oversight

U.S. Fish and Wildlife Service Grants Awarded to the Commonwealth of Pennsylvania, Fish and Boat Commission, From July 1, 2016, Through June 30, 2018, Under the Wildlife and Sport Fish Restoration Program

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 OFTHE INTERIOR




  U.S. Fish and Wildlife Service Grants
  Awarded to the Commonwealth of
  Pennsylvania, Fish and Boat Commission,
  From July 1, 2016, Through June 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 $54,000.



Report No.: 2019-WR-006                                                         July 2020
Memorandum

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

From:          Michael P. Colombo
               Regional Manager, Western Region

Subject:       Final Audit Report – U.S. Fish and Wildlife Service Grants Awarded to the
               Commonwealth of Pennsylvania, Fish and Boat Commission, From July 1, 2016,
               Through June 30, 2018, Under the Wildlife and Sport Fish Restoration Program
               Report No. 2019-WR-006

        This final report presents the results of our audit of costs claimed by the Commonwealth
of Pennsylvania’s Fish and Boat Commission (Commission) under grants awarded by the
U.S. Fish and Wildlife Service (FWS). The FWS provided the grants to the Commonwealth
under the Wildlife and Sport Fish Restoration Program. The audit included claims totaling
approximately $36 million on 17 grants that were open during the State fiscal years that ended
June 30, 2017, and June 30, 2018 (see Appendix 1). The audit also covered the Commission’s
compliance with applicable laws, regulations, and FWS guidelines, including those related to
collecting and using fishing license revenues and reporting program income.

        We found that the Commission was unable to demonstrate that it had adequate support
for labor costs charged to Program grants because of its inability to reconcile these costs with the
Commonwealth’s accounting system and its use of estimated values for labor costs. We therefore
question the Federal share of unsupported labor costs and related indirect costs, totaling
$17,701,030.

        We provided a draft of the report to the FWS. The FWS concurred with our
recommendations and will work with the Commission to implement corrective actions. In this
report we summarize the Commission’s and the FWS’ responses to our recommendations, as
well as our comments on their responses. The full responses from the Commission and the FWS
are included in Appendix 3. We list the status of the recommendations in Appendix 4.

        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
the recommendations, as well as target dates and titles of the officials responsible for
implementation. Please send your response to aie_reports@doioig.gov.

        If you have any questions regarding this report, please contact me at 916-978-6199.




                      Office of Audits, Inspections, and Evaluations | Sacramento, CA
      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.


cc: Colleen E. Sculley, Chief, Division of Wildlife and Sport Fish Restoration, Region 1,
    U.S. Fish and Wildlife Service




                                                2
Table of Contents
Introduction ......................................................................................................................................1
       Background...............................................................................................................................1
       Objectives .................................................................................................................................1
       Scope ........................................................................................................................................1
       Methodology.............................................................................................................................2
       Prior Audit Coverage ................................................................................................................3
Results of Audit ...............................................................................................................................4
       Audit Summary ........................................................................................................................4
       Finding and Recommendations ................................................................................................4
Appendix 1 .......................................................................................................................................8
Appendix 2 .......................................................................................................................................9
Appendix 3 .....................................................................................................................................10
Appendix 4 .....................................................................................................................................15
Introduction
Background
The Pittman-Robertson Wildlife Restoration Act and the Dingell-Johnson Sport Fish Restoration
Act 1 established the Wildlife and Sport Fish Restoration Program. Under the Program, the
U.S. Fish and Wildlife Service (FWS) provides grants to States to restore, conserve, manage,
and enhance their wildlife and sport fish resources. The Acts and Federal regulations contain
provisions and principles on eligible costs and allow the FWS to reimburse States up to
75 percent of the eligible costs incurred under the grants. The Acts also require that hunting and
fishing license revenues be used only for the administration of State fish and game agencies.
Finally, Federal regulations and FWS guidance require States to account for any income they
earn using grant funds.

