oversight

U.S. Fish and Wildlife Service Grants Awarded to the State of Alabama, Department of Conservation and Natural Resources, Marine Resources Division, From October 1, 2016, Through September 30, 2018

Published by the Department of the Interior, Office of Inspector General on 2020-07-30.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                                                                  AUDIT




                OFFICE OF
                INSPECTOR GENERAL
                U.S.DEPARTMENT OF THE INTERIOR




 U.S. Fish and Wildlife Service Grants
 Awarded to the State of Alabama,
 Department of Conservation and Natural
 Resources, Marine Resources Division,
 From October 1, 2016, Through
 September 30, 2018, Under the Wildlife
 and Sport Fish Restoration Program




 This is a revised version of the report prepared for public release.


In recognition of Secretarial Order No. 3380, we are providing estimated costs
associated with certain work products. Applying a formula involving prior salary and
benefit expenses, we estimate the cost of preparing this report to be $85,000.



Report No.: 2019-ER-053                                                        July 2020
                  OFFICE OF
                  INSPECTOR GENERAL
                  U.S.DEPARTMENT Of THE INTERIOR



Memorandum

To:            Aurelia Skipwith
               Director, U.S. Fish and Wildlife Service

From:          Nicki Miller
               Regional Manager, Eastern Region

Subject:       Final Audit Report – U.S. Fish and Wildlife Service Grants Awarded to the State
               of Alabama, Department of Conservation and Natural Resources, Marine
               Resources Division, From October 1, 2016, Through September 30, 2018, Under
               the Wildlife and Sport Fish Restoration Program
               Report No. 2019-ER-053

        This final report presents the results of our audit of costs claimed by the Alabama
Department of Conservation and Natural Resources, Marine Resources Division (Department),
under grants awarded by the U.S. Fish and Wildlife Service (FWS) through the Wildlife and
Sport Fish Restoration Program. We conducted this audit to determine whether the Department
used grant funds and State fishing license revenue for allowable fish activities and complied with
applicable laws and regulations, FWS guidelines, and grant agreements. The audit period
included claims totaling $5.1 million on 23 grants that were open during the State fiscal years
that ended September 30, 2017, and September 30, 2018.

        We found that the State generally ensured that grant funds and State fishing license
revenue were used for allowable fish activities and complied with applicable laws and
regulations, FWS guidelines, and grant agreements. We noted, however, the Marine Resources
Division purchased items with grants funds that were unallowable, and we questioned $3,112
($2,334 Federal share) in ineligible costs associated with these purchases. We also found that the
Department overdrew $5,164 ($3,873 Federal share) from a grant because the Department failed
to appropriately report program income. We further determined the Department did not comply
with Digital Accountability and Transparency Act of 2014 requirements by not reporting
subawards greater than $25,000 on USASpending.gov.

       We provided a draft of this report to the FWS. The FWS concurred with all five
recommendations and will work with the Department to implement corrective actions. The full
responses from the Department and the FWS are included in Appendix 4. In this report, we
summarize the Department’s and FWS Region 2’s responses to our recommendations, as well as
our comments on their responses. We list the status of the recommendations in Appendix 5.

      Please provide us with a corrective action plan based on our recommendations by
 October 28, 2020. The plan should provide information on actions taken or planned to address



                       Office of Audits, Inspections, and Evaluations | Herndon, VA
the recommendations, as well as target dates and titles of the officials responsible for
implementation. Please address your response to me and submit a signed PDF copy to
aie_reports@doioig.gov.

      The legislation creating the Office of Inspector General requires that we report to
Congress semiannually on all audit reports issued, actions taken to implement our
recommendations, and recommendations that have not been implemented.

