see Figure 3). 

Figure 3: Questioned Costs Related to Subaward 

Questioned Costs ($) 

(Federal Share) 

Grant No. Grant Title Ineligible 

F16AF01229 National Bobwhite 

Conservation Initiative 38,782 

Total $38,782 

Recommendation 

We recommend that the FWS work with the Department to: 

3. Resolve the ineligible questioned costs related to the subaward totaling

$38,782 (Federal share)

Potential Diversion of License Revenue—$30,728 

The Department sells hunting and fishing licenses and collects license fees from hunters and 

anglers throughout the State. During our audit scope, State fiscal years 2017 and 2018, the 

Department potentially diverted hunting and fishing license revenue for non-fish and game 

activities.3 The Department discovered a potential diversion of license revenue and told us that it 

inadvertently allowed the Division of Tourism (Division) to use the vehicles that were purchased 

with WSFR funds during the last 6 years. The Division did not contribute funds to the purchase 

3 According to 50 C.F.R. § 80.21, the Director may declare a State to be in diversion if it violates the requirements of 

50 C.F.R. § 80.10 by diverting license revenue from the control of its fish and wildlife agency to purposes other than the agency's 

administration. Only the Director may declare a State to be in diversion, and only the Director may rescind the declaration. 

5 
 

price or pay for any maintenance on the vehicles. The use of the vehicles by the Division did not 

benefit the Department nor was it related to fish and wildlife activities. 

Federal regulation 50 C.F.R. § 80.20(b) states that license revenue includes personal property 

acquired with license revenue. Furthermore, 50 C.F.R. § 80.10(c)(1) and (2) require that license 

revenue be controlled only by the State fish and wildlife agency and be used only for the 

administration of the State fish and wildlife agency. In addition, 50 C.F.R. § 80.11 explains that a 

State becomes ineligible under the WSFR program if it diverts hunting and fishing license 

revenue for purposes other than the administration of the State fish and wildlife agency. 

The Department did not have controls in place to prevent unauthorized use of the vehicles for 

non-fish and wildlife activities. Informing staff of the requirement to use license revenue for the 

sole purpose of fish and wildlife activities may prevent future misuse of the license revenue 

funds. 

As the license revenue did not solely benefit fish and wildlife activities, the Department 

potentially diverted $30,728 to the administration of other unrelated activities. Potential 

diversion of license revenue jeopardizes the State's continued participation in the WSFR program 

and brings into question whether fish and wildlife resources appropriately benefitted from the 

funds. The Division repaid $30,728, and the Department deposited the funds into the license 

revenue account. 

Recommendations 

We recommend that the FWS work with the Department to: 

4. Resolve the potential diversion of license revenue totaling $30,728

5. Ensure the Department communicates to relevant employees that license

revenue must be used solely for the administration of fish and wildlife activities

Control Deficiencies 

Lack of Policies and Procedures 

The Department did not report subawards of $25,000 or more on the Federal Funding 

Accountability and Transparency Act Subaward Reporting System (fsrs.gov) for posting on 

USAspending.gov, a website dedicated to promoting transparency in Federal spending. We 

identified 12 applicable subawards that were not reported on the website. 

In accordance with 2 C.F.R. § 170, Appendix A, Paragraphs I.a.1 and I.a.2.i, Federal grantees 

must report each subaward action that obligates $25,000 or more in Federal funds at 

www.fsrs.gov. This information is then posted to USAspending.gov. 

6 
 

 

 

 

The Department did not have policies and procedures to report subawards for posting on 

USAspending.gov. Establishing policies and procedures will ensure staff understand the 

requirement to report subawards of more than $25,000. 

By not reporting the awards greater than $25,000, the Department created a lack of transparency 

on how it spent Federal money. 

Recommendation 

We recommend that the FWS work with the Department to: 

6. Ensure the Department establishes and communicates policies and procedures

to report subawards for posting on USAspending.gov

Finding Repeated From Previous Audit 

In our 2015 audit report, we found Inaccurate and Unreconciled Real Property Records. The 

Department has completed its reconciliation of real property; the FWS, however, has not yet 

completed its reconciliation. Therefore, we found that this issue has not been implemented. 

Repeat Recommendations (Tracked Under Report No. R-GR-FWS-0008-2014, 

Recommendation Nos. 4 – 7) 

We recommend that the FWS: 

• Work with the Department to ensure that real property records easily identify

Program-funded land transactions

• Work with the Department to develop processes and procedures to ensure

timely and accurate recording of Program-funded additions, deletions, and

changes to land records

• Work with the Department to reconcile its respective land records

• Require the Department to certify that Program-funded real property is being

used for its intended purposes

7 
 

Recommendations Summary 

We recommend that the FWS work with the Department to: 

1. Resolve the ineligible questioned costs related to indirect costs totaling $64,409 (Federal

share)

2. Ensure the Department establishes policies and procedures outlining the process for

determining indirect cost expenditures

3. Resolve the ineligible questioned costs related to the subaward totaling $38,782 (Federal

share)

4. Resolve the potential diversion of license revenue totaling $30,728

5. Ensure the Department communicates to relevant employees that license revenue must be

used solely for the administration of fish and wildlife activities

6. Ensure the Department establishes and communicates policies and procedures to report

subawards for posting on USAspending.gov

8 
Appendix 1: Scope and Methodology 

Scope 

We audited the Kansas Department of Wildlife, Parks and Tourism’s (Department’s) use of 

grants awarded by the U.S. Fish and Wildlife Service (FWS) under the Wildlife and Sport Fish 

Restoration Program (WSFR). The audit period included claims totaling $49.3 million on 69 

grants that were open during the State fiscal years (SFYs) that ended June 30, 2017, and June 30, 

2018. 