Objectives
In June 2016, we entered into an intra-agency agreement with the 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 Commonwealth of Pennsylvania’s Fish and
Boat Commission (Commission):

       •    Claimed the costs incurred under the Program grants in accordance with the Acts and
            related regulations, FWS guidelines, and grant agreements

       •    Used Commonwealth hunting and fishing license revenues solely for fish and wildlife
            program activities

       •    Reported and used program income in accordance with Federal regulations

Scope
Audit work included claims totaling approximately $36 million on the 17 grants open during the
State fiscal years (SFYs) that ended June 30, 2017, and June 30, 2018 (see Appendix 1). We
report only on those conditions that existed during this audit period. We performed our audit at
the Commission’s headquarters office in Harrisburg, PA, and visited two regional offices, six
fish hatcheries, and five boating access sites (see Appendix 2).

We performed this audit to supplement—not replace—the audits required by the Single Audit
Act.



1   16 U.S.C. §§ 669 and 777, as amended, respectively.


                                                                                                  1
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.

Our tests and procedures included:

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

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

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

   •   Conducting site visits to inspect equipment and other property

   •   Determining whether the Commission used fishing license revenues solely for the
       administration of fish and wildlife program activities

   •   Determining whether the Commonwealth passed required legislation assenting to the
       provisions of the Acts

We also identified the internal controls over transactions recorded in the labor and license-fee
accounting systems and tested their operation and reliability. Based on the results of initial
assessments, we assigned a level of risk to these systems and selected a judgmental sample of
transactions for testing. We did not project the results of the tests to the total population of
recorded transactions or evaluate the economy, efficiency, or effectiveness of the Commission’s
operations.

We relied on computer-generated data for other direct costs and personnel costs to the extent that
we used these data to select Program costs for testing. Based on our test results, we either
accepted the data or performed additional testing. For other direct costs, we took samples of
costs and verified them against source documents such as purchase orders, invoices, receiving
reports, and payment documentation. For personnel costs, we selected Commission employees
who charged time to Program grants and verified their hours against timesheets and other
supporting data.




                                                                                                   2
Prior Audit Coverage
On July 24, 2015, we issued U.S. Fish and Wildlife Service Wildlife and Sport Fish Restoration
Program Grants Awarded to the Commonwealth of Pennsylvania, Fish and Boat Commission,
From July 1, 2011, Through June 30, 2013 (Report No. R-GR-FWS-0005-2014).

We followed up on the recommendation in the report (related to license certification) and found
that it was resolved and implemented prior to issuance of the final report.

We also reviewed the Commonwealth’s single audit reports for SFYs 2016 and 2017. Neither
report contained any findings directly affecting the Program grants.




                                                                                                  3
Results of Audit
Audit Summary
We found that the Commission was unable to demonstrate adequate support for labor costs
charged to Program grants because of its inability to reconcile these costs with the
Commonwealth’s accounting system and its use of estimated values for labor costs. We question
a total of $17,701,030, the Federal share of unsupported labor costs and related indirect costs.

Finding and Recommendations
Inadequate Financial Management—Questioned Costs of $17,701,030

The Commission uses two systems to account for grant expenditures: System Analysis and
Program Development (SAP) and Microsoft Excel. SAP, the Commonwealth’s official
accounting system, accounts for all nonlabor direct costs and can provide reports of actual
expenditures coded to grants. The Commission does not use the SAP system to account for labor
expenditures charged to grants. Instead, the Commission uses a separate grants accounting
process reliant upon Microsoft Excel to track labor hours recorded on employee timesheets.
These labor hours are valued according to a composite labor rate computed by the Commission.
This process produces an estimated value of the labor costs associated with grants rather than
actual labor expenditures. The two systems do not interface, and the labor costs recorded in the
Excel workbooks are not reconciled with the Commonwealth’s official accounting system
(SAP). In addition, the Excel records are not audited or evaluated as part of the Commonwealth’s
single audit.

Further, the records of labor hours are manually input into the Excel system by one employee,
and this employee’s work is only spot-checked for accuracy. Thus, there are not adequate
internal controls in place to ensure that the hours and related costs recorded are accurate.