       If you have any questions regarding this report, me at 202-208-5745.


cc: Leopoldo Miranda, Regional Director, Region 2, U.S. Fish and Wildlife Service




                                                 2
Contents
Introduction......................................................................................................................................1
     Objective ....................................................................................................................................1
     Background ................................................................................................................................1
Results of Audit ...............................................................................................................................2
     Questioned Costs—$8,276 ($6,207 Federal Share)...................................................................2
     WSFR Program Deficiency .......................................................................................................4
Recommendations Summary ...........................................................................................................6
Appendix 1: Scope and Methodology..............................................................................................9
Appendix 2: Sites Visited ..............................................................................................................12
Appendix 3: Monetary Impact .......................................................................................................13
Appendix 4: Responses to Draft Report ........................................................................................14
Appendix 5: Status of Recommendations......................................................................................19
Introduction
Objective
In June 2016, we entered into an intra-agency agreement with the U.S. Fish and Wildlife Service
(FWS) to conduct audits of State agencies receiving grant funds under the Wildlife and Sport
Fish Restoration Program. These audits fulfill the FWS’ statutory responsibility to audit State
agencies’ use of these grant funds.

We conducted this audit to determine whether the Alabama Department of Conservation and
Natural Resources, Marine Resources Division (Department), used grant funds and State fishing
license revenue for allowable fish activities and complied with applicable laws and regulations,
U.S. Fish and Wildlife (FWS) guidelines, and grant agreements. See Appendix 1 for details
about our scope and methodology. See Appendix 2 for sites we visited.

Background
The FWS provides grants to States 1 through its Wildlife and Sport Fish Restoration Program
(WSFR) for the conservation, restoration, and management of wildlife and sport fish resources.
In addition, WSFR supports activities related to hunting and sport fishing, such as hunter
education programs and boating access projects.

WSFR was established by the Pittman-Robertson Wildlife Restoration Act and the Dingell-
Johnson Sport Fish Restoration Act. 2 The Acts and related Federal regulations allow the FWS to
reimburse grantees a portion of eligible costs incurred under WSFR grants—up to 75 percent for
States and 100 percent for the District of Columbia, Puerto Rico, the U.S. Virgin Islands, Guam,
American Samoa, and the Northern Mariana Islands. The reimbursement amount is called the
Federal share. The Acts require that hunting and fishing license revenue be used only for
allowable fish and wildlife activities. In addition, Federal regulations require States to account
for any income earned from grant-funded activities and to spend this income before requesting
grant reimbursements.




1 The Wildlife and Sport Fish Restoration Program defines the term “State” to include the District of Columbia, the
Commonwealth of Puerto Rico, the U.S. Virgin Islands, Guam, American Samoa, and the Commonwealth of the Northern
Mariana Islands.
2 Formally known, respectively, as the Federal Aid in Wildlife Restoration Act, 16 U.S.C. § 669, as amended, and the Federal

Aid in Sport Fish Restoration Act, 16 U.S.C. § 777, as amended.


                                                                                                                               1
Results of Audit
We determined that the State generally ensured that grant funds and State fishing license revenue
were used for allowable fish activities and complied with applicable laws and regulations, FWS
guidelines, and grant agreements. We note the following exceptions:

   •   Questioned Costs. We questioned $3,112 ($2,334 Federal share) as ineligible for
       unallowable purchases because the items purchased only promoted the Department and
       were not directly related to the WSFR grant purpose. We also determined $5,164 ($3,873
       Federal share) to be ineligible because the Department failed to expend program income
       before drawing down WSFR grant funds, resulting in an excess reimbursement.

   •   WSFR Program Deficiency. The Department did not comply with Federal regulations
       that require it to report subawards greater than $25,000 on USASpending.gov.

See Appendix 3 for a statement of monetary impact.

Questioned Costs—$8,276 ($6,207 Federal Share)
Ineligible Other Direct Costs Charges—Questioned Costs of $2,334

In order to be eligible for reimbursement under WSFR, grant expenses must be reasonable,
allowable, allocable, and adequately support the grant agreement. The Marine Resources
Division purchased ineligible items with funds from Grant Nos. F16AF01319 and F17AF01289
that were not directly related to the grants’ intended purpose, which is to enhance the public’s
appreciation for the marine environment and fishing regulations. The Marine Resources Division
spent $3,112 (Federal share $2,334) on polo shirts and boots (see Figure 1). The polo shirts
contained only an embroidered Alabama Marine Resources Division logo and nothing promoting
WSFR. Likewise, we found the boots, which ranged in cost from $103 to $133 a pair, to be of no
promotional value to the WSFR program. As a result, we questioned other direct costs totaling
$2,334 (Federal share).

