Wildlife and Sport Fish Restoration: Competitive Grant Programs Managed Consistently with Relevant Regulations, but Monitoring Could Be Improved
Released: 2018-02-22T00:00:00

Letter

Background

FWS provides grants to a variety of recipients, including state agencies, tribal governments, and nongovernmental organizations. In fiscal year 2016, FWS awarded $1.5 billion in grants, which was about 50 percent of the agency’s total $2.9 billion budget authority. Within FWS, WSFR is responsible for awarding most of the grant funding available from FWS, and in fiscal year 2016, WSFR awarded $1.2 billion in grants.

As we have previously reported, most federal grant-making agencies generally follow a grants management process that includes awarding grant funds and monitoring grant projects. The award process generally involves announcing the grant opportunities, reviewing applications, and making award decisions. During the monitoring process, the agency oversees the implementation of the grant project and periodically reviews financial and performance reports from grant recipients. In our past reports, we have found that it is important for federal agencies to employ a fair and transparent process to make award selections for competitive grant programs and to monitor federal grant funds to ensure that they are used properly and effectively to achieve program goals.

In general, WSFR awards two types of grants: formula and competitive grants.

Formula grants: WSFR awards these grants to recipients in amounts based on required formulas. The two largest formula grant programs WSFR manages are the Wildlife Restoration Program and Sport Fish Restoration Program, which provided $699 million and $356 million, respectively, in grants to states in fiscal year 2016. According to WSFR documents and officials, these grants are often used by states to help their fish and wildlife agencies restore, enhance, and manage wildlife and sport fish resources and provide public access to those resources. Each state’s use of certain funds and each state’s wildlife and sport fish activities are to be audited every 5 years, and these audits have generally been conducted by Interior’s Office of Inspector General (OIG). According to Interior OIG officials, these audits have been conducted since 2002, and each state has been audited three times over the past 15 years.

Competitive grants: WSFR awards these grants to eligible applicants for specific projects based on a competitive process in which grant applications are scored against certain criteria. Competitive grants comprise a much smaller portion of the grant funding that WSFR awards; in fiscal year 2016, WSFR awarded about $54 million in competitive grants. Competitive grants, unlike the formula grants, are not required under their program-specific statutes to be regularly audited. According to the Interior OIG and WSFR officials, the OIG has conducted few audits of these programs.

Funding for most of WSFR’s grant programs comes from two sources: the Wildlife Restoration Account and the Sport Fish Restoration and Boating Trust Fund. These accounts are generally funded by industries paying excise taxes and import duties on certain equipment and gear manufactured for purchase by hunters, anglers, boaters, archers, and recreational shooters, including pistols, bows and arrows, and fishing rods and reels, among other items. Federal taxes on fuel for motorboats and small engines are also a source of funding.

In administering grant programs, WSFR adheres to federal laws and regulations, as well as agency policies and guidance.

Federal laws: The 1937 Pittman-Robertson Wildlife Restoration Act and the 1950 Dingell-Johnson Sport Fish Restoration Act established the Wildlife Restoration Program and the Sport Fish Restoration Program, respectively. The Pittman-Robertson and Dingell-Johnson Acts have been amended to, among other things, establish additional grant programs, many of which are competitive programs. For example, the Clean Vessel Act of 1992 amended the Dingell-Johnson Act and created the Clean Vessel Act Grant Program. In addition, in 1998, the Sportfishing and Boating Safety Act amended the Dingell- Johnson Act and established the Boating Infrastructure Grant Program.

Federal government-wide grant regulations: The Uniform Guidance, issued by OMB and adopted by federal grant-making agencies, includes requirements for several aspects of the federal grants management process, including the award and monitoring processes. For example, sections 327 and 328 lay out general requirements for financial and performance reporting by grant recipients.

Agency regulations: Some of the WSFR grant programs have specific regulations that, among other things, define eligible activities, application procedures, and the conditions for using grant funding. For example, the Boating Infrastructure Grant Program, the Clean Vessel Act Grant Program, and the National Coastal Wetlands Conservation Grant Program have program-specific regulations that govern aspects of the grant process, such as the eligible uses of grant funding.

Agency policies and guidance: WSFR also has agency guidance found in the FWS Service Manual, along with other guidance on grants. The manual describes the structure and functions of FWS’s organization and contains policies and procedures that govern administrative activities and program operations. For example, the FWS Service Manual contains a chapter focused on the Multistate Conservation Grant Program that reiterates or clarifies requirements, including program-specific statutory requirements as well as those found in the Uniform Guidance. In addition to the FWS Service Manual, the FWS, and WSFR within it, is subject to grant management guidance issued by the Department of the Interior. For example, in December 2014, Interior’s Office of Acquisition and Property Management issued a memorandum that required (1) maximum competition in grant awards through a fair and impartial competitive process, and (2) a comprehensive, impartial, and objective grant application review process based on criteria contained in the grant award announcement.