Because of the Commission’s use of an unreconciled and unofficial system to support its grant
labor expenditures, we classified all labor costs ($22,618,822) and related indirect costs
($3,491,192) claimed by the Commission for grants open during our audit period as unsupported.
These costs total $26,110,014, with a Federal share of $17,701,030, as summarized in Figure 1
below.




                                                                                                4
                Figure 1. Federal Share of Unsupported Labor Costs and
                            Related Indirect Costs, by Grant

               Unsupported       Unsupported        Questioned       Questioned              Total
                     Labor           Indirect            Labor         Indirect        Questioned
Grant No.         Costs ($)         Costs ($)        Costs ($)        Costs ($)         Costs ($)

F16AF00090            417,331             69,778         267,029            46,375          313,404
F16AF00091          3,923,567           656,162        2,942,675           492,121        3,434,796
F16AF00101          1,022,559           170,715          758,637           126,957          885,594
F16AF00105          1,147,197           191,789          860,398           143,842        1,004,240
F16FA00625            201,078             33,439         150,808            25,079          175,887
F16AF00768              15,875             2,640           11,907            1,980           13,887
F17AF00084          1,490,106           229,863        1,117,580           172,038        1,289,618
F17AF00085          4,235,287           654,740        2,837,340           446,723        3,284,063
F17AF00086          1,153,735           177,711          806,578           125,896          932,474
F17AF00087            560,643             86,575         256,595            44,899          301,494
F17AF00731            270,864             38,842         192,785            27,734          220,519
F17AF00903              55,951             8,023           41,964            6,018           47,982
F18AF00116          1,330,028           191,745          997,521           143,272        1,140,793
F18AF00122            721,991           104,076          255,417            44,337          299,754
F18AF00123          1,268,189           182,744          756,036           115,340          871,376
F18AF00159          4,804,422           692,350        3,036,621           448,528        3,485,149

Total           $22,618,822         $3,491,192     $15,289,891        $2,411,139      $17,701,030


Federal regulations (2 C.F.R. § 200.302(a)) require that a State’s financial management system
be sufficient to permit the tracing of funds to a level of expenditures adequate to establish that
such funds have been used according to Federal statutes, regulations, and the terms and
conditions of the Federal award. The Commission’s Excel-based financial management process
does not permit such tracing because the labor costs claimed do not represent actual
expenditures, but rather are estimated values based on a composite labor rate.

Further, Federal regulations (2 C.F.R. § 200.302(b)(1)) require that the financial management
system of each grant recipient provide for identification, in its accounts, of all Federal awards
received and expended.

In addition, Federal regulations (2 C.F.R. § 200.430(i)) require that records of charges to Federal
awards for salaries and wages be supported by a system of internal controls that provides
reasonable assurance that the charges are accurate, allowable, and properly allocated, and that
they are incorporated in the State’s official records.




                                                                                                     5
Commission officials told us this labor accounting process has been in place in some form for
decades. It is based on a legacy system of handwritten ledgers that was later adapted to Excel.
Officials also told us that they are highly confident the records they rely on are accurate. Without
sufficient internal controls or efforts to reconcile labor costs, however, the continued use of this
process as-is prevents the Commission from complying with Federal grant regulations.

Because of its inability to reconcile its grant claims with actual labor costs recorded in its
accounting system, the Commission cannot provide assurance that grant claims for labor costs
are accurate, allowable, and properly allocated.

 Recommendations


 We recommend that the FWS:

     1. Resolve questioned costs of $17,701,030

     2. Require the Commission to implement a financial management system with
        sufficient internal controls to provide for a reconciliation of all grant claims to
        actual expenditures recorded in the Commonwealth’s System Analysis and
        Program Development (SAP) accounting system



Commission Response
The Commission did not concur with our finding, stating that it does not offer an accurate
representation of the Commission’s accounting for and internal controls over Federal grant
reporting. Specifically, the Commission believes that it maintained sufficient and appropriate
evidence to support the audit’s questioned costs and that its financial management system for
labor costs charged to grants complies with Federal grant management and internal control
requirements. The Commission, however, is committed to working with the FWS to resolve the
questioned costs and explore options to improve its financial management system. See
Appendix 3 for the Commission’s full response.

