5 - Comp Planning, Coordination, and Audits - Wednesday, August 26

1. Comprehensive management system grants: Fully address comprehensive management systems and incorporate the remaining features from Service Manual chapter 522 FW 4. (80)

From the 2000 FA Audit Resolution Task Force:

'The (audit committee) and FWS advised the task force about the criteria that must be met for the grantee to be approved for the CMS program, which is a multiyear funding program option.  The major benefit of the CMS program to the grantee is the ability to reduce administrative and reporting burdens, along with associated costs.  Thus far, only 5 of 50 States have elected and received approval for the CMS program.  

Aside from the reduced administrative and reporting burdens associated with the CMS program, the statutory and regulatory requirements to schedule, budget, receive approval for, and to account and accumulate annual costs on a project-level basis still apply.  Moreover, FWS does not have the authority to waive these project-level requirements.'  

     2.  Coordination grants: Address issue of contact and location information for all coordinators in a coordination grant. (80)

      3.  Multiyear funding: Consider modifying 50 CFR 80.67 to state that multiyear funding may be used for any allowable, eligible, and substantial project, whether grant-by-grant or CMS.

This was a suggestion from a comment for WSFR to further articulate the requirements for multiyear funding.  Would it add value?

      4.  Proposed questions on audits:  The WSFR Branch of Audits recommends the following new regulatory sections:  (1) Will recipients participating in the Wildlife and Sport Fish Restoration Programs be audited? (2) What programs will be audited? (3) What will be examined during an audit? (4) Who will choose the auditors and fund the audits? (50)

Shuwen from the Audits Branch will be with us to discuss this section and the associated questions.

      5.  Monitoring: Incorporate monitoring procedures into the regulations, including site visits. See recommendations 1 and 3 in the 2013 CIAP audit on pp. 6 and 42. (75)

The OIG suggested that (3) FWS conduct and document regular site visits to ensure compliance with grant objectives, and that (1) FWS (should) design and implement monitoring procedures to ensure that (recipients) submit timely financial and performance reports.  

      6.  Government revenue: Review the issue of the status of monthly service fees for new sewer lines to homes that were installed with Federal financial assistance. See the June 2013 Inspector General’s audit of the Coastal Impact Assessment program, page 39.  The Inspector General considered these fees to be program income instead of governmental revenue and the FWS concurred with the its finding. Develop regulatory language to clarify 2 CFR 200.307(c). (75)

From the CIAP Audit, Page 39:

'In one instance, (auditors) found that the (recipient) was awarded a grant to install 260 new sewer lines in homes around the county.  These sewer lines replaced the existing septic tanks, some of which were leaching was into Gulf waters.  Homeowners were required to pay a $32 monthly service fee after these new lines were connected.  As a result, from October 2010 through January 2012, the (recipient) earned $43,232 in service fees for 206 active sewers.  

The grant periods for each of the two grants remains open and, therefore, the amount of program income earned will continue to increase.  In addition, both (recipients) plan to install sewer lines that could also earn substantial program income. 

Revenue earned from these programs was not reported appropriately because the (recipient) officials believed the fees earned were for operations and maintenance, not program income. Operations and maintenance, however, if authorized by Federal regulations or the grant agreement, is a deduction from program income, not in lieu of program income.'

So, when a fee is levied for a grant-funded public benefit, those charges must be substantiated or itemized, and not as a lump category, such as operations and maintenance.  It other words, such income must be documented.  

      7.  Match: Review 50 CFR 80.84 for consistency with 48 U.S.C. 1469a on match requirements in insular areas.

This issue is to make sure that we are all on the same page.  The language has been interpreted as unclear, or commenters have suggested that it may be misconstrued to mean something different from statutory language, so we are looking for input to make sure that what is currently at 50 CFR 80.84 is sufficient.  

      8.  Electronic signatures: The WSFR Audits Branch recommends that we clarify in regulation what constitutes an electronic signature. (75)

Currently, this is defined broadly in the law.  Is there reason to disallow some forms of electronic signature and further protect the recipient or subrecipient from inadvertently signing important documentation?