- -

OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

AUDIT

Independent Auditors’ Biennial

Report on the Audit of 

Expenditures and Obligations 

Used by the Secretary of the 

Interior in the Administration of 

the Wildlife and Sport Fish

Restoration Programs

Improvement Act of 2000 for 

Fiscal Years 2017 Through 2018

Report No.: 2019-FIN-044 May 2020

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

 

 

OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

Memorandum 

To: Aurelia Skipwith 

Director, U.S. Fish and Wildlife Service 

From: Mark Lee Greenblatt 

Inspector General 

Subject: Independent Auditors’ Biennial Report on the Audit of Expenditures and 

Obligations Used by the Secretary of the Interior in the Administration of the 

Wildlife and Sport Fish Restoration Programs Improvement Act of 2000 for 

Fiscal Years 2017 Through 2018 

Report No. 2019-FIN-044 

Introduction 

This memorandum transmits the report prepared by Saint George Consulting Inc. for its 

audit of the expenditures and obligations used by the Secretary of the Interior in the 

administration of the Wildlife and Sport Fish Restoration Programs under the Improvement Act 

of 2000, Public Law 106-408, for fiscal years 2017 through 2018. The U.S. Fish and Wildlife 

Service (FWS) administers programs covered by the Act. 

Under a contract issued by the Office of Inspector General (OIG), Saint George 

Consulting, an independent public accounting firm, performed the required audit of the 

expenditures and obligations for fiscal years 2017 through 2018. The contract required that the 

audit be performed in accordance with the Generally Accepted Government Auditing Standards 

issued by the Comptroller General of the United States. 

Results of Independent Audit 

In its biennial audit report, dated April 1, 2020, Saint George Consulting identified 

deficiencies resulting from ineffective internal controls and noncompliance related to certain 

unallowable costs. The report contains 10 recommendations that, if implemented, should resolve 

the findings. 

Office of Inspector General | Washington, DC 
 

 

 

 

Evaluation of Saint George Consulting Audit Performance 

To ensure the quality of the audit work performed, the OIG— 

• reviewed Saint George Consulting’s approach to and planning of the audit; 

• evaluated the qualifications and independence of the auditors; 

• monitored the progress of the audit at key points; 

• participated in periodic meetings with FWS management and Saint George 

Consulting to discuss audit progress, findings, and recommendations; 

• reviewed Saint George Consulting’s audit report; and 

• performed other procedures we deemed necessary. 

Saint George Consulting is responsible for the attached report and conclusions expressed 

therein. We do not express an opinion on the findings and recommendations or on Saint George 

Consulting’s conclusions regarding effectiveness of internal controls or compliance with laws 

and regulations. 

Report Distribution 

The legislation creating the OIG requires that we report to Congress semiannually on all 

audit, inspection, and evaluation reports issued; actions taken to implement recommendations; 

and recommendations that have not been implemented. 

As required by the Act, this report was transmitted to the Secretary and the Inspector 

General on April 2, 2020, and has been transmitted to the appropriate Senate and House of 

Representative committees. We appreciate the courtesies and cooperation extended to Saint 

George Consulting by FWS staff during the audit. If you have any questions regarding the report, 

please contact me at 202-208-5745. 

Attachment 

2 
SAINT GEORGE 

CONSULT I NG 

-

Saint George Consulting Inc. T 

2603 Amanda Ct. 

Vienna, VA 22180 

April 1, 2020 

Mr. Mark Lee Greenblatt, Inspector General 

Office of Inspector General 

U.S. Department of the Interior 

1849 C Street, N.W. 

Washington, DC 20240 

Dear Inspector General Greenblatt: 

Please find enclosed the final report titled 'Performance Audit of Expenditures and Obligations Used 

by the Secretary of the Interior in the Administration of the Wildlife and Sport Fish Restoration 

Programs Improvement Act of 2000, Public Law (PL) 106-408, for Fiscal Years 2017 and 

2018’dated March 31, 2020 for the U.S. Department of Interior. 

If you have any questions or require additional information, please contact me by telephone at -

 or via email at @saintgeorgeconsulting.com. 

Sincerely, 

David Bloom, MBA, CPA, CGFM, CDFM-A, PMP 

President 

Saint George Consulting Inc. 
 

SAINT GEORGE 

CO N S ULTIN G 

Performance Audit 

Of 

Expenditures and Obligations Used by the Secretary of the Interior in 

the Administration of the Wildlife and Sport Fish Restoration 

Programs Improvement Act of 2000, Public Law 106-408, for Fiscal 

Years 2017 and 2018 

Prepared for: 

U.S. Department of Interior 

Office of Inspector General 

As of Date: March 31, 2020 

Prepared by: 

Saint George Consulting Inc. 

2603 Amanda Ct 

Vienna, VA 22180 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Performance Audit of Expenditures and Obligations Used by the Secretary of the 

Interior in the Administration of the Wildlife and Sport Fish Restoration Programs 

Improvement Act of 2000, Public Law 106-408 for Fiscal Years 2017-2018. 

Table of Contents 

1.0 EXECUTIVE SUMMARY.........................................................................1 

2.0 BACKGROUND......................................................................................3 

3.0 OBJECTIVE, SCOPE, AND METHODOLOGY..............................................5 

3.1 Objective...........................................................................................................5 

3.2 Scope...............................................................................................................6 

3.3 Methodology........................................................................................................6 

3.3.1 Internal Controls ......... ................................................................................7

3.3.1.1 Internal Controls Over Payroll..........................................................................7 

3.3.1.2 Internal Controls Over Non-Payroll..................................................................8

3.3.2 Compliance Testing.......................................................................................9

3.3.2.1 Full-Time Provision......................................................................................9 

3.3.2.2 Part-Time Provision......................................................................................9 

3.3.2.3 Overhead and Common Program Services Allocation..............................................9 

3.3.2.4 Training.................................................................................................10 

3.3.2.5 Travel...................................................................................................10 

3.3.2.6 Relocation..............................................................................................10 

3.4 Reporting Phase................................................................................................10 

4.0 RESULTS.............................................................................................11 

5.0 FINDINGS.............................................................................................17 

5.1 Internal Controls-Compliance, Condition, Criteria, Cause & Effect .................................17 

5.2 Compliance - Personnel Costs Full-Time Employees, Condition, Criteria, Cause & Effect.......18 

5.3 Compliance – Personnel Costs Part-Time, Condition, Criteria, Cause & Effect....................20 

5.4 Compliance – Relocation Costs, Condition, Criteria, Cause & Effect................................21 

6.0 CONCLUSIONS.....................................................................................22 

7.0 RECOMMENDATIONS...........................................................................23 

8.0 MANAGEMENT RESPONSE TO REPORT..................................................24 

9.0 AUDITOR EVALUATION OF MANAGEMENT RESPONSE.....................................30 

10.0 PRIOR YEAR NON-COMPLIANCE..............................................................33 

11.0 ABBREVIATIONS...................................................................................34 

i 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

1.0 EXEC UTIVE SUMMARY 

March 31, 2020 

Mr. David L. Bernhardt, Secretary 

U.S. Department of the Interior 

1849 C Street, N.W. 

Washington, DC 20240 

Mr. Mark Lee Greenblatt, Inspector General 

Office of Inspector General 

U.S. Department of the Interior 

1849 C Street, N.W. 

Washington, DC 20240 

Dear Mr. Bernhardt and Mr. Greenblatt: 

This report presents the results of our work to address the performance audit objective relative to 

expenditures and obligations used by the Secretary in administering the Wildlife and Sport Fish 

Restoration (“WSFR”) Programs Improvement Act of 2000 (hereinafter called the Act), Public Law 

106-408, for fiscal years (FYs) 2017 and 2018. We performed our audit work from April 25, 2019 

through January 28, 2020, and our results are as of February 7, 2020. 

We conducted this performance audit in accordance with generally accepted government auditing 

(GAGAS) 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 conclusion based on our audit 

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

conclusion based on our audit objective. 

The objective of our work was to determine whether expenditures and obligations used by the 

Secretary as reported by the U.S. Fish and Wildlife Service (“FWS”) in administering the Act for FYs 

2017 and 2018 were appropriate, adequately supported by appropriate documentation, and with the 

criteria set forth in the Act, and to report on FWS’s compliance with applicable laws and regulations

and the internal control system for effectively accounting for expenditures and obligations under the 

Act. 

1. FWS’s internal controls for effectively accounting for expenditures and obligations under the

Act was effective to ensure all costs as reported under the “Report to Congress” for FY 2017

and FY 2018 were adequately supported by appropriate documentation. To continue FWS 

should ensure these internal controls are maintained and monitored on a monthly basis as a 

result of any change to FWS organizational structure that may affect the internal controls 

currently being implemented. 

2. FWS’s policies and procedure in place aren’t fully effective to ensure full compliance with the

Act Provisions. FWS is currently in violation with the Full-Time (FT), Part-Time (PT) and 

Relocation provisions of the Act and therefore not in compliance with the Act. 

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 FWS WSFR FT employees in most cases weren’t charging FT to the Act. 

 FWS allowed FWS employees that weren’t FWS WSFR PT employees to charge 

time to the Act. 

 FWS allowed FWS WSFR employees to relocate and not charge 100% of their time 

to the WSFR programs for one year after they relocated. 

This performance audit didn’t constitute an audit of financial statements in accordance with

Government Auditing Standards (GAS). Saint George Consulting Inc. wasn’t engaged to and didn’t

render an opinion on the Department of the Interior’s (“DOI”) or FWS’s internal controls over

financial reporting or over financial management systems (for purposes of the Office of Management 

and Budget’s (OMB) Circular No. A-127, Financial Management Systems, dated July 23, 1993, as 

revised). Saint George Consulting Inc. cautions that projecting the results of our evaluation to future 

periods is subject to the risks that controls may become inadequate because of changes in conditions or 

because compliance with controls may deteriorate. 