FWS Response
The FWS concurred with our finding and recommendations and will work with the Commission
to resolve the questioned costs and develop a corrective action plan. See Appendix 3 for the
FWS’ full response.

OIG Comment
We disagree with the Commission’s contention that it was able to support the allocation of labor
costs among specific Federal awards in sufficient detail to fulfill Federal requirements. In
addition, the Commission was unable to demonstrate that it deployed sufficient control activities
through established policies and procedures to permit corroboration of management’s assertions




                                                                                                   6
over internal controls. Further, we gave the Commission ample opportunity to thoroughly
explain its grant reporting process.

To provide support for questioned costs, the Commission has agreed to crosswalk information
from the SAP system to its grant accounting subledgers. Specifically, the Commission will
recalculate a compensation and fringe rate for each employee, based on the costs for each pay
period, and apply that rate against the actual hours recorded on the grants for all reporting
periods in question. The Commission’s target date for resolving all questioned costs is
December 31, 2020.

In addition, to improve its financial management system, the Commission will explore methods
for identifying grant-related personnel expenses in SAP to provide a clearer link to these costs in
its subledgers. The Commission will provide these data to the FWS to demonstrate that grant
claims can be reconciled to actual expenditures. The Commission proposes to have an enhanced
financial management system in place no later than December 31, 2024.

Based on the Commission’s and the FWS’ responses, we consider Recommendations 1 and 2
resolved but not implemented (see Appendix 4).




                                                                                                  7
Appendix 1
                  Commonwealth of Pennsylvania
                     Fish and Boat Commission
               Grants Open During the Audit Period
                July 1, 2016, Through June 30, 2018

                     Grant               Claimed       Questioned
  Grant No.      Amount ($)             Costs ($)       Costs ($)

  F10AF00430        4,706,400           4,684,889               0
  F16AF00090          538,864             608,102         313,404
  F16AF00091        5,411,641           5,388,094       3,434,796
  F16AF00101        1,470,000           1,481,059         885,594
  F16AF00105        2,400,000           1,670,624       1,004,240
  F16FA00625          308,032             269,082         175,887
  F16AF00768          730,500              21,334          13,887
  F17AF00084        2,448,000           2,119,869       1,289,618
  F17AF00085        5,152,030           5,663,306       3,284,063
  F17AF00086        1,502,340           1,590,486         932,474
  F17AF00087          549,642             794,868         301,494
  F17AF00731          311,112             326,793         220,519
  F17AF00903        1,912,000             131,238          47,982
  F18AF00116        2,496,960           1,959,224       1,140,793
  F18AF00122          560,635             987,030         299,754
  F18AF00123        1,535,391           1,824,488         871,376
  F18AF00159        5,389,289           6,239,195       3,485,149

  Totals        $37,422,836          $35,759,681      $17,701,030




                                                                    8
Appendix 2
             Commonwealth of Pennsylvania
               Fish and Boat Commission
                      Sites Visited

                    Headquarters
                    Harrisburg, PA

                   Regional Offices
                    Central Region
                   Northwest Region

                    Fish Hatcheries
                     Benner Spring
                        Fairview
                       Huntsdale
                       Linesville
                     Reynoldsdale
                       Union City

                    Boating Access
                      Elk Creek
                      Kyle Lake
                    Lake LeBoeuf
                    Tamarack Lake
                     Walnut Creek




                                            9
Appendix 3
                              Commonwealth of Pennsylvania
                                Fish and Boat Commission
                                Responses to Draft Report

The Commonwealth of Pennsylvania’s Fish and Boat Commission’s response to our draft report
follows on page 11. The U.S. Fish and Wildlife Service’s response to our draft report follows
on page 14.




