United States Department of Agriculture 

OFFICE OF INSPECTOR GENERAl 
What Were OIG’s 

Objectives

Our objectives were to 

determine if wildlife damage 

management activities were 

justified and effective, assess 

controls over cooperative 

agreements, assess MIS for 

integrity and reliability, and 

review WS’ accountability for 

hazardous materials and 

equipment. 

What OIG Reviewed

In FY 2014, we observed 40 

WS field specialists from 5 

sampled States based on their 

(1) high number of takes of 

selected predators, (2) most 

unintentional kills, or in some 

cases (3) most hours on the 

job with the fewest takes. To 

assess data accuracy in MIS, 

we sampled and reconciled 

29,958 logbook entries from 

January 2012 through March 

2014.

What OIG Recommends 

APHIS should develop and 

implement procedures that 

require a second party 

reviewer to sample and 

reconcile field specialists’ 

logbook entries to 

corresponding MIS entries. 

APHIS also should enforce the 

requirement to renew Form 

12s at least every 5 years.

OIG audited APHIS’ Wildlife Services (WS) to 

determine whether its damage management 

activities complied with applicable laws and 

requirements.

What OIG Found

WS assists a variety of cooperators (farmers, ranchers, and other 

entities) by providing wildlife management advice and controlling 

wildlife damage with nonlethal and lethal methods. Wildlife control 

arrangements are formalized on Form 12s (also known as Work 

Initiation Documents), and WS field specialists record the results in a 

database called Management Information System 2000 (MIS).

OIG’s audit did not reveal problems with wildlife damage 

management activities, or with WS’ system for tracking controlled 

materials. WS’ actions in these areas complied with all applicable 

Federal and State laws and regulations. Thus, this report contains no 

findings or recommendations associated with the first and last 

objectives of our audit. However, we found that MIS contained 

inaccurate information, including external party access and data entry 

errors. These conditions resulted in inflated wildlife control numbers 

and the transmission of inaccurate data to the public. 

WS also was not following its policy of renewing Form 12s at least 

every 5 years. We found that, nationally, 47,362 (or 30.5 percent) of 

Form 12s were older than 5 years. WS personnel were not renewing 

Form 12s because WS policy was not clearly communicated. Almost 

all WS personnel OIG interviewed believed that the 5-year life cycle 

for Form 12s was a best practice, not a policy. WS also did not have 

controls to enforce compliance with its policy. While MIS flagged 

expired Form 12s, WS personnel ignored them without consequence. 

APHIS agreed with our findings and recommendations, and we 

accepted management decision on all seven recommendations. 

APHIS Wildlife Services –

Wildlife Damage Management

Audit Report 33601-0002-41

United States Department of Agriculture

Office of Inspector General

Washington, D.C. 20250

DATE: September 8, 2015 

AUDIT

NUMBER: 33601-0002-41 

TO: Kevin Shea 

Administrator 

Animal and Plant Health Inspection Service 

ATTN: Marilyn Holland

Deputy Administrator

Marketing and Regulatory Program Business Services

FROM: Gil H. Harden

Assistant Inspector General for Audit 

SUBJECT: APHIS Wildlife Services - Wildlife Damage Management

This report presents the results of the subject review. Your written response to the official draft 

is included at the end of the report. Excerpts from the response and the Office of Inspector 

General’s (OIG) position are incorporated into the relevant sections of the report. Based on your 

written response, we have accepted your management decision on all seven recommendations. 

In accordance with Departmental Regulation 1720-1, final action is to be taken within 1 year of 

each management decision to prevent being listed in the Department’s annual Agency Financial 

Report. For agencies other than the Office of the Chief Financial Officer (OCFO), please follow 

your internal agency procedures in forwarding final action correspondence to OCFO.

We appreciate the courtesies and cooperation extended to us by members of your staff during our 

audit fieldwork and subsequent discussions. This report contains publically available 

information and will be posted in its entirety to our website (http://www.usda.gov/oig) in the 

near future. 

Table of Contents

Background and Objectives................................................................................... 1

Finding 1: WS’ Database Contains Inaccurate Information............................ 10

Recommendation 1 ......................................................................................14

Recommendation 2 ......................................................................................14

Recommendation 3 ......................................................................................15

Recommendation 4 ......................................................................................16

Finding 2: WS Did Not Timely Renew its Form 12s ......................................... 17

Recommendation 5 ......................................................................................18

Recommendation 6 ......................................................................................19

Recommendation 7 ......................................................................................19

Scope and Methodology........................................................................................ 20

Abbreviations ........................................................................................................ 24

Exhibit A: Audit Sites Visited............................................................................. 25

Agency's Response ................................................................................................ 26

Background and Objectives

AUDIT REPORT 33601-0002-41 1

Background

The Animal Damage Control Act of 1931, as amended, authorized the Secretary of Agriculture 

to conduct activities for controlling injurious animals.1 As a result, the U.S. Department of 

Agriculture (USDA) established the Wildlife Services (WS), a non-regulatory program. In 1939, 

Congress transferred the program from USDA to the U.S. Department of the Interior. In 1985, 

Congress returned the program to USDA wherein it was placed under the purview of Animal and 

Plant Health Inspection Service (APHIS). The Rural Development, Agriculture, and Related 

Agencies Appropriations Act of 1988, authorized the Secretary of Agriculture to enter into 

agreements with cooperators2and conduct animal damage control activities of nuisance 

mammals and birds.3 The WS program also operates under the provisions of numerous other 

laws, including the National Environmental Policy Act of 1969, as amended,4and the 

Endangered Species Act of 1973, as amended.5

WS’ Office of the Deputy Administrator, located in Washington, D.C., provides national 

program oversight and policy guidance. WS has two regional offices (ROs). One is located in 

Raleigh, North Carolina, and the other in Fort Collins, Colorado. WS also has 42 State offices 

that work directly with various cooperators to resolve wildlife conflicts.6 The State offices are 

divided into districts; each district is assigned a supervisor and field specialists. The National 

Wildlife Research Center (NWRC), a research arm of WS, conducts scientific research and 

assessments to refine wildlife management methods and develop new science-based solutions to 

contemporary wildlife challenges, such as rabies control and reproductive control methods to 

limit the population of deer and Canada geese.

Funding Sources and Allocation 

WS receives both Federal appropriations funding and cooperator-provided funds to sustain its 

operations.7 WS uses Federal appropriated funds for its national and regional office operations, 

and for its research functions. It funds State office operations through a combination of Federal 

appropriated and cooperator-provided funds. WS’ total program funds in fiscal year (FY) 2013 

were about $165 million, including $85 million in direct appropriations and $80 million in 

 

1

7 U.S.C. §426-426b (March 2, 1931).

2 To help address wildlife damage problems and recover costs for the services provided, WS enters into various 

agreements with cooperators including interagency agreements with federal entities, and cooperative or 

reimbursable agreements with state, county, city, university, airport, and private entities (i.e., associations, boards, 

businesses, and individuals). 

3

7 U.S.C. §426c (December 22, 1987).

4

42 U.S.C. §4321 et seq. (January 1, 1970).

5

16 U.S.C. §1531 et seq. (December 28, 1973). 

6 Conflicts occur when wildlife negatively impact agricultural and natural resources, properties, and public health 

and safety. 

7 WS conducts research and delivers program services that assist cooperators in resolving wildlife damage 

challenges. Cooperators reimburse WS for the cost of services. 
cooperator-provided funds. Of the $165 million, WS used $116 million ($36 million of 

appropriated funds, plus $80 million of cooperator-provided funds) to support operational 

activities at the State level (the summary of funding sources for all States is shown in Chart 1 

below). 

Chart 1: FY 2013 Funding Sources for WS Operational Activities 1

2 AUDIT REPORT 33601-0002-41

1Chart 1 shows three different funding sources and their proportion to support WS 

nationwide (except National Office and Regional Office) operational activities in FY 

2013: 51 percent from cooperative funding, 18 percent from federal cooperative

funding, and 31 percent from federal funding. 

2 Cooperative funding is funding received through Cooperative Service Agreements 

with State and local governments and private entities.

3

Federal Cooperative funding is funding received through Interagency Agreements 

with other Federal agencies. 

4

Federal funding is funding received through Congressional appropriations.