Saint George Consulting Inc. 

Vienna, VA 

March 31, 2020 

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2.0 BACKGROUND 

Performance Audit of U.S. Fish & Wildlife Service Wildlife Restoration and Sport Fish 

Restoration Programs for Fiscal Years 2017 & 2018 

Wildlife Restoration and Sport Fish Restoration (“WSFR”) programs are the responsibility of the 

Secretary of the Interior as per the Pittman-Robertson Wildlife Restoration Act (16 U.S.C. 669 et seq.) 

and the Dingell-Johnson Sport Fish Restoration Act (16 U.S.C. 777 et seq., except 777e-1 and g-1). 

The Secretary delegated administration of these two Acts to the Fish and Wildlife Service (“FWS”). 

The Wildlife and Sport Fish Restoration Programs Improvement Act of 2000 (hereinafter called the 

Act) established requirements and restrictions concerning the use of funds for expenses for 

administration and delineated that expenses be limited to 12 ‘Costs Distributed by Improvement Act 

Categories’ (CDIAC) as outlined below: 

(1): Personnel costs of employees who directly administer this chapter on a full-time (FT) 

basis; 

(2): Personnel costs of employees who directly administer this chapter on a part-time (PT) 

basis for at least 20 hours each week, not to exceed the portion of those costs incurred 

with respect to the work hours of the employee during which the employee directly 

administers this chapter, as those hours are certified by the supervisor of the employee; 

(3): Support costs directly associated with personnel costs authorized under paragraphs (1) and 

(2), excluding costs associated with staffing and operation of regional offices of the FWS 

and the DOI other than for the purposes of this chapter; 

(4): Costs of determining under section 669e (a) of this title whether State comprehensive plans 

and projects are substantial in character and design; 

(5): Overhead costs, including the costs of general administrative services, that are directly 

attributable to administration of this chapter and are based on: (A) Actual costs, as 

determined by a direct cost allocation methodology approved by the Director of the Office 

of Management and Budget for use by Federal agencies; and (B) in the case of costs that 

are not determinable under subparagraph (A), an amount per FT equivalent employee 

authorized under paragraphs (1) and (2) that does not exceed the amount charged or 

assessed for costs per FT equivalent employee for any other division or program of the 

FWS; 

(6): Costs incurred in auditing, every 5 years, the wildlife and sport fish activities of each State 

fish and game department and the use of funds under section 669e of this title by each 

State fish and game department; 

(7): Costs of audits under subsection (d) of this section (the Act); 

(8): Costs of necessary training of Federal and State FT personnel who administer this chapter 

to improve administration of this chapter; 

(9): Costs of travel to States, territories, and Canada by personnel who: (A) Administer this 

chapter on a FT basis for purposes directly related to administration of State programs or 

projects; or (B) Administer grants under sections 669e, 669h-1, or 669h-2 of this title; 

(10): Costs of travel outside the United States (except travel to Canada) by personnel who 

administer this chapter on a FT basis for purposes that directly relate to administration of 

this chapter and that are approved directly by the Assistant Secretary for Fish and Wildlife 

and Parks; 

Page 3 of 34 
 

 

 

 

.... + .. + .. + .. .. .. + .... + .. + .. + .. .. .. + .... ,- .. ,- .. ,- .. .. .. ,-

I 

.... 

.. 

.. .. 

.. + + + .. + 

I 

Report to Congress - Administration Obligations for FY 2017

as Required by Public Law 106 -408, Section 133(b) 

Wildlife and Sport Fish Res toration Programs Improvement Act of 2000 

(in thousands of dollars) 

.... + + .. + .. .. 

Costs Distributed by Improvement Act Category WR SFR Total .... ,- +- ,- +- +-

1. 

.... 

Personnel working full time to administer the Act (salary plus benefits) ,- +- ,- +- +-6,624 6,326 12,950 

2. Personnel working part time to administer the Act (salary plus benefits) 43 29 72 .... ,- +- ,-

3. Support costs for personnel 

+- +-

1,489 1,358 2,847 

.... ,- +- 1 .. +-

4. Determining substantiality of character and design of State plans and projects 0 0 ---

5. a. Overhead - Based on Actual Costs 488 610 1,098 .... ,- +- 1 +-

b. Overhead - Based on FTE 1,062 1,228 2,290 

6. Audits of States 680 1,167 1,847 +-+- +-

7. Audits of administration expenditures 0 0 0 

8. Training of Federal and State full -time personnel 25 20 45 

9. 

.... .. 

Travel to the States, territories, Canada 344 402 746 

10. Travel outside the United States 0 0 0 

11. Relocation of personnel 140 91 231 >: : • 

12. Audit, evaluate, approve, etc., grants 0 0 --- +-+- + +- + +- + +- +-

2017 Cost to Administer the Restoration Acts under P.L. 106 -408: 10,895 11,231 22,126 

.. .. .. .. .. .. .. .. .. 

, .. .. Note: Categories 4 and 12 are not tracked separately. Costs for these administrative activities are included primarily in 

categories 1 and 9. 

Summary: Amount allowed in the Acts: 10,931 12,172 23,103 

Less amount spent as of 9/30/2017 (see above): 10,895 11,231 22,126 

Funds not spent as of 9/30/2017: 36 941 977 

(11): Relocation expenses for personnel who, after relocation, will administer this chapter on a

FT basis for at least 1 year, as certified by the Director of the United States Fish and 

Wildlife Service at the time at which the relocation expenses are incurred; and

(12): Costs to audit, evaluate, approve, disapprove, and advise concerning grants under sections 

669e, 669h-1, and 669h-2 of this title.”

Amounts allowed by the Acts and actual expenses reported by FWS in its ‘Report to CongressAdministration Obligations for FY 2017 & FY 2018’ are detailed in the next two tables.

Note: Categories 4 and 12 aren’t tracked separately. Costs for these administrative activities are

included primarily in categories 1 and 9. 

Page 4 of 34 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

"-

.... 1 .... 1 .... "-

... ... ... ... ... ... ... ... ... ... ... 

Report to Congress - Administration Obligations for FY 2018

as Required by Public Law 106-408, Section 133(b)

Wildlife and Sport Fish Restoration Programs Improvement Act of 2000

(in thousands of dollars)

WR SFR Total 

1. Personnel working full time to administer the Act (salary plus benefits) 6,582 6,091 12,673 

2. Personnel working part time to administer the Act (salary plus benefits) 49 45 94 

3. Support costs for personnel 1,463 856 2,319 

4. Determining substantiality of character and design of State plans and projects 0 0 ---

5. a. Overhead - Based on Actual Costs 593 621 1,214 

b. Overhead - Based on FTE 1,105 1,203 2,308 

6. Audits of States 1,075 939 2,014 

7. Audits of administration expenditures 0 0 0 

8. Training of Federal and State full-time personnel 27 23 50 

9. Travel to the States, territories, Canada 283 319 602 

10. Travel outside the United States 0 0 0 

11. Relocation of personnel -11 203 192 

12. Audit, evaluate, approve, etc., grants 0 0 ---

11,166 10,300 21,466 

Note: Categories 4 and 12 are not tracked separately. Costs for these administrative activities are included primarily in

categories 1 and 9. 

Costs Distributed by Improvement Act Category

2018 Cost to Administer the Restoration Acts under P.L. 106-408: 

11,177 12,366 23,543 

11,166 10,300 21,466 

11 2,066 2,077 

Less amount spent as of 9/30/2018 (see above): 

Funds not spent as of 9/30/2018: 

Summary: Amount allowed in the Acts:

Note: Categories 4 and 12 aren’t tracked separately. Costs for these administrative activities are

included primarily in categories 1 and 9.

3.0 OBJECTIVE, SCOPE, AND METHODOLOGY

3.1 Objective

The objectives of the performance audit were to:

 To determine whether expenditures and obligations used by the Secretary of the Interior, as

reported by the FWS, in the administration of the Act for fiscal years 2017 and 2018 were

appropriate, adequately supported by appropriate documentation, and in accordance with the

criteria set forth in the Act;

 Report on FWS’s compliance with applicable laws and regulations; and

 Report on FWS’s internal controls for effectively accounting for expenditures and

obligations under the Act. 

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E 1 1 1111 I 1111 bE 1 1 1111 I 1111 b3.2 Scope 

The scope of this performance audit included expenditures and obligations incurred by the 

Secretary of the Interior in administering the Act for FYs 2017 and 2018. The Secretary has 

delegated administration of the Act to FWS; accordingly, FWS reports all related expenditures and 

obligations incurred. 

3.3 Methodology 

In planning the engagement, we interviewed FWS Region 9 Headquarter personnel involved in 

administering the Act, including personnel at Region 3, Region 5, Region 6 and Region 8, to 

understand regional administration policies and procedures in place surrounding internal controls 

developed and operating at FWS in FYs 2017 and 2018. 

For each fiscal year, FY 2017 and FY 2018 we performed the following procedures to select 

transactions subject to test work procedures. We obtained the electronic general ledger transaction 

detail of expenditures and obligations (transactional detail) reported by FWS and reconciled it 

without material exception to the FY 2017 and FY 2018 ‘Report to Congress’ for the 

Administration of the Act to ensure the completeness of the population. Our population size for FY 

2017 consisted of 40,421 transactions. Our population size for FY 2018 consisted of 35,950 

transactions. Using a confidence level of 95%, desired precision ± 5% and anticipated error rate of 

10% we grouped our transactions into five separate groups where we pulled our transactions to test 

for both internal controls and for compliance with the Act. The below tables are our group 

breakouts on our sample item selections for each FY. 

