OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OFTHE INTERIOR 

U.S. FISH AND WILDLIFE SERVICE WILDLIFE AND SPORT FISH 

RESTORATION PROGRAM 

Grants Awarded to the State of Montana Fish,Wildlife, and Parks, 

From July 1, 2015,Through June 30, 2017 

AUDIT 

Report No.: 2018-CR-014 February 2020 
 

 

 

 

 

OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

Memorandum 

To: Aurelia Skipwith 

Director, U.S. Fish and Wildlife Service 

From: Amy R. Billings 

Regional Manager, Central Region 

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

Restoration Program Grants Awarded to the State of Montana Fish, Wildlife, and 

Parks, From July 1, 2015, Through June 30, 2017 

Report No. 2018-CR-014 

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

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

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

Restoration Program. The audit included claims totaling approximately $82.7 million on 58 

grants that were open during the State fiscal years that ended June 30, 2016, and June 30, 2017 

(see Appendix 1). The audit also covered the Department’s compliance with applicable laws, 

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

fishing license revenues and the reporting of program income. 

We questioned costs totaling $795,097 for unsupported in-kind contributions and 

unsupported other direct costs. We also found the Department had unsupported direct costs base, 

inadequate equipment management, and had not excluded duplicate license holders from the 

license certifications. We also observed that, while the Department provided the FWS with its 

real property inventory, the FWS had not reconciled the Department records with the FWS’ real 

property inventory records. 

We provided a draft of the report to the FWS. In this report we summarize the 

Department’s and FWS Region 6’s response to our recommendations, as well as our comments 

on their response. We list the status of the recommendations in Appendix 3. 

Please provide us with a corrective action plan based on our recommendations by May 5, 

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

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

implementation. Please address your response to me and submit a signed PDF copy to 

aie_reports@doioig.gov. 

The legislation creating the Office of Inspector General requires that we report to 

Congress semiannually on all audit reports issued, actions taken to implement our 

recommendations, and recommendations that have not been implemented. 

Office of Audits, Inspections, and Evaluations | Lakewood, CO 
If you have any questions regarding this report, please contact me at 303-236-9243 

or you can email aie_reports@doioig.gov.

cc: Regional Director, Region 6, U.S. Fish and Wildlife Service 

2 
Table of Contents 

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

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

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

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

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

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

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

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

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

Observation Regarding Real Property Records ....................................................................15 

Appendix 1.....................................................................................................................................16 

Appendix 2.....................................................................................................................................19 

Appendix 3.....................................................................................................................................20 
 

 

 

 

Introduction 

Background 

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

Act1 established the Wildlife and Sport Fish Restoration Program. Under the Program, the U.S. 

Fish and Wildlife Service (FWS) provides grants to States to restore, conserve, manage, and 

enhance their wildlife and sport fish resources. The Acts and Federal regulations contain 

provisions and principles on eligible costs and allow the FWS to reimburse States up to 75 

percent of the eligible costs incurred under the grants. The Acts also require that hunting and 

fishing license revenues be used only for the administration of the States’ fish and game 

agencies. Finally, Federal regulations and FWS guidance require States to account for any 

income they earn using grant funds. 

Objectives 

We conducted this audit to determine if the State of Montana Fish, Wildlife, and Parks 

(Department): 

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

related regulations, FWS guidelines, and grant agreements

• Used State hunting and fishing license revenues solely for fish and wildlife program

activities

• Reported and used program income in accordance with Federal regulations

Scope 

Audit work included claims totaling approximately $82.7 million on the 58 grants open during 

the State fiscal years (SFYs) that ended June 30, 2016, and June 30, 2017 (see Appendix 1). We 

report only on those conditions that existed during this audit period. We performed our audit at 

the Department’s headquarters in Helena, MT, and visited two regional offices, three fish 

hatcheries, nine wildlife management areas, eight fishing access sites, and three boat access sites 

(see Appendix 2). 

We performed this audit to supplement—not replace—the audits required by the Single Audit 

Act. 

1 16 U.S.C. §§ 669 and 777, as amended, respectively. 