WS’ operational activities at the State level provide wildlife damage control assistance in four 

major areas: (1) agriculture resources, which includes protecting livestock from predators and 

alleviating bird damage at aquaculture facilities; (2) natural resources, which includes protecting 

threatened and endangered species and managing invasive species; (3) property, which includes 

protecting homes, landscaping, and industrial facilities from damage by mammals and birds; and 

(4) health and human safety, which includes reducing the risk of aircraft strikes of wildlife 

around airport runways as well as reducing and monitoring the spread of wildlife diseases to 

livestock, pets, or humans. The funds allocated to the four major areas in all States for FY 2013 

are shown in Chart 2. 
Chart 2: Funding Allocation for Operational Activities in FY 2013 1 

AUDIT REPORT 33601-0002-41 3

Natural 

Resources

12.3%

Agriculture

37.4%

Property 

16.3%

Health & 

Safety

34.0%

1 Chart 2 shows the proportion of $116 million allocated to each of the four 

major areas in which WS conducted operational activities in FY 2013: 34 

percent for health & safety, 12.3 percent for natural resources, 16.3 percent 

for property, and 37.4 percent for agriculture. 

WS monitors its fund allocation and expenditures through the Financial Management 

Modernization Initiative (FMMI).8

 FMMI provides online, real-time transaction capabilities and 

access. FMMI was designed to improve the agency’s planning, budgeting, and reporting process 

through the use of integrated data from financial and non-financial sources. It also enables the 

agency to be financially accountable and transparent in its spending. To ensure consistency in its 

financial control and cost management activities, WS also issued a new directive in August 2013, 

to provide field offices with specific guidance on cost recovery and accounting oversight for 

various cost-share agreements.9

Coordination with Cooperators 

WS enters into memoranda of understanding (MOU) with other Federal agencies and State 

regulatory agencies to establish the framework governing its activities and coordinate efforts in 

managing predatory animals.10 The MOUs define and clarify the respective roles and 

responsibilities of each agency for resolving wildlife conflicts. An MOU between WS and a 

State wildlife agency requires both parties to conduct wildlife damage management activities in 

accordance with applicable Federal, State, and local laws and regulations. While WS assumes 

primary responsibility for resolving wildlife conflicts involving migratory birds, Federally 

protected species, and airport hazards, State agencies are responsible for providing wildlife 

damage assistance with State-regulated species. State agencies also cooperate with WS to ensure 

that proper permits are secured for wildlife damage management activities. 

 

8

FMMI is an initiative by the U.S. Department of Agriculture, Office of the Chief Financial Officer, to modernize 

the Departmental accounting system. APHIS, including WS, adopted FMMI in October 2011, as part of a 

Departmental mandate. 

9 USDA APHIS Wildlife Services, Financial Control and Risk Management, Directive 2.215(August 23, 2013). 

10 WS has signed MOUs with the U.S. Fish and Wildlife Service, the Bureau of Land Management, the U.S. Forest 

Service, the Federal Aviation Administration, and the Department of Defense. It also has MOUs with many State 

wildlife, agriculture, natural resource, and public health and safety agencies.
In addition to performing specific wildlife damage tasks directed by Congress and providing 

technical assistance to the general public,

4 AUDIT REPORT 33601-0002-41

11 WS enters into cooperative service agreements 

(CSAs) to resolve specific wildlife conflicts at the request of cooperators, which can be a State, 

county, city, or private entity (such as a business or an individual farmer or rancher). WS uses 

CSAs to establish a cooperative framework with the cooperator and recover the partial or entire 

cost of its services. For each CSA, the WS State office develops both an annual work plan and a 

financial plan. The work plan describes the actions to be taken and the types of animal to be 

controlled. The financial plan describes the amount of funds to be spent on the project. The 

cooperators must review and approve both plans. In order to follow laws unique to State and 

local governments, cooperative arrangements with WS may vary considerably. In some cases, 

cooperators pay all of the costs associated with wildlife damage management.12

After a CSA is signed, WS field specialists can work directly with cooperators or landowners to 

address wildlife damage problems.13

 After a landowner makes initial contact with WS, the field 

specialist will conduct a site visit to assess wildlife damage, examine the property, and discuss 

options for reducing losses. If the landowner requests that WS conduct direct control activities, 

both parties negotiate and sign a Work Initiation Document called a Form 12.14

 A Form 12 gives 

the field specialist access to the cooperator’s property; it also specifies WS’ methods, tools, and 

species to be managed. 

Although WS uses various methods to mitigate wildlife damage problems, and prevent future 

predation, WS policy requires its field specialists to address wildlife damage problems by using 

an integrated wildlife damage management approach. Thus, when selecting damage 

management techniques for specific wildlife damage situations, the WS field specialists must 

consider the frequency, extent, and magnitude of the damage. In addition to confirming and 

assessing damage to the cooperator’s property, they must consider the status of target and 

potential non-target species, local environmental conditions, relative costs of applying 

management techniques, environmental impacts, and social and legal concerns specific to the 

case.15

 WS field specialists must formulate a management strategy that minimizes harmful 

effects on humans, non-target species, and the environment while applying practical wildlife 

damage prevention methods. For example, if a field specialist uses M-44 (sodium cyanide) 

devices, he or she must ensure that they are not used near roads, where they could be set off 

unintentionally, or near a water supply, where they could cause adverse effects on humans or 

animals.16

 

11 Technical assistance is provided in the form of advice, recommendations, information, and materials for use in 

managing wildlife conflicts. 

12 If a private entity requests WS’ direct assistance and the activity is not funded by another source, the entity enters 

into a CSA with WS and the entity pays WS for all the costs associated with the service provided. 

13 Field specialists are appointed to state-level positions by the State Director. They are responsible for conducting 

operational activities in the field and responding to requests from the public. 

14 WS field specialists provide direct assistance with their knowledge and expertise to disperse, remove, or relocate 

the wildlife causing damage, such as vultures, raccoons, coyotes, and bears.

15 The agreement between WS and the cooperator (Form 12) must list specific target species that need to be 

managed. If a species is not listed on the agreement, it is considered a non-target species. 

16 M-44(sodium cyanide capsules) devices may only be used for the control of coyotes, red and gray foxes, and wild 

dogs that are vectors of communicable diseases or are suspected of preying upon livestock, poultry, and Federally 

designated threatened and endangered (T/E) species. They may also be used for control of arctic foxes that 
WS provides both technical and direct assistance to entities and individuals who request help 

with wildlife conflicts. WS field specialists may provide technical assistance by providing 

information and guidance, and, at times, they may lend equipment so the requester could resolve 

wildlife conflicts by themselves. When the wildlife conflict is complex and cannot be safely and 

effectively resolved by the use of technical assistance, direct assistance will take place, and field 

specialists use their knowledge and expertise to disperse, remove, or relocate the offending 

species. 

Information Systems 

The Management Information System (MIS) is WS’ system of record for monitoring wildlife 

damage management and predator control activities.

AUDIT REPORT 33601-0002-41 5

17

 MIS records efforts to resolve wildlife 

threats and damage to agricultural products and livestock, private and industrial property, human 

health and safety, threatened and endangered species, natural resources, and public 

infrastructure.18 WS field specialists are required to report in MIS their daily tasks, animal 

“takes”

19, methods used, resources protected and lost, and all other pertinent data. 

MIS enables WS managers to have access to valuable data in a timely manner. It also assists 

researchers by making data available that, in the past, could not be collected. It provides field 

specialists with the independent capability to generate specialized reports for cooperators that 

include the number of takes on a property, the species taken on a property, and the value of the 

livestock killed by predators. It facilitates enhanced information gathering and distribution, both 

internally, for decision makers, and externally, for those requesting information through 

appropriate channels.20

Within MIS is an inventory system called Controlled Materials Inventory Tracking System 

(CMITS), which allows WS to fully account for its hazardous materials (e.g., M-44 devices, 

poisonous chemicals, etc.). Field specialists who use hazardous material are assigned a virtual 

CMITS warehouse; for instance, if an M-44 device is deployed in the field, field specialists enter 

a work task in the system accordingly, and the system deducts the M-44 device from the virtual 

warehouse. WS upgraded its security and storage facilities for hazardous materials after 

receiving additional funding in FYs 2002 and 2003. 

 

depredate Federally designated T/E species in the Aleutian Islands, Alaska. M-44 devices must be used in 

accordance with the U.S. Environmental Protection Agency use restrictions. 