FY 2017 

Number of Strata 10 Stratum Cat 1&2 F Cat 1&2 WL Cat 3 F Cat 3 WL Cat 5&5e F Cat 5&5e WL Cat 9 F Cat 9 WL Other F Other WL SUM

Population Size 40,421 Size 11,287 9,482 2,089 4,281 411 432 4,480 7,562 158 239 40,421

Confidence Level 95 % Sample size 40 34 7 15 1 2 16 27 1 1 144

Desired Precision ± 5 % Final size 40 34 7 15 5 5 16 27 5 5 159

Anticipated Error Rate 10 %

FY 2018 

Number of Strata 10 Stratum Cat 1&2 F Cat 1&2 WL Cat 3 F Cat 3 WL Cat 5&5e F Cat 5&5e WL Cat 9 F Cat 9 WL Other F Other WL SUM

Population Size 35,950 Size 10,924 9,554 1,455 3,092 443 435 3,692 6,038 145 172 35,950

Confidence Level 95 % Sample size 44 38 6 12 2 2 15 24 1 1 145

Desired Precision ± 5 % Final size 44 38 6 12 5 5 15 24 5 5 159

Anticipated Error Rate 10 %

The below table is a ‘Summary of Sample Transactions by Region by FY by CDIAC for Testing.’

For CDIAC 1&2 sample transactions were further broken down into individual payroll records. 

Transactions for FY 2017 CDIAC 1&2 consisted of 295 payroll transactions and for FY 2018 

CDIAC 1&2 consisted of 261 payroll transactions. 

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I I Region 1 Region 2 Region 3 Region 4 Region 5 Region 6 Region 7 Region 8 Region 9 Total

Portland, 

Oregon

Albuquere, 

New Mexico

Bloomington, 

Minnesota

Atlanta, 

Georgia

Hadley, 

Massachusetts

Lakewood, 

Colorado

Anchorage, 

Alaska

Sacramento, 

California

Falls Church, 

Virginia

FY 2017 5 4 6 8 (5) 6 3 6 2 34 (5) 74 (42) Category 1 & 2

FY 2018 5 11 (5) 5 5 7 5 3 7 34 (5) 82 (47) Category 1 & 2

FY 2017 2 3 1 3 1 12 22 Category 3

FY 2018 3 2 1 3 1 8 18 Category 3

FY 2017 10 10 Category 5

FY 2018 10 10 Category 5

FY 2017 5 1 1 1 2 10 Category 6, 8 & 11

FY 2018 1 1 2 1 1 4 10 Category 6, 8 & 11

FY 2017 1 3 10 3 3 3 2 2 16 43 Category 9

FY 2018 4 3 6 3 4 4 1 1 13 39 Category 9

2 4 26 (20) 3 1 20 (17) 2 6 2 1 1 5 1 2 143 318 (251)

Note: For Region 2 (FY2018); Region 4 (FY2017); and Region 9 (FY2017 & FY2018) we performed 2nd Stage Sampling.

Note: Green cells above are Regions where we performed on-site fieldwork visits.

Summary of Sample Transactions By Region By Fiscal Year By 'Cost Distributed By Improvement Act Category' For Testing

Cost Distributed By 

Improvement Act 

Category

For all other FY 2017 & FY 2018 transactional groupings making up CDIAC 3, CDIAC 5, CDIAC 

6, 8, 11 and CDIAC 9 we selected the following: (1) for CDIAC 3 a sample of 22 non-payroll 

transactions for FY 2017 and 18 non-payroll transactions for FY 2018; (2) for CDIAC 5 a sample 

of 10 Overhead-Based on Actual Costs transactions for both FY 2017 and FY 2018; (3) for CDIAC 

6, 8, and a sample of 10 transactions for both FY 2017 and FY 2018; and (4) for CDIAC 9 a sample 

of 43 transactions for FY 2017 and 39 transactions for FY 2018 based on statistical methods. 

Due to batch transaction data received for CDIAC 1 and the resulting size of regional batches we 

decided to conduct a second stage sampling of transactions for Region 2 (FY 2018), Region 4 (FY 

2017) and Region 9 (FY 2017 & FY 2018). 

3.3.1 Internal Controls 

In order to test the operating effectiveness of relevant internal controls, we performed both ‘Internal

Controls over Payroll’ and 'Internal Controls over Non-Payroll’ testing.

3.3.1.1 Internal Controls over Payroll 

For payroll CDIAC 1 & 2 we tested the following payroll controls: 

 Control #1: Timesheet is signed and approved by the approving official. 

 Control #2: Timesheet is reviewed and signed (verified) by the employee for each 

pay cycle. 

 Control #3: Timesheet is validated by the timekeeper for each pay cycle. 

 Control #4: Timesheet is reviewed and approved (certified) by the employee’s 

supervisor for each pay cycle. 

 Control #5: Timekeeper is on the list of authorized timekeepers. 

 Control #6: Timesheet is charged correctly to 5110 Wildlife Restoration 

Administration and/or 9410 Sport Fish Restoration Administration for each pay 

cycle. 

 Control #7: Certifiers are on the authorized official list. 

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3.3.1.2 Internal Controls over Non-Payroll 

For non-payroll CDIAC 3, 5, 6, 8, 9 and 11 we tested the following non-payroll controls where 

applicable: 

 Control #1: An obligating document is properly kept. 

 Control #2: The program approver reviews the acquisition request and signs it either 

electronically or manually. 

 Control #3: The funds certifier reviews the Budget Tracking System and/or the Financial 

and Business Management System to confirm that funds are available for purchases. To 

document that funds are available, the funds certifier signs the acquisition request either 

electronically or manually. 

 Control #4: The contracting officer is on the authorization list. 

 Control #5: A contracting officer may only approve an acquisition request up to his or her 

warrant authority limit. 

 Control #6: Procurement documents must be signed by the contractor and contracting 

officer. 

 Control #7: The invoice amount agrees with purchase order, acquisition request, or 

contract. 

 Control #8: A receipt of goods or services receipt is certified or a receiving document is 

signed. 

 Control #9: Journal vouchers are adequately supported. 

 Control #10: The cardholder has signed and dated his or her monthly statement verifying 

that the reconciliation has been performed and submits the statement to an approving 

official for review within 10 days of receipt. 

 Control #11: The approving official reviews the cardholder’s statement for activity and

the appropriateness of charges. If approved, the statement is signed and dated after 

review within 10 days of receipt. 

 Control #12: The payment is properly recorded. 

 Control #13: The transaction is supported by proper and appropriate documentation. 

 Control #14: The transaction is recorded for the correct amount. 

 Control #15: The transaction is recorded in the correct period. 

 Control #16: The transaction is recorded in the correct cost category. 

 Control #17: The transaction is in a cost category allowed by the Act. 

 Control #18: The cost charged is reasonable and appropriate under the Act. 

For each sample item selected, we first determined whether the identified relevant controls were 

operating effectively. We did this by reviewing supporting documentation, such as acquisition 

requests, charge card statements, invoices, personnel records, purchase orders and timesheets. 

Afterwards we tested to ensure the amounts were allowable and supported with proper 

documentation. 

Region Site Visits and Non-Region Site Visits 

To obtain assurances of FWS compliance with the Act and waste, fraud and abuse we conducted 

fieldwork/visited and interviewed FWS WSFR personnel at the following locations: 

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 Region 9, HQ, U.S. FWS, Falls Church, Virginia 

 Region 3, Bloomington, Minnesota 

 Region 5, Hadley, Massachusetts 

 Region 6, Lakewood, Colorado 

 Region 8, Sacramento, California 

To gain additional assurances of FWS’s compliance with the Act and waste, fraud and abuse we 

conducted telephone interviews with regional Fiscal Grant Officers from the following locations: 

 Region 1, Portland, Oregon 

 Region 2, Albuquerque, New Mexico 

 Region 4, Atlanta, Georgia 

 Region 7, Anchorage, Alaska 

3.3.2 Compliance 

3.3.2.1 Full-Time Provision 

To test compliance with the FT provision of the Act, we used extracted sampled payroll records 

of employees we pulled from the population of transactions from the electronic general ledger 

transaction detail of expenditures and obligations for FY 2017 and FY 2018. We then matched 

these sampled payroll records with FWS WSFR FT employee rosters for each region. Then, 

during our visit to each region, we interviewed a random sample of FT personnel that tied to the 

extracted sampled payroll records who were listed on the region roster and who charged FT to 

the Act to determine whether they were actually performing work FT in support of the WSFR 

programs for FYs 2017 and 2018. In addition, we reviewed the payroll records (i.e., employee 

statements) to see if selected FT employees were charging to other cost codes besides the 

WSFR programs. 

3.3.2.2 Part-Time Provision 

To test compliance with the PT provision of the Act, we analyzed PT budget object classes for 

all the regions for FY 2017 and FY 2018 to determine what FWS employees were charging to 

the Act on a PT basis and if they were charging more than 20 hours per week, but less than 40 

hours per week. We requested explanations from the region for any PT employee that we found 

to be charging less than 20hrs a week in addition to those charging to the Act that weren’t listed 

on the region’s PT roster. 

3.3.2.3 Overhead and Common Program Services Allocation 

To test compliance with the Act’s overhead provisions (CDIAC 5b) we obtained reports from 

DOI finance and FWS HQs showing annual breakout of CDIAC 5b costs charged to the Act for 

FY 2017 and FY 2018. These costs included both ‘Enterprise Common Program Service (CPS)’

costs and ‘Regional Cost Share Allocated by FT employee (FTE). From each region we 

requested documentation showing their methodology for developing costs by FTE for both FY 

2017 and FY 2018. In addition, we inquired about the methodology used by DOI finance and 

FWS in allocating costs to FTEs and breakouts not only at the WSFR program level but how 

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their share of costs compared with other FWS programs. Thereafter, we analyzed these costs 

both at the region level and FWS headquarter level to see if they tied and rolled up to the costs 

being reported at the FWS enterprise level as reported on the ‘Report to Congress’ for FY 2017 

and FY 2018. 

3.3.2.4 Training 

To test compliance with the Act’s training expense provisions, we used the extracted sampled 

training transactions we pulled from the FY 2017 and FY 2018 general ledger of transactions. 