WSFR Program Awards and Monitors Five Competitive Grant Programs

WSFR awards and monitors five competitive grant programs, according to agency documents and officials we interviewed. These five grant programs are (1) the Boating Infrastructure Tier 2 Grant Program, (2) the Clean Vessel Act Grant Program, (3) the Competitive State Wildlife Grant Program, (4) the Multistate Conservation Grant Program, and (5) the National Coastal Wetlands Conservation Grant Program. While these grant programs support different types of projects, they generally are funded from the Sport Fish Restoration and Boating Trust Fund, and most require non-federal matching funds from the grant recipient based on statute. The exceptions to this are the Multistate Conservation Grant Program, which also receives funds from the Wildlife Restoration Account and does not require matching funds, and the Competitive State Wildlife Grant Program, which receives funding from annual appropriations. Table 1 provides summary information on these five competitive grant programs.

Across the five competitive grant programs, the number of grants and the funding awarded varied by program. In fiscal years 2012 through 2016, the largest amount of federal grant funding was awarded through the National Coastal Wetlands Conservation Grant Program—about $94 million total—while the least amount of grant funding was awarded through the Competitive State Wildlife Grant Program—about $24 million total, as shown in table 2.

Based on our review of competitive grant award documentation for fiscal years 2012 through 2016, the percentage of projects selected from the applications received ranged from 63 percent for the Competitive State Wildlife Grant Program to 100 percent for the Clean Vessel Act Grant Program. While all Clean Vessel Act grant applicants received funding, they did not all receive the total amount of funding requested; rather, the amount of funding was based on the total amount of funding available and the score the application received. The same applies for other grant programs, as the agency sometimes provides less funding to a recipient than was requested depending on various factors, such as the total amount of funding available. For more information on the number of applications received and awards for each grant program, see appendixes II through VI.

In fiscal year 2016, the five WSFR competitive grant programs funded a variety of projects according to our review of the list of awarded projects.

Boating Infrastructure Tier 2 Grant Program. Grants were awarded to states for projects focused on improving facilities for recreational boaters. These projects included installing docks, installing boat slips, and constructing restroom and shower facilities for boaters. For more information on this grant program, see appendix II.

Clean Vessel Act Grant Program. Grants were awarded to states for projects focused on constructing and maintaining facilities to accept sewage from recreational boats, including sewage pumpout stations and floating restrooms. In addition, some of the grants were to be used for public education materials on the importance of properly disposing sewage from boats. For more information on this grant program, see appendix III.

Competitive State Wildlife Grant Program. Grants were awarded to states and a nongovernmental organization for projects focused on state-identified species of greatest conservation need, which may include endangered or threatened species. These projects included conducting research on these species along with creating and enhancing habitat for these species. For more information on this grant program, see appendix IV.

Multistate Conservation Grant Program. Grants were awarded to nongovernmental organizations and federal agencies for a variety of projects that were national or regional in scope, such as providing training to state fish and wildlife officials. Over half of the grants awarded (11 of 18) were awarded to the Association of Fish and Wildlife Agencies (AFWA), but most of the funding went towards the administration of the National Survey of Fishing, Hunting and Wildlife- Associated Recreation ($6.4 million of the $7.7 million). According to AFWA and WSFR officials, the reason many grants are awarded to AFWA is because this organization is in a unique position to carry out projects that benefit multiple states as required by law. For more information on this grant program, see appendix V.

National Coastal Wetlands Conservation Grant Program. Grants were awarded to states for projects focused on acquiring and restoring wetlands. Many of these projects focused on acquiring wetlands that benefit wildlife. For more information on this grant program, see appendix VI.

Under these five grant programs, state agencies often partner with subgrantees to carry out grant projects. According to WSFR officials, subgrants are common in the Boating Infrastructure Tier 2, Clean Vessel Act, and Competitive State Wildlife grant programs. For example, states are the recipients of Boating Infrastructure Tier 2 grants, but they can subgrant the money to marina operators to oversee the construction of dock facilities.

Grant Award Process Involves Announcing Grant Opportunity, Reviewing Applications, and Making Award Decisions and Is Generally Consistent with Regulations

The award process WSFR uses for the five competitive grant programs generally involves announcing the grant opportunity and reviewing applications to make award decisions, and in some cases federal agencies or third parties are involved in these activities. The award process used for the five competitive WSFR grant programs is generally consistent with federal grant regulations in the Uniform Guidance.

Award Process Involves Announcing Opportunities, Reviewing Applications, and Making Award Decisions, and Third Parties Play a Role in this Process for Some Grant Programs

The award process WSFR uses for the five competitive grant programs we reviewed involves announcing the grant opportunity and reviewing applications to make award decisions, and third parties are involved in these activities for some grant programs. Based on our review of agency guidance and interviews with WSFR officials, announcing a grant opportunity begins with developing a Notice of Funding Opportunity (NOFO). The NOFO contains information for applicants to consider when deciding whether to apply, including the amount of funding available, the types of applicants that are eligible, the process to apply, and the criteria that will be used to score applications. NOFOs are available publicly at www.grants.gov. Interested parties then submit grant applications, which WSFR reviews for eligibility by examining the project’s goals, budget, and environmental impact, among other things. A review panel comprised of WSFR staff, and in some cases other FWS staff or a third party organization, reviews and scores the applications based on criteria in the NOFO and develops a list of recommended projects and funding amounts for these projects. This list is forwarded to the Director of FWS for review and approval and if approved, FWS then awards the grant.