17 MIS is a non-mission critical system. 

18 USDA APHIS, System Security Plan (SSP) for Management Information System 2000 (January 15, 2014). 

19 “Takes” is the common term used by WS to denote animals that are relocated, dispersed, released, captured, or 

killed. 

20 USDA APHIS, System Security Plan (SSP) for Management Information System 2000 (January 15, 2014).
Related Prior Audits 

In 2004, the Office of Inspector General (OIG) audited WS’ controls over its hazardous material 

inventory.21 The audit found that WS was unable to fully account for its inventories of 

hazardous pesticides and controlled drugs. Furthermore, these inventories were not always 

stored in a safe and secure manner. Since WS management had not established effective controls 

over its inventories to ensure full accountability and effective safeguarding measures were in 

operation, hazardous materials remained vulnerable to undetected theft and unauthorized use, 

which posed a threat to human and animal safety. The audit did not review CMITS because it 

was being implemented at that time. 

In 2001, the U.S. Government Accountability Office (GAO) conducted a review of WS’ program 

to determine (1) the nature and severity of threats posed by wildlife, (2) the actions the program 

had taken to reduce such threats, (3) the studies done to assess specific costs and benefits of 

program activities, and (4) opportunities for developing effective nonlethal methods of predator 

control on farms and ranches.22 The review found that some wildlife can pose significant threats 

to people and their property, leading to costly damage and loss. Most nonlethal control methods 

for these animals – such as fencing, guard animals, and animal husbandry practices – are most 

appropriately implemented by the livestock producers themselves, with technical assistance from 

WS. 

Objectives

Our objectives were to: (1) determine whether wildlife damage management activities were 

justified and effective, (2) assess the controls over cooperative agreements, (3) assess WS’ 

information system for reliability and integrity, and (4) follow up on the implementation of prior 

audit recommendations, such as the accountability over hazardous materials and equipment. 

Overview of Objectives

WS’ wildlife damage management activities can be controversial among the general public, 

animal rights organizations, and conservation groups. The agency has received considerable 

media attention due to alleged unsanctioned activities conducted by some of its field employees. 

OIG has received numerous hotline complaints and letters from the public outlining concerns 

about WS’ employees and wildlife management activities. The complaints by animal rights 

organizations have included the following concerns: (1) WS uses indiscriminate methods to kill 

animals, which result in the killing of animals that are not the target of WS’ wildlife management 

activities; (2) animals suffer because WS’ wildlife management activities do not result in 

immediate death; and (3) WS wildlife management activities are not transparent. The 

organizations that raised these complaints, as well as some members of Congress, requested that 

we perform an audit of WS’ wildlife management activities. 

6 AUDIT REPORT 33601-0002-41

 

21 Audit Report 33001-05-Hy, Animal and Plant Inspection Services Control over Hazardous Material (July 2004). 

22 GAO-02-138, Wildlife Service Program Information on Activities to Manage Wildlife Damage (November 2001).
In light of these concerns, based on the complaints we received, we undertook to determine in 

this audit whether WS’ wildlife management activities were justified and effective. We 

examined Federal and State laws, as well as State and local requirements, to determine whether 

WS was in compliance with these requirements and therefore justified in their actions. We also 

examined WS’ policies and procedures and determined that WS was generally in compliance. 

We also performed extensive tests of agency records and observed conditions at numerous 

locations in the field. While performing site visits, we observed WS field specialists conducting 

wildlife damage management activities, and we verified that the results of those activities were 

in accordance with agency policies and procedures. In addition, during our site visits, we 

determined that WS specialists were using WS’ decision model

AUDIT REPORT 33601-0002-41 7

23 to assess the damage and to 

justify the course of action to pursue. 

We interviewed owners or managers of 15 properties and 27 State game and wildlife officials. 

Based on OIG’s interviews, we concluded that they found WS activities to be necessary and 

effective.24 As one property owner put it, “WS guys are an absolute necessity for our business. 

The number of sheep they save is huge and we cannot function without them. [...] WS 

specialists are professional and good at what they do.” In support of this same point, a State game 

official we interviewed explained that WS provides help for wildlife and is run efficiently. A 

State agricultural official we interviewed characterized the collaboration of State and Federal 

programs to manage control predators and protect domestic livestock and wildlife as “seamless”. 

Operationally, WS received $80 million in cooperator-provided funding for wildlife damage 

management during FY 2013. These cooperative funds provide evidence of the public’s need for 

WS’ services. The following subsections describe the work we performed as it relates to our first 

objective to determine if WS’ actions were justified and effective. 

Observation of Field Specialists 

During our field site visits, we observed WS field specialists conducting activities, which 

included the setting and checking of traps, snares, M-44 devices, shooting, and other typical field 

activities. We also interviewed each field specialist we accompanied to determine that 

specialist’s process for assessing predation on a landowner’s property. During our visits, we 

confirmed that livestock had been killed by predators.25

There were two matters of concern raised by several animal rights organizations and members of 

Congress that we also deemed significant: (1) the indiscriminate killing of non-target animals 

that were not the target of WS’ wildlife damage management activities, and (2) the suffering of 

animals not immediately killed by WS. We specifically watched for these conditions during our 

field visits, and observed that agency officials were generally following prescribed and allowable 

practices to either avoid or mitigate these conditions. 

 

23 USDA APHIS Wildlife Services, WS Decision Model, Directive 2.201 (July 21, 2008). WS’ personnel use the 

WS Decision Model to determine the appropriate damage management method(s) to implement. WS personnel 

evaluate the appropriateness of strategies, and methods are evaluated for availability (legal and administrative) and 

suitability based on biological, economic, and social considerations. 

24 We accompanied the field specialists to 99 properties based on the activities reported in MIS. We did not preannounce our visits to the selected properties. However, we were able to meet with owners or managers of 15 of the 

99 properties we visited during our field visits. 

25 We observed the carcasses of three lambs, three goats, a chicken, and a deer.
We did, however, occasionally observe the unintentional killing of non-targeted animals by WS, 

as well as targeted animals not killed immediately. We noted in each case, however, that the WS 

field specialist had followed prescribed agency practices, which adhered to applicable laws and 

regulations. For instance, we observed 8 targeted animals (out of 27 targeted animals caught by 

snares or hit by M-44s) that were still alive during our field visits. Seven coyotes were still alive 

in snares and one coyote was still alive after being hit by an M-44 device. The WS specialists 

subsequently euthanized the coyotes. The field specialists had set the snares and M-44 devices, 

which we determined to be the appropriate actions and in accordance with laws and regulations. 

We also observed three unintentional deaths: two javelinas

8 AUDIT REPORT 33601-0002-41

26 were trapped by snares, and a 

porcupine was killed by a foothold trap. In these cases, the field specialists had set the traps, 

which we concluded were in accordance with applicable laws and regulations. Lastly, we 

observed one field specialist as he freed a javelina that had been caught in a snare. 

We also observed two separate aerial hunting operations and reviewed their records in MIS.27 

Before these operations began, WS personnel planned and coordinated activities between the 

aerial crews and the ground crews. The ground crews were responsible for tracking and spotting 

targeted animals and radioing their location to the pilots. The aerial hunting operations that we 

observed resulted in the killing of 14 coyotes and 28 feral swine. Based on our observations, the 

aerial hunting crews’ wildlife management activities adhered to applicable laws and regulations. 

While conducting fieldwork, we also observed the application of non-lethal means for predator 

control, such as fencing, guard dogs, and human herders, which were the responsibility of the 

producers. We noted that, on all the sites we visited, the producers were using some form of 

non-lethal predator control. It is WS’ position that, currently, in predator control, the number of 

non-lethal direct control methods available to WS personnel is limited and these available 

methods focus on resource management rather than control of the offending animal. Further, 

WS believes that these methods are more appropriately applied by the resource owner.

Our observations of both the field specialists’ activities and WS’ aerial hunting operations 

revealed no systemic problems with the process or manner with which WS conducted its 

predator control program. WS field specialists complied with both Federal and State 

requirements, including WS directives, in carrying out wildlife damage management activities. 

We also recognized that Federal law provides WS broad authority in conducting its program. It 

allows WS to take any action the Secretary considers necessary, with regards to injurious animal 

species, in conducting the program.28

 

 

26 Javelinas are members of the peccary family. There are three species of peccaries, but the only species found in 

the United States is the collared peccary, also known as a javelina. 