Title 2 C.F.R. § 200.421(e)(4) states that unallowable advertising and public relations costs are
those designed solely to promote the non-Federal entity.

Because there were no written policies and procedures to inform personnel how to determine
whether items should be charged to WSFR grants, the staff did not know the shirt and boot
purchases were ineligible. Using grant funds for these purchases reduced the effect of the grant
because it left fewer funds available for its intended purposes.




                                                                                                    2
     Figure 1: Federal Share of Questioned Costs Related to Other Direct Costs

                                                                                   Ineligible
                                                                            Questioned Costs
 Grant No.        Grant Title                               Items                         ($)

                  Coastal Alabama Outreach and
 F16AF01319                                                 Polo shirts                    1,458
                  Education
                  Coastal Alabama Outreach and
 F17AF01289                                                 Boots                            876
                  Education

 Total                                                                                   $2,334

Source: Alabama Department of Conservation and Natural Resources, Marine Resources
Division.


 Recommendations


 We recommend that the FWS:

     1. Resolve the questioned costs related to other direct costs totaling $3,112
        ($2,334 Federal share)

     2. Require the Department to develop written policies and procedures to ensure
        grant costs claimed are eligible, allowable, and reasonable charges to WSFR


Excess Reimbursement—Questioned Costs of $3,873

The Department overdrew on Grant No. F15AF01359 because it failed to expend program
income of $5,164 (Federal share $3,873) generated through the Artificial Reef Permits Program
before the final draw of the grant was made. Because the Department did not report all its
program income before the grant was closed, it received a larger amount of Federal
reimbursement.

Title 2 C.F.R. § 200.307(e)(1) states that program income the non-Federal entity did not
anticipate at the time of the Federal award must be used to reduce the Federal award and
non-Federal entity contributions rather than to increase the funds committed to the project.
Further, the regulation states that program income must be used for the current cost unless the
Federal awarding agency authorizes otherwise.

The Department’s central accounting employee, who was responsible for the Department’s
drawdown process, did not consult with the Alabama Marine Resources Division accountant to
see if any program income was generated during the grant period, and so did not report it
appropriately. As a result, the Department failed to appropriately report all its program income
generated during the grant period, violating Federal regulations. Further, because the Department




                                                                                                  3
did not properly credit the grant with program income totaling $5,164 (Federal share $3,873), it
overdrew Federal funds for Grant No. F15AF01359 (see Figure 2).

  Figure 2: Federal Share of Questioned Costs Related to Excess Reimbursement

                                                                              Ineligible
                                                                       Questioned Costs
     Grant No.           Grant Title                                                 ($)

                         Enhancement of Recreational Fishing in
     F15AF01359                                                                      3,873
                         Coastal Alabama

     Total                                                                         $3,873

    Source: Alabama Department of Conservation and Natural Resources, Marine
    Resources Division.


 Recommendations


 We recommend that the FWS:

      3. Require the Department to implement controls that ensure program income is
         properly accounted for and reported

      4. Resolve the questioned costs related to the excess reimbursement totaling
         $5,164 ($3,873 Federal share)



WSFR Program Deficiency
Inadequate Oversight of Subrecipients

We found that the Department did not comply with Federal regulations related to subawards.
It did not report all subawards greater than $25,000 on USASpending.gov, a website intended to
promote Government transparency under the Digital Accountability and Transparency Act of
2014. Specifically, we found that seven subawards issued through four grants awarded in fiscal
years 2017 and 2018 were not reported on USASpending.gov (see Figure 3). Auburn University
and South Alabama, pass-through entities, received all seven subawards to conduct fish research.

Title 2 C.F.R. § 200.330 requires that subrecipient and contractor determinations must occur
when the recipient decides to issue Federal awards to a pass-through entity. In accordance with
Title 2 C.F.R. § 170.220(a), Federal grantees must report each subaward action that obligates
$25,000 or more in Federal funds on www.fsrs.gov. This information is then posted in
USASpending.gov.