For all of the grant programs except for the Competitive State Wildlife Grant Program, other federal agencies or third party organizations are involved in some aspects of the award process (as shown in table 3). In general, these entities are more involved in reviewing grant applications than in developing the NOFOs for the grant programs.

AFWA, a third party, has the largest involvement in the award process for the Multistate Conservation Grant Program, and implements most aspects of the award process. Specifically, the Wildlife and Sport Fish Restoration Programs Improvement Act of 2000, which established this grant program, requires that FWS only fund grant projects that are on a priority list established by AFWA. To develop this list, AFWA has developed a process to review and score applications, and the highest-scoring applications are put on a priority list. This list is presented to all AFWA members at their annual meeting and if approved by the membership, AFWA forwards the priority project list to the Director of the U.S. Fish and Wildlife Service for review and approval. The Multistate Conservation program leader at WSFR said he also reviews grant applications to determine whether the project’s budget is reasonable and whether the project is eligible for funding.

Other federal agencies and third party organizations are also involved in the award process for other WSFR competitive grants programs as follows:

Boating Infrastructure Tier 2 Grant Program: The Sport Fishing and Boating Partnership Council reviews and scores each grant application and provides these scores to WSFR. The scores from the Council are averaged with WSFR’s scores to develop a final ranked list of grant projects. Officials from the Council said that they provide expertise to the review process since Council members are often engineers or members of boating organizations.

Clean Vessel Act Grant Program: Program regulations state that WSFR will convene a review panel to include representatives from WSFR, the U.S. Environmental Protection Agency (EPA), the U.S. Coast Guard, and the National Oceanic and Atmospheric Administration (NOAA). WSFR provides the grant applications and WSFR’s proposed list of recommended projects to these agencies for review. According to WSFR officials, they have received limited input from these agencies, due in part to staff turnover at these agencies in recent years. For example, in fiscal year 2016, EPA indicated in an email to WSFR that it agreed with the proposed funding decisions for the program, and NOAA sent a letter to WSFR indicating that it had not reviewed all of the applications but it supported the program and did not object to the agency’s scoring of the applications.

National Coastal Wetlands Conservation Grant Program: Staff from FWS’ Coastal Program partner with WSFR in developing the NOFO, reviewing applications, and scoring applications. For example, the review panel for fiscal year 2016 included seven staff from the Coastal Program and four staff from WSFR.

Award Process Is Generally Consistent with Federal Grant Regulations

The five competitive WSFR grant programs we reviewed follow an award process that is generally consistent with federal grant regulations found in the Uniform Guidance. Specifically, the Uniform Guidance requires that grant funding opportunities be publicly announced and that the NOFO contains certain information, including the criteria and process used to evaluate applications. In reviewing the five NOFOs used for the fiscal year 2016 grant cycle for the five competitive grant programs, we found that all five NOFOs were made publicly available on the website www.grants.gov, and the NOFOs contained the information required by the Uniform Guidance. These NOFOs contained criteria for scoring applications that matched the criteria in program-specific regulations for the grant programs that have them. For example, the regulations for the National Coastal Wetlands Conservation Grant Program contain 13 different scoring criteria, which were listed in the NOFO for that program.

The Uniform Guidance also contains provisions regarding a review process for grant applications. Specifically, the Uniform Guidance requires that, unless prohibited by federal statute, the agencies must design and execute a merit review process for competitive grant applications, and that this process must be described in the NOFO. In accordance with the Uniform Guidance, Interior issued guidance on implementing a merit review process in December 2014. This guidance requires that the “competitive process be fair and impartial” and that all applicants be evaluated based on the criteria in the funding announcement. In reviewing the five competitive grant programs, we found that there was a merit review process and that this process was described in the five NOFOs for fiscal year 2016 that we reviewed. As part of the merit review process, four of the competitive grant programs convened review panels attended by those that scored applications for the fiscal year 2016 grant cycle, and these panels developed a recommended list of projects, according to our review of award documents. The exception was the Clean Vessel Act Grant Program, where an in-person review panel meeting was not held but rather projects were scored separately within each region, and regional officials submitted their scores to WSFR headquarters. These two sets of scores were combined and the WSFR program leader developed a recommended list of projects, according to WSFR officials.

The Uniform Guidance also requires that federal agencies must establish conflict of interest policies for federal awards. As a result, in December 2014, Interior established a policy requiring agency officials who evaluate grant applications as part of a review panel to sign a conflict of interest certificate. In our review of the award documents for the fiscal year 2016 grant cycle, we generally found signed copies of these certificates for members of the review panels, except for the Multistate Conservation Grant Program. This program did not have certificates for the fiscal year 2016 grant cycle because AFWA, which oversees the scoring of applications, did not require these forms until the fiscal year 2017 grant cycle. We reviewed these forms for the fiscal year 2017 grant cycle and found that each member of the AFWA review panel had submitted a form. AFWA officials said that the organization had previously required a general conflict of interest form to be signed by its members, and they started requiring a specific form for review panel members in fiscal year 2017 to align with Interior’s policy.