27 We selected the two aerial facilities in Texas because at the time of our site visit there were ongoing scheduled 

aerial operations that we were able to observe. We did not accompany WS personnel on a third operation in Utah 

because the pilot and specialist were both injured in a helicopter crash prior to our arrival at the facility. We 

selected Texas due to the high number of aerial activities and Utah because WS’ Aviation Program and Training 

Center was located at Cedar City, Utah. The other three States in our sample (see Scope and Methodology section 

under “Selected Sample States”; CA, MN, and WY, did not have aerial operations at the time of our visit. 

28 7 U.S.C. §426. 
WS is required to follow all applicable State and local laws that do not directly and substantively 

conflict with WS’ Federal statutory authorities.

AUDIT REPORT 33601-0002-41 9

29

 We noted that WS field specialists complied 

with State laws. For example, the State of California banned the use of M-44 devices. While we 

were conducting site visits in California, we examined the hazardous materials records of WS’ 

State and district offices, and of its field specialists. In addition, we conducted a physical 

inventory of WS’ State, districts, and field specialists’ hazardous materials inventories. We 

determined that WS in California did not use or maintain M-44 devices. Additionally, while we 

were out with a field specialist taking a mountain lion, we verified he had the proper permit from 

the State. 

We also interviewed various State game wardens to determine if WS’ field specialists were 

substantively following all applicable State laws and regulations, and the State game wardens 

confirmed that they were. 

Finally, our audit did not identify any findings related to the Controlled Materials Inventory 

System (CMITS), WS’ system for tracking controlled materials. Thus, this report contains no 

findings or recommendations associated with the first and last objectives of our audit. 

 

29 USDA APHIS Wildlife Services, Compliance with Federal, State, and Local Laws and Regulations, Directive 

2.210 (October 27, 2009). 
Finding 1: WS’ Database Contains Inaccurate Information 

WS’ Management Information System 2000 (MIS), which tracks the agency’s wildlife 

management activities, contained inaccurate data. Specifically, we found data entry errors, 

unsupported data, and data for activities carried out by external non-agency individuals. We 

attributed these conditions primarily to weak controls over data integrity, which included an 

inadequate verification of whether the information entered into MIS was accurate and complete, 

as well as the lack of policy addressing whether external party activities should be entered into 

MIS. Consequently, WS incorrectly reported its official wildlife management activities to the 

public and other parties. 

WS Directive 4.205 states that “all WS personnel are accountable for field activities and 

technical assistance work they conduct while on official duty.” The directive further states,

“employees are expected to accurately report work activities conducted [...], and to accurately 

and completely report all wildlife damage management activities, animals taken (species, 

number, intentional/unintentional, etc.), methods employed, resources protected and lost, 

recommendations made to the cooperator, methods tried by the cooperator, and all other 

pertinent data prescribed on MIS data entry forms and formats [...]”

10 AUDIT REPORT 33601-0002-41

30

WS summarizes MIS data into reports that may be disseminated to internal and external parties, 

and used in actions such as investigations and court proceedings. For example, field specialists 

can generate a property itinerary for cooperators, which details the WS activities conducted on 

the cooperator’s property for a specific timeframe.31

 Therefore, MIS data must accurately and 

reliably reflect the program’s activities.

Our audit in 5 States and 12 districts found numerous instances where the data in MIS did not 

accurately reflect WS’ activities, which included the entering of external party activities in MIS, 

and data entry errors.

External Party Activities were Recorded in MIS

WS limits direct access to data in MIS to WS personnel;32 however, WS had not 

established policy or guidelines concerning the recording of external activities in MIS. 

We identified numerous instances where external party activities were included in MIS, 

thus overstating WS’ take numbers. The following are some examples of our findings: 

· Four individuals in California, who were county employees and not supervised by 

WS, had entered wildlife management activities into MIS since 2005. The current 

WS State Director informed us that WS had a long history of collaboration with 

county officials in California, and that a former WS State Director had granted 

 

30 USDA APHIS Wildlife Services, Data and Activity Reporting, Directive 4.205 (July 2013). 

31 Activities include “takes,” which are animals killed/euthanized, removed from the area, freed/released/relocated to 

another area, and/or dispersed back to nature. 

32 Access to WS data is determined by the data usage role of the employee, which is determined by their duties and 

responsibilities. Direct access to data in the system is limited to WS personnel only, with one exception for the 

USDA-OCIO-National Information Technology Center. 
those individuals access to MIS. The agricultural commissioners of the counties 

where the four county employees worked had originally requested access to MIS 

because it was a better record keeping system than the counties’ systems. The 

current WS State Director stated that he was not completely comfortable with the 

arrangement and added that WS’ activities were inflated by the county employees’ 

activities. 

WS did not have any guidance on whether external party activities should be 

included in MIS. However, the WS handbook stated that access to MIS was 

limited to WS personnel.

AUDIT REPORT 33601-0002-41 11

33

 We analyzed the activities of the four county 

employees and determined that they entered 1,864 and 2,036 takes into MIS for 

FYs 2012 and 2013, respectively.34 Those numbers increased WS’ activities in 

California by 12 percent in FY 2012, and by 14 percent in FY 2013. 

· The WS supervisors in four of eight districts in Texas included activities in MIS 

from private aerial companies, contracted by the Sheep and Goat Predatory 

Management Board to conduct aerial hunting. WS employees were not aboard 

the flights. However, the State Director explained that WS coordinated with the 

contractors and the district offices validated the invoices before the Sheep and 

Goat Predatory Management Board made payments. The State Director 

explained that for transparency reasons, he decided to have the district offices

enter the activities into MIS. He stated it was best to fully report the direct and 

indirect consequences of the program rather than appear to try and hide the 

activities. Consequently, reporting such activities increased WS’ aerial takes in 

Texas by 2,350 (30 percent) and 1,099 (12 percent) for FYs 2012 and 2013, 

respectively.

We discussed this issue with WS national officials, and they agreed that the external 

parties should not have access to, or be allowed to enter, information into MIS. Further, 

they agreed it was not appropriate to include any external party data in MIS because it 

inflated WS’ take numbers. Additionally, they agreed that guidance was warranted to 

establish whether external party activities can be recorded in MIS. 

Data Entry Errors

Typically, WS field specialists use daily hand-written logbooks to note the cooperators 

they serviced, the time spent on a work site, the activities performed (such as the number 

and types of species takes), the number of livestock losses, and the equipment used or 

checked while in the field. WS requires its field specialists to, on a periodic basis, 

transfer information from their logbooks into MIS.35

 

 

33 USDA APHIS Wildlife Services, 2012 Information and Data Management Handbook §9 (2012).

34 Our analysis only included the specific species taken (killed and euthanized) by the four county employees. 

Those species included black bears, beavers, bobcats, coyotes, feral dogs, gray foxes, mountain lions, woodchucks, 

minks, Virginia opossums, raccoons, striped skunks, fox squirrels, western squirrels, and feral swine. 

35 Field specialists enter data into MIS at different frequencies, but the majority of them do it once every 1-2 weeks. 
According to the WS Directive, the district supervisor and then the State Director review 

the entries in MIS for accuracy. A district supervisor might determine if the time spent 

on a particular agreement appeared consistent with the type of work. However, district 

and State offices did not generally reconcile field specialists’ logbook entries to the 

corresponding MIS entries to ensure accuracy of the data. 

We reconciled 40 sampled field specialists’ logbook entries to the corresponding MIS 

entries and noted the following deficiencies:

12 AUDIT REPORT 33601-0002-41

36

· We found that 32 of 40 sampled field specialists made data entry errors. In our 

view, since nearly all of the field specialists made data entry errors, WS needs to 

implement additional controls, such as having a second party review to compare 

information in the field specialists’ logbooks to data entered into MIS. Most 

errors we found were related to the number of takes entered into the system by the 

field specialists that included instances of both under reporting and over 

reporting.37

 We found numerous instances of entries in logbooks that were not 

entered into MIS. Conversely, we found numerous entries in MIS that were not 

supported by the logbooks. Additionally, field specialists had not always entered 

producer losses in MIS, even though they were recorded in the logbooks. Table 1 

summarizes the types of discrepancies we identified. 