We found that the Department’s guidance in place during the audit period did not state that
personnel must report subawards greater than $25,000 on www.fsrs.gov. Failure to report such



                                                                                                   4
subawards created a lack of transparency to the public regarding the use of Federal funds. In
August 2019, the Department updated policies and procedures to include this process; however,
it still does not include clear guidance to satisfy the requirement to post subawards in excess of
$25,000 to USAspending.gov.

  Figure 3: Grants With Subawards Not Reported, Violating Federal Requirements


          Subrecipients                         Grant No.           Federal Share ($)

          Auburn University                                                     149,894
                                               F16AF00207
          University of South Alabama                                            51,175
          Auburn University                                                     200,000
                                               F17AF00123
          University of South Alabama                                            64,640
          Auburn University                                                     250,610
                                               F18AF00230
          University of South Alabama                                            63,025
          Auburn University                    F18AF00231                        89,151

          Total                                                               $868,495

         Source: Alabama Department of Conservation and Natural Resources,
         Marine Resources Division.


 Recommendation


 We recommend that the FWS:

      5. Require the Department to report all prior subawards of more than $25,000
         and implement controls to ensure compliance with Federal regulations in the
         future




                                                                                                     5
Recommendations Summary
We recommend that the FWS:

   1. Resolve the questioned costs related to other direct costs totaling $3,112 ($2,334 Federal
      share)

      Department Response

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

      FWS Response

      The FWS concurred with the finding and will work with the Department to develop a
      corrective action plan.

      OIG Comment

      Based on the responses from the Department and the FWS, we consider the
      recommendation resolved but not implemented.

   2. Require the Department to develop written policies and procedures to ensure grant costs
      claimed are eligible, allowable, and reasonable charges to WSFR

      Department Response

      The Department did not concur with the finding or recommendation. The Department
      explained that policies and procedures were in place at the time to ensure grant costs
      claimed were eligible, allowable, and reasonable charges to WSFR, but staff did not
      follow the policy. It stated that all staff would be made aware of these policies and
      instructed to follow them going forward.

      FWS Response

      The FWS concurred with the finding.

      OIG Comment

      Based on the responses from the Department and the FWS, we consider the
      recommendation resolved and implemented. However, the Department’s updates to the
      policy were implemented after the first invoice in question was received and paid in June
      2017. The Department told us that updates to the policy to ensure grant costs claimed are
      eligible, allowable, and reasonable, were implemented in December 2017. Therefore,



                                                                                                   6
   there was no specific policy in place at the time of the June 2017 purchase. This policy
   was further revised August 2019 and is sufficient support to close this recommendation.

3. Require the Department to implement controls that ensure program income is properly
   accounted for and reported

   Department Response

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

   FWS Response

   The FWS concurred with the finding and will work with the Department to develop a
   corrective action plan.

   OIG Comment

   Based on the responses from the Department and the FWS, we consider the
   recommendation resolved but not implemented.

4. Resolve the questioned costs related to the excess reimbursement totaling $5,164 ($3,873
   Federal share)

   Department Response

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

   FWS Response

   The FWS concurred with the finding and will work with the Department to develop a
   corrective action plan.

   OIG Comment

   Based on the responses from the Department and the FWS, we consider the
   recommendation resolved but not implemented.

5. Require the Department to report all prior subawards of more than $25,000 and
   implement controls to ensure compliance with Federal regulations in the future

   Department Response

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



                                                                                              7
FWS Response

The FWS concurred with the finding and will work with the Department to develop a
corrective action plan.

OIG Comment

Based on the responses from the Department and the FWS, we consider the
recommendation resolved but not implemented.




                                                                                    8
Appendix 1: Scope and Methodology
Scope
We audited the Alabama Department of Conservation and Natural Resources, Marine Resources
Division’s (Department’s) use of grants awarded by the U.S. Fish and Wildlife Service (FWS)
under the Wildlife and Sport Fish Restoration Program (WSFR). The audit period included
claims totaling $5.1 million on 23 grants that were open during the State fiscal years (SFYs) that
ended September 30, 2017, and September 30, 2018.