                                                                                           10
                      Pennsylvania Fish & Boat Commission
                                                                       OFFICE OF ADMINISTRATION
                                                                       P.O. Box 67000
                                                                       H ARRlSBURG, PA 17106-7000

   established 1866
                                                                       1111111111111  FAX: (717) 705-7802
                                                                                @P.\ .GO\'




                                            March 11, 2020



                    , Grants Fiscal Officer
Wildlife and Sport Fish Restoration Program
U.S. Fish and Wildlife Service
300 Westgate Center Drive
Hadley, MA 01035



        The Pennsylvania Fish & Boat Commission (Commission) has reviewed the Draft Audit
Report-US. Fish and Wildlife Service Wildlife and Sport Fish Restoration Program Grants
Awarded to the Commonwealth of Pennsylvania, Fish and Boat Commission, From July 1, 2016,
Through June 3 0, 2018 Report and appreciates the opportunity to provide comments. Since
Generally Accepted Government Auditing Standards state that the purpose of providing a draft
report with findings for review and comment by the audited entity is to help the auditors develop a
report that is fair, complete, and objective, these written comments will primarily serve to
demonstrate why the Commission firmly believes this audit finding does not offer an accurate
representation of its accounting for and internal controls over Federal grant reporting.

         In accordance with 2 C.F.R. §200.302(a), the Commission is required to use the
Commonwealth's SAP system to record all revenues and expenditures - including total
compensation and fringe benefit costs; and therefore, these costs are not only incorporated into the
official records of the State, but also comply with the State's established accounting policies and
practices. Additionally, the Commission is able to produce reports indicating that it maintains
accurate records for the identification of all federal awards in sufficient detail to fulfill the
requirements of2 C.F.R. §200.302(b)(l ). However, in an effort to properly support the distribution
of an employee' s salary or wages among specific Federal activities, the Commission allocates the
compensation costs from SAP in a separate sub-ledger (i.e. Excel). Notably, all the information
used to prepare the grant requests is derived from the SAP system, and the costs are traceable from
the (1) Grant Funding request to the (2) Sub-ledger, and back to the (3) Time and Activity reports;
and all of this information can be traced to the SAP system through SAP payroll reports.

         According to 2 C.F.R. §200.430(i)(iv) these records must "encompass both federally
 assisted and all other activities compensated by the non-Federal entity on an integrated basis,
 but may include the use of subsidiary records as defined in the non-Federal entity's written

Our Mission:                                                                                 www.fishandboat.com
To protect, conserve and enhance the Commonwealths aquatic resources and provide fishing and boating opportunities.
                                                                                                        11
Ms.­
March 11 , 2020
Page 2



policy. " Thus, the Commission affim1s that this audit conclusion does not appear to be
substantiated, and arguably conflicts with the applicable statutes. To comply with Uniform
Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, the
Commission has made a concerted effort to ensure that its allocated costs are reasonable,
consistent, and that they conform to established written policies. Additionally, charges to federal
awards for salaries and wages must be based on records that accurately reflect the work
performed. Therefore, to be in compliance with time and effort requirements, employees of the
Commission submit bi-weekly Time and Activity Reports, which are duly authorized, reviewed
and approved, and clearly detail the exact number of hours worked on all grant and non-grant
activity. Since most employees work on more than one federally funded grant or project, all
hours are supported by these detailed personal activity reports and they serve as the basis for
allocating all direct compensation and fringe benefit costs. The Commission takes great
measures to ensure that the hours on the Time and Activity Reports are properly recorded, as
evidenced by its strong system of internal controls. An internal audit process is performed after
the reports are reviewed and approved by an employee's supervisor, and importantly, prior to
any drawdown or funding requests being charged against a grant.