WSFR Monitors Grants in a Manner Consistent with Federal Grant Regulations, but Performance Reports Were Sometimes Missing Required Information WSFR Monitors Grants through Review of Financial and Performance Reports

WSFR monitors its competitive grants primarily by reviewing annual financial and performance reports submitted by grant recipients, which is consistent with federal regulations. We found in our review of these reports for a sample of grant projects awarded funds in fiscal year 2015 that grant recipients generally submitted them on time, but that some performance reports were missing required information.

According to WSFR officials, their primary method for monitoring projects funded by competitive grants is to review financial and performance reports submitted by grant recipients. Grant recipients submit these reports to WSFR staff in FWS regional offices. According to regional WSFR officials, regional staff who specialize in financial matters review the financial reports to ensure they are filled out correctly. Staff do this by comparing financial information on the amount of federal funding reported by recipients with amounts found in Interior’s Financial and Business Management System, which is used to track grants. In addition, WSFR grant specialists review the performance reports to ensure they contain required information, such as an update on the progress of meeting the specified goals of a grant project. If WSFR staff identify discrepancies in the financial reports or deficiencies in the performance reports, WSFR regional staff work with the grant recipients to resolve them. WSFR regional staff occasionally perform site visits to grant projects to verify grant activities described in the performance reports. WSFR regional staff said they perform site visits as funding and time allow and that recently they have had to limit site visits due to budget and staffing constraints.

Actions to Monitor Grants Are Consistent with Federal Grant Regulations, but Some Performance Reports Were Missing Required Information

The Uniform Guidance contains requirements for financial and performance reports for monitoring federal grants. Specifically, the Uniform Guidance requires federal agencies to collect financial information from grant recipients at least annually. The Uniform Guidance also requires grant recipients to submit performance reports at least annually, and these reports are to include certain information, such as a comparison of the actual accomplishments of a grant with its goals and the reasons why goals were not met, if appropriate. To further guide FWS staff in implementing these requirements, the FWS Service Manual provides additional information on the agency’s expectations for these reports, including the required content. For example, the Service Manual states that recipients should submit financial information, including the amount of federal and matching funds spent and remaining on a grant. The Service Manual also identifies the standard federal form that should be used for this report. For performance reports, the FWS Service Manual states that FWS must require certain information from grant recipients, including a comparison of actual accomplishments to the goals of the grant projects, and if the goals were not met, the reasons why.

In our review of the agency’s monitoring process for selected grants awarded in fiscal year 2015, we found that WSFR required both financial and performance reports at least annually, as required by the Uniform Guidance. In addition, the number and due dates of these reports were specified in the letters provided to grant recipients when they were awarded the grant. These award letters also specified the amount of federal funding for the grant along with any required non-federal matching funds. We reviewed 53 financial reports and 51 performance reports for a sample of 32 grants awarded in fiscal year 2015 and found that most reports were submitted by their due date or within 2 weeks of this date, as table 4 shows.

In addition, the majority of the reports we reviewed met the content requirements found in the Uniform Guidance and the FWS Service Manual. Specifically, all 53 financial reports were submitted on the standard form prescribed by the Service Manual. In addition, the financial information on the amount of the grant and non-federal matching funds aligned with the amounts specified in the award letter for nearly all the financial reports we reviewed. In our review of performance reports, we found that most contained information required by the Uniform Guidance on the grant project’s goals, progress toward those goals, and an explanation for why the goals had not been met, if applicable. However, in our sample, nine performance reports submitted for six awarded grants were missing some of this information. For example, one performance report stated that “no activities had occurred” under the grant, but it did not specify what the goals of the grant were or why no progress had been made, as required by the Uniform Guidance. Additionally, two annual performance reports for another grant described the goals of the grant and said they had not been met, but did not provide information as to why. Officials from one state fish and wildlife agency said that there was not a template to follow when preparing performance reports. Officials from another state agency said that while the requirements for performance reporting were laid out clearly in most NOFOs, they could be interpreted differently by different state officials, and these officials needed to ask for clarification from WSFR officials.

The format and content of the performance reports is generally left for grant recipients to choose, according to WSFR officials, because neither the Uniform Guidance nor internal FWS guidance recommends a specific template for the performance reports. However, the program leader for the Multistate Conservation Grant Program provides grant recipients with a suggested template to follow when preparing performance reports. The template contains areas in which to describe the goals and objectives of the grant along with progress made towards these. The seven performance reports we reviewed for the Multistate Conservation Grant Program followed this template and, as a result, all contained the information required by the Uniform Guidance. We also found that Region 8 developed a suggested template for performance reports, but the template did not explicitly ask for grant recipients to explain why the goals of a grant had not been met. The lack of a clear performance report template may have contributed to 2 of the 10 performance reports from region 8 we reviewed not including clear explanations of why the goals of the grant had not been met, as required by the Uniform Guidance. According to WSFR officials, the agency is planning to develop a more standardized reporting process for performance reports but the timeline for completion of this has not been formally established and remains uncertain.

According to Standards for Internal Control in the Federal Government, management should design control activities to achieve objectives and respond to risks. This includes designing mechanisms to help monitor performance to ensure the objectives of the program are being achieved. As noted previously, the Uniform Guidance specifies that grant performance reports contain a comparison of actual accomplishments to the goals of the project, and the reasons why the goals were not met, as appropriate. The absence of a clear format for these reports may have contributed to some reports not containing all the information needed to comply with federal grant requirements. Without a template or some other standardized method for performance reporting across competitive grant programs, WSFR grant recipients may continue to submit performance reports to WSFR that do not meet all of the content requirements of the Uniform Guidance and do not convey all the information needed for FWS to oversee its competitive grant programs.

