United States Department of Agriculture NRCS—Final Action Verification—NRCS Wetland Conservation Provisions in the Prairie Pothole Region Report 10026-0001-21 December 2019 OFFICE OF INSPECTOR GENERAL UNITED STATES DEPARTMENT OF AGRICULTURE OFFICE OF INSPECTOR GENERAL Washington D.C. 20250 DATE: December 20, 2019 FAV NUMBER: 10026-0001-21 TO: Annie Walker Director, Internal Control Division Office of the Chief Financial Officer FROM: Gil H. Harden Assistant Inspector General for Audit SUBJECT: Natural Resources Conservation Services (NRCS) – Final Action Verification – NRCS: Wetland Conservation Provisions in the Prairie Pothole Region The Office of Inspector General (OIG) completed a final action verification of the two recommendations in our January 19, 2017, report on the NRCS: Wetland Conservation Provisions in the Prairie Pothole Region. Final action verification determines whether the final action documentation the agency provides to the Office of the Chief Financial Officer (OCFO) supports the agency’s management decision reached with OIG. 1,2 Our objective was to determine whether the documentation NRCS provided OCFO was sufficient to close the recommendations made in Audit Report 10601-0003-31. In a memorandum dated June 13, 2017, OCFO reported to NRCS that it closed all of the recommendations, and we concur with this decision. 1 Final action is the completion of all actions that management has concluded, in its management decision, are necessary with respect to the finding and recommendations included in an audit report. DR1720-001, 6g(1), Audit Follow-up and Management Decision (Nov. 2, 2011). 2 Management decision is an agreement between agency management and OIG on the action(s) taken or to be taken to address a finding and recommendations cited in an audit report. The management decision must include the agreed-upon dollar amount affecting the recommendations and an estimated completion date unless all corrective action is completed by the time agreement is reached. DR1720-001, 6i, Audit Follow-up and Management Decision (Nov. 2, 2011). UNITED STATES DEPARTMENT OF AGRICULTURE OFFICE OF INSPECTOR GENERAL Washington D.C. 20250 Background Our report, NRCS: Wetland Conservation Provisions in the Prairie Pothole Region,3 made two recommendations to improve NRCS’ controls for making wetland determinations and certifications, including the status of pre-1996 determinations. OIG and NRCS reached management decision on all the recommendations in a memorandum dated January 23, 2017. The memorandum detailed what actions NRCS needs to implement in order achieve final action on the recommendations. In accordance with Departmental Regulation 1720-001,4 OCFO has the responsibility to determine final action for recommendation(s) for which OIG has agreed to management decision. As such, OCFO evaluates agency-provided documentation to support planned corrective actions and to determine if final action has occurred. Scope and Methodology The scope of this final action verification was limited to determining whether NRCS’ plan of action for all of the recommendations in the subject report was completed in accordance with the management decisions reached on January 23, 2017. To accomplish our objective, we reviewed the final action documentation NRCS submitted to OCFO. We did not perform internal control testing or make site visits to determine whether the underlying deficiencies that were initially identified had been corrected. In addition, we did not provide an opinion on the results of the implementation or effectiveness of each recommendation. This final action verification was conducted in accordance with our internal guidance, IG-7710, Nonaudit Work, and Final Action Verification Guidance and Procedures. As a result, this final action verification was not conducted in accordance with Generally Accepted Government Auditing Standards, issued by the Comptroller General of the United States, or the Quality Standards for Inspection and Evaluation, issued by the Council of the Inspectors General on Integrity and Efficiency. However, before we performed the non-audit service, we determined that it would not impair our independence to perform audits, inspections, attestation engagements, or any other future or ongoing reviews of the subject. Results of Final Action Verification We determined that NRCS provided OCFO sufficient documentation to close the two recommendations we made in our audit report, NRCS: Wetland Conservation Provisions in the Prairie Pothole Region, published January 19, 2017. The following table summarizes the action NRCS took with respect to each recommendation. 3 Audit Report 10601-0003-31, NRCS: Wetland Conservation Provisions in the Prairie Pothole Region, January 19, 2017. 4 DR1720-001, 7d(1-9), Audit Follow-up and Management Decision (Nov. 2, 2011). UNITED STATES DEPARTMENT OF AGRICULTURE OFFICE OF INSPECTOR GENERAL Washington D.C. 20250 We informed NRCS officials of the results of this final action verification. Table 1. Recommendations with Sufficient Documentation to Achieve Final Action Rec. No. Recommendation Action Taken 1 Issue official guidance NRCS provided an updated reinforcing correct and National Food Security current rules and clarifying Manual (NFSAM), Part procedures for making 514, “Wetland wetland determinations and Determination and Labels;” certifications, including theguidance on wetland status of pre-1996 certification in accordance determinations. with the NFSAM referenced 1996 amendment; and guidance policy and certification status sent to States. 2 Review all National NRCS provided a Appeals Division (NAD) spreadsheet containing decisions in the prairie NAD cases and dispositions pothole region from for the prairie pothole January 1, 2010, through the region from 2010 through present to determine 2016, and the applicable whether the decisions were law—National Food implemented. In those Security Act Manual cases where the NAD final (NFSAM), Part 514, determination was set-aside “Wetland Determination or modified instead of and Labels.” implemented as directed by NAD, require the State office to implement the NAD decision in accordance with applicable law. cc: Gary Weishaar, Branch Chief, External Audits and Investigations Division, NRCS Learn more about USDA OIG Visit our website: www.usda.gov/oig Follow us on Twitter: @OIGUSDA Report Suspected Wrongdoing in USDA Programs OIG Hotline: www.usda.gov/oig/hotline.htm Monday–Friday, 9:00 a.m.– 3:00 p.m. ET In Washington, D.C. (202) 690-1622 Outside D.C. (800) 424-9121 TYY (Call Collect) (202) 690-1202 Bribery / Assault (202) 720-7257 (24 hours) In accordance with Federal civil rights law and U.S. Department of Agriculture Relay Service at (800) 877-8339. 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NRCS - Final Action Verification - NRCS Wetland Conservation Provisions in the Prairie Pothole Region
Published by the Department of Agriculture, Office of Inspector General on 2019-12-26.
Below is a raw (and likely hideous) rendition of the original report. (PDF)