We then reviewed this training documentation to see if the training received tied to training 

required to administer the WSFR programs. In addition, for the regions we visited for those we 

interviewed we inquired about the training they underwent for FY 2017 and FY 2018, if any, and 

what the reasons were for the training to see if any training they underwent was not in 

compliance with Act’s training provision. 

3.3.2.5 Travel 

To test compliance with the Act’s travel expense provisions, we used the extracted sampled 

travel transactions we pulled from the FY 2017 and FY 2018 general ledger of transactions. We 

then reviewed this travel documentation to see if the travel was for appropriate reasons and 

required for the administration of the Act. In addition, for the regions we visited for those we 

interviewed we inquired about the travel they underwent for FY 2017 and FY 2018, if any, and 

what the reasons were for the travel to see if any travel they underwent was not in compliance 

with Act’s travel provision.

3.3.2.6 Relocation 

To test compliance with the Act’s relocation cost provisions, we analyzed relocation budget 

object classes for all the regions for FY 2017 and FY 2018 to determine what FWS employees 

were charging against the Act for relocation costs for FY 2017 and FY 2018. For those we 

identified, we provided the WSFR employee names to the respective region to obtain 

documentation that they actually relocated to the region and that prior to their relocation signed 

documentation that committed them FT to the WSFR programs for one year after reporting to the 

new region location. We then requested employee statements near the beginning and near the 

end of their one-year period of commitment to see if they were charging FT to the Act or if they 

were charging less than FT and to other FWS programs. 

3.4 Reporting Phase 

During the reporting phase, we: 

 Reported on FWS’s internal controls for effectively accounting for expenditures and 

obligations under the Act; 

 Determined whether expenditures and obligations used by the Secretary of the Interior as 

reported by FWS in administering the Act for FYs 2017 and 2018 were appropriate, 

adequately supported by appropriate documentation, and in accordance with criteria set 

forth in the Act; 

Page 10 of 34 
 

 

 

 

 

 

 

 

 

 

 

 

 Reported on FWS’s compliance with applicable laws and regulations and the Act; 

 Identified any recommended actions that may be needed; and 

 Performed independent referencing between work papers and the report. 

4.0 RESULTS 

Internal Control Procedures Results Summary For Payroll and Non-Payroll Expenditures 

Payroll Internal Control Exceptions for FYs 2017 and 2018 

Payroll internal controls were operating effectively with minor exceptions. 

Our review of the 295 payroll transactions (CDIAC 1 & 2) tested for FY 2017 we found 58 internal 

control exceptions. Our review of 261 payroll transactions (CDIAC 1 & 2) tested for FY 2018 we 

found 66 internal control exceptions. 

CDIAC 1 = Personnel working FT to administer the Act (salary plus benefits). 

CDIAC 2 = Personnel working PT to administer the Act (salary plus benefits). 

Payroll Expenditures for FYs 2017 and 2018 

FY 2017 FY 2018 Total 

Control No. of 

Internal 

Control 

Exceptions 

Error 

Rate (% 

of 295 

Payroll 

Records) 

No. of 

Internal 

Control 

Exceptions 

Error 

Rate 

(% of 261 

Payroll 

Records) 

Total Internal 

Control 

Exceptions of 

556 Sampled 

Payroll 

Records 

Error Rate 

(% of 556 

Sampled 

Payroll 

Records) 

1 0 0 0 0 0 0 

2 51 17.29% 63 24.14% 114 20.50% 

3 7 2.37% 3 1.15% 10 1.80% 

4 0 0 0 0 0 0 

5 0 0 0 0 0 0 

6 0 0 0 0 0 0 

7 0 0 0 0 0 0 

Total 58 19.66% 66 25.29% 124 22.30% 

Each control in table above correlates to control #1-7 listed above under 3.3.1.1 Internal Controls 

Over Payroll. 

Payroll Expenditure Results 

One hundred and twenty-four of 556 samples, representing 22.30% percent of the sample of total 

sampled payroll records charged for payroll expenses in FY 2017 and FY 2018, had internal control 

exceptions as shown in the following table. See below table for more detail of exceptions found. 

Page 11 of 34 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Fiscal Year Number of 

Payroll 

Records 

Sampled 

Number of 

Exceptions 

Error Rate Remarks 

2017 295 

51 17.29% Timesheets were signed by the 

timekeeper instead of the employee. 

7 2.37% Timesheets were validated by the employee 

(validator) instead of another timekeeper. 

2018 261 

63 24.14% Timesheets were signed by the 

timekeeper instead of the employee. 

3 1.15% Timesheets were validated by the employee 

(validator) instead of another timekeeper. 

Total 556 124 22.30% 

Non-Payroll Expenditures for FYs 2017 and 2018 

Our review of the 22 non-payroll transactions (CDIAC 3) tested for FY 2017 we found 0 exceptions. Our 

review of the 18 non-payroll transactions (CDIAC 3) tested for FY 2018 we found 0 exceptions. 

CDIAC 3 = Support costs for personnel 

Non-Payroll Expenditure Exceptions for FYs 2017 and 2018 

FY 2017 FY 2018 Total 

Control 

No. of 

Internal 

Control 

Exceptions 

Error Rate 

(% of 22 

Sampled 

Support 

Costs 

Records) 

No. of 

Internal 

Control 

Exceptions 

Error Rate 

(% of 18 

Sampled 

Support 

Costs 

Records) 

Total Internal 

Control 

Exceptions of 

40 Sampled 

Support Cost 

Records 

Error 

Rate (% 

of 40 

Sampled 

Support 

Cost 

Records) 

1 0 0 0 0 0 0 

2 0 0 0 0 0 0 

3 0 0 0 0 0 0 

4 0 0 0 0 0 0 

5 0 0 0 0 0 0 

6 0 0 0 0 0 0 

7 0 0 0 0 0 0 

8 0 0 0 0 0 0 

9 0 0 0 0 0 0 

10 0 0 0 0 0 0 

11 0 0 0 0 0 0 

12 0 0 0 0 0 0 

13 0 0 0 0 0 0 

14 0 0 0 0 0 0 

15 0 0 0 0 0 0 

16 0 0 0 0 0 0 

17 0 0 0 0 0 0 

Page 12 of 34 
 

 

 

 

 

 

18 0 0 0 0 0 0 

Total 0 0 0 0 0 0 

Overhead Based on Actual Expenditures for FYs 2017 and 2018 

Our review of the 10 overhead transactions (CDIAC 5a) tested for FY 2017 we found 0 exceptions. Our 

review of the 10 overhead transactions (CDIAC 5a) tested for FY 2018 we found 0 exceptions 

CDIAC 5 = Overhead – Based on Actual Costs 

Overhead Expenditure Exceptions for FYs 2017 and 2018 

FY 2017 FY 2018 Total 

Control No. of 

Internal 

Control 

Exceptions 

Error 

Rate (% 

of 10 

Sampled 

Overhead 

- Based 

on Actual 

Costs) 

No. of 

Internal 

Control 

Exceptions 

Error 

Rate (% 

of 10 

Sampled 

Overhead 

- Based 

on Actual 

Costs) 

Total 

Internal 

Control 

Exceptions of 

20 Samples 

Error 

Rate (% 

of 20 

Sampled 

Overhead 

-Based on 

Actual 

Costs) 

1 0 0 0 0 0 0 

2 0 0 0 0 0 0 

3 0 0 0 0 0 0 

4 0 0 0 0 0 0 

5 0 0 0 0 0 0 

6 0 0 0 0 0 0 

7 0 0 0 0 0 0 

8 0 0 0 0 0 0 

9 0 0 0 0 0 0 

10 0 0 0 0 0 0 

11 0 0 0 0 0 0 

12 0 0 0 0 0 0 

13 0 0 0 0 0 0 

14 0 0 0 0 0 0 

15 0 0 0 0 0 0 

16 0 0 0 0 0 0 

17 0 0 0 0 0 0 

18 0 0 0 0 0 0 

Total 0 0 0 0 0 0 

In addition to sample testing 5a above we performed an analysis of 5b (Overhead – Based on FTE) 

to ensure the ‘Overhead-Based on FTE’ was developed per the methodology used by DOI and 

FWS. See below table of total overhead and common program service cost broken down by FY, 

type of program and type of CDIAC. 

Page 13 of 34 
 

 

 

 

 

 

 

 

 

 

 

'- ,_ 

I 

Region/Description FY 2017 FY 2017 FY 2017 FY 2017 FY 2018 FY 2018 FY 2018 FY 2018

FWS Summary

Wildlife 

Restoration

Wildlife 

Restoration

Sportfish 

Restoration

Sportfish 

Restoration

Wildlife 

Restoration

Wildlife 

Restoration

Sportfish 

Restoration

Sportfish 

Restoration

5a. Overhead - 

Based On Actual 

Costs

5b. Overhead - 

Based on FTEs

5a. Overhead - 

Based On Actual 

Costs

5b. Overhead - 

Based on FTEs

5a. Overhead - 

Based On Actual 

Costs

5b. Overhead - 

Based on FTEs

5a. Overhead - 

Based On Actual 

Costs

5b. Overhead - 

Based on FTEs

CPS Costs Charged by Regions -$33,075.83 -$46,417.50 $8,944.29 $8,374.80

Regional Cost Share Allocation By FTE $373,681.59 $655,996.58 $429,202.17 $378,844.03 $381,659.30

Total CPS and Regional Cost Share Allocation by 

Regions -$33,075.83 $373,681.59 -$46,417.50 $429,202.17 $8,944.29 $378,844.03 $8,374.80 $381,659.30

Overhead Costs charged by HQ for Regional Office Support $521,355.61 $655,996.58 $583,962.29 $612,904.73

FWS Headquarters Cost Share Allocation Charged by FTE $418,892.86 $504,202.28 $443,399.17 $518,833.22

Total Overhead Costs Charged HQ $488,279.78 $792,574.45 $609,579.08 $933,404.45 $592,906.58 $822,243.20 $621,279.53 $900,492.52

Enterprise-wide CPS Costs Charged by HQ to Wildlife $266,600.00 $283,200.00

Enterprise-wide CPS Costs Charged by HQ to Sportfish $295,500.00 $302,700.00

Total Enterprise-wide Costs Charged by HQ $266,600.00 $295,500.00 $283,200.00 $302,700.00

Total Overhead & CPS Costs $488,279.78 $1,059,174.45 $609,579.08 $1,228,904.45 $8,944.29 $1,105,443.20 $621,279.53 $1,203,192.52

CPS—Common Program Services FY 2017 FY 2018

Total for Fiscal Year $2,288,078.90 $2,308,635.72

Check Number $488,000.00 $1,062,000.00 $610,000.00 $1,228,000.00 $593,000.00 $1,105,000.00 $621,000.00 $1,203,000.00

Difference -$2,825.55 $904.45 $443.20 $192.52

As noted above there are unsupportable costs of $2,825.55 for the WR Program for FY 2017. 