Conclusions

WSFR awards and monitors five competitive grant programs and, in general, WSFR’s process for awarding and monitoring these grants is consistent with regulations for federal grants established in OMB’s Uniform Guidance. However, there were instances in which the performance reports submitted by grant recipients did not include a comparison of actual accomplishments to the goals of the project, as required by the Uniform Guidance. WSFR does not have a template for performance reporting for four of the five competitive grant programs we reviewed, and the template used by one region does not clearly ask for all required information. Without a template or standardized method that facilitates the collection of performance information, WSFR grant recipients may continue to submit performance reports to WSFR that do not contain the information required by the Uniform Guidance and do not convey all the needed information for FWS to oversee its competitive grant programs.

Recommendation for Executive Action

The Director of the U.S. Fish and Wildlife Service should direct WSFR to develop a template or other standardized method to facilitate collection of all required information for grant performance reports. (Recommendation 1)

Agency Comments

We provided a draft of this report to the Department of the Interior for review and comment. In its written comments, reproduced in appendix VII, the Department of the Interior agreed with our recommendation and described actions it plans to take.

We are sending copies of this report to the appropriate congressional committees, the Secretary of the Interior, and other interested parties. In addition, the report is available at no charge on the GAO website at http://www.gao.gov.

If you or your staff members have any questions about this report, please contact me at (202) 512-3841 or fennella@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made major contributions to this report are listed in appendix VIII.

Appendix I: Objectives, Scope, and Methodology

Our objectives were to (1) identify and describe the competitive grant programs that the Wildlife and Sport Fish Restoration (WSFR) program awards and monitors; (2) examine how WSFR awards grants under these programs and the extent to which this is consistent with relevant federal regulations; and (3) examine how WSFR monitors grants under these programs and the extent to which this is consistent with relevant federal regulations.

To identify the competitive grant programs that WSFR both awards and monitors, we reviewed federal laws and regulations related to WSFR grant programs. In particular, we reviewed the 1937 Pittman-Robertson Wildlife Restoration Act and the 1950 Dingell-Johnson Sportfish Restoration Act and amendments to these laws, along with associated regulations for these laws. We also reviewed OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) for federal grant awards. In addition, we reviewed agency guidance and information on grant programs; agency budget documents; and grant program descriptions in the Catalog of Federal Domestic Assistance, a compilation of federal assistance programs that includes grants. Based on our review of these materials, we developed an initial list of grant programs that WSFR had a role in managing, and we spoke with WSFR officials to gather information on which competitive grant programs met the criteria of WSFR being responsible for both awarding and monitoring grants. We corroborated this list of grant programs with WSFR officials. We analyzed data on the competitive grant programs we identified from Interior’s Financial and Business Management System for fiscal years 2012 through 2016, the most recent five-year period for when the award process had been completed. To determine the reliability of these data, we interviewed agency officials and conducted electronic testing of the data, and we determined the data were sufficiently reliable for our purposes.

To examine the process WSFR uses to award competitive grants and the extent to which this is consistent with relevant federal regulations, we reviewed relevant agency regulations and guidance along with relevant sections of the Uniform Guidance. To assess the extent to which the award process is consistent with relevant regulations, we compared the process WSFR uses to award grants with OMB’s Uniform Guidance. In addition, we reviewed award documents for grants awarded in fiscal year 2016 for the competitive grant programs we identified. We selected fiscal year 2016 because it was the most recently completed award cycle. These documents included the Notice of Funding Opportunity, which described the funding opportunity to applicants; documentation of the scoring of applications; and memos that documented the results of the scoring process. We also reviewed the entire grant files for eight grants awarded in fiscal year 2016 to determine what documents were contained in these files. In selecting this non-probability sample of files, we selected at least one file for each of the grant programs we examined and at least one file from each of the FWS regional offices that had a grant awarded in fiscal year 2016. However, one of these files was misclassified under an incorrect grant program, so we excluded it from our review. As a result, we did not examine an entire file from the FWS Region 8 office. We reviewed the award documents and files using a standard document review tool to examine specific parts of these documents, such as the descriptions of the process used to review and score applications. To ensure that this review tool was filled out correctly, two GAO staff members reviewed the documents: one filled out the data collection instrument and the other verified this work. In addition to looking at award documents for fiscal year 2016, we also examined memos that documented the results of the grant scoring process for fiscal years 2012 through 2015 for the grant programs we identified. We reviewed the grant scoring memos from fiscal years 2012 through 2016 grants cycles because they comprise the most recent five-year period for when the award process had been completed.

