State fish and wildlife agencies often have wildlife species and habitat management objectives that extend beyond their borders. As a result, initiatives have developed whereby States having similar species and/or habitat needs, or other WSFR-related program needs, will contribute individually to a common initiative. These may have an operational model whereby States contribute a desired amount, varied amounts of funds contributed are "pooled," and the initiative accomplishes certain activities.
We will refer to these as "Cooperative Conservation Initiatives" (CCIs), which means an entity implementing a comprehensive, strategic initiative with support from multiple State fish and wildlife agencies and possibly other conservation and management partners (including Federal agencies, State agencies with responsibility for fish and wildlife resources, non-governmental organizations (NGOs), and academic institutions) to accomplish shared conservation or other program objectives. The initiative must provide regional, national, or landscape-level conservation or programmatic support to benefit mammals, wild birds, sport fish, or other WSFR-eligible objectives.
During recent audits, the OIG identified that this model conflicts with 2 CFR 200 because work is typically accomplished at the species/habitat level, instead of at the State grant level. The auditors found that States contributing to NBCI are unable to demonstrate that costs are allocable to benefits (A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received; see 2 CFR 200.405). In addition, participant States obligate differing amounts to NBCI subawards, and yet all sub-awards are spent in full. This effectively creates a fixed amount award (Fixed amount awards means a type of grant or cooperative agreement under which the Federal awarding agency or pass-through entity provides a specific level of support without regard to actual costs incurred under the Federal award. This type of Federal award reduces some of the administrative burden and record-keeping requirements for both the non-Federal entity and Federal awarding agency or pass-through entity. Accountability is based primarily on performance and results; see 2 CFR 200.1), which is not allowed for a program with a mandatory cost share (A fixed amount award cannot be used in programs which require mandatory cost sharing or match; see 2 CFR 200.201(b)(2)). As a result, the OIG issued WSFR a Management Advisory.
If you have questions, please contact Sherry_Martin@fws.gov and/or Diana_Swan-Pinion@fws.gov.