Table 1: Summary of Discrepancies

Discrepancies Totals

Under reported or over reported takes 425

Entry in MIS, but not in logbook 118

Entry in logbook, but not in MIS 80

Equipment related* 31

Method related** 15

Double entry 9

Reported loss not reported in MIS 8

Incorrect site location 1

The table above summarizes the types of discrepancies we identified when we 

reconciled field specialists’ logbooks against their corresponding MIS entries.

* Equipment related discrepancies relate to equipment that must be accountable 

such as M-44 devices and traps.

** The method used to take the animal was not reported correctly in MIS. 

· We also determined that 6 of the 40 field specialists we accompanied on our site 

visits had incorrectly reported their activities or takes in MIS on the dates of our 

 

36 We reviewed 29,958 entries and found discrepancies with 619 entries. Some entries contained multiple 

discrepancies; thus, the total discrepancies we identified do not equal total entries with errors.

37 Takes were either under reported or over reported depending on the individual MIS entry we reviewed. 
visits.38

 We identified several entry errors when we verified each of the MIS 

entries associated with our observations. We found instances where takes were 

both under reported and over reported and where a method associated with the 

takes was not correctly reported in MIS. For example, one field specialist 

reported in MIS that one coyote was taken during the field visit. However, we did 

not observe any coyotes taken during the visit. 

Form 12 Discrepancies 

Before WS begins work on a property, the landowner or a representative must sign a 

Work Initiation Document (Form 12).39 The Form 12 includes information such as the 

location of the work site, what species will be managed, and what methods or tools will 

be used on the property. WS field specialists transfer the information from the Form 12 

into MIS and the signed form is then sent to the WS State office where the records are 

kept. At the State Offices, WS needs to strengthen controls to prevent unsupported 

changes to Form 12 information in MIS. Under the current system, a specialist can 

change information in MIS without any supporting documentation. 

It is essential that information, such as species and methods authorized, on the Form 12s 

be accurately reflected in MIS. For instance, if coyotes were listed in the “species” 

section of the agreement, then all coyote takes will subsequently be classified as “target” 

takes in MIS.40 Conversely, if coyotes were not listed in the “species” section, then all 

coyote takes would subsequently be classified as “non-target” takes in MIS. We sampled 

756 agreements (including addenda) for accuracy, and found data integrity issues with 

MIS.

Our analysis also disclosed discrepancies between the species and methods listed on 224 

Form 12s (30 percent), and the corresponding information listed on Form 12s entered into 

MIS.41

 Our analysis further identified data integrity issues; specifically, there were 77 

instances where species or methods were listed in the agreements but not entered into 

MIS; and 231 instances of species or methods that were entered into MIS, but were 

unsupported by both the agreement and addenda. Consequently, there were 22 instances 

of “takes” that were misclassified in MIS as “target” rather than “non-target”. 

Based on the aforementioned deficiencies, we conclude that WS needs to ensure that information 

entered into MIS accurately reflects program activities. It is essential that WS work towards data 

integrity as MIS is especially important for recording and reporting activities in several areas of 

the wildlife damage management program. WS uses the data to annually report its performance 

measures to Congress and to report its activities to cooperators. WS needs to determine whether 

AUDIT REPORT 33601-0002-41 13

 

38 During site visits with the selected field specialists, we recorded all activities and takes observed during our visit.

39 A permission document signed by a cooperator allowing WS access to lands owned or controlled by the 

cooperator, and allowing the use of stipulated methods to address identified damage agent(s) in a WS conducted 

activity (WS Information Data Management Handbook Pg. 1). The signed Form 12 is sent to the State office for 

approval, and a specialist at the State office would approve the corresponding version in MIS. The original signed 

Form 12 is maintained at the applicable State office. 

40 Target is defined by what species is (identified) on the Form 12 (MIS Manual FAQ). 

41 Some of the agreements included more than one type of discrepancy. 
external party activities can be recorded in MIS. WS should also revise its directives to require a 

second party reviewer to sample and reconcile field specialists’ logbook entries to the 

corresponding MIS entries. To ensure accuracy, WS needs to implement a second party review 

and sign-off on all changes to Form 12 information in MIS.

Recommendation 1 

Remove MIS access privileges from non-WS affiliated individuals.

Agency Response

APHIS agrees with this Recommendation. Effective April 1, 2015, WS’ managers and

supervisors notified non-WS affiliated individuals that they would no longer be able to use 

the MIS to report and document non-WS activities, nor have access to the MIS. In addition, 

the WS Deputy Administrator will issue a revision of WS Directive 4.205 by August 20,

2015, to all supervisors and managers communicating the new procedure, and stating that

written approval is required from the WS Deputy Administrator or his designee for access to 

MIS data base by non-WS personnel. 

OIG Position 

We accept APHIS’ management decision on this recommendation.

Recommendation 2 

Determine whether external party activities should be recorded in MIS. 

Agency Response

APHIS agrees with this recommendation. WS has determined that external party activities, 

such as species taken, will not be entered into the MIS data base; however, such activities

as cooperator employed methods, depredation permit information, or similar activities that

provide documentation of the WS decision model will be entered. As stated in our 

response to Recommendation #1, the WS Deputy Administrator will issue a revision of WS

Directive 4.205 to all supervisors and managers stating that written approval is required

from the WS Deputy Administrator or his designee for access to the MIS data base by nonWS personnel. 

OIG Position 

We accept APHIS’ management decision on this recommendation. 

14 AUDIT REPORT 33601-0002-41
Recommendation 3 

Develop and implement procedures that require a second party reviewer to sample and reconcile 

field specialists’ logbook entries to the corresponding MIS entries. 

Agency Response

APHIS agrees with this Recommendation and will implement the following: 

· A reminder will be issued by September 30, 2015, that all field supervisors 

immediately review item 14 of WS Form 82, Field Inspection Report, that 

requires the supervisor to review the field log (i.e. diary, book, electronic device)

for consistency with the specialist's MIS itinerary report.

· During the employee field inspection visit, the field supervisor will randomly pick 4

weeks of MIS electronic data from the previous 12 months and verify against the 

employee field diary or log book records. Checking item 14 on WS Form 82 will be 

acknowledgement that the verification has been accomplished at least once each year.

· In addition, WS will issue guidance by September 30, 2015, to all personnel and

require all WS personnel who enter data into the MIS to review and electronically 

verify the accuracy of their data entries as reported in a standard MIS monthly

employee itinerary report.

· Employee Data verification will occur every 30 days.

· Inmost cases, field personnel should enter data into the MIS on a daily basis, if not a 

weekly basis; but not less often than every 2 weeks.

· WS personnel who do not enter MIS data on a daily basis, will be required to record 

these activities in a journal, field diary, paper, or electronic form and transfer the data

into MIS as required.

· Employees who are not able to abide by these requirements because of remote 

connectivity issues should work with their supervisor to resolve them and implement

measures that allow for regular and consistent data entry until the connectivity issues

have been resolved.

OIG Position 

We accept APHIS’ management decision on this recommendation. 

AUDIT REPORT 33601-0002-41 15
Recommendation 4 

Establish a policy requiring a second party review and sign-off on all Form 12 information in 

MIS.

Agency Response

APHIS agrees with this Recommendation. WS will issue new guidance by August 31, 2015,

to all WS supervisors and managers reasserting that the appropriate data technicians will

review all work initiation documents (field agreements) by comparing the electronic copy 

against the signed hard copy for any discrepancies and only switch the work initiation

document from a pending to an active status when all data fields have been verified for

accuracy. 

OIG Position 

We accept APHIS’ management decision on this recommendation. 

16 AUDIT REPORT 33601-0002-41
Finding 2: WS Did Not Timely Renew its Form 12s

WS did not timely renew 47,362 of 155,481 (30.5 percent) Work Initiation Documents 

(Form12)

AUDIT REPORT 33601-0002-41 17

42

. Some WS personnel incorrectly believed renewing Form 12s after 5 years was a 

best practice, not a policy. Also, some personnel were unaware of the requirement because it 

was in a directive concerning information and data management and security. Furthermore, for

the WS personnel who were aware of the policy, WS did not have sufficient controls in place to 

ensure the policy was followed by the field staff. As a result, if the Form 12s for ongoing 

projects are not renewed timely, WS cannot ensure that it has current information on changes in 

ownership, address, and borders at the properties it serves. This may lead to inadvertent 

trespassing by WS personnel. Further, the cooperators may no longer want the same species 

targeted or the same methods used on their property. 