         Time and Activity Reports for each pay period are submitted from the various field
offices every two weeks. These reports summarize hours worked on applicable projects,
including any federally funded grant project. Once approved by the responsible supervisor or
manager, the data is recorded in the Commonwealth's accounting system (SAP) by timekeepers
for each bi-weekly payroll. Copies of these Time and Activity Reports are then forwarded to the
Federal Aid Section for subsequent review by the Grant Accounting Specialist. This internal
audit function is designed to offer objective assurance that the employees' time and activity is
properly recorded. Once the Grant Accounting Specialist is satisfied that the time recorded is
eligible to be charged to each project, she posts the hours, by employee, to the appropriate
project accounting file in a subsidiary ledger. Care is also taken to ensure that the postings are
applicable to the respective grant period and that all records are properly retained. Once all the
information is summarized by project, the Federal Program Manager reviews all charges and
then prepares scheduled, semi-annual or periodic Grant Funding request. As a result, the
Commission maintains that its control activities contribute to the mitigation of risk (especially as
it pertains to federal grant requests). The Commission also believes that it deploys control
activities through established policies which put the procedures into action. Considering the
auditors should be able to corroborate management's assertions over its internal controls, the
audit report should be modified accordingly.

        The Commission does acknowledge that a composite rate has been used to systematically
and rationally allocate allowable fringe benefit costs. Nonetheless, 2 C.F.R. §200.43l(d) states
the following: "Fringe benefits may be assigned to cost objectives ... by allocating on the basis of
entity wide salaries and wages ofthe employees receiving the benefits, " and the Commission is
able to demonstrate that these costs in relationship to the salaries and wages do not differ
significantly for different groups of its employees. The Commission further recognizes that the
fringe benefit component of the composite rate calculation was based upon the prior year's actual
costs, though it adamantly refutes the audit report's claim that the composite rate is a mere
estimate. Unfortunately, this undermines the reality that the use of prior year's cost is predicated
on the expectation that benefit costs are likely to increase the following year, thus creating a

                                                                                                  12
March 11, 2020
Page 3



conservative approach for the Commission to charge Federal grants. And, despite the fact that
Uniform Guidance was intended to ease the administrative burden on Federal award recipients,
the Commission believes that it has consistently applied the general meaning of the law. But be
that as it may, the Commission agrees, in an effort to support total questioned costs, it will take
whatsoever steps that are necessary to substantiate the direct costs (and the indirect costs).

        Notwithstanding our disagreement with the audit findings, to the satisfaction of the U.S.
Fish and Wildlife Service, the Commission fully intends to resolve the questioned costs and, in
an attempt to reduce the chance of receiving any future audit findings , will also explore all
available options to more fully utilize the Commonwealth's SAP accounting system. The
Commission believes that it maintained sufficient and appropriate evidence to support the
$17,701 ,030 in questioned costs and emphasizes its position that if the Commission had been
afforded the opportunity to adequately explain its grant reporting processes thoroughly, the
auditors likely would have disabused themselves of at least some of their notions. As such, the
Commission will crosswalk information from the SAP system to its grant accounting sub­
ledgers. This will be accomplished by re-calculating a compensation and fringe rate for each
employee, based on the costs for each pay period, and applying that factor against the actual
hours previously recorded on the grants for all grant reporting periods in question. The
Commission is unequivocally confident that the results will confirm and prove that its charges to
the Wildlife and Sport Fish Restoration Program grants were fully supported.

                         Federal Program Manager for the Commission, will conduct a full
review of the grants identified in the audit finding. Given the number of grants to be examined
and the volume of personnel charging to each grant, the process will be lengthy; however, the
Commission's target date for resolving all questioned costs is December 31 , 2020.

        -           will also be the team lead to improve the Commission's financial
management system. Methods for identifying grant-related personnel expenses in SAP will be
explored to provide a clearer link to these costs in Commission sub-ledgers. Upon
implementation of suitable improvements, grant costs will be accrued for a minimum of 12
months; this data will be provided to WSFR to demonstrate grant claims can be reconciled to
actual expenditures. To ensure sufficient testing of available SAP options, allow adequate time
to capture costs using improved methods, and review of the dataset by WSFR staff, the
Commission proposes to have an enhanced financial management system in place by no later
than December 31, 2024.

       Thank you for the opportunity to provide comment on the draft audit report. We
respectfully request that our response be published in its entirety in the Office of Inspector
General's final audit report.