To examine the process WSFR uses to monitor competitive grants and the extent to which those processes are consistent with relevant federal regulations, we reviewed relevant agency regulations and guidance along with relevant sections of the Uniform Guidance. To assess the extent to which the monitoring process is consistent with relevant regulations, we compared the process WSFR uses to monitor grants with OMB’s Uniform Guidance. We used a standard document review tool to review financial and performance reports for 32 of 129 grants that were awarded in fiscal year 2015 to determine the extent to which these reports contained information required by the Uniform Guidance. We selected fiscal year 2015 to ensure that enough time had elapsed under these grants for financial and performance reports to have been required and submitted. In selecting this non-probability sample of files, we ensured that we had at least one file for each of the grant programs and at least one file from each of the eight FWS regional offices. For financial reports, we determined whether reported financial information on the grant award and matching funds aligned with the dollar amounts in their award letters, whether the reports were submitted by their due dates, and whether they were submitted on the correct form. For performance reports, we determined whether they were submitted by their due dates and whether they contained information on the grant project’s goals, progress toward those goals, and an explanation why the goals had not been met, if applicable. The Uniform Guidance requires this information to be in performance reports. The results from our analysis of these documents are not generalizable to all monitoring documents for grants awarded in fiscal year 2015, but allowed us to examine how WSFR monitored selected grants.

For all three objectives, we interviewed WSFR staff responsible for managing WSFR grant programs. These included WSFR program leaders at headquarters and WSFR staff in each of the eight FWS regional offices that are responsible for the five competitive grant programs we reviewed. We asked these officials about the role they played in awarding and monitoring competitive grants. In addition, we interviewed other FWS officials that were involved with managing grants and officials from select third party organizations that played a role in awarding grants, including the Association of Fish and Wildlife Agencies and the Sport Fishing and Boating Partnership Council. We also interviewed grant applicants, including state fish and wildlife agency officials and nongovernmental organizations to learn about their experiences during the award and monitoring process for WSFR grants. We selected applicants that had various experiences with the grant programs in fiscal year 2016, including those that applied and did not receive funding and those that applied and received funding. The results of the interviews with grant applicants cannot be generalized to other applicants, but were used to obtain perspectives on the grant award and monitoring processes.

We conducted this performance audit from March 2017 to February 2018 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.

Appendix II: Information on the Boating Infrastructure Tier 2 Grant Program

Below is summary information on the Boating Infrastructure Tier 2 Grant Program that we compiled from reviewing relevant laws and regulations, reviewing agency documents, and interviewing agency officials.

Establishment and goals of the program:

The program was established by the Sportfishing and Boating Safety Act of 1998, which amended the Dingell-Johnson Sport Fish Restoration Act.

The program provides grants to be used for constructing, renovating, or maintaining docking or mooring facilities for transient, nontrailerable recreational vessels that are 26 feet or greater in length. These facilities generally must allow public access, and examples of facilities that can be built with these funds include boat slips, piers, buoys, fuel stations, restrooms, bulkheads, dredging, or laundry facilities. Grants can also be awarded to produce information and education materials specific to the program or projects funded by the program.

Governor-designated agencies in a state of the United States, the District of Columbia, American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, or the U.S. Virgin Islands are eligible for this grant program. The designated agency is often a state natural resource or fish and wildlife agency.

Subgrants to other entities are allowed. According to Wildlife and Sport Fish Restoration (WSFR) officials, subgrants under this program are common.

About 2 percent of the Sport Fish Restoration and Boating Trust Fund is devoted to the grant program. In fiscal year 2016, there was $8.6 million in federal funds available for the Tier 2 program.

The maximum grant award is $1.5 million per project, and recipients generally must provide matching funds worth at least 25 percent of the total cost of projects.

Funds not obligated within three fiscal years shall be transferred to the Coast Guard and expended for state recreational boating safety programs.

Highlights from the award process used in fiscal year 2016:

The Notice of Funding Opportunity for fiscal year 2016 was posted on www.grants.gov on June 22, 2015, and applications were due by September 18, 2015.

Thirteen states submitted a total of 22 applications for projects.

Regional staff for the Wildlife and Sport Fish Restoration Program and members from the Sport Fishing and Boating Partnership Council scored the applications and recommended that 10 projects be fully funded and one be partially funded. The Deputy Director of the U.S. Fish and Wildlife Service approved the list of recommended projects on March 11, 2016.

The U.S. Fish and Wildlife Service announced the selected projects on March 17, 2016.

Information on past applications and selected projects: Table 5 shows the number of applications received and selected projects under the Boating Infrastructure Tier 2 Grant Program in fiscal years 2012 through 2016.

Appendix III: Information on the Clean Vessel Act Grant Program

Below is summary information on the Clean Vessel Act Grant Program that we compiled from reviewing relevant laws and regulations, reviewing agency documents, and interviewing agency officials.

Establishment and goals of the program:

The program was established by the Clean Vessel Act of 1992, which amended the Dingell-Johnson Sport Fish Restoration Act.

This program funds grants to coastal states for certain activities, such as constructing and renovating pumpout stations and waste reception facilities and conducting a program to educate recreational boaters about the problem of human body waste discharges from vessels and inform them of the locations of pumpout stations and waste reception facilities. The program also funds grants to inland states meeting certain criteria. Under program regulations, facilities need to be open to the public in order to be eligible for a grant.

Since the program was established, over 6,000 dump or pumpout facilities have been built and over 3,700 of these facilities have been operated or maintained using grant funds.