1 
 

 

Methodology 

We conducted this audit in accordance with Generally Accepted Government Auditing 

Standards. Those standards require that we plan and perform the audit to obtain sufficient, 

appropriate evidence to provide a reasonable basis for our findings and conclusions based on our 

audit objectives. We believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives. 

Our tests and procedures included: 

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

the Department

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

reimbursements, in-kind contributions, and program income

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

grants were supportable

• Conducting site visits to inspect equipment and other property

• Determining whether the Department used hunting and fishing license revenues

solely for the administration of fish and wildlife program activities

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

of the Acts

We also identified the internal controls over transactions recorded in the labor- and license-fee 

accounting systems and tested their operation and reliability. Based on the results of initial 

assessments, we assigned a level of risk to these systems and selected a judgmental sample of 

transactions for testing. We did not project the results of the tests to the total population of 

recorded transactions or evaluate the economy, efficiency, or effectiveness of the Department’s 

operations. 

We relied on computer-generated data for other direct costs and personnel costs to the extent that 

we used these data to select Program costs for testing. Based on our test results, we either 

accepted the data or performed additional testing. For other direct costs, we took samples of 

costs and verified them against source documents such as purchase orders, invoices, receiving 

reports, and payment documentation. For personnel costs, we selected Department employees 

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

supporting data. 

Prior Audit Coverage 

On February 24, 2014, we issued U.S. Fish and Wildlife Service Wildlife and Sport Fish 

Restoration Program Grants Awarded to the State of Montana Department of Fish, Wildlife and 

Parks From July 1, 2010, Through June 30, 2012 (Report No. R-GR-FWS-0011-2013). 

2 
 

 

 

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

of the Interior, Office of the Assistant Secretary for Policy Management and Budget (PMB) 

considered one recommendation resolved and implemented, and two recommendations resolved 

but not yet implemented. As discussed in the “Findings and Recommendations” section of this 

report, we are repeating one recommendation related to in-kind contributions. Additionally, we 

made an observation regarding the Department’s land reconciliation. 

We reviewed single audit reports for SFYs 2016 and 2017. None of these reports contained any 

findings that would directly affect the Program grants. 

3 
 

 

 

 

 

Results of Audit 

Audit Summary 

We identified the following conditions that resulted in our findings including questioned costs 

totaling $795,097. 

A. Questioned Costs—$795,097.

1. Unsupported In-Kind Contributions—$794,029. We questioned $794,029 as

unsupported in-kind contributions. The Department did not ensure that volunteer

hours used as in-kind contributions were sufficiently documented to allow us to verify

the volunteers’ time.

2. Unsupported Other Direct Costs—$1,068. The Department is required to keep

accurate and complete accounting records of the Program and license expenditures.

The Department, however, could not provide supporting documentation for a travel

expenditure for a school.

B. Unsupported Direct Costs Base. Although the Department obtained negotiated indirect

cost rates for SFY 2016 and SFY 2017, it did not provide the financial data to support its

grants’ direct costs base.

C. Inadequate Equipment Management. Although the Department performed physical

inventories, it has not maintained accurate and complete equipment inventory and

disposal records.

D. Duplicate Hunting and Fishing Licenses. The Department completed annual hunting

and fishing license certifications. It did not, however, eliminate duplicate resident hunting

and fishing license holders in its annual license certifications to the FWS.

We also make one observation regarding the reconciliation of real property records between the 

Department and the FWS. 

Findings and Recommendations 

A. Questioned Costs—$795,097

1. Unsupported In-Kind Contributions—$794,029

Since the Department did not sufficiently document the volunteer hours used as inkind contributions, we were unable to verify the volunteers’ time. The Department

used the value of volunteer hours worked as part of its matching share on Grant Nos.

F15AF00491 and F15AF00535 for SFY 2016 and on Grant Nos. F16AF00603 and

F16AF00612 for SFY 2017 under the Program. After volunteers recorded their hours

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on timesheets, Department officials applied an hourly rate to determine the value of 

the in-kind contributions. 