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 

objective. We believe that the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objective. 

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

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

audit objectives: 

• 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 activities related to our audit 

objective. 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

• Inspecting equipment and other property

• Determining whether the Department used hunting and fishing license revenue for the

administration of fish and wildlife program activities

9 
 

 

 

 

 

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

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

Restoration Act

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

• Visiting sites throughout the State (see Appendix 2 for a list of sites visited)

We found deficiencies in internal control resulting in our three findings related to indirect costs, 

subawards, and equipment management. We are also repeating a finding on real property from 

our 2015 report. 

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

judgmental sample of transactions for testing. We used auditor judgement and considered risk 

levels relative to other audit work performed to determine the degree of testing performed in 

each area. 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. 

This audit supplements, but does not replace, the audits required by the Single Audit Act 

Amendments of 1996. Single audit reports address controls over Statewide financial reporting, 

with emphasis on major programs. Our report focuses on the administration of the Kansas fish 

and wildlife agency, and that agency’s management of WSFR resources and license revenue. 

Kansas provided computer-generated data from its official accounting system and from informal 

management information and reporting systems. We tested the data by sampling expenditures 

and verifying them against WSFR reports and source documents such as purchase orders, 

invoices, and payroll documentation. While we assessed the accuracy of the transactions tested, 

we did not assess the reliability of the accounting system as a whole. 

Prior Audit Coverage 

OIG Audit Reports 

We reviewed our last two audits of costs claimed by the Department on WSFR grants.4 We 

followed up on 10 recommendations from these reports and found that the U.S. Department of 

the Interior’s Office of Policy, Management and Budget considered 6 recommendations resolved 

and implemented, and 4 recommendations as resolved but not implemented. As discussed in the 

“Results of Audit” section in this report, we are repeating four recommendations, which relate to 

inaccurate and unreconciled real property records. 

4 Final Audit Report – U.S. Fish and Wildlife Service Wildlife and Sport Fish Restoration Program Grants Awarded to the State 

of Kansas, Department of Wildlife, Parks, and Tourism From July 1, 2011, Through June 30, 2013 (Report No. R-GR-FWS0008-2014), dated March 2015. 

Final Audit Report – U.S. Fish and Wildlife Service Federal Assistance Program Grants Awarded to the State of Kansas, 

Department of Wildlife and Parks, From July 1, 2004, Through June 30, 2006 (Report No. R-GR-FWS-0001-2007), dated May 

2007. 

10 
State Audit Reports 

We reviewed the single audit reports for SFYs 2017 and 2018 to identify control deficiencies or 

other reportable conditions that affect WSFR. In those reports, the Schedule of Expenditures of 

Federal Awards indicated $32.2 million (combined) in Federal expenditures related to WSFR. 

For SFY 2017, the Department was not tested as a major program in the State single audit. There 

were two findings related to WSFR, which was deemed a major program for Statewide audit 

purposes for SFY 2018. The single audit report for SFY 2018 noted a material weakness and 

significant deficiency in internal control over compliance. We considered these as risk indicators 

when we prepared our audit procedures and tests. 

11 
 

 

Appendix 2: Sites Visited 

Headquarters Topeka 

Operations Office Pratt 

Chanute Regional/District Offices Hays 

Research and Survey Office Emporia 

Fish Hatchery Farlington 

Fall River 

Boating Access Facilities Glen Elder 

Neosho 

Elk City 

Fall River 

Glen Elder 

Grand Osage 

Neosho Wildlife Areas Ottawa 

Pillsbury Crossing 

Webster 

Wilson 

Woodson 

Shooting Range El Dorado Lake 

Subrecipient Kansas State University 

12 

16
 

Appendix 3: Monetary Impact 

The audit period included claims totaling $49.3 million on 69 grants that were open during the 

State fiscal years that ended June 30, 2017, and June 30, 2018. We questioned $139,087 

($103,191 Federal share) as ineligible. We also identified a potential diversion of $30,728 in 

license revenue from the Department of Wildlife, Parks and Tourism (Department) (non-Federal 

funds). 

