Supersedes 417 FW 3, FWM 454, 08/23/04
Date: April 19, 2010
Part 417: Wildlife and Sport Fish Restoration Program Audits
Originating Office: Office of Wildlife and Sport Fish Restoration
3.1 What is the purpose of this chapter? This chapter tells employees how to conduct Service-administered audits of grantees in the Wildlife and Sport Fish Restoration Program (WSFR).
3.2 To which grant programs does this chapter apply? This chapter applies to the Federal grant programs in 417 FW 1.2.
3.3 What are the authorities for this chapter? The authorities for this and the other chapters in Part 417 are in 417 FW 1.
3.4 Who is responsible for ensuring that auditors follow Government Auditing Standards in conducting field audits and issuing reports? The individuals responsible for Service-administered audits of grantees in the WSFR program and their responsibilities are in 417 FW 1.
3.5 What terms do you need to know to understand this chapter? The terms you need to know to understand this chapter are in the Service handbook, Wildlife and Sport Fish Restoration Program Glossary.
3.6 What are the steps for conducting audits and reporting on them?
A. Audit Entrance Conference. The auditor meets with the Service, the grantee, and others at the beginning of the audit fieldwork. (See 417 FW 1.6 for information on the qualifications of auditors, how the Service selects them, and the contractual arrangements under which they provide their services.) During this meeting, the auditor:
(1) Explains the audit objectives and process,
(2) Discusses logistical needs,
(3) Establishes a tentative schedule, and
(4) Answers participants’ questions.
B. Fieldwork. The auditor performs fieldwork between the entrance and exit conference. It usually takes 3–4 months to complete, including site visits. The auditor, the grantee, and the Service communicate regularly during fieldwork to resolve potential audit findings and recommendations before the auditor prepares the draft audit report.
C. Compilation of Findings and Recommendations. Before the exit conference, the auditor provides the grantee and the Service with a compilation of the findings and recommendations. The auditor uses the findings and recommendations for preparing the draft audit report.
D. Audit Exit Conference. The auditor meets with the Service, the grantee, and others after completing fieldwork to review the preliminary results of the audit. The auditor offers an exit conference as a service to the grantee unless the grantee decides that it is unnecessary. One reason that a grantee may find an exit conference unnecessary is when the audit has no findings.
E. Draft Audit Report. The auditor prepares the draft audit report after the audit exit conference and distributes it within the Service following the instructions of the Chief of WSFR’s Division of Administration and Information Management in Headquarters (Chief–AIM/HQ). The Chief–AIM/HQ gives a copy to the grantee for an audit of a program where WSFR’s HQ administers the grants. The Regional Director gives a copy to the grantee for an audit of a program where the Regional WSFR Divisions administer the grants. The Service and the grantee may give the auditor a written response to the draft audit report (normally within 45 days).
F. Final Audit Report. The Office of the Inspector General (OIG) issues the final audit report to the Director regardless of who conducts the audit. The final report includes any grantee or Service response and the auditor’s reply.
3.7 Who provides technical guidance to the auditor on interpretation and application of program rules and regulations?
A. The following individuals may provide routine guidance and interpret laws, regulations, and policies for the auditor during the audit:
(1) The Regional Director,
(2) The Assistant Director, WSFR (AD–WSFR),
(3) The Chief–AIM/HQ, and
(4) The Chief, Branch of Audits, WSFR, HQ (Chief–Audits).
B. The AD–WSFR ensures consistent interpretation and application of laws, regulations, and policies nationwide.
3.8 Does the auditor issue status reports? Yes.
A. The auditor provides weekly status reports to the Regional Director, the Chief–AIM/HQ, and the Chief–Audits during fieldwork. The status reports describe preliminary findings and audit progress.
B. We share these reports with the grantee only when the grantee requests it. The Service’s grants management specialist tells the grantee that it may request a status report.
3.9 Does the auditor consult with the Service on potential findings while the audit is in progress? Yes. The auditor:
A. Reports preliminary findings to the grantee, the Regional Director, and the Chief–Audits as soon as possible.
B. Immediately reports illegal activity or suspected fraud to the OIG, Division of Investigations, without notifying us or the grantee.