In addition, there are differences of $904.45 for the SFR Program for FY 2017, $433.30 for the WR 

Program for FY 2018, and $192.52 for the SFR Program for FY 2018. 

Given the knowledge that 253 D (Bureau Wide Assessment) was not fully in place in FY 2017 

resulting in different cost centers being used the first exception noted above of unsupportable costs 

of $2,825.55 were considered acceptable. In addition, the additional exceptions i.e. the differences 

noted above may be the result of system changes FWS went through in FY 2017 and/ or considered 

rounding differences and were considered acceptable. 

Audit of States, Training and Relocation Expenditures for FYs 2017 and 2018 

Our review of the 10 transactions (CDIAC 6, 8 & 11) tested for FY 2017 we found 0 exceptions. Our review 

of the 10 transactions (CDIAC 6, 8 & 11) tested for FY 2018 we found 0 exceptions. 

CDIAC 6 = Audits of States. 

CDIAC 8 = Training of Federal and State FT personnel. 

CDIAC 11 = Relocation of personnel 

Page 14 of 34 
 

 

 

 

 

 

 

 

 

Audits of States, Training and Relocation Expenditure Exceptions for FYs 2017 and 2018 

FY 2017 FY 2018 Total 

Control No. of 

Internal 

Control 

Exceptions 

Error Rate 

(% of 10 

Transactions) 

No. of 

Internal 

Control 

Exceptions 

Error Rate 

(% of 10 

Transactions) 

Total 

Internal 

Control 

Exceptions of 

20 

Transactions 

Error Rate 

(% of 20 

Transactions) 

1 0 0 0 0 0 0 

2 0 0 0 0 0 0 

3 0 0 0 0 0 0 

4 0 0 0 0 0 0 

5 0 0 0 0 0 0 

6 0 0 0 0 0 0 

7 0 0 0 0 0 0 

8 0 0 0 0 0 0 

9 0 0 0 0 0 0 

10 0 0 0 0 0 0 

11 0 0 0 0 0 0 

12 0 0 0 0 0 0 

13 0 0 0 0 0 0 

14 0 0 0 0 0 0 

15 0 0 0 0 0 0 

16 0 0 0 0 0 0 

17 0 0 0 0 0 0 

18 0 0 0 0 0 0 

Total 0 0 0 0 0 0 

Travel Expenditures for FYs 2017 and 2018 

Our review of the 43 travel transactions (CDIAC 9) tested for FY 2017, we found 0 exceptions. 

Our review of the 39 travel transactions (CDIAC 9) tested for FY 2018, we found 0 exceptions. 

CDIAC 9 = Travel to the States, territories, Canada 

Travel Expenditure Exceptions for FYs 2017 and 2018 

FY 2017 FY 2018 Total 

Control 

No. of 

Internal 

Control 

Exceptions 

Error Rate 

(% of 43 

Sampled 

Travel 

Records) 

No. of 

Internal 

Control 

Exceptions 

Error 

Rate (% of 

39 

Sampled 

Travel 

Records) 

Total 

Internal 

Control 

Exceptions of 

82 Sampled 

Travel 

Records 

Error Rate 

(% of 82 

Sampled 

Travel 

Records) 

1 0 0 0 0 0 0 

2 0 0 0 0 0 0 

3 0 0 0 0 0 0 

Page 15 of 34 
 

 

 

 

4 0 0 0 0 0 0 

5 0 0 0 0 0 0 

6 0 0 0 0 0 0 

7 0 0 0 0 0 0 

8 0 0 0 0 0 0 

9 0 0 0 0 0 0 

10 0 0 0 0 0 0 

11 0 0 0 0 0 0 

12 0 0 0 0 0 0 

13 0 0 0 0 0 0 

14 0 0 0 0 0 0 

15 0 0 0 0 0 0 

16 0 0 0 0 0 0 

17 0 0 0 0 0 0 

18 0 0 0 0 0 0 

Total 0 0 0 0 0 0 

Compliance Procedures Results Summary 

This table summarizes unallowable and/or unsupportable costs we identified as a result of our testing of 

expenditures. 

Category 

Obligated Amounts Unallowable/Questioned 

Costs 

Total 

Unallowable/ 

Questioned 

Costs 

FY 2017 FY 2017 

WR SFR Total 

Obligations WR SFR 

Payroll $6,667,000 $6,355,000 $13,022,000 $430.38 $31.88 $462.26 

Support $1,489,000 $1,358,000 $2,847,000 0 0 0 

Overhead $1,550,000 $1,838,000 $3,388,000 0 0 0 

Audits of 

States 

$680,000 $1,167,000 $1,847,000 0 0 0 

Training $25,000 $20,000 $45,000 0 0 0 

Travel to 

States 

$344,000 $402,000 $746,000 0 0 0 

Relocation $140,000 $91,000 $231,000 $66,019.52 0 $66,019.52 

Total $10,895,000 $11,231,000 $22,126,000 $66,449.90 $31.88 $66,481.78 

Page 16 of 34 
 

 

 

 

 

 

 

 

 

 

 

 

 

Category 

Obligated Amounts Unallowable/Questioned 

Costs 

Total 

Unallowable/ 

Questioned 

Costs 

FY 2018 FY 2018 

WR SFR Total 

Obligations WR SFR 

Payroll $6,631,000 $6,136,000 $12,767,000 0 0 0 

Support $1,463,000 $856,000 $2,319,000 0 0 0 

Overhead $1,698,000 $1,824,000 $3,522,000 0 0 0 

Audits of 

States 

$1,075,000 $939,000 $2,014,000 0 0 0 

Training $27,000 $23,000 $50,000 0 0 0 

Travel to 

States 

$283,000 $319,000 $602,000 0 0 0 

Relocation ($11,000) $203,000 $192,000 $6,514.03 $43,601.06 $50,115.09 

Total $11,166,000 $10,300,000 $21,466,000 $6,514.03 $43,601.06 $50,115.09 

5.0 FINDINGS 

5.0 Internal Controls-Compliance Minor Exceptions 

5.1.1 Condition: 

Internal controls for payroll was effective to ensure all time recorded for WSFR programs were 

recorded as allocated. However, minor exceptions were annotated as follows: (1) timesheets were 

verified by the timekeeper instead of the employee; (2) timekeeper was able to verify own 

timesheets. 

Fiscal Year 

Number of 

Payroll 

Records 

Sampled 

Number of 

Exceptions 

Error 

Rate Remarks 

2017 295 

51 17.29% Timesheets were signed by the 

timekeeper instead of the employee. 

7 2.37% Timesheets were validated by the employee 

(validator) instead of another timekeeper. 

2018 261 

63 24.14% Timesheets were signed by the 

timekeeper instead of the employee. 

3 1.15% Timesheets were validated by the employee 

(validator) instead of another timekeeper. 

Total 556 124 22.30% 

5.1.2 Criteria: 

Page 17 of 34 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

U.S. Department of Interior, National Business Center, Time & Attendance (T&A) Pay Codes 

Manual, May 2006. 

5.1.3 Cause: 

(1) FWS uses DOI Quick Time as the official timekeeping system where employees are 

required to use the web-based software to record allocated hours charged to approved, FWS 

programs to include the WSFR programs. Hence, the Quick Time system is the system, 

employees use too record and code hours worked. Employees are required to input hours 

into Quick Time at least on a biweekly basis. However, it’s an accepted practice in all

Regions for the timekeeper to input hours worked for employees if the employee doesn’t

have computer access or not available for some reason during pay period end to enter 

his/her time. 

(2) The system allows for the timekeeper to not only verify his/her own time, but to validate 

his/her own time. 

5.1.4 Effect: 

Timekeepers were able to prepare (record and code hours worked) their own time in QuickTime. 

Then, validate own time. 

5.1.5 Recommendations: 

5.1.5.1 Ensure the internal controls in place for payroll and non-payroll are reviewed on a 

monthly basis to ensure they are being implemented to avoid any future violations of 

the Act. 

5.1.5.2 Consult with the DOI Business Center to initiate additional controls in the Quick Time 

system so that timekeeper can’t prepare (input own time in QuickTime) and then also validate

own time. 

5.1 Compliance – Personnel Costs Full-Time Employees (Repeat Condition) 

5.2.1 Condition: 

FWS’s practice for charging personnel FT under CDIAC 1 above didn’t fully comply with the

Act’s provision (repeat condition).

The Act limits personnel hours to personnel supporting the Act FT, CDIAC 1 and to personnel 

supporting the Act PT for a minimum of 20 hours per week CDIAC 2. 

In implementing the Act, under CDIAC 1 FWS uses two categories of FT personnel: 

1. Full-time FWS employee members who work 100 percent of the time in support of 

WSFR programs; and 

2. Full-time FWS employee members who work 100 percent of the time in support of the 

WSFR programs and other wildlife restoration-related grant programs, but not 100 

percent performing work chargeable to the Act. 

