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The Service has developed an innovative approach to administering awards to eligible recipients of Wildlife and Sport Fish Restoration (“WSFR”), State Wildlife Grant (“SWG”) and Competitive State Wildlife Grant (“C-SWG”) funds (“States”) financial assistance program awards who have identified a common conservation need , eligible projects best served by combining their efforts and resources.
We use the term “Collaborative Conservation Initiative” (“CCI”) to refer to agreements between parties who work together to plan, fund, and/or implement projects and activities designed to conserve regionally significant habitats and populations of fish and wildlife on eligible projects, including those to conserve fish, wildlife, and their habitats across geopolitical boundaries. Funding for a CCI must include Federal awards to two or more States using WSFR, SWG or C-SWG funds. CCI activities must provide a conservation benefit to all participantsParticipating States, although it is possible work will not always occur within each stateParticipating State.
This operational guidance page will be updated as new information about CCI implementation becomes availablepage is designed to provide information and resources to best help understand the CCI innovative process.
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Authorities
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Frequently Asked Questions
Is the Q-1 Is the new CCI award process expected to be permanent?
The Service will implement a five-year pilot program to evaluate the new approach. The first three years will constitute the initial pilot phase. In the fourth year, we will begin an evaluation of effectiveness and compliance, which will include an OIG audit of both completed and ongoing CCI awards. By the end of the fifth year, a decision will be made on whether it is appropriate to continue awarding funds under the CCI framework, based on any audit findings and a comprehensive assessment of effectiveness.
Q-2 What is the window of opportunity for submitting CCI applications within the pilot and evaluation period?
CCI applications may be submitted at any point during the five-year pilot period. Award period of performance should reflect a reasonable duration to complete proposed objectives and may extend beyond the anticipated end of the pilot period if necessary.
Q-3 How does the new process address the concerns from the OMB Management Advisory and reduce audit risk to State grantees?
The primary compliance issue identified in the Management Advisory was individual States’ inability to demonstrate that their cost to participate was in proportion to the relative benefit they received as compared to other States, as required by 2 CFR 200.405.
Under the new administrative framework, the Service will evaluate cost and benefit for the overall CCI rather than for individual State awards. Actual costs incurred will be allocable to the CCI. A State may choose an amount to subaward based on availability of funds and on its own priorities without having to demonstrate relative benefit. This removes the audit risk inherent in the traditional process.
Q-4 What other regulatory requirements will be applied differently for CCIs than is typical for individual State grants?
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For example, “State A” may provide cost sharing that exceeds the minimum required for their individual award and “State B” may provide less, but at the CCI level, the full cost sharing requirement for Federal awards is met. This lowers a barrier for participation for States that have funds available to support a CCI but struggle to provide some or all of the required cost sharing.
Q-5 May existing regional or multi-state awards meet the cost allocation and cost sharing requirements in the same manner described in the responses to Q3 and Q4?
No. A new application must be submitted to receive prior written approval from the Service to proceed as a CCI and to meet the cost allocation and cost sharing requirements in the manner described.
Q-6 May funds already obligated to an award be used to contribute to a CCI project?
No. A new application must be submitted for approval to fund a CCI.
Q-7 Which program funds may be used to support a CCI?
The new approach to administering CCI awards will be implemented on a limited basis until after the five-year pilot and evaluation period. The pilot program only applies to the Wildlife Restoration, Sport Fish Restoration, State Wildlife Grant and Competitive State Wildlife Grant programs. The pilot program will not include discretionary subaccounts under SFR, i.e., Clean Vessel Act, Boating Infrastructure Grants, or National Coastal Wetlands Conservation Grants.
Q-8 Can a CCI be funded by both competitive and mandatory grant programs?
Yes. The State team may develop a competitive State Wildlife Grant application that includes apportioned Wildlife Restoration, Sport Fish Restoration, and / or State Wildlife Grant funds. The application must meet all content requirements for a CCI and must be submitted by the CCI Entity by the due date in the annual Competitive SWG Notice of Funding Opportunity. If selected for a competitive award, the CCI Entity must track costs by subaccount for both Federal funds and cost sharing.
Any CCI application that includes C-SWG funding must follow the competitive application process described in the C-SWG NOFO.
Q-9 What activities are eligible for funding under a CCI?
Any activity consistent with the authorizing legislation for each program may be funded for a CCI.
Q-10 Who initiates development of a CCI?
There is an expectation that CCIs will be State-driven. The CCI application process requires significant involvement from at least two Participating States. However, the process to develop any large-scale conservation initiative will be affected by the specific combination of participants, their priorities, and the defined purpose of the collaboration.
Q-11 May a single State apply for a CCI award?
No. Funding for a CCI must include awards to two or more States.
Q-12 Can a State act as a CCI Entity?
Yes, a State may be designated to act as the CCI Entity.
Q-13 When can a State join a CCI?