When we reviewed volunteer hours related to the hunter education and aquatic 

education programs we found the following problems with the supporting 

documentation: 

Aquatic Education: 

• Department officials did not consistently sign volunteer instructors’

timesheets to indicate approval.

• Timesheets listed multiple instructors with combined volunteer hour totals

rather than individual itemization.

• Volunteers totaled hours worked over multiple days as a lump sum rather than

on a daily basis.

• Volunteers claimed an excessive 20 to 248 hours in a single day.

• The Department could not provide timesheets to support reported hours.

Hunter Education: 

• Department officials did not consistently sign volunteers’ timesheets to

indicate approval.

• The instructors were also approving their own time on the volunteers’

timesheets.

• The Department claimed duplicate hours for eight individuals.

We found that the Department did not properly document 72 percent of all volunteer 

hours submitted under these programs, as shown in Figure 1. 

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Project 

Grant 

Number 

Sampled 

Hours 

Claimed 

Questioned 

Hours 

Sampled 

Amount 

Claimed 

Sampled 

Amount 

Questioned 

Percentage 

of Hours 

Questioned 

Hunter 

Education F15AF00535 2,728 1,123 $45,903 $18,900 41% 

Hunter 

Education F16AF00612 4,391 2,092 73,892 35,200 48% 

Aquatic 

Education F15AF00491 1,984 1,984 25,592 25,592 100% 

Aquatic 

Education F16AF00603 2,412 2,412 52,463 52,463 100% 

Total 11,515 7,611 $197,850 $132,155 72% 

Figure 1. Questioned hunter and aquatic education in-kind volunteer hours. 

A Department official from the aquatic education program informed us that the 

Department only requires volunteers to fill out report forms that track hours worked 

over multiple days as a lump sum rather than on a daily basis. The Department does 

not keep timesheets for the volunteer hours from instructors. Therefore, we are 

questioning all the aquatic education program’s volunteer hours. For SFY 2016 we 

are questioning $524,276 ($393,207 Federal share) and we are questioning $534,428, 

($400,822 Federal share) for SFY 2017. While the State did have overmatch in both 

SFY 2016 and 2017, we determined it was unreliable because of the systemic issue 

we identified for aquatic education. 

The Code of Federal Regulations, specifically 2 C.F.R.§ 200.403(g), requires costs to 

be adequately documented to be allowable under Federal awards. In addition, 

2 C.F.R. § 200.306(b)(1) states that for all Federal awards, any shared costs or 

matching funds and all contributions, including cash and third-party in-kind 

contributions, must be accepted as part of the non-Federal entity’s cost-sharing or 

matching requirement if they are verifiable from the records of grantees, among other 

requirements. To the extent feasible, services donated to the non-Federal entity will 

be supported by the same methods used to support the allocability of regular 

personnel services (2 C.F.R.§ 200.434(d)). 

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Several issues led to the problems with in-kind contribution documentation: 

Aquatic Education: 

• The timesheets for the programs we reviewed were not formatted in a way

that allowed volunteers to report their hours on a daily basis.

• The Department did not restrict the number of hours that volunteers can

reasonably donate in a single day.

• The Department did not have written policies and procedures for completing

timesheets for the aquatic education program.

• The Department did not adequately track the volunteer hours by event, name,

date, and hours, allowing for duplicate entries and volunteer hours to be

applied to the wrong SFY.

Hunter Education: 

• The Department did not have procedures requiring the certification of each

instructor’s time.

• The Department did not track the volunteer hours by event, name, date, and

hours, allowing for duplicate entries and volunteer hours to be applied to the

wrong SFY.

As a result, we are questioning costs for unsupported in-kind contributions totaling 

$794,029 for the aquatic education program (see Figure 2). We did not question any 

costs for the hunter education program because the in-kind contributions exceeded the 

Department’s matching requirements. Overmatch, however, cannot be guaranteed in 

the future. The Department could face even greater questioned costs in subsequent 

audits if it does not fully address these issues and its overmatch falls short. 