Page 18 of 34 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

FWS Regions have policies and procedures in place that require FWS WSFR employees to charge 

time to the Act when only managing the WSFR programs that are part of the Act and charge their 

other time to the other restoration-related grant programs they spend time on. Not limiting 

personnel who charge time to the Act to only FT personnel who spend 100 percent of their time 

managing the Act is a violation of the Act. 

5.2.2 Criteria: 

U.S.C. Title 16 Chapter 5B: Section 669h, Requirements and restrictions concerning use of 

amounts for expenses for administration, states “The Secretary of the Interior may use available 

amounts under section 669c (a) (1) of this title only for expenses for administration that directly 

support the implementation of this chapter that consists of: 

(1): Personnel costs of employees who directly administer this chapter on a FT basis. 

5.2.3 Cause: 

Subsequent to passage of the Act, additional wildlife restoration-related grant programs have been 

authorized by Congress for which administrative funds are provided. To achieve efficiency in 

managing these programs, FWS has chosen to use personnel who are FWS WSFR Program 

employees to also manage these new programs, which results in them not being employees who 

directly administer the Act on a FT basis. Procedures are established in all FWS Regions [(Region 

1 (Portland, OR), Region 2 (Albuquerque, NM), Region 3 (Bloomington, MN), Region 4 (Atlanta, 

GA), Region 5 (Hadley, MA) Region 6 (Lakewood, CO), Region 7 (Anchorage, AK), Region 8 

(Sacramento, CA) and Region 9 (Falls Church, VA)] to charge their hours to the program for which 

they work; however, language in the Act is still waiting to be changed to allow for this 

arrangement. The DOI prepared for the House Natural Committee on Natural Resources 

Subcommittee on Federal Lands Hearing on H.R.5875, To Amend the Pittman-Robertson Wildlife 

Restoration Act and the Dingell-Johnson Federal Aid in Sport Fish Restoration Act dated May, 22 

2018. The purpose of the amendment is to provide parity for United States territories and the 

District of Columbia, to make technical corrections to such Acts and related laws. 

5.2.4 Effect: 

FWS continues to not be in compliance with the Act’s provision CDAIC 1 that allows for personnel 

costs only for FT employees who directly administer the Act on a FT basis. 

5.2.5 Recommendations: 

5.2.5.1 Monitor and follow-up on a monthly basis with ‘Congressional and Legislative 

Affairs’ for proposed written language changes to be made to the PittmanRobertson Wildlife Restoration Act and the Dingell-Johnson Federal Aid in Sport 

Fish Restoration Act affecting FT employees. 

5.2.5.2 Discontinue allowing FWS WSFR program FTEs the ability to charge to nonWSFR programs until language in the Act is revised that will allow FWS WSFR 

Page 19 of 34 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

program FTEs who are assigned to the WSFR programs on a FT basis the ability to 

charge time to other wildlife restoration-related grant programs. 

5.2 Compliance – Personnel Costs Part-Time Employees 

5.3.1 Condition: 

FWS’s practice for charging personnel PT under CDIAC 2 above didn’t fully comply with the

Act’s provision (repeat condition).

The Act limits personnel hours to personnel supporting the Act PT for a minimum of 20 hours per 

week CDIAC 2. 

In implementing the Act, under CDIAC 2 FWS uses two categories of PT personnel: 

1. Full-time FWS employee members who work 50 percent of the time in support of 

WSFR programs and 50 percent of the time in support of other wildlife restorationrelated grant programs; and 

2. Full-time FWS employee members who are assigned to other wildlife restoration-related 

grant programs and charge hours to the WSFR program on a less than part-time basis. 

5.3.2 Criteria: 

U.S.C. Title 16 Chapter 5B: Section 669h, Requirements and restrictions concerning use of 

amounts for expenses for administration, states “The Secretary of the Interior may use available 

amounts under section 669c (a) (1) of this title only for expenses for administration that directly 

support the implementation of this chapter that consists of: 

(2): Personnel costs of employees who directly administer this chapter on a PT basis for 

at least 20 hours each week, not to exceed the portion of those costs incurred with respect 

to the work hours of the employee during which the employee directly administers this 

chapter, as those hours are certified by the supervisor of the employee. 

5.3.3 Cause: 

Archaeological expertise is required to provide cultural resource compliance and comply with the 

National Historic Preservation Act of 1966 (NHPA), Public Law 89-665; 54 U.S.C. 300101 et seq.). 

The NHPA is legislation intended to preserve historical and archaeological sites in the United States 

of America. 

In order to meet the NHPA cultural resource compliance and comply with the NHPA, Region 7 

(Anchorage, AK) has a memorandum of understanding (MOU) with FWS Refuges to use the two 

archeologists that are FT and PT Refugee’ employees (and are not FT or PT WSFR Program

employees) to provide this compliance service, as needed in executing the WSFR Programs. 

5.3.4 Effect: 

Page 20 of 34 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

FWS continues to not be in compliance with the Act’s provision CDIAC 2 Personnel costs of 

employees who directly administer this chapter on a PT basis for at least 20 hours each week, not to 

exceed the portion of those costs incurred with respect to the work hours of the employee during 

which the employee directly administers this chapter, as those hours are certified by the supervisor 

of the employee. In summary, FWS has total unallowable costs of $462.26 against CDIAC 2 for FY 

2017 where costs were incurred by other FWS employees that aren’t PT WSFR employees.

5.3.5 Recommendations: 

5.3.5.1 Monitor and follow-up on a monthly basis with ‘Congressional and Legislative

Affairs’ for proposed written language changes made to be made to the PittmanRobertson Wildlife Restoration Act and the Dingell-Johnson Federal Aid in Sport 

Fish Restoration Act affecting PT employees. 

5.3.5.2 Review the amount of work required by the archeologists on an annual basis. If 

there is enough work to meet the Act’s PT provision for one archeologist then 

reassign an archeologist to the WSFR Program on a PT basis with an MOU in place 

with FWS Refugee to use this archeologist. 

5.3.5.3 Discontinue using WSFR program funds for PT FWS employees that aren’t PT

WSFR employees that charge more than 20hrs a week, but less than 40hrs a week 

for purposes related to the administration of the Act, until language is changed in the 

Act allowing for non-PT WSFR employees to charge to the Act. 

5.3 Compliance – Relocation Costs 

5.4.1 Condition: 

FWS’s practice for charging relocation expenses for personnel, who after relocation will administer

the Act on a FT basis for at least one year, was not in compliance with the provision of the Act for 

relocation costs i.e. CDAIC 11. 

The Act limits relocation expenses to personnel supporting the Act FT who, after relocation, will 

administer the Act on a FT basis for at least one year, as certified by the Director of the United 

States Fish and Wildlife Service at the time at which the relocation expenses are incurred. 

5.4.2 Criteria: 

U.S.C. Title 16 Chapter 5B: Section 669h, Requirements and restrictions concerning use of 

amounts for expenses for administration, states “The Secretary of the Interior may use available 

amounts under section 669c (a) (1) of this title only for expenses for administration that directly 

support the implementation of this chapter that consists of: 

(11): Relocation expenses for personnel who, after relocation, will administer this chapter on a FT 

basis for at least one year, as certified by the Director of the United States Fish and Wildlife 

Service at the time at which the relocation expenses are incurred. 

5.4.3 Cause: 

Page 21 of 34 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Subsequent to passage of the Act, additional wildlife restoration-related grant programs have been 

authorized by Congress for which administrative funds are provided. To achieve efficiency in 

managing these programs, FWS has chosen to use personnel who are WSFR Program employees 

(Act) to also manage these new programs. Procedures are established in all FWS Regions to charge 

employee hours to the program for which they work; however, language in the Act is still waiting 

to be changed to allow for this arrangement. This FWS practice (a nexus) resulted in a secondary 

non-compliance issue where WSFR employees who relocated and incurred relocation expenses, 

charged within one year of relocation, time to other restoration-related programs, and as a result 

became non-compliant with the Act’s provision CDAIC 11.

5.4.4 Effect: 

FWS not being in compliance with the Act’s provision CDAIC 11: Relocation expenses for 

personnel who, after relocation, will administer this chapter on a FT basis for at least one year, as 

certified by the Director of the United States Fish and Wildlife Service at the time at which the 

relocation expenses are incurred. In summary, FWS has total unallowable costs of $106,134.61 

against CDAIC11 for FY 2017 and FY 2018 where costs were incurred by WSFR employees that 

relocated and didn’t charge FT for one year after relocating to only WSFR programs.

5.4.5 Recommendations: 

5.4.5.1 Ensure that individuals that are paid relocation costs charge FT to only WSFR 

programs for one year after relocation and do not charge to other wildlife 

restoration-related grant programs until they have completed administering the Act 

on a FT basis for at least one year. 

5.4.5.2 Ensure certification by the Director or Region WSFR that permanently change of 

station (PCS) employees administered the Act FT for at least 1 year once relocation 

expenses are incurred. And that the PCS’d employees don’t charge to other wildlife

restoration-related grant programs during this 1-year period. 

5.4.5.3 For FT employees assigned to the WSFR programs that relocated (and WSFR paid 

the relocation costs) and subsequently didn’t charge FT to the WSFR programs (in 

addition charged to other wildlife restoration-related grant programs) reimburse the 

WSFR programs the relocation cost (on an allocated program/non-program 

percentage of costs) per FY basis (if relocation costs crossed FYs). 

Note: Above occurred at Region 1 (Portland, OR), Region 2 (Albuquerque, NM) & Region 5 

(Hadley, MA). 