A State may only join a CCI prior to obligation of funds requested in the initial application. Any CCI with potential to implement substantially similar activities for multiple years is encouraged to seek one-year awards. This will allow changes to Participating States with each application.
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In addition, the allocation of costs between participants is set based on the initial application and is communicated to the CCI Entity in the Notice of Subaward. ASAP draws will be monitored for compliance with that approved allocation and will be part of future OIG audits of CCI awards. Each change to the allocation will increase the risk of non-compliance that could result in audit findings.
Q-14 Can awards be approved Subject to Availability of Funds?
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Amendments to a multi-year CCI will only be accepted once a year, including amendments to obligate additional funds. When funds are added, a new rate of participation will be calculated and provided in the Notice of Subaward. All costs incurred after the effective date of the amendment will be allocated based on the new rate of participation.
Q-15 Who is responsible for processing and approving CCI applications and monitoring award performance?
The Lead Region is responsible for managing CCI awards.
Q-16 What is the role of the HQ the HQ Point of Contact (HQ POC) for CCI awards?
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The HQ POC will serve as a central source of information on utilization of the new process. A wide range of stakeholders participated in the multiyear effort to identify a practical and legal approach to CCI award administration. Contributors included Office of Conservation Investment staff and senior management, the Director of the U.S. Fish and Wildlife Service, the DOI Office of Inspector General, the DOI Solicitor’s Office, and the DOI Office of Grants Management. It is essential that the Service be able to provide information necessary to evaluate the results and make adjustments as needed.
Q-17 What is the role of the HQ the HQ Compliance Branch Subject Matter Expert for CCI awards?
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This person will also check periodically to ensure that the CCI Entity is drawing funds from ASAP in the proportions specified in the Notice of Subaward. The new method of allocating costs between awards is a direct response to the Management Advisory and will be audited. This check is a control put in place to reduce risk for all participants.
Q-18 How will environmental compliance be completed for a CCI?
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When an activity is proposed that affects multiple Regions and may be impactful, the Lead Region or HQ POC will ask all affected Regions for input regarding compliance. The Regions will jointly determine if and how the project should proceed and may designate a Region to act as lead for necessary compliance processes as appropriate.
Q-19 If the Service obligates funds to the CCI Entity in GrantSolutions, does that violate the Wildlife and Sport Fish Restoration Acts and the annual appropriation for State Wildlife Grants by making the CCI Entity the recipient of the Federal award?
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States awarded funds for a CCI retain all the responsibilities of a pass-through entity detailed in 2 CFR 200.332, with the exception of the specific administrative tasks the Service will perform on behalf of all CCI award recipients for the sake of efficiency and improved oversight. The Service will conduct a risk assessment of the CCI Entity, obligate the State’s subawarded funds to the CCI Entity in GrantSolutions and issue Notices of Award and Subaward.
Q-20 How will the Service obligation of funds to the CCI Entity affect the process for reporting subawards to recipients to report their first-tier subawards in SAM.gov, as required under the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) at http://www.fsrs.govFFATA) of 2006 and 2 CFR 170?
The new process approach will require the Service to perform some manual processing by the Service steps before States will be able to report the information as required. Specific process their subawards. Process details are still being developed . The Service will share that information as soon as it is and will be shared when finalized.
Q-21 How must the CCI Entity draw funds from the multiple State subawards?
The CCI Entity must draw funds from each State subaward in the proportions specified in the Notice of Subaward. Costs will be allocated to each State award in proportion to its share of Federal funds awarded by subaccount for the CCI. If a post-award amendment changes the budget, the new proportions will be provided in the Notice of Subaward and costs incurred after the effective date of the amendment will be allocated based on the new rate of participation.
Q-22 How must the CCI Entity track cost sharing?
If all Participating States subaward funds from the same subaccount (e.g., 5222 - Sec 4 Wildlife Restoration), the CCI Entity must ensure sufficient cost sharing is provided at the CCI level for all Federal funds awarded. If funds are awarded from multiple subaccounts, the CCI Entity must cost account and track Federal funds and the required cost sharing by subaccount.
Will unspent Q-23 At the end of a CCI project, will unspent Federal funds that are deobligated at the end close of the period of performance pass through awards be required to “pass-through” the State’s safety margins?
Yes, if the unspent Federal funds are from any of the mandatory programs (i.e., Wildlife Restoration, Sport Fish Restoration, and Formula State Wildlife Grants). The only way those funds would not pass through the State’s safety margin would be if they were obligated and then deobligated in the same Federal fiscal year. In this scenario, funds are simply returned to the State’s apportionment account.
Unspent Federal funds from the Competitive State Wildlife Grant Program are returned to the Program.
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Learning Aids
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Federal Admin Process - This document summarizes the Federal administrative process for CCIs including Federal oversight responsibilities, grant management details, and increase of operational efficiency.
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Related Pages
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Resources
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CCI FAQ Document - Contains a series of Frequently Asked Questions related to the CCI process. This resource will be updated as new FAQs are answered.
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References
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