WS policy states that the “life cycle of a Work Initiation Document [WID] is five years” for 

ongoing projects, WIDs “must be renewed through review, update, and signature of a new 

document by the Cooperator or his/her assigns at least every five years.”43 The WID “identifies 

the location of the work site, what species WS will manage, [and] what methods or tool will be 

used.” The policy was co-mingled in a directive concerning information and data management 

and security,44 rather than in a separate directive. WIDs are also known as Form 12s. 

In the five States we sampled, we found 219 of 975 (22 percent) Form 12s had not been renewed 

after their 5-year life cycle. Of these, 59 forms were signed 20 to 30 years ago, and 12 were 

more than 30 years old. We later expanded our scope and determined that the nationwide rate 

for Form 12s that were not renewed beyond the 5 year life cycle was 30.5 percent as of February 

2015. Even though these Form12s were out of date, WS field personnel continued to perform 

work on these properties. 

OIG found that many WS personnel believed the 5-year life cycle was not a requirement, but 

rather a best practice. Only two of the five State Directors we interviewed knew it was a WS 

policy. The 12 district supervisors and 14 of the 15 field specialists we interviewed also were 

unaware that the requirement to renew Form 12s for ongoing projects was a WS policy 

documented in a Directive.45

In addition to the lack of timely renewal, WS did not provide specific guidance to its personnel 

on how to renew a Form 12. We noted inconsistent renewal practices among the States and, at 

times, within the same districts. Many field specialists did not fill out the “species” and 

“methods” sections of the new Form 12, but simply wrote “same ...” or left it blank and had the 

cooperator sign it. Because some cooperators have several addenda added to their prior 

 

42 The number was obtained from MIS by a WS IT Staff Officer on March 2, 2015; the actual number could be 

higher than 30.5 percent, because the “Last Signed” field in MIS does not always match the date that the Form 12 

was signed. 

43 USDA APHIS Wildlife Services, 2012 Information and Data Management Handbook, §3 (2012). 

44 USDA APHIS Wildlife Services, Information and Data Management Security, Directive 4.130 §4 (August 29, 

2011).

45 Although we interviewed 40 field specialists in 12 different districts, only 15 provided us with information 

regarding Form 12s’ renewal process and only 1 field specialist was aware of the WS policy. 
agreements, it could lead to a misunderstanding between WS and the cooperator on which 

species and methods the cooperator has authorized. Further, this could lead to WS targeting 

species and using methods not actually authorized by the cooperator. 

WS needs a system that will allow employees to track expiring or out of date Form 12s. The 

current system does not always accurately track the 5-year life cycle of Form 12s. WS uses 

MIS’ “Last Signed” field to track the age of Form 12s. However, we noted that the “Last 

Signed” field in MIS did not always match the date that the Form 12 was signed. For example, 

we found a few Form 12s that were beyond the 5 year life cycle, but were listed as current in 

MIS. Additionally, we also found that on almost half of the 219 Form 12s we reviewed, the 

signed date differed from the “Last Signed” date in MIS. According to the IT Staff Officer, who 

wrote the 5-year life cycle policy and is responsible for coordinating WS’ annual report, the 

“Last Signed” field in MIS changes if something is added to or edited in MIS, but in the Form 12 

document, the date remains the same. 

The IT Staff Officer, who wrote the 5-year life cycle policy, affirmed that the 5-year requirement 

applied to all Form 12s, including those in place prior to the issuance of the policy in August 

2011. WS national officials and some employees also stated that the 5-year life cycle policy was 

an appropriate and important measure. A national official agreed that renewing Form 12s every 

5 years is an appropriate requirement due to changes in addresses, land ownership, and property 

borders in the regions. 

In order to prevent potential problems arising from the failure to follow the 5-year life cycle 

policy, OIG recommends that WS ensure its personnel are aware of and follow the 5-year 

renewal requirement, and establish a process regularly to remind employees of when their 

Form12s are near the end of the 5-year life cycle; further controls should be implemented to 

ensure the enforcement of the policy.

Recommendation 5 

Ensure WS personnel are aware of and follow the policy to renew Form 12s at least every 5 

years. 

Agency Response

APHIS agrees with this Recommendation. On August 5, 2015, the WS Deputy Administrator

reissued WS Directive 4.130, "Information and Data Management and Security," to all WS

managers and supervisors reasserting the WS policy requirement to renew Form 12 every

5 years. Specifically, the Directive states that the life cycle of the Work Initiation Document 

(WID) is five years and that the "Wildlife Services Information and Data Management 

Handbook" provides additional information about the initiation, completion and renewal of 

the WID. 

OIG Position 

We accept APHIS’ management decision on this recommendation. 

18 AUDIT REPORT 33601-0002-41
Recommendation 6 

Establish a process that will give employees a formal reminder of expiring Form 12s, and include 

more detailed procedures for the renewal of Form 12s.

Agency Response

APHIS agrees with this Recommendation. By August 31, 2015, WS will issue new guidance

directing all supervisors and managers to issue a report, "Agreements, Years old Listing" or 

equivalent report, every 6 months to all field personnel that lists all Work Initiation

Documents set to expire at the end of the current 5 year cycle. This new guidance will include 

detailed instructions addressing requirements for amending species and methods information;

signature requirements for renewing including signatures by absentee landowners; no activity

within a 5 year period; and distribution of hard or electronic copies to supervisors and data

technicians. This new guidance will also reinforce the current requirement for a completed

Work Initiation Document to be in place prior to any work being initiated. The MIS Field

Handbook will be modified, by September 30, 2015, to reflect this new guidance. 

OIG Position 

We accept APHIS’ management decision on this recommendation. 

Recommendation 7 

Ensure MIS can accurately track the 5-year life cycle of the Form 12 by including a “Form 12 

signed date” field in MIS that cannot be changed. 

Agency Response

APHIS agrees with this Recommendation. By August 31, 2015, WS will issue new guidance

that reasserts the need to enter the current agreement date into the MIS data field entitled,

"Form 12 signed date". The current data field entitled, "Last Signed Date"will be converted 

to, "Form 12 signed date" and will be hard coded and only select personnel with the 

appropriate administrative rights can manipulate this data field, if needed. 

OIG Position 

We accept APHIS’ management decision on this recommendation. 

AUDIT REPORT 33601-0002-41 19
Scope and Methodology

20 AUDIT REPORT 33601-0002-41

We conducted a nationwide audit of APHIS’ WS animal damage management activities covering 

FY 2012 through the second quarter of FY 2014.46 To accomplish our audit objectives, we 

performed fieldwork at APHIS’ headquarters in Riverdale, Maryland, and the two APHIS 

regional offices: Eastern Region in Raleigh, North Carolina, and Western Region in Fort Collins, 

Colorado. We performed fieldwork at the APHIS National Wildlife Research Center (NWRC) 

in Fort Collins, Colorado; a NWRC field station in Millville, Utah; the Aviation Safety, Training 

and Operations Center in Cedar City, Utah; 5 APHIS WS State offices (California, Minnesota, 

Texas, Utah, Wyoming); and 12 APHIS WS field offices (see exhibit A for a complete list of 

audit sites). In completing this audit, we looked at documentation covering the period from FY 

2012 to FY 2014. We also examined some trust account documents related to FY 2015. We 

also reviewed 10 complaints sent to OIG and APHIS related to WS’ animal damage management 

program to determine whether the complaints were related to our audit objectives.47 We 

conducted fieldwork from January 2014 to March 2015. 

In accomplishing our objectives for this audit, we performed the following steps and procedures: 

· Reviewed Criteria: We reviewed Title 7 U.S.C. § 426; USDA Departmental Regulation 

1074-001, Scientific Integrity (May 10, 2013); 9 C.F.R § 2.31 and § 2.37; USDA APHIS, 

2010 Cooperative Agreements Manual; WS’ policy directives; and the USDA APHIS, 

2012 Wildlife Services Information and Data Management Handbook. 

· Selected Sample States: We non-statistically selected four APHIS Western Region 

States (California, Texas, Utah, and Wyoming) and one Eastern Region State 

(Minnesota) to conduct fieldwork. We selected more States in the Western Region 

because of its higher number of predator control activities. The majority of the highest 

funded States are also in that region. We selected our sample based on the following 

criteria: 

a. States with large allocated budgets for FYs 2012 and 2013. 

b. States with the most kills of our selected predators (bears, bobcats, coyotes, feral 

dogs, foxes, mountain lions, and wolves) during FYs 2012 and 2013. 

c. States with the most diversity of kills of our selected predators. 

d. The State with the least number of non-target kills.