Monetary Impact: Questioned Costs 

Questioned Costs ($) 

(Federal Share) 

Cost 

Grant No. Grant Title Category Ineligible 

F16AF00651 Hunting Access to 

Private Lands Indirect Costs 653 

F16AF00668 Wildlife Research and 

Surveys Indirect Costs 103 

Assessment of Lesser 

F17AF00226 Prairie Chicken 

Response to 

Indirect Costs 22,461 

Translocation 

Survival Rates, Habitat 

Selection, and 

F17AF00359 Movement of Sympatric Indirect Costs 41,192 

Mule Deer and WhiteTailed Deer in Kansas 

F16AF01229 National Bobwhite 

Conservation Initiative Subaward 38,782 

Total $103,191 

13 
 

 

Monetary Impact: Potential Diversion of License Revenue 

Finding Area Amount ($) 

Unallowable use of vehicles purchased with 30,728 license revenue funds 

Total $30,728 

14 
Appendix 4: Responses to Draft Report 

The Kansas Department of Wildlife, Parks and Tourism’s response to our draft report follows on 

page 16. The U.S. Fish and Wildlife Service’s response to our draft report follows on page 18. 

15 
16
17
INTERIOR REGION 5 

Missouri Basin 

INTERIOR REGION 7 

Upper Colorado River Basin 

Kansas, Montana*, Nebraska, North Dakota, 

South Dakota

*PARTIAL

Colorado, New Mexico, Utah, Wyoming

United States Department of the Interior

FISH AND WILDLIFE SERVICE

134 Union Blvd 

Lakewood, Colorado 80228 In Reply Refer to:

 FWS/IR05/IR07/WSFR/DCN072808

Memorandum 

To:

From:

Subject:

Regional Manager for Audits, Office of Inspector General, Central Region 

(Attention: Amy R. Billings) 

Chief (Acting), Wildlife and Sport Fish Restoration Program, 

U.S. Fish and Wildlife Service, Regions 5 and 7 

Draft Audit Report on the U.S. Fish and Wildlife Service Wildlife and Sport Fish 

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

Wildlife, Parks and Tourism (Department) from July 1, 2016 through June 30, 

2018 (Report No. 2019- CR-047). 

This responds to your memorandum requesting our comments on the subject Draft Audit Report. 

We have the following comments: 

Findings and Recommendations

A. Questioned Costs—$139,087 ($103,191 Federal Share)

1. Ineligible indirect costs—$64,409

The Department overcharged the FWS for indirect costs claimed under four of its

WSFR grants.

2. Ineligible Subaward Costs—$38,782

The Department entered into a subaward agreement with the University of Tennessee,

National Bobwhite Conservation Initiative (NBCI) for Grant No. F16AF01229. It was

determined that the NBCI did not properly allocate expenditures among all benefiting

members. The NBCI did not have a policy or a sound and reasonable methodology to

determine and allocate assignable expenditures among all benefiting members in

proportion to the received benefits.

We have discussed this finding and recommendations with the Department and concur 

with the draft audit report. We will work with the Department to prepare a draft 

corrective action plan. 

18
2 

INTERIOR REGION 5 

Missouri Basin 

INTERIOR REGION 7 

Upper Colorado River Basin 

Kansas, Montana*, Nebraska, North Dakota, 

South Dakota

*PARTIAL

Colorado, New Mexico, Utah, Wyoming

B. Potential Diversion of License Revenue - $30,728

We have discussed this finding and recommendations with the Department and concur

with the draft audit report. We will work with the Department to prepare a draft

corrective action plan.

C. Control Deficiencies – Lack of Policies and Procedures

We have discussed this finding and recommendation with the Department and concur

with the draft audit report. We will work with the Department to prepare a draft

corrective action plan.

D. Repeat Finding (Land Reconciliation)

We have discussed this finding and recommendation with the Department and concur

with the draft audit report. We will work with the Department to prepare a draft

corrective action plan.

We have attached a copy of the Department’s response to the draft audit report contained in their 

July 21, 2020 letter to our office. 

If you have any questions regarding our response to the draft audit report, please contact Maria 

Sanchez Maes at (303) 236-8185 or me at (303) 236-4411. 

Attachment

cc: Ord Bargerstock, Compliance Lead, Branch of Policy and Compliance, 

 Wildlife and Sport Fish Restoration Program, HQ 

19
20 

Appendix 5: Status of Recommendations

Recommendation Status Action Required

1 – 3, 5, and 6 

Resolved but not 

implemented: 

U.S. Fish and Wildlife Service 

(FWS) regional officials 

concurred with these 

recommendations and will 

work with staff from the 

Kansas Department of 

Wildlife, Parks and Tourism 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 November 23, 

2020) to the Assistant 

Secretary for Policy, 

Management and Budget to 

track implementation. 

4 Resolved and implemented No action is required.

Repeat 

Recommendations 4 – 7 

(Report No. R-GR-FWS0008-2014) 

Resolved but not 

implemented: 

U.S. Fish and Wildlife Service 

(FWS) regional officials 

concurred with these 

recommendations and will 

work with staff from the 

Kansas Department of 

Wildlife, Parks and Tourism 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 November 23, 

2020) to the Assistant 

Secretary for Policy, 

Management and Budget to 

track implementation. 
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