SFY Grant Project 

Questioned 

Costs 

2016 F15AF00491 Aquatic Education $393,207 

2017 F16AF00603 Aquatic Education 400,822 

Total Questioned Costs $794,029 

Figure 2. Questioned costs for unsupported in-kind contributions. 

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Recommendations 

We recommend that the FWS work with the Department to: 

1. Resolve the $794,029 of questioned costs related to unsupported in-kind costs

2. Reformat its volunteer timesheets so that hours can be reported on a daily basis

3. Develop and implement policies and procedures that (a) restrict the number of

hours that volunteers can reasonably donate in a single day, and (b) ensure that all

timesheets are approved by a third-party for all volunteer programs using in-kind

contributions to satisfy cost-share or matching requirements

4. Track the volunteer hours by event, name, date, and hours to reduce the risk of

duplicate entries and out-of-period volunteered hours

We are also repeating the recommendation from our 2014 audit report. The FWS 

should submit any documentation to PMB to track implementation using the previous 

report number. 

Repeat Recommendation (Tracked Under Report No. R-GR-FWS-0011-2013, 

Recommendation No. A2) 

We recommend that the FWS work with the Department to: 

• Establish and implement procedures requiring volunteer instructors to certify their

hours worked and to document donated costs

Department Response 

The Department concurred with our finding and recommendations. It will address the finding 

and recommendations in the corrective action plan. 

FWS Response 

The FWS concurred with our finding and recommendations. It will work with the Department to 

develop a corrective action plan. 

OIG Comment 

Based on the Department’s and the FWS’ responses, we consider Recommendations 1 – 4 

resolved but not implemented and the repeat recommendation resolved but not implemented 

(see Appendix 3).

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2. Unsupported Other Direct Costs—$1,068

The Department could not provide supporting documentation for a travel expenditure

amounting to $1,068 for a school. Federal regulation (50 C.F.R. § 80.10) requires that

all revenue from hunting and fishing licenses be used only for administration of the

State fish and wildlife agency. Without supporting documentation, we are unable to

verify if the funds were used for the authorized purpose. The Montana Operations

Manual policy on employee travel, requires reimbursable travel expenses to be

supported by a receipt. The internal process set up for the grant program, however,

did not require schools to submit receipts for all of their transactions. A Department

employee stated that the Department does not require supporting documentation on

any vendor travel costs. Therefore, we are reporting this control issue because there is

a potential for it to be material if other travel costs, not tested as part of our sample,

do not have supporting documentation.

We tested 79 expenditures (39 license and 40 grant) for SFY 2016 and SFY 2017.

Since this was the only travel expense in our sample, we cannot determine whether

other travel costs are reasonable and necessary to achieve Program purposes, and

therefore allowable.

Recommendations 

We recommend that the FWS work with the Department to: 

5. Resolve the potential diversion of $1,068

6. Implement a policy to require support for all expenditures

Department Response 

The Department partially concurred with our finding and recommendations. The Department 

agreed that the cost was unsupported but clarified that the unsupported costs were paid with 

license revenues, therefore the draft report’s reference to compliance with 2 C.F.R. § 225 was 

incorrect. It will address the finding and recommendations in the corrective action plan. 

FWS Response 

The FWS concurred with our finding and recommendations. It will work with the Department to 

develop a corrective action plan. 

OIG Comment 

Based on the comments from the Department, we modified the finding and recommendations. 

Instead of referencing 2 C.F.R. § 225 as the criteria for the unsupported costs, we reference 50 

C.F.R. § 80.10, which requires that all revenue from hunting and fishing licenses be used only

for administration of the State fish and wildlife agency. Based on the Department’s and the

FWS’ responses, we consider Recommendations 5 and 6 resolved but not implemented (see

Appendix 3).

9 
 

 

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B. Unsupported Direct Costs Base

The Department was unable to support the total direct cost bases on three of the nine

grants we reviewed. Specifically, when we recalculated the direct cost base on these

three grants, our calculation resulted in a direct cost base of $4,683,867, while the

direct cost base that the Department used was $4,764,510. The State was therefore

unable to support the direct cost base of $80,643 charged to these grants. This means

the State could not support 33 percent of the grants sampled. When we calculated the

indirect costs on these three grants, we found a total difference of $1,547 in indirect

costs claimed (see Figure 3).

