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)

     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
                                        OFFICE OF INSPECTOR GENERAL

                                             Washington D.C. 20250

DATE:            December 20, 2019

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.

  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).
  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).
                                       OFFICE OF INSPECTOR GENERAL

                                             Washington D.C. 20250

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.

  Audit Report 10601-0003-31, NRCS: Wetland Conservation Provisions in the Prairie Pothole Region, January 19,
  DR1720-001, 7d(1-9), Audit Follow-up and Management Decision (Nov. 2, 2011).
                                   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
  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

cc: Gary Weishaar, Branch Chief, External Audits and Investigations Division, NRCS
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