Methodology
We conducted this performance audit in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions
based on our audit objectives. We believe that the evidence obtained provides a reasonable basis
for our findings and conclusions based on our audit objectives.

We assessed whether internal control was significant to the audit objective. We determined that
the Department’s control activities and related principles were significant to the audit objective.

   •   Management should design control activities to achieve objectives and respond to risks.

   •   Management should design the entity’s information system and related control activities
       to achieve objectives and respond to risks.

   •   Management should implement control activities through policies.

We tested the operation and reliability of internal controls over activities as related to our audit
objective. Our tests and procedures included:

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

   •   Reviewing transactions related to purchases, direct costs, drawdowns of reimbursements,
       in-kind contributions, and program income

   •   Interviewing Department employees to ensure that personnel costs charged to the grants
       were supportable

   •   Inspecting equipment and other property

   •   Determining whether the Department used fishing license revenue for the administration
       of fish and wildlife program activities


                                                                                                       9
    •    Determining whether the State passed required legislation assenting to the provisions of
         the Pittman-Robertson Wildlife Restoration Act and the Dingell-Johnson Sport Fish
         Restoration Act

    •    Evaluating State policies and procedures for assessing risk and monitoring subawards

    •    Visiting sites throughout the State (see Appendix 2 for a list of sites visited)

We found deficiencies in internal controls resulting in our three findings of ineligible other direct
cost charges, excess reimbursement, and inadequate oversight of subrecipients.

Based on the results of our initial assessments, we assigned a level of risk and selected a
judgmental sample of transactions for testing. We used auditor judgement and considered risk
levels relative to other audit work performed to determine the degree of testing performed in
each area. Our sample selections were not generated using statistical sampling, and therefore we
did not project the results of our tests to the total population of transactions.

This audit supplements, but does not replace, the audits required by the Single Audit Act
Amendments of 1996. Single audit reports address controls over Statewide financial reporting,
with emphasis on major programs. Our report focuses on the administration of the Alabama fish
and wildlife agency, and that agency’s management of WSFR resources and license revenue.

Alabama provided computer-generated data from its official accounting system and from
informal management information and reporting systems. We tested the data by sampling
expenditures and verifying them against WSFR reports and source documents, such as purchase
orders, invoices, and payroll documentation. Our testing was limited to the data sampled;
therefore, we did not assess the reliability of the accounting system.

Prior Audit Coverage
OIG Audit Reports

We reviewed our last two audits of costs claimed by the Department on WSFR grants, 3 from
2010 and 2015. We followed up on four recommendations from these reports and found that the
U.S. Department of the Interior’s Office of Policy, Management and Budget considered all
recommendations resolved and implemented.




3U.S. Fish and Wildlife Service Sport Fish Restoration Program Grants Awarded to the State of Alabama, Department of
Conservation and Natural Resources, Marine Resources Division, From October 1, 2007, Through September 30, 2009 (R-GR-
FWS-0010-2010), dated August 2010.
U.S. Fish and Wildlife Service Sport Fish Restoration Program Grants Awarded to the State of Alabama, Department of
Conservation and Natural Resources, Marine Resources Division, From October 1, 2012, Through September 30, 2014 (2015-
EXT-042), dated January 2016.


                                                                                                                    10
State Audit Reports

We reviewed the single audit reports for SFYs 2017 and 2018 to identify control deficiencies or
other reportable conditions that affect WSFR. In those reports, the Schedule of Expenditures of
Federal Awards indicated $12.1 million (combined) in Federal expenditures related to WSFR,
but did not include any findings directly related to WSFR, which was not deemed a major
program for Statewide audit purposes. Neither of these reports contained any findings that would
directly affect the program grants.