FBMS 

Grant 

Number 

Base 

Amount 

on SF 425 

Rate 

Applied 

(per 

SF 425) 

Indirect 

Costs 

Claimed 

(per SF 

425) 

OIG Base 

Amount 

Calculation 

OIG 

Indirect 

Costs 

Calculation 

Difference 

in Indirect 

Costs 

Claimed 

F15AF00605 $2,064,364 18.29% $364,709* $2,001,326 $366,042 $1,333 

F16AF00612 579,746 16.36% 94,846 592,906 96,999 2,153 

F16AF00662 2,120,400 16.36% 346,898† 2,089,635 341,864 (5,033) 

Total $4,764,510 $806,453 $4,683,867 ($1,547) 

* 2,064,364 x 18.29% = $377,572

† 2,120,400 x 16.36% = $346,897

Figure 3. Unsupported direct cost base. 

Federal regulation (2 C.F.R. § 225 Appendix A, C.1.) requires that for a cost to be 

allowable under Federal awards, it must be necessary and reasonable, allocable, 

authorized or not prohibited, and adequately documented. In addition, Federal 

regulation (2 C.F.R. § 225 Appendix A, F.1.) states that indirect costs should be 

distributed to benefitted cost objectives on bases that will produce an equitable result 

in consideration of relative benefits derived. The Department used a direct cost base 

of total direct costs, less capital expenditures and pass-through funds, as identified in 

the indirect cost rate agreements. The Department then multiplied the direct cost base 

by the negotiated rate to obtain the indirect costs, which it then charged against certain 

grants. 

While the Department had an approved indirect cost rate, of 18.29 percent for SFY 

2016 and 16.36 percent for SFY 2017, it had not established and implemented 

procedures to support the grant base costs used in the application of the approved rate. 

The Department also did not establish and implement procedures to correctly calculate 

the Federal share of indirect costs. 

Because the Department could not provide documentation to support the direct cost 

base, we were unable to determine if the rates were applied to the correct direct cost 

base. In addition, since one-third of the grants in our sample did not have a supported 

10 
 

 

 

 

 

 

 

 

direct cost base, we do not have assurance that other grants that were not in our 

sample had a supported direct cost base. 

After we brought the issues to the Department’s attention, the Department submitted 

additional support for one grant and corrected the direct cost base on the other two 

grants in question. Based on these actions, we consider the issue resolved. The FWS, 

however, needs to put additional controls in place to ensure the Department follows 

policies and procedures and uses the correct direct cost base. 

Recommendation 

We recommend that the FWS work with the Department to: 

7. Establish and implement policies and procedures to ensure the Department

maintains direct cost base data for use in applying indirect cost rates and

calculates the Federal share of indirect costs correctly

Department Response 

The Department concurred with our finding and recommendation. It will address the finding and 

recommendation in the corrective action plan. 

FWS Response 

The FWS concurred with our finding and recommendation. It will work with the Department to 

develop a corrective action plan. 

OIG Comment 

Based on the Department’s and the FWS’ responses, we consider Recommendation 7 resolved 

but not implemented (see Appendix 3). 

C. Inadequate Equipment Management

We found that although the Department is performing physical inventories, it has not

maintained accurate and complete equipment inventory and disposal records. We tested

a sample of 250 property items identified in the Department’s inventory data, plus an

additional 97 items that we found during site visits at two regional offices. We also

tested a sample of 15 disposed assets. As a result of our testing, we found:

• Assets that were on the inventory list even though we were told by staff that they

had been transferred, disposed of or lost

• Assets on the inventory list that the Department could not account for or locate

• Assets we identified during the site visits that were not on the inventory list

11 
 

 

 

 

 

 

 

 

 

 

 

• Assets we located during the site visits that were classified as disposed of or

assigned to a different region on the inventory list

• One asset on the disposed asset list that was still in use (if it was added in error, the

Department did not have a report available to show that it was retired and uploaded

back into its asset management system)

• Assets on the disposed asset list without documentation of the disposal method (i.e.,

disposed, transferred, or auctioned off)

• Assets without specific locations and custodians listed on the inventory

Federal regulation (C.F.R. 50 § 80.90 (f)) requires a State fish and wildlife agency to be 

responsible for the control of all assets acquired under Program grants to ensure that 

they serve the purpose for which they were acquired throughout their useful life. 