3.10 How does the Service address major issues identified during the audit? If the Regional Director or the Chief–AIM/HQ:
A. Has a concern about potential findings by the auditor, he or she contacts the AD–WSFR, the auditor, the grantee, or all three to address the issue(s) as soon as possible.
B. Believes that an issue is of national concern, he or she notifies the AD–WSFR. The AD–WSFR decides how to resolve the matter and gives written guidance to the Regional Directors.
3.11 May the Service resolve audit findings while the field audit is still in progress? Yes.
A. We work with grantees, when practical, to resolve audit findings while the auditor is still on site. This allows the auditor to verify and document the resolution in audit work papers and report it in the draft and final audit reports.
B. The auditor:
(1) Documents all reportable conditions following Government Auditing Standards, including those resolved during the audit; and
(2) Gives us or the grantee any additional details necessary to understand and resolve audit findings and recommendations if either of us requests it in writing.
3.12 Does the Service or the grantee have an opportunity to review findings and recommendations before the audit exit conference? Yes. The auditor issues Notices of Potential Findings and Recommendations to us and the grantee for comments as soon as possible during the audit fieldwork phase. The notices describe the potential findings. The auditor may revise the findings and recommendations based on additional comments or documentation from us or the grantee. Afterwards, the findings and recommendations become the basis for the draft audit report.
3.13 When does the audit exit conference occur? The auditor schedules the audit exit conference with the Regional Director, or designee, and the grantee on a mutually agreeable date unless the grantee decides that an audit exit conference is unnecessary. This conference is an opportunity for the grantee and for the Service to request or provide further clarification on any Notices of Potential Findings and Recommendations and to discuss any other concerns about the audit.
3.14 May audit findings change as a result of the audit exit conference? Yes. The auditor may modify the findings or recommendations before preparing the draft audit report based on information the auditor receives during the audit exit conference.
3.15 Does the Service or the grantee have an opportunity to review and respond to audit findings in the draft audit report? Yes. After the audit exit conference, the auditor provides a draft audit report to us with a request for comments within 45 days. We give the grantee a copy of the draft report. The grantee may send comments to the Regional Director, who must send them to the auditor. If neither comments on the draft within the allotted time, the auditor prepares the final audit report and notes that he or she received no comments on the draft. After the draft audit report is issued:
A. The grantee and the Service may:
(1) Concur with the audit recommendations,
(2) Offer clarifying language for incorporation into the report, or
(3) Do any of the following:
(a) Disagree with audit findings or recommendations and provide additional information to support its position.
(b) Provide additional information to assist the auditor with an accurate and complete final audit report. Since this a draft, the Regional comments on the draft report must not say that we:
(i) Do not concur with a recommendation,
(ii) Have decided that a proposed resolution is adequate or inadequate, or
(iii) Have resolved and implemented a recommendation.
B. The grantee may ask the Regional Director for additional review time.
3.16 Who issues the final audit report, and to whom do they issue it? The OIG issues the final audit report to the Director and sends a copy to:
A. The AD–WSFR,
B. Chief–AIM/HQ (who may distribute a copy to other Regional Directors if they request it),
D. Regional Director (who immediately gives a copy to the grantee), and
E. The Service Audit Liaison Officer.
3.17 Who may make final audit reports available to the public?
A. Only the OIG, as the “office of record” may make final audit reports available to people outside of the Service.
B. If employees receive requests for audit reports from the public, employees should tell them to check the OIG’s Web site. If the audit report is not on the OIG’s Web site, employees should direct the public to the OIG Freedom of Information Act Officer.
3.18 May a grantee register a formal complaint about the conduct of the audit? Yes. A grantee may register a written complaint with the Regional Director at any point during the audit.
For information on the content of this chapter, contact the Office of Wildlife and Sport Fish Restoration. For more information on this Web site, contact Krista Bibb in the Division of Policy and Directives Management.