                                                                                             11
Appendix 2: Sites Visited
     Headquarters                Montgomery

                                 Dauphin Island
     Fisheries Offices
                                 Gulf Shores

     Fish Hatcheries             Claude Peteet Mariculture Center

                                 Bay Watch Boat Ramp
                                 Billygoat Hole Ramp
                                 Boggy Point Boat Ramp
                                 Cotton Bayou
     Boating Access Facilities   Delta Port Marina
                                 Ft. Morgan Boat Ramp
                                 Little Billygoat Hole Ramp
                                 The Pines Boat Launch
                                 View Point Launch

     Subrecipients               Auburn University




                                                                    12
Appendix 3: Monetary Impact
The audit period included claims totaling $5.1 million on 23 grants that were open during the
State fiscal years that ended September 30, 2017, and September 30, 2018. We questioned
$3,112 ($2,334 Federal share) of other direct costs as ineligible. We found that the Alabama
Department of Conservation and Natural Resources, Marine Resources Division, did not report
program income earned on a grant during the audit period, resulting in an excess reimbursement
of $5,164 ($3,873 Federal share). We questioned costs totaling $8,276 ($6,207 Federal share) as
ineligible, and found no controls in place to ensure program income was captured and reported
properly.

                 Monetary Impact: Federal Share of Questioned Costs

                                                                               Ineligible
                                                                              Questioned
    Grant No.         Grant Title                       Cost Category          Costs ($)

                      Coastal Alabama Outreach          Other Direct
    F16AF01319                                                                       1,458
                      and Education                     Costs


                      Coastal Alabama Outreach          Other Direct
    F17AF01289                                                                         876
                      and Education                     Costs


                      Enhancement of Recreational
    F15AF01359                                          Drawdown                     3,873
                      Fishing in Coastal Alabama

    Total                                                                          $6,207

    Source: Alabama Department of Conservation and Natural Resources, Marine Resources
    Division.




                                                                                             13
Appendix 4: Responses to Draft Report
The Alabama Department of Conservation and Natural Resources, Marine Resources Division’s,
response to our draft report, which includes the FWS’ response, follows on page 15.




                                                                                        14
                   United States Department of the Interior
                                FISH AND WILDLIFE SERVICE
                                          1875 Century Blvd
                                        Atlanta, Georgia 30345
                                            June 11, 2020

IN REPLY REFER TO:
FWS/R2/R4/WSFR




Nicki Miller, Regional Manager, Eastern Region
U.S. Department of the Interior
Office of Inspector General
381 Elden Street, Suite 3000
Herndon, VA 20170

Re:           Draft Audit Report – U.S. Fish and Wildlife Service Grants Awarded to the State of
              Alabama, Department of Conservation and Natural Resources, Marine Resources
              Division, From October 1, 2016, Through September 30, 2018 Under the Wildlife
              and Sport Fish Restoration Program. Report No. 2019-ER-053, Issued 04/27/2020


Dear Ms. Miller:

The enclosed response to the draft audit report referenced above was developed by the State of
Alabama Department of Conservation and Natural Resources, Marine Resources Division, in
cooperation with the U.S. Fish and Wildlife Service South Atlantic - Gulf and Mississippi Basin
Unified Regions Wildlife and Sport Fish Restoration Program.

If you have any questions or need additional information, please contact Alex Coley at
(404) 679-7242.

                                                     Sincerely,

                                                      MARILYN            Digitally signed by
                                                                         MARILYN LAWAL

                                                      LAWAL              Date: 2020.06.11
                                                                         15:48:06 -04'00'
                                                     Marilyn H. Lawal-Carter, Acting Manager
                                                     Wildlife and Sport Fish Restoration


Enclosure

Cc:    Ord Bargerstock, Shuwen Cheung
       Division of Financial Assistance Support and Oversight




                                                                                               15
                                   Response to Draft Report

                        U.S. FISH AND WILDLIFE SERVICE
            WILDLIFE AND SPORT FISH RESTORATION PROGRAM
    Grants Awarded to the State of Alabama Department of Conservation and Natural
                        Resources, Marine Resources Division
                 From October 1, 2016, Through September 30, 2018
                    Report No. 2019-ER-053, Issued April 27, 2020


Auditor Recommendation 1

The auditors recommend that the FWS resolve the questioned costs related to other direct costs
totaling $3,112 ($2,334 Federal share).