The Montana Operations Manual states that all capital assets, tagged minor equipment, 

and sensitive equipment should be included in the inventory. Personnel conducting the 

physical inventory should record all data possible on the inventory by location report to 

update the asset management system for individual capital asset items. 

In addition, State policies require that agencies with perpetual capital asset inventory 

systems perform physical inventory biennially and non-perpetual inventory systems 

require an annual physical inventory near June 30 or December 31 for Montana State 

Funds. Capital assets disclosed by the physical inventory should agree with the items on 

the inventory list. The Department must thoroughly investigate and report discrepancies 

to the agency property coordinator. Upon completion of the physical inventory, the 

Department should make all necessary adjustments to the asset management system to 

accurately reflect capital assets total. 

Department personnel are not following State policies and procedures requiring 

inventory control and adequate equipment disposal. Further, the Department told us 

that the disposed asset issues we encountered were caused by a former employee 

responsible for the equipment disposal. 

Equipment purchased with Federal Assistance Program funding and license revenue is at 

risk of loss, misuse, or theft. Additionally, the Department and the FWS cannot ensure 

that equipment purchased with Program funds is being used for its intended purpose or 

that license-funded equipment is used solely for fish and wildlife purposes. 

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Recommendation 

We recommend that the FWS work with the Department to: 

8. Ensure that the official inventory records are updated regularly and accurately reflect

the current location or disposition of each asset

Department Response 

The Department partially concurred with our finding and recommendation. According to the 

Department, some missing assets were inaccurately reported due to the time difference between 

the date of the property report and the actual date the property review was conducted. The 

Department also noted that not all disposed asset issues were due to a personnel problem. It will 

address the finding and recommendation in the corrective action plan. 

FWS Response 

The FWS concurred with our finding and recommendation. It will work with the Department to 

develop a corrective action plan. 

OIG Comment 

Based on the Department’s response, we agree that there was a time difference between the date 

of the property report and the actual date the property review was conducted. We took that 

information into consideration when reviewing the supporting documentation provided. We also 

noted that all the issues were not due to a personnel problem. We received copies of some of the 

transfer forms and noted the inventory records were not always updated within a reasonable 

amount of time. We did not receive all of the copies of the transfer forms, lost or stolen forms, or 

disposal forms we requested. The Department told us it was unable to locate all of the 

paperwork. Based on the Department’s and the FWS’ responses, we consider Recommendation 8 

resolved but not implemented (see Appendix 3). 

D. Duplicate Hunting and Fishing Licenses

For license year 2015, the Department double-counted certain resident hunting and

fishing licenses. This led to the Department overstating its hunting license count by

950 (see Figure 4) and its fishing license count by 2,500 (see Figure 5). By not

eliminating duplicate fishing and hunting licenses, the Department reported a higher

number of license certifications, potentially resulting in a larger apportionment of

Program funds.

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Hunting License Holders 

State 

Count OIG Count Duplicates 

Residents – Hunting Only 31,427 31,289 138 

Residents – Combination 174,840 174,282 558 

Nonresidents – Hunting Only 13,259 13,171 88 

Nonresidents – Combination 33,886 33,720 166 

Total 253,412 252,462 950 

Figure 4. Duplicate hunting license holders. 

Fishing License Holders 

State 

Count OIG Count Duplicates 

Residents – Fishing Only 93,006 92,439 567 

Residents – Combination 174,840 174,282 558 

Nonresidents – Fishing Only 156,030 154,821 1,209 

Nonresidents – Combination 33,886 33,720 166 

Total 457,762 455,262 2,500 

Figure 5. Duplicate fishing license holders. 