· Selected APHIS District Offices and Field Specialists: We non-statistically selected 

50 percent of the APHIS WS district offices in each of our sampled States. We based our 

selection on the district offices with the highest number of kills of our selected predators. 

If there were fewer than three districts, we reviewed 100 percent of the districts. In 

 

46 To determine the nation-wide rate for Form 12s that were not renewed beyond the 5 year life cycle (see finding 2), 

we expanded our documentation review to February 2015. 

47 OIG reviewed 10 complaints for audit consideration. We received 11 complaints, but 1 complaint was outside of 

USDA’s authority. 
Texas, we selected at least four field specialists per sampled district, and in California 

and Utah

AUDIT REPORT 33601-0002-41 21

48, we selected three specialists in each district, based on the (1) highest predator 

take, (2) most unintentional kills, or (3) most hours on the job with the fewest takes. We 

adjusted our sampling methodology in Minnesota and Wyoming by selecting two field 

specialists per district with the (1) highest predator take or (2) most unintentional kills 

during the period of our audit. We adjusted our methodology because each State was 

structured differently including the number of specialist and the types of activities varied 

in each State. We selected each of our States based on different criteria, see the above 

bullet on our State selection. 

· Interviewed APHIS and State Agency Personnel: We interviewed 96 personnel at 

APHIS’ National and regional offices, WS’ State and district offices, the National 

Wildlife Research Center in Colorado, a NWRC field station in Utah, and WS’ Aviation 

Safety, Training and Operations Center in Utah. We also interviewed 27 State wildlife 

personnel, such as directors, deputy directors, and game wardens in our sampled States. 

These State personnel were from the California Department of Fish and Game, the 

Minnesota Department of Natural Resources, the Wyoming Department of Agriculture,

the Wyoming Game and Fish Department, the Utah Department of Agriculture and Food, 

the Utah Division of Wildlife Resources, Texas Parks and Wildlife Department, and the 

Texas Agrilife Extension. 

· Reviewed Activities at the NWRC: At NWRC, we obtained information about NWRC 

policies, procedures, and activities conducted. We determined how research projects are 

ranked and prioritized for funding. We also reviewed a non-statistical sample of research 

projects to identify sources of funding, purposes of the projects, and expected goals and 

actual outcomes.

· Accompanied WS and State Personnel: We accompanied 40 WS field specialists in 

the field while they conducted their wildlife damage management activities to observe the 

different methods used to reduce damage caused by predators. We also flew with aerial 

program pilots to observe their operations for predator control. 

· Interviewed Property Owners: We interviewed owners or managers of 15 properties 

who utilize WS to control predation problems on private property to obtain comments 

regarding the need for the program, the quality of service received, and if improvements 

could be made. We did not pre-announce our visits to the property. Therefore, we were 

only able to interview owners or managers of 15 of the 99 properties, who were 

physically present at the time of our field visit. We also interviewed 3 board members of 

Wildlife Associations in Texas and Wyoming. 

· Reviewed Cooperative Service Agreements: We non-statistically selected and 

reviewed CSAs. We picked our sampled CSAs based on the CSAs with the highest 

 

48 Although we initially selected three field specialists in Utah, we conducted site visits with two specialists. The 

third field specialist was injured in a helicopter crash prior to our arrival. 
funding. We selected 50 percent of the CSAs between WS and State, county, municipal, 

and private cooperators at the five sampled WS State offices. If there were less than 20 

CSAs at a WS State office, we reviewed 100 percent of the CSAs. We reviewed the 

CSAs to determine if relevant regulations, policies, and procedures were followed and to 

determine if funding between WS and cooperators was equitable. 

We also non-statistically selected and reviewed a sample of agreements under the 

thresholds, which are not required to be approved by WS’ regional office.

22 AUDIT REPORT 33601-0002-41

49

 The 

agreements (CSA and Cooperative Service Field Agreements) are between WS and local 

governments and private entities. We picked our sampled Cooperative Service Field 

Agreements based on those with the highest funding. We selected 50 percent of the 

Cooperative Service Field Agreements between WS and county cooperators, and private 

cooperators at the five sampled WS State offices. If there were less than 20 Cooperative 

Service Field Agreements at a WS State office, we reviewed 100 percent of the 

Cooperative Service Field Agreements. We reviewed the Cooperative Service Field 

Agreements to determine if relevant regulations, policies, and procedures were followed. 

· Assessed MIS: We used Audit Command Language to match the MIS users list to the 

selected States’ employee roster to determine whether external parties had access to MIS. 

We also compared 29,958 MIS entries with our sampled field specialists’ 

logbooks/trapping records to determine the accuracy of MIS data and the adequacy of 

existing controls over MIS. We obtained each of our specialist’s logbooks and sampled a 

complete month for each quarter that spanned from January 2012 through March 2014. 

· Compared CMITS to the State, District, and Field Specialists Inventories: We 

compared the CMITS printouts for the State, District, and field specialists and reconciled 

the physical inventories of hazardous materials, including M-44 devices and Livestock 

Protection Collars. 

· Analyzed Form 12s: We took a 25 percent non-statistical sample of Form 12s from our 

sampled districts in our sampled States. We selected our sample based on the Form 12s 

with the highest associated number of takes of our selected predators. We compared our 

sampled Form 12s with data reported in MIS to determine if predators taken and methods 

used were accurately entered and reported, if WS renewed these documents every 5 

years, and if there were any agreements with extensive gaps in activity.

· Reviewed National Environmental Policy Act (NEPA) Documentation: We reviewed 

Environmental Assessments dealing with predator control for all five of our sampled 

States to determine whether WS was following the applicable law. 

· Reviewed WS Financial Data: We reviewed WS and APHIS financial records, 

including both the WS trust fund account and revolving reimbursable accounts, which are 

 

49 State Directors in Western Region can sign CSAs under $7,500, and State Directors in Eastern Region can sign 

CSAs up to $20,000, so we used $7,500 as a threshold for Western Region and $20,000 as a threshold for Eastern 

Region when selecting CSAs. 
funded by CSAs. We reviewed these documents and determined that WS is no longer 

entering cooperator funds into the trust fund account and WS is spending down the 

remaining funds in the trust fund account WS pays its field specialist salaries and 

expenses; and is later reimbursed by the cooperators for their services. We determined 

that the reimbursed funds from cooperators were being accounted for in the APHIS’ 

Salaries and Benefits appropriation account.

During the course of our audit, we did limited verification of information in WS’ electronic 

information systems, and make no representation regarding the adequacy of any agency 

computer system or the information generated from it. 

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

issued by the Comptroller General of the United States. 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 the evidence obtained 

provide a reasonable basis for our findings and conclusions based on our audit objectives. 

AUDIT REPORT 33601-0002-41 23
Abbreviations

24 AUDIT REPORT 33601-0002-41

APHIS........................Animal and Plant Health Inspection Service 

CFR............................Code of Federal Regulations 

CMITS .......................Controlled Materials Inventory Tracking System 

CSA............................Cooperative Service Agreement 

DR..............................Departmental Regulation 

FMMI.........................Financial Management Modernization Initiative 

FY ..............................Fiscal Year 

GAO...........................Government Accountability Office 

IDMH.........................Information Data Management Handbook 

MIS ............................Management Information System 

MOU ..........................Memorandum of Understanding 

NWRC........................National Wildlife Research Center 

NEPA.........................National Environmental Policy Act 

OIG ............................Office of Inspector General 

PL...............................Public Law 

RO..............................Regional Office 

T/E..............................Threatened and Endangered 

USDA.........................United States Department of Agriculture 

WID............................Work Initiation Document 

WS.......................Wildlife Services
Exhibit A:  Audit Sites Visited

AUDIT REPORT 33601-0002-41 25

Organization Location

APHIS National Office Riverdale, MD 

APHIS National Wildlife Research Center 

 Logan Field Station

Fort Collins, CO 

Millville, UT 

APHIS Wildlife Services Western Regional Office

 Texas State Office

 Corpus Christi District Office

 San Angelo District Office

 Canyon District Office

 College Station District Office

 