Agency Response

The Alabama Department of Conservation and Natural Resources agrees with the finding and
will recharge the unallowable expenses to state funds reducing grant expenditures by $1,944
($1,458 Federal Share) related to F16AF01319. We will offset a current draw to return the
federal funds. The unallowable costs related to F17AF01289 $1,168 ($876 Federal share) will be
replaced with expenditures which were overmatch on the grant. State overmatch was $7,605.
This will result in no payback for this item of unallowable expense.

Contact Person:              , Division Accountant
Anticipated Completion Date: 7/31/2020

Service Response

The Service concurs with the auditor’s finding.


Auditor Recommendation 2

The auditors recommend that the FWS require the Department to develop written policies and
procedures to ensure grant costs claimed are eligible, allowable, and reasonable charges to
WSFR.

Agency Response

The Alabama Department of Conservation and Natural Resources disagrees with the assertion
that it did not have written policies and procedures to ensure grant costs claimed are eligible,
allowable, and reasonable charges to WSFR. We had policies that we developed in December
2017 and further revised in August 2019. We will ensure that all staff are made aware of these
policies and are instructed to follow them.




                                                                                                   16
Contact Person:               , Accounting Director
Anticipated Completion Date: 7/31/2020

Service Response

The Service concurs with the auditor’s finding.


Auditor Recommendation 3

The auditors recommend that the FWS require the Department to implement controls that ensure
program income is properly accounted for and reported.

Agency Response

The Alabama Department of Conservation and Natural Resources agrees with the finding and
has subsequently implemented the requirement that the Marine Resources Division accountant
review and approve the Federal financial reports prior to submission on all Federal grants for that
Division.

Contact Person:               , Accounting Director
Anticipated Completion Date: 7/31/2020

Service Response

The Service concurs with the auditor’s finding.


Auditor Recommendation 4

The auditors recommend that the FWS resolve the questioned costs related to the excess
reimbursement totaling $5,164 ($3,873 Federal share).

Agency Response

The Alabama Department of Conservation and Natural Resources agrees with the finding and
will recharge the unallowable expenses to state funds reducing grant expenditures by $5,164
($3,873 Federal share). We will offset a current draw to return the federal funds.

Contact Person:              , Division Accountant
Anticipated Completion Date: 7/31/2020

Service Response

The Service concurs with the auditor’s finding.




                                                                                                17
Auditor Recommendation 5

The auditors recommend that the FWS require the Department to report all prior subawards of
more than $25,000 and implement controls to ensure compliance with Federal regulations in the
future.

Agency Response

The Alabama Department of Conservation and Natural Resources agrees with the finding and
implemented a plan in November 2018 to capture and report all subawards more than $25,000.
We retroactively reported all subawards back to 10/1/2017.

Contact Person:               , Accounting Director
Anticipated Completion Date: 7/31/2020

Service Response

The Service concurs with the auditor’s finding.




                                                                                             18
Appendix 5: Status of Recommendations
Recommendation   Status                           Action Required

2                Resolved and implemented         No action is required.

                                                  Complete a corrective action
                                                  plan that includes information
                                                  on actions taken or planned to
                                                  address the recommendations,
                 Resolved but not
                                                  target dates and titles of the
                 implemented:
                                                  officials responsible for
                                                  implementation, and
                 U.S. Fish and Wildlife Service
                                                  verification that FWS
                 (FWS) regional officials
                                                  headquarters officials reviewed
                 concurred with these
1, 3 – 5                                          and approved the actions the
                 recommendations and will
                                                  State has taken or planned.
                 work with staff from the
                 Alabama Department of
                                                  We will refer the
                 Conservation and Natural
                                                  recommendations not
                 Resources to develop and
                                                  implemented at the end of 90
                 implement a corrective
                                                  days (after October 28, 2020)
                 action plan.
                                                  to the Assistant Secretary for
                                                  Policy, Management and
                                                  Budget to track
                                                  implementation.




                                                                                19
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By Internet:       www.doioig.gov

By Phone:          24-Hour Toll Free:                800-424-5081
                   Washington Metro Area:            202-208-5300

By Fax:            703-487-5402

By Mail:           U.S. Department of the Interior
                   Office of Inspector General
                   Mail Stop 4428 MIB
                   1849 C Street, NW.
                   Washington, DC 20240