6.0 CONCLUSIONS 

FWS management had the policies and procedures in place for the proper administration of internal 

controls over both payroll and non-payroll expenditures. However, at times FWS Regional 

management didn’t follow the internal control policies and procedures in place in full for payroll 

leading to minor exceptions. In addition, Regional management involved in administering the Act 

didn’t ensure that the policies and procedures in place to fully comply with the Act’s provisions 

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were being followed leading to being in violation of the FT provision, PT Provision and Relocation 

Provision of the Act. As a result, not all of the expenditures and obligations that were incurred in 

administering the Act in FY 2017 and FY 2018 were appropriate and allowable. 

7.0 RECOMMENDATIONS 

7.1 5.1.5.1 Ensure the internal controls in place for payroll and non-payroll are reviewed on 

a monthly basis to ensure they are being implemented to avoid any future violations of 

the Act. 

7.2 5.1.5.2 Consult with the DOI Business Center to initiate additional controls in the Quick Time 

system so that timekeeper can’t prepare (input own time in QuickTime) and then also validate 

own time. 

7.3 5.2.5.1 Monitor and follow-up on a monthly basis with ‘Congressional and Legislative

Affairs’ for proposed written language changes to be made to the Pittman-Robertson 

Wildlife Restoration Act and the Dingell-Johnson Federal Aid in Sport Fish Restoration 

Act affecting FT employees. 

7.4 5.2.5.2 Discontinue allowing FWS WSFR program FTEs the ability to charge to nonWSFR programs until language in the Act is revised that will allow FWS WSFR 

program FTEs who are assigned to the WSFR programs on a FT basis the ability to 

charge time to other wildlife restoration-related grant programs. 

7.5 5.3.5.1 Monitor and follow-up on a monthly basis with ‘Congressional and Legislative

Affairs’ for proposed written language changes made to be made to the PittmanRobertson Wildlife Restoration Act and the Dingell-Johnson Federal Aid in Sport Fish 

Restoration Act affecting PT employees. 

7.6 5.3.5.2 Review the amount of work required by the archeologists on an annual basis. If 

there is enough work to meet the Act’s PT provision for one archeologist then reassign 

an archeologist to the WSFR Program on a PT basis with an MOU in place with FWS 

Refugee to use this archeologist. 

7.7 5.3.5.3 Discontinue using WSFR program funds for PT FWS employees that aren’t PT

WSFR employees that charge more than 20hrs a week, but less than 40hrs a week for 

purposes related to the administration of the Act, until language is changed in the Act 

allowing for non-PT WSFR employees to charge to the Act 

7.8 5.4.5.1 Ensure that individuals that are paid relocation costs charge FT to only WSFR programs 

for one year after relocation and do not charge to other wildlife restoration-related grant 

programs until they have completed administering the Act on a FT basis for at least one year. 

7.9 5.4.5.2 Ensure certification by the Director or Region WSFR that permanently change of 

station (PCS) employees administered the Act FT for at least 1 year once relocation 

expenses are incurred. And that the PCS’d employees don’t charge to other wildlife

restoration-related grant programs during this 1-year period. 

7.10 5.4.5.3 For FT 

employees assigned to the WSFR programs that relocated (and WSFR paid the 

relocation costs) and subsequently didn’t charge FT to the WSFR programs (in addition

charged to other wildlife restoration-related grant programs) reimburse the WSFR 

programs the relocation cost (on an allocated program/non-program percentage of costs) 

per FY basis (if relocation costs crossed FYs). 

Page 23 of 34 
 

8.0 MANAGEMENT RESPONSE TO REPORT 

Page 24 of 34 
United States Department of tl1e Interior 

FISH AND WILDLIFE SERVICE 

WashingtonD.C. 20240 

In ~eply refu to: 

FWSIAMAD.•PBR1>1A.IRM!DCN072 12<t 

°'!1!"11,tlglod ~ ~AIA. To PAUL : Director, Financial Audits IIALlOi 

Dlt<t 2020.JJJ.2.0 RAUCH l],27,)4-IMW 

From: Assistant Director, Wildlife and Sport Fish Restoration 

Subject: Response to Draft Audit Report: Perfonnance Audit of Expenditures and 

Obligation Used by the Secretary of the Interior in the Administration of the 

Wildlife and Sport Fish Restoration Programs Improvement Act of 2000, Public 

Law 106-408, forFisc.al Years 2017-2018 

Thank you for the opportunity to comment on and respond to the draft audit report Perfonnance 

Audit of Expenditures and Obligations Used by the Secretary of the Interior in the. 

Administration of the Wildlife and Sport Fish Restoration Programs Improvement Act of 2000, 

Public Law 106-408,for Fiscal Years 2017-2018. Resolving audit issues continues to be an 

agency priority, and the Service values the opportunity to improve the Wildlife and Sport Fish 

Restoration Program to better serve the States and the American people. 

The Service's responses to the recommendations in the draft report and the Service's planned 

actions to address the recommendations are listed below. If you require additional information, 

please contact Jvlr. Paul Rauch, Assistant Director,_ 

Summary Response: 

The Fish and Wildlife Sen,ice (Service) partially concurs with two of the four audit finding.5. 

The Wildlife and Sport Fish Restoration Program (WSFR) is coOllllitted to take all necessary 

actions to assure the integrity oftbe Wildlife and Sport Fish Restoration Acts (Act), and has, 

since its reorganization, taken action to enhance its internal controls. 

The Service and WSFR partially agree \vith the findings related to personnel costs for full time 

employees and reloc~tion costs. It will be emphasized that fiscal staff should continue to review 

all coding related to Pennanent Change of Station (PCS) costs. Toe WSFR Program will work 

with the Interior Business Center (IBC) to potentially pay the other programs' shares of 

relocation costs. 

In addition, the Service wi.ll continue to work \\rith Congress to have language added related to 

number of hours for \Vorkers. In the meantime, it is inefficient to keep employees \Vorking only 

on specific programs. By leveraging expertise among the various grant programs, the Service 

reduces costs to the taxpayer. WSFR currently holds bi-weekly meeting.5 with Congressional 

Page 25 of34 
 

and Legislative affilirs on the progress of the language change requests and any other pe.rtinent 

infonnation or legal changes. 

Toe Service does not concur with the internal control finding related to tin1ekeepers validating 

their own timesheets. The control in place is the supen.~sory certification and is sufficient to 

prevent or detect and correct any potential error. Toe IBC has deen1ed this control to be the 

required control in the system, as certifiers cannot certify their own time. Toe Service would 

note this would be a Deparnnent of Interior (Depan=t) control deficiency and has not been 

identified in any financial audits of the Department. 

Toe Service also does not concur ·with !he finding related to !he part time employees charging 

time. In this instance, specific expertise was required (archaeology) and was provided by a 

Service employee in another program. Coruracting out this function would ha\'C ineffectively 

collSll1lled bolh time and resources. 

As more requirements are added to grant compliance, sucb as arcbaeological review, !he \VSFR 

program may need assistance from other areas of !he Service to meet these requirements. It is 

inefficient and costly to !he programs to not leverage expertise fhat are already on staff ,vithi.n the 

Departmenl. 

Internal Controls - PayTOll costs: 

Toe Service disagrees ,vith the control finding. 

Toe control for tirnesheets is at the supervisory certification level, and not the tin1ekeeper level. 

Toe Department and the Interior Business Center have not disallowed the validation function for 

timekeepers on their own tituesheets in the Quicklime system. Both financial audits and 0MB 

Circular A-123 re\<i ews have deen1ed this to be sufficient controls for timesheets. 

Compliance Finding - Personnel Cos.ts Full Time Employees: 

Toe Service partially agrees u,ith the finding. We have requested a language cbange to ensure 

wolkers are exempt or the language is clarified. We 1Nill also continue to meet with 

Congressional and Legislative affilirs every two weeks to discuss progress on the request. 

However, due to cost saving$ and efficiency, !he Service will conlinue to leverage eniployees · 

skills to better manage the program. 

Compliance Finding - Personnel Costs Part-Time Employees: 

Toe Service disagrees ,vith the finding. New conipliance requirements have placed an extra need 

of various skills on the progran1. If the Setvice employs individuals "~th the necessary skills. we 

will leverage those skills in the least costly and most efficient manner. We will ensure 110 

charges above !hat for any work performed for the progran1 OCC\lf. 

Compliance Finding - Relocation Costs: 

Toe Service partially agrees with the finding. We are awaiting a language change to clarify the 

time wolked requirement for e111ployees. Costs should be allocated to Olher programs in which 

the employee will be working. \VSFR will eniphasize that in its annual fiscal meeting in May. 

Page 26 of 34 
 

However, as with Pf'l'Sonncl costs, the Service is leveraging skills among the various grant 

prognims in order to improve efficiency. 

RecollllJlelldation I: Ensure the internal controls in place for payroll and non-payroll are 

revi ewed on a monthly basis to ensure they are being implemented to avoid any future violations 

of the Act. 

Response: Do Not Coocur. WSFR already meets \,ith branch managers and regional managers 

every other week. Adlllinistrative and financial controls are often reinforced during those calls. 

RecollllllClldation 2: CollS\llt with the DOI Business Center (IBC) to initiate additional controls 

in the Quick1ime system so that timekeepers can't prepare (input own time in Quicktin1e) and 

then also validate their own time. 

Response: Do Not Concur: lbe Department of Interior and Interior Business Center ha\·e 

already determined the timekeeper validation is not a key control and financial statement audits 

and A-123 reviews have not identified this as a flilure. 

RecollllJlelldation 3: Monitor and follow-upon a monthly basis with 'Congressional and 

Legislath·e Affairs' for proposed \\'Titten language changes to be made to the Pinman-Robertson 

Wildlife Restoration Act and the Dingell-Johnson federal Aid in Sport Fish Restoration Act 

affecting fbll-time employees. 

Respon,;e: Partially Concur: WSFR meets with Congressional and LegislatiYe Affairs every 

other week to discuss proposed legislation. We will continue this schedule. 