Governor-designated agencies in a state of the United States, the District of Columbia, American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, or the U.S. Virgin Islands are eligible for this grant program. The designated agency is often a state natural resource or fish and wildlife agency.

Subgrants to other entities are allowed. According to Wildlife and Sport Fish Restoration (WSFR) officials, subgrants under this program are common.

About 2 percent of the Sport Fish Restoration and Boating Trust Fund is devoted to the grant program. In fiscal year 2016, there was $13.7 million in federal funds available for the program.

The maximum award amount is generally $1.5 million, and recipients generally must provide matching funds worth at least 25 percent of the total cost of projects.

Funds not obligated within three fiscal years shall be transferred to the U.S. Coast Guard and expended for state recreational boating safety programs.

Highlights from the award process used in fiscal year 2016:

The Notice of Funding Opportunity (NOFO) for fiscal year 2016 was posted on www.grants.gov on August 12, 2015, and applications were due by December 2, 2015.

A total of 21 states and the District of Columbia submitted 33 applications. WSFR staff from the U.S. Fish and Wildlife Service regions scored applications in their regions; then, these scores were averaged with scores from the WSFR program leader for the Clean Vessel Act grant program, who scored all of the applications. WSFR provided copies of grant applications to the U.S. Environmental Protection Agency (EPA), U.S. Coast Guard, and National Oceanic and Atmospheric Administration (NOAA) for them to review and score the applications. WSFR also provided its scores on the applications to these agencies. EPA informed WSFR in an email that it agreed with the proposed funding decisions for the program. According to WSFR, the Coast Guard did not provide comments on the proposed scores. NOAA sent a letter to WSFR indicating that it had not reviewed all of the applications but it supported the program and did not object to the agency’s scoring of the applications. The Deputy Director of the U.S.

Fish and Wildlife Service approved the list of recommended projects on April 28, 2016.

The U.S. Fish and Wildlife Service announced the winning grant awards on May 11, 2016.

According to the fiscal year 2016 NOFO, this program attempts to provide support to as many eligible projects as possible. In practice, all eligible applications have been awarded funds from fiscal year 2012 through fiscal year 2016. If funding requests exceed available funds, WSFR applies a formula to allocate funding based on the score the application receives.

Information on past applications and selected projects: Table 6 shows the number of applications received and selected projects under the Clean Vessel Act Grant Program in fiscal years 2012 through 2016.

Appendix IV: Information on the Competitive State Wildlife Grant Program

Below is summary information on the Competitive State Wildlife Grant Program that we compiled from reviewing relevant laws and regulations, reviewing agency documents, and interviewing agency officials.

Establishment and goals of the program:

The State Wildlife Grant Program provides grants for the development and implementation of programs for the benefit of wildlife and their habitats, including species that are not hunted or fished. Eligible activities include planning and conservation implementation.

The competitive portion of the State Wildlife Grant Program was established by the Consolidated Appropriations Act, 2008.

Fish and wildlife agencies in a state of the United States, the District of Columbia, American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, or the U.S. Virgin Islands and at the discretion of affected states, the regional Association of Fish and Wildlife Agencies are eligible for this grant program. According to the Notice of Funding Opportunity (NOFO) for this program, for each of the 48 contiguous United States and the District of Columbia, at least two states must be active participants in proposed conservation actions.

Applicants are also encouraged to engage with other partners on projects. Potential partners include tribes, federal agencies, other state agencies, local governments, nongovernmental organizations, academic institutions, private landowners, industry groups, and international partners.

The program is governed and funded through annual appropriations acts. In fiscal year 2016, there was about $5.6 million available for the program.

For most applicants proposing a multi-state project, the maximum award is $500,000 and the minimum award is $50,000. Applicants must provide matching funds worth at least 25 percent of the total cost of projects.

Past appropriations for these grants have been appropriated to remain available until expended. The appropriations acts governing the program have generally provided that any amount apportioned in one fiscal year that remains unobligated by the end of the next fiscal year are to be reapportioned in the following fiscal year.

Highlights from the award process used in fiscal year 2016:

The NOFO for fiscal year 2016 was posted on www.grants.gov on November 20, 2015, and applications were due by February 19, 2016.

The Wildlife and Sport Fish Restoration Program (WSFR) received 21 eligible applications. Applications were reviewed by a panel consisting of WSFR staff from each region of the U.S. Fish and Wildlife Service (FWS). The panel recommended fully funding 14 projects and partially funding 1 project, for a total of $5.6 million, with $2.9 million in non- federal matching funds. The Deputy Director of the U.S. Fish and Wildlife Service approved the list of recommended projects on May 19, 2016.

FWS announced the selected projects on May 20, 2016.

Information on past applications and selected projects: Table 7 shows the number of applications received and selected projects under the Competitive State Wildlife Grant Program in fiscal years 2012 through 2016.

Appendix V: Information on the Multistate Conservation Grant Program

Below is summary information on the Multistate Conservation Grant Program that we compiled from reviewing relevant laws and regulations, reviewing agency documents, and interviewing agency officials.

Establishment and goals of the program:

The program was established by the Wildlife and Sport Fish Restoration Programs Improvement Act of 2000, which amended the Pittman-Roberts Wildlife Restoration Act and the Dingell-Johnson Sport Fish Restoration Act.