Regulation (50 C.F.R. § 80.30) requires each State to certify, annually, the number of 

paid hunting and fishing license holders to the FWS. According to 50 C.F.R. § 

80.31(b)(3), fish and wildlife agencies are responsible for eliminating multiple 

counting of the same individuals in the information certifying the number of paid 

license holders. 

In our 2014 audit report, we found that the Department was not eliminating duplicate 

license holders. In response to our report, the Department changed its system codes to 

report calculations for the gross number of license holders, potential duplicates, and the 

net numbers with duplicates removed. Therefore, the Department reported the 

recommendation as closed. 

After we notified the Department of the issue during our current audit, the Department 

amended the license certification with the corrected numbers. The Montana bureau chief 

for Federal assistance and compliance was unsure why the report did not show the net 

numbers with the identified duplicates removed for the license year in question, as the 

Department did not have issues in subsequent reports. 

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Recommendation 

We recommend that the FWS work with the Department to: 

9. Develop and implement procedures to review reports for potential calculation errors

before reporting on license certifications in the future

Department Response 

The Department concurred with our finding and recommendation. It will address the finding and 

recommendation in the corrective action plan. 

FWS Response 

The FWS concurred with our finding and recommendation. It will work with the Department to 

develop a corrective action plan. 

OIG Comment 

Based on the Department’s and the FWS’ responses, we consider Recommendation 9 resolved 

but not implemented (see Appendix 3). 

Observation Regarding Real Property Records 

In our 2014 report, we noted that the Department had not reconciled its Program-funded, real 

property records with FWS records. We recommended that the FWS work with the Department 

to reconcile their respective records pertaining to lands purchased with Program funds. While the 

FWS and the Department agreed that they have not reconciled the real property records, the 

Department has provided all necessary records to the FWS. Therefore, we are not reporting a 

repeat finding. The FWS and the Department have coordinated to make any necessary 

modifications to the data, correct errors, and exchange additional information and source 

documents where needed. The FWS needs to conduct a final evaluation of all documents and 

data to determine if discrepancies exist between the data the Department provided and the data 

the FWS extracted from grant records. We will include this issue in a management advisory to 

the FWS. 

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Appendix 1 

State of Montana 

Fish, Wildlife, and Parks 

Grants Open During the Audit Period 

July 1, 2015, Through June 30, 2017 

We questioned $794,029 due to unsupported in-kind contributions. We also identified 

unsupported other direct costs of $1,068 in license revenue. 