                                                      Sinc~ely,


                                               ~'=J!zl(__J(_.R_~>---
                                                      Brian P. Barner
                                                      Deputy Executive Director
                                                                                                      13
                                                                                                U.S.
                                                                                          PJSHst~LIFH

               United States Department of the Interior
                               FISH AND WILDLIFE SERVICE                                                         -
                                                                                            ~~·o.,-r,,t',
                                                                                                            ,'
                                     300 Westgate Center Drive
                                      Hadley, MA 01035-9589



                                                                            March 18, 2020

In Reply Refer To:
FWS/Region 5/WSFR

Michael P. Colombo, Regional Manager, Western Region
Office of Inspector General

2800 Cottage Way, Suite
                         -
U.S. Department of the Interior

Sacramento, California 95825


Dear Mr. Colombo:

Attached is the Commonwealth of Pennsylvania’s Fish and Boat Commission’s (Commission),
response to the Office of Inspector General’s Draft Audit Report No. 2019-WR-006. The Service
has confirmed with the State these are the only comments they have on this Draft Report.

The Service concurs with the auditors recommendations and has reviewed and accepted the
State’s response. The Service fully anticipates that the Commission will be able to demonstrate
adequate support to resolve the all of the questioned costs ($17,701.030) related to labor and
indirect charges.

The Service will work closely with the Commission staff in developing and implementing a
corrective action plan that will resolve all of the findings and recommendations.

Details on each recommendation:

       The Service is working with the Commission to demonstrate adequate support for labor
       costs charged to Program grants by reviewing labor hours and actual labor expenditures
       to verify that labor costs and related indirect costs are accurate, allowable and properly
       allocated to resolve the question costs. The official responsible for implementing these
       actions is Charlene Seifert, Federal Program Manager for the Commission. Target date
       for implementation is December 31, 2020.

       The Commission is exploring ways to improve their financial management system. This
       includes exploring methods to identify grant-related personnel expenses in the
       Commonwealth’s System Analysis and Program Development (SAP) accounting system
       in order to reconcile this information with Commission sub-ledgers.


                                                                                                       14
      Upon implementation of improvements the Commission will demonstrate to the Service
      that they can reconcile grant claims to actual expenditures recorded in the SAP. The
      official responsible for leading the team to improve the Commissions financial
      management system is Charlene Seifert. Target date for implementation is December 31,
      2024.

      We note that the Commission, in their response to the draft audit report, requested that
      their full response be included in the final audit report. We respectfully ask that this
      request be met.


                                            Sincerely,




                                              Colleen E. Sculley
                                                Chief, Division of Wildlife
                                                    and Sport Fish Restoration


Attachment




                                                                                                 15
Appendix 4
                       Commonwealth of Pennsylvania
                          Fish and Boat Commission
                      Status of Audit Recommendations

Recommendations   Status                         Action Required

                                                 Complete a corrective action plan that
                  We consider the                includes information on actions taken
                  recommendations resolved       or planned to address the
                  but not implemented.           recommendations, target dates and
                                                 titles of the officials responsible for
                  U.S. Fish and Wildlife         implementation, and verification that
                  Service (FWS) regional         FWS headquarters officials reviewed
                  officials concurred with the   and approved of the actions taken or
1–2
                  recommendations and will       planned by the State.
                  work with the
                  Pennsylvania Fish and          We will refer the recommendations
                  Boat Commission to             not implemented at the end of
                  develop and implement a        90 days (after October 28, 2020) to
                  corrective action plan for     the Assistant Secretary for Policy,
                  these recommendations.         Management and Budget to track
                                                 implementation.




                                                                                       16
          Report Fraud, Waste,
          and Mismanagement
              Fraud, waste, and mismanagement in
             Government concern everyone: Office
            of Inspector General staff, departmental
             employees, and the general public. We
                actively solicit allegations of any
            inefficient and wasteful practices, fraud,
                 and mismanagement related to
             departmental or Insular Area programs
                 and operations. You can report
                allegations to us in several ways.


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