The program focuses on funding multistate conservation projects that benefit a certain number of states or a regional association of state fish and game departments.

Fish and wildlife agencies in a state of the United States, the District of Columbia, American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, or the U.S. Virgin Islands are eligible for this grant program. The U.S. Fish and Wildlife Service (FWS) is also an eligible applicant for the purpose of carrying out the National Survey of Fishing, Hunting, and Wildlife-Associated Recreation, which is conducted every five years. Nongovernmental organizations are also eligible, provided that they submit a certification that they will not use the grant funds to fund, in whole or in part, any activity of the organization that promotes or encourages opposition to the regulated hunting or trapping of wildlife or the regulated taking of fish.

Grant projects shall not be eligible unless they will benefit at least 26 states, a majority of states in a FWS region, or a regional association of state fish and wildlife agencies.

By statute, FWS may only make grants for projects identified on a priority list prepared by the Association of Fish and Wildlife Agencies (AFWA), a nongovernmental organization that represents state fish and wildlife agencies on conservation and land management issues, after following certain procedures.

Up to $6 million annually is authorized to fund grants, with no more than $3 million from the Wildlife Restoration Account and $3 million from the Sport Fish Restoration Trust Fund. In practice, some of the grant funds are carried over to future years to fund certain multi-year projects, such as the National Survey of Fishing, Hunting, and Wildlife-Associated Recreation.

This program does not have a matching funds requirement.

Funds not obligated within two fiscal years revert back to the Wildlife Restoration and Sport Fish Restoration programs for apportionment to the states.

Highlights from the award process used in fiscal year 2016:

The Notice of Funding Opportunity for fiscal year 2016 was posted on www.grants.gov on April 13, 2015, and the deadline for submitting letters of intent to AFWA was May 11, 2015. These letters of intent provide a summary of the grant project, and they were scored by AFWA’s national grants committee. The highest-scoring applicants were invited to submit a full grant application to AFWA by August 14, 2015. The national grants committee scored these applications and presented these scores to AFWA members at its annual meeting in September 2015. Members voted to approve the priority list at this meeting.

AFWA provided the priority list containing 18 projects to FWS. The Deputy Director of Program Management and Policy of the U.S. Fish and Wildlife Service approved the list of recommended projects on December 7, 2015.

During the award process, Wildlife and Sport Fish Restoration staff also reviewed the grant applications.

FWS announced the selected projects on February 11, 2016.

Information on past applications and selected projects: Table 8 shows the number of applications received and selected projects under the Multistate Conservation Grant Program in fiscal years 2012 through 2016.

Appendix VI: Information on the National Coastal Wetlands Conservation Grant Program

Below is summary information on the National Coastal Wetlands Conservation Grant Program that we compiled from reviewing relevant laws and regulations, reviewing agency documents, and interviewing agency officials.

Establishment and goals of the program:

The program was established by the Coastal Wetlands Planning, Protection and Restoration Act.

This program’s primary goal is the long-term conservation of coastal wetlands’ ecosystems. It accomplishes this by helping states protect, restore, and enhance their coastal habitats through a competitive grants program.

Since 1992, the U.S. Fish and Wildlife Service (FWS) has awarded over $377 million through these grants.

Governor-designated agencies of an eligible coastal state are eligible for this grant program. The designated agency is often a state natural resource or fish and wildlife agency.

Subgrants are allowed, are relatively common, and can be awarded to local governments and nonprofit organizations.

About 3 percent of the Sport Fish Restoration and Boating Trust Fund is devoted to the grant program. In fiscal year 2016, there was about $20.3 million in federal funds available for the program.

The maximum award amount is $1 million, and states generally must provide 50 percent of the total cost of the project. However, states that have established and are using a state fund for the purpose of acquiring coastal wetlands must provide a minimum of 25 percent of the total cost of projects.

Projects are generally funded through annual proposals. Funds must be obligated by December 31st of the year after funds were allocated, meaning that, for example, fiscal year 2015 funds must be obligated by December 31, 2016. Funds not obligated during the specified time frame return to the FWS program account.

Highlights from the award process used in fiscal year 2016:

The Notice of Funding Opportunity for fiscal year 2016 was posted on www.grants.gov on February 5, 2015, and applications were due by June 24, 2015.

The FWS Wildlife Sport Fish Restoration Program (WSFR) received 32 applications. A panel of WSFR and FWS Coastal Program regional officials scored and ranked the applications, and recommended 28 projects for funding. The Deputy Director of the U.S. Fish and Wildlife Service approved the list of recommended projects on January 13, 2016.

WSFR awarded $20 million in grant funding, which was supplemented by $20.5 million in non-federal matching funds.

FWS announced the selected projects on February 2, 2016.

Information on past applications and selected projects: Table 9 shows the number of applications received and selected projects under the National Coastal Wetlands Conservation Grant Program in fiscal years 2012 through 2016.

Appendix VII: Comments from the Department of the Interior

Appendix VIII: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the individual named above Elizabeth Erdmann (Assistant Director), Steven Bagley, and Scott Heacock made key contributions to this report. Additional contributions were made by Thomas M. James, Ying Long, Kim McGatlin, Patricia Moye, Anne Rhodes-Kline, and Sheryl Stein.