FBMS Grant 

Number 

Grant 

Amount 

Claimed 

Costs 

Questioned 

Costs Ineligible 

Questioned Costs 

Unsupported 

F11AF01282 $533,974 $416,695 $0 $0 

F13AF00104 296,876 180,980 0 0 

F13AF00116 56,237 56,237 0 0 

F14AF00109 1,319,278 933,736 0 0 

F14AF00439 15,733 15,733 0 0 

F14AF00714 961,059 961,059 0 0 

F14AF01028 74,590 74,590 0 0 

F14AF01091 128,425 127,340 0 0 

F15AF00010 12,505,000 6,219,723 0 0 

F15AF00022 635,083 361,115 0 0 

F15AF00097 275,105 275,001 0 0 

F15AF00176 160,000 159,737 0 0 

F15AF00204 97,120 93,688 0 0 

F15AF00404 59,325 33,185 0 0 

F15AF00452 281,707 552,866 0 0 

F15AF00488 1,062,389 1,060,436 0 0 

F15AF00489 574,622 574,622 0 0 

F15AF00490 1,568,392 448,566 0 0 

F15AF00491 524,276 524,276 0 393,207 

F15AF00527 3,050,497 2,644,264 0 0 

F15AF00528 5,216,471 2,717,378 0 0 

F15AF00529 667,224 844,419 0 0 

F15AF00531 5,946,618 4,835,271 0 0 

F15AF00532 4,158,045 4,158,045 0 0 

16 
-

FBMS Grant -

Number 

Grant 

Amount 

Claimed 

Costs 

Questioned 

Costs Ineligible 

Questioned Costs 

Unsupported 

F15AF00533 $7,702,574 $7,702,574 $0 $0 

F15AF00534 7,330,282 7,116,857 0 0 

F15AF00535 987,246 986,075 0 0 

F15AF00605 3,572,351 3,613,833 0 0 

F15AF00619 57,349 48,507 0 0 

F15AF00620 3,620,596 3,700,319 0 0 

F15AF00916 76,967 56,911 0 0 

F15AF01050 60,000 57,170 0 0 

F15AF01166 191,596 0 0 0 

F16AF00108 1,476,254 541,533 0 0 

F16AF00109 1,031,447 255,408 0 0 

F16AF00124 652,000 652,000 0 0 

F16AF00233 1,414,496 1,400,414 0 0 

F16AF00234 250,000 233,886 0 0 

F16AF00293 856,307 96,504 0 0 

F16AF00294 1,074,152 155,811 0 0 

F16AF00359 96,043 0 0 0 

F16AF00516 56,360 56,042 0 0 

F16AF00603 534,428 534,428 0 400,822 

F16AF00612 945,627 919,875 0 0 

F16AF00643 56,030 49,232 0 0 

F16AF00649 287,920 485,403 0 0 

F16AF00660 3,000,581 3,000,581 0 0 

F16AF00661 3,976,486 3,977,026 0 0 

F16AF00662 3,520,825 3,333,143 0 0 

F16AF00663 666,305 735,110 0 0 

F16AF00865 11,286,816 11,266,971 0 0 

F16AF00970 107,686 103,979 0 0 

F16AF01082 168,140 0 0 0 

F16AF01118 508,493 49,063 0 0 

F16AF01144 335,000 287,574 0 0 

F16AF01202 876,309 55,567 0 0 

17 
-

FBMS Grant -

Number 

Grant 

Amount 

Claimed 

Costs 

Questioned 

Costs Ineligible 

Questioned Costs 

Unsupported 

F17AF00170 $2,327,200 $1,476,190 $0 $0 

F17AF00257 1,519,796 1,517,609 0 0 

Totals $100,791,708 $82,734,556 $0 $794,029 

18 
 

Appendix 2 

State of Montana 

Fish, Wildlife, and Parks 

Sites Visited 

Headquarters 

Helena, MT 

Regional Offices 

Region 5, Billings, MT 

Region 7, Miles City, MT 

Fish Hatcheries 

Bluewater Springs Trout Hatchery 

Miles City Fish Hatchery 

Yellowstone River Trout Hatchery 

Wildlife Management Areas 

Amelia Island 

Big Lake 

Elk Island 

Grant Marsh 

Haymaker 

Isaac Homestead 

Seven Sisters 

Silver Run 

Yellowstone 

Fishing Access 

Amelia Island 

Boulder Forks 

Cliff Swallow 

Elk Island 

Grant Marsh 

Manuel Lisa 

Myers Bridge 

Seven Sisters 

Boating Access 

Cooney 

South Sandstone 

West Rosebud 

19 
 

 

 

 

Appendix 3 

State of Montana 

Fish, Wildlife, and Parks 

Status of Audit Recommendations 

Recommendations Status Action Required 

1 – 9 

We consider the 

recommendations resolved but 

not implemented. 

U.S. Fish and Wildlife Service 

(FWS) regional officials 

concurred with the findings 

and recommendations and will 

work with the State of 

Montana Fish, Wildlife, and 

Parks staff to develop and 

implement a corrective action 

plan that will resolve all 

findings and recommendations. 

Complete a corrective action plan 

that includes information on actions 

taken or planned to address the 

recommendations, target dates and 

title(s) of the official(s) responsible 

for implementation, and verification 

that FWS Headquarters officials 

reviewed and approved the actions 

taken or planned by the State. 

We will refer the 

recommendations not 

implemented at the end of 90 days 

(May 5, 2020) to the Assistant 

Secretary for Policy, Management 

and Budget for tracking of 

implementation. 

20 
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