RecollllllClldation 4: Discontinue allowing FWS WSFR program FTEs the ability to charge nonWSFR programs until the language in the Act is revised that will allow FWS WSFR prognim 

FTEs who are assigned to the WSFR programs on a ftill time basis the ability to charge time to 

other v.<ilcllife restoration-related grant activities. 

Response: Do Not Coocur: Toe prograni oversees more !hall just the Wildlife and Sport Fish 

Restoration Programs. In order to provide the most cost effective and efficient organization, we 

leverage skills of the employees across the progJaJns. This results in an overall administrative 

cost reduction for ta.xpayers. We will continue 10 request a language change in the Act, but in 

order 10 remain efficient, we must continue the practice. WSFR monitors the amount of time 

charged to the programs and ensures they are commensurate with the an10W1t ofworl.: performed 

by the employee. 

RecollllJlelldation 5: Monitor and follow-up 011 a monthly basis with 'Congressional and 

ugislative Affairs' for proposed \\'Titten language changes to be made to the Pinman-Robertson 

Wildlife Restoration Act and lhe Dingell-Johnson Federal Aid in SpOrt Fish Restoration Act 

affecting ft11l-time employees. 

Page 27 of 34 
 

Response: This is a repeat of Recommendation 3. Partially Concur: WSFR meets v.~tb 

Congressional and Legislative Affairs e\-ery other week to discuss proposed legislation. We will 

continue this meeting schedule. 

Recommendation 6: Review the amount of work required by the archaeologists on an aimual 

basis. Ifthere is enough work to meet the Act's part-time provision for one archaeologist, then 

hire or re-assign an archaeologist for the WSFR program on a part time basis with an MOU in 

place to urilize the archaeologist 

Response: Do )lot Concur: An archaeological review requirement was added to grants in the 

past fifteen years, after the passage of the Act. The arnotmt of work for an archaeologist would 

not equate to a full-time position. As such, we have leveraged the skillset from eniployees in 

Refuges with a memorandum of wide!standing. This is the most efficient and cost-dfective way 

of performing the required due diligence for the grant programs. In addition, some 

archaeologists' knowledge is region specific and may not translate to various areas across the 

country. 

Recommendation 7: Discontinue using WSFR program ftmds for PT FWS employees that aren't 

PT WSFR employees that charge more than 20 hours a week, but less than 40 hours a week for 

purposes related to the administration of the Act, until the language is chai1ged in the Act 

allowing for non-PT WSFR en1ployees to charge to the Act. 

Response: Do "101 Concur: The Service will not contract out the work or adjust our practices in 

order to keep the program and the organization streamlined. \VSFR monitors the amOWlt of 

time charged to the programs and ensures they are comn1enrorate with the amOWlt of work 

performed by the employee. 

Recommendation 8: Ensure that individuals that are paid relocation coSIS charge FT to only 

\VSFR programs for one year after relocation and do not charge to other wildlife restorationrelated grant programs unlil they have completed administering the Act 011 a FT basis for at least 

one year. 

Response: Partially Concur: The Service typically does this, unless the employee has a 

managerial or administrative type position. In those instances, we utilitt the employee for 

multiple programs in order to reduce costs. We will continue to operate in Ille most effective and 

efficient way to ensure our obligations to ta.xpayers and partners are met. 

Recommendation 9: Ensure certification by the Director or Region WSFR that permanent 

change of station (PCS) employees administered the Act FT for at least one year ooce relocation 

e..-,.penses are incurred. And that the PCS'ed employees don't charge to other 11,ildlife 

restoration-related grant programs during this one-year period. 

Response: Partially Concur: The Service does require the Regional Director to sign a 

certification that the employee 11,iJJ work for the program for a year. Again, to leverage skills 

and reduce overall costs, employees v.ill work on multiple progran1S, and 11,ill continue to do so. 

Page 28 of 34 
 

Recommendaiion 10: For FT employees assigned to the WSFR programs that relocated (and 

WSFR paid the relocation costs) and subsequently clidn"t charge FT 10 rhe WSFR programs (in 

addition charged the olher v.ildlife restoration-related grant programs) reimburse the WSFR 

programs tile relocation cost (on an allocated program/non-program percentage of costs) per FY 

basis (if relocation costs crossed FYs). 

Response.: Concur: The Service will consul! \\ith the Interior Business Center on lhe possibility 

of dividing out the costs among nmlriple programs. 

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9.0 AUDITOR EVALUATON OF MANAGEMENT RESPONSE 

The following are our comments to the Department of Interior’s letter dated March 24, 2020 related

to the findings for which the Service partially non-concurs or non concurs: 

Internal Controls – Payroll Costs 

FWS Response: 

The Service does not concur with the internal control finding related to timekeepers validating their 

own timesheets. The control in place for timesheets is at the supervisory certification, not at the 

timekeeper level and is sufficient to prevent or detect and correct any potential error. The Interior 

Business Center (IBC) has deemed this control to be the required control in the system, as certifiers 

cannot certify their own time. The Service would note this would be a Department of Interior 

(Department) control deficiency and has not been identified in any financial audits of the 

Department. The Department and the IBC have not disallowed the validation function for 

timekeepers on their own timesheets in the Quicktime system. Both financial audits and OMB 

Circular A-123 reviews have deemed this to be sufficient controls for timesheets. 

Evaluation of FWS response: 

SGC concurs that the Department and the IBC have not disallowed the validation function for 

timekeepers on their own timesheets in the Quicktime system. As a result timekeepers are able to 

verify and validate their own timesheets prior to submitting their timesheets to their supervisor, 

who are designated and authorized in the QuickTime system (a control in place) to certify 

timesheets. 

SGC concurs the Service should continue to meet every other week versus monthly with Branch 

Managers and Regional Directors to ensure financial and administrative controls are reinforced. 

SGC doesn’t concur or non-concur if DOI and IBC have already determined the timekeepers 

validation is not a key control and that financial statement audits and OMB A-123 reviews have 

not identified this as a failure or to be sufficient controls for timesheets. 

Compliance Finding – Personnel Costs Full-Time Employees: 

FWS Response: 

The Service partially agrees with the finding. We have requested a language change to ensure 

workers are exempt or the language is clarified. We will also continue to meet with Congressional 

and Legislative affairs every two weeks to discuss progress on the request. However, due to cost 

savings and efficiency, the Services will continue to leverage employees’ skills to better manage the

program. 

Evaluation of FWS response: 

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SGC concurs the Service requested a language change to ensure workers are exempt or the 

language is clarified. 

SGC concurs that the Service should continue to meet with Congressional and Legislative affairs 

every two weeks versus monthly to discuss progress on the request. 

SGC’s observation is that due to cost savings and efficiency the Service is leveraging employees’

skills to better manage the program. However, until language is changed in the Act allowing fulltime employees the ability to charge to other programs not covered by the Act, the Service practice 

for allowing full time personnel to charge to other programs doesn’t comply with the Act’s full time 

provision. 

Compliance Finding – Personnel Costs Part-Time Employees: 

FWS Response: 

The Service disagrees with the finding. New compliance requirements have placed an extra need of 

various skills on the program. If the Service employs individuals with the necessary skills, we will 

leverage those skills in the least costly and most efficient manner. We will ensure no charges above 

that for any work performed for the program occur. 

Evaluation of FWS response: 

SGC concurs that the Service should continue to meet with Congressional and Legislative affairs 

every two weeks versus monthly to discuss progress on the request. 

SGCs’ observations are that new compliance requirements have placed an extra need of various 

skills on the program and that for these various skills no charges above the work performed are 

charged to the program. However, until language is changed in the Act allowing FWS employees 

that are not assigned to the FWS Program as a part-time employee, the ability to charge time to the 

FWS Program while not be a part-time employee doesn’t comply with the Act’s part time

provision. 

Compliance Finding – Relocation Costs: 

FWS Response: 

The Service partially agrees with the finding. We are awaiting a language change to clarify the 

time worked requirement of employees. Costs should be allocated to other programs in which the 

employees will be working. WSFR will emphasize that in its annual fiscal meeting in May. 

Evaluation of FWS response: 

SGC concurs the Service is awaiting language change to ensure workers are exempt or the language 

is clarified. SGC concurs costs should be allocated to the programs in which the employee is 

Page 31 of 34 
 

 

 

working. However, until language is changed in the Act allowing Service employees that relocate 

and not charge full time to the FWS Program for one year after relocation, the Service doesn’t

comply with the Act’s relocation provision. 

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10.0 PRIOR YEAR NON-COMPLIANCE 

Year Number Recommendation Status 

2013/2014 1 Request revising language in the Act to allow for 

personnel who work on other WR/SFR programs to 

charge time to the appropriate WR/SFR program and 

remove the limitation of allowable personnel costs to 

only those personnel who directly administer the Act 

on a full-time basis or part-time for no fewer than 20 

hours per week (Repeat). 

Open 

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11.0 ABBREVIATIONS 

ACT Programs Improvement Act of 2000 

CAM Cost Allocation Methodology 

CAT Category 

CDIAC Costs Distributed by Improvement Act Categories’

CPS Common Program Services 

DOI Department of Interior 

F Sport Fish Restoration 

FWS U.S. Fish and Wildlife Service 

FT Full Time 

FTE Full-time Equivalent 

FY Fiscal Year 

GAGAS Generally Accepted Government Auditing Standards 

GAO Government Accountability Office 

GAS Government Auditing Standards 

HQ Headquarters 

IBC Interior Business Center 

MOU Memorandum of Understanding 

NHPA National Historic Preservation Act of 1966 

OIG Office of the Inspector General 

OMB Office of Management and Budget 

PCS Permanent Change of Station 

PL Public Law 

PT Part Time 

SFR Sport Fish Restoration 

T&A Time and Attendance 

U.S.C. United States Code 

WL Wildlife Restoration 

WSFR Wildlife and Sport Fish Restoration 

WR Wildlife Restoration 

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