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Wildlife Restoration Sport Fish Restoration State Wildlife Grants |
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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”) who have identified a common conservation need 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 across geopolitical boundaries. Funding for a CCI must include awards to two or more States using WSFR, SWG or C-SWG funds. CCI activities provide a conservation benefit to all participants, although it is possible work will not always occur within each state.
This operational guidance page will be updated as new information about CCI implementation becomes available.
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Collaborative Conservation Initiatives: Frequently Asked Questions
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.
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.
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.
What other regulatory requirements will be applied differently for CCIs than is typical for individual State grants?
The cost sharing requirement for Federal funds awarded may be met at CCI level rather than at the individual State level. Cost sharing may be provided by the State, by the CCI Entity, or by another partner. The sources and amounts of cost sharing must be identified by subaccount in the budget narrative and then tracked and documented accordingly.
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.
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.
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.
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.
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.
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.
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.
May a single State apply for a CCI award?
No. Funding for a CCI must include awards to two or more States.
Can a State act as a CCI Entity?
Yes, a State may be designated to act as the CCI Entity.
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.
The CCI application is required to be a single submission on behalf of all participants. The application must identify the full scope of work and the period of performance in which it will be accomplished. State subawards to the CCI Entity must have the same period of performance. All reports will be developed for that single period of performance.
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.
Can awards be approved Subject to Availability of Funds?
Yes, Wildlife Restoration and Sport Fish Restoration funds may be approved subject to availability, although some amount of funding must be obligated from each Participating State at the time of the initial award. The CCI Entity must draw funds as specified in the Notice of Subaward, based on the amount of each State subaward as a percentage of the total approved budget.
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.
Who is responsible for processing and approving CCI applications and monitoring award performance?
The Lead Region is responsible for managing CCI awards.
What is the role of the HQ Point of Contact (HQ POC) for CCI awards?
The HQ POC will provide administrative support on request from ROs administering CCI awards. This person will provide CCI process updates or reminders as needed across Regions.
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.
What is the role of the HQ Compliance Branch Subject Matter Expert for CCI awards?
The HQ Compliance Branch SME will provide support to RO staff administering CCI awards when concerns related to regulatory compliance arise.
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.
How will environmental compliance be completed for a CCI?
The Lead Region will be responsible for completing and documenting all compliance and will provide guidance to the CCI applicant regarding any compliance needs or concerns.
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.
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?
No. The obligation of funds is a strictly administrative action carried out on behalf of and at the direction of each Participating State.
The CCI application will include a Letter of Intent from each State directing the Service to obligate a specific amount of their apportioned funds directly to the CCI Entity as a subaward from the State to the CCI Entity. The Service will create a single obligation to the CCI Entity in GrantSolutions that includes all Participating State subawards. Each State will receive a Notice of Award. The CCI Entity will receive a Notice of Subaward the identifies each State subaward.
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.
How will the Service obligation of funds to the CCI Entity affect the process for reporting subawards to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) at http://www.fsrs.gov?
The new process will require some manual processing by the Service before States will be able to report the information as required. Specific process details are still being developed. The Service will share that information as soon as it is finalized.
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.
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 funds that are deobligated at the end of the period of performance pass through the State’s safety margins?
Yes.
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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.
State Admin Process - This document summarizes the State administrative process of CCIs including initiation procedures, requirements for a CCI project statement, reporting requirements, and oversight.
Environmental Compliance Process - This document describes the framework for compliance review for a CCI application, whether the project is limited to one Service Region or may impact multiple Service Regions.
Template for State Letter of Intent - States interested in participating in a CCI must use this template to request the Service initiate the CCI process.
Notice of Award Template - Regional Offices awarding a CCI must use this NOA Template which includes award terms and conditions specifically related to the CCI.
Notice of Subaward Template - Regional Offices must use this Notice of Subaward Template to document the approval of the CCI, detail the budget of each subaward, and apply subaward terms and conditions specifically related to the CCI.
Certification of State Review of Reports - This template is used to notify the Lead Region that Financial and Performance Reports associated with the CCI have been reviewed and approved for the applicable reporting period.
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