 California State Office

 North District Office

 Sacramento District Office

 San Luis District Office

 Utah State Office

 Northern District Office

 Southern District Office

 Aviation Training & Operations Center

 Wyoming State Office

 East District Office

 Southwest District Office

Fort Collins, CO 

San Antonio, TX 

Corpus Christi, TX 

San Angelo, TX 

Canyon, TX 

College Station, TX 

Sacramento, CA 

McArthur, CA 

Sacramento, CA 

Taft, CA 

West Valley City, UT 

West Valley City, UT 

Richfield, UT 

Cedar City, UT 

Casper, WY 

Torrington, WY 

Rock Springs, WY 

APHIS Wildlife Services Eastern Regional Office

Minnesota State Office

 Grand Rapids District Office

Raleigh, NC 

St. Paul, MN 

Grand Rapids, MN

Agency's Response

26 AUDIT REPORT 33601-0002-41

USDA’S

ANIMAL AND PLANT HEALTH INSPECTION 

SERVICE

RESPONSE TO AUDIT REPORT
MEMORANDUM

TO: Gil Harden August 19, 2015

Assistant Inspector General

 for Audit

FROM: Kevin Shea 

Administrator

SUBJECT: APHIS Response and Request for Management Decision on

OIG Report “APHIS Wildlife Services – Wildlife Damage 

Management” (33601-0002-41)

Thank you for the opportunity for the Animal and Plant Health Inspection Service 

(APHIS) to comment on your August 12, 2015, Official Draft Report. We have 

restated each Recommendation below, along with our planned corrective actions 

and the timeframes for implementation of these actions.

Recommendation 1: Remove Management Information System (MIS) access 

privileges from non-Wildlife Services (WS) affiliated individuals.

APHIS Response: APHIS agrees with this Recommendation. Effective April 1, 

2015, Wildlife Services’ (WS) managers and supervisors notified non-WS

affiliated individuals that they would no longer be able to use the MIS to report 

and document non-WS activities, nor have access to the MIS. In addition, the 

WS Deputy Administrator will issue a revision of WS Directive 4.205 by August 

20, 2015, to all supervisors and managers communicating the new procedure, and 

stating that written approval is required from the WS Deputy Administrator or 

his designee for access to MIS data base by non-WS personnel. 

Recommendation 2: Determine whether external party activities should be 

recorded in MIS.

APHIS Response: APHIS agrees with this recommendation. WS has 

determined that external party activities, such as species taken, will not be 

entered into the MIS data base; however, such activities as cooperator employed 

methods, depredation permit information, or similar activities that provide 

documentation of the WS decision model will be entered. As stated in our 

response to Recommendation #1, the WS Deputy Administrator will issue a 

revision of WS Directive 4.205 to all supervisors and managers stating that 

written approval is required from the WS Deputy Administrator or his designee 

for access to the MIS data base by non-WS personnel. 

 An Equal Opportunity Provider and Employer

Animal and Plant 

Health Inspection 

Service

Office of the 

Administrator

1400 Independence 

Avenue SW

Washington,

DC 20250

Voice 202.799.7000

Fax 202.720.3054
Recommendation 3: Develop and implement procedures that require a 

second party reviewer to sample and reconcile field specialists’ logbook 

entries to the corresponding MIS entries.

APHIS Response: APHIS agrees with this Recommendation and will implement 

the following:

· A reminder will be issued by September 30, 2015, that all field supervisors 

immediately review item 14 of WS Form 82, Field Inspection Report, that 

requires the supervisor to review the field log (i.e. diary, book, electronic 

device) for consistency with the specialist’s MIS itinerary report. 

· During the employee field inspection visit, the field supervisor will randomly 

pick 4 weeks of MIS electronic data from the previous 12 months and verify 

against the employee field diary or log book records. Checking item 14 on WS 

Form 82 will be acknowledgement that the verification has been accomplished 

at least once each year. 

· In addition, WS will issue guidance by September 30, 2015, to all personnel 

and require all WS personnel who enter data into the MIS to review and 

electronically verify the accuracy of their data entries as reported in a standard 

MIS monthly employee itinerary report. 

· Employee Data verification will occur every 30 days. 

· In most cases, field personnel should enter data into the MIS on a daily basis, 

if not a weekly basis; but not less often than every 2 weeks. 

· WS personnel who do not enter MIS data on a daily basis, will be required to 

record these activities in a journal, field diary, paper, or electronic form and 

transfer the data into MIS as required. 

· Employees who are not able to abide by these requirements because of remote 

connectivity issues should work with their supervisor to resolve them and 

implement measures that allow for regular and consistent data entry until the 

connectivity issues have been resolved. 

Recommendation 4: Establish a policy requiring a second party review and 

sign-off on all Form 12 information in MIS. 

APHIS Response: APHIS agrees with this Recommendation. WS will issue new 

guidance by August 31, 2015, to all WS supervisors and managers reasserting that 

the appropriate data technicians will review all work initiation documents (field 

agreements) by comparing the electronic copy against the signed hard copy for 

 An Equal Opportunity Provider and Employer
any discrepancies and only switch the work initiation document from a pending to 

an active status when all data fields have been verified for accuracy.

Recommendation 5: Ensure WS personnel are aware of and follow the policy 

to renew Form 12s at least every 5 years.

APHIS Response: APHIS agrees with this Recommendation. On August 5, 

2015, the WS Deputy Administrator reissued WS Directive 4.130, “Information 

and Data Management and Security,” to all WS managers and supervisors 

reasserting the WS policy requirement to renew Form 12 every 5 

years. Specifically, the Directive states that the life cycle of the Work Initiation 

Document (WID) is five years and that the “Wildlife Services Information and 

Data Management Handbook” provides additional information about the initiation, 

completion and renewal of the WID.

Recommendation 6: Establish a process that will give employees a formal 

reminder of expiring Form 12s, and include more detailed procedures for the 

renewal of Form 12s.

APHIS Response: APHIS agrees with this Recommendation. By August 31, 

2015, WS will issue new guidance directing all supervisors and managers to issue 

a report, “Agreements, Years old Listing” or equivalent report, every 6 months to 

all field personnel that lists all Work Initiation Documents set to expire at the end 

of the current 5 year cycle. This new guidance will include detailed instructions 

addressing requirements for amending species and methods information; signature 

requirements for renewing including signatures by absentee landowners; no 

activity within a 5 year period; and distribution of hard or electronic copies to 

supervisors and data technicians. This new guidance will also reinforce the 

current requirement for a completed Work Initiation Document to be in place 

prior to any work being initiated. The MIS Field Handbook will be modified, 

by September 30, 2015, to reflect this new guidance. 

Recommendation 7: Ensure MIS can accurately track the 5-year life cycle of 

the Form 12 by including a “Form 12 signed date” field in MIS that cannot 

be changed.

APHIS Response: APHIS agrees with this Recommendation. By August 31, 

2015, WS will issue new guidance that reasserts the need to enter the current 

agreement date into the MIS data field entitled, “Form 12 signed date”. The 

current data field entitled, “Last Signed Date” will be converted to, “Form 12 

signed date” and will be hard coded and only select personnel with the 

appropriate administrative rights can manipulate this data field, if needed.

 An Equal Opportunity Provider and Employer
T

To learn more about OIG, visit our website at 

www.usda.gov/oig/index.htm

How To Report Suspected Wrongdoing in USDA Programs

Fraud, Waste, and Abuse

File complaint online: http://www.usda.gov/oig/hotline.htm

Click on Submit a Complaint

Telephone: 800-424-9121

Fax: 202-690-2474

Bribes or Gratuities 

202-720-7257 (24 hours a day)

he U.S. Department of Agriculture (USDA) prohibits discrimination in all of its programs and activities on the basis of race, color, national 

origin, age, disability, and where applicable, sex (including gender identity and expression), marital status, familial status, parental status, 

religion, sexual orientation, political beliefs, genetic information, reprisal, or because all or part of an individual’s income is derived from 

any public assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means 

for communication of program information (Braille, large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600 

(voice and TDD).

To file a complaint of discrimination, write to USDA, Assistant Secretary for Civil Rights, Office of the Assistant Secretary for Civil Rights, 

1400 Independence Avenue, SW., Stop 9410, Washington, D.C. 20250-9410, or call toll-free at (866) 632-9992 (English) or (800) 877-

8339 (TDD) or (866) 377-8642 (English Federal-relay) or (800) 845-6136 (Spanish Federal-relay). USDA is an equal opportunity provider 

and employer.