417 FW 4
Administered Audits of Grantees - Resolution

Supersedes 417 FW 4, FWM 454, 08/23/04

Date:  April 19, 2010

Series: Audits

Part 417: Wildlife and Sport Fish Restoration Program Audits

Originating Office: Office of Wildlife and Sport Fish Restoration



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4.1 What is the purpose of this chapter? This chapter tells employees how to track and resolve audit findings and implement recommendations from Service-administered audits in the Wildlife and Sport Fish Restoration Program (WSFR).


4.2 To which grant programs does this chapter apply? This chapter applies to the Federal grant programs in 417 FW 1.2.


4.3 What are the authorities for this chapter? The authorities for this and the other chapters in Part 417 are in 417 FW 1.3.


4.4 Who is responsible for tracking and resolving the findings and carrying out the recommendations in Service-administered audits in the WSFR program? The individuals responsible for Service-administered audits of grantees in the WSFR program and their responsibilities are in 417 FW 1.


4.5 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.


4.6 When does audit resolution begin? Although the Regional Director should work with the grantee while the audit is in progress to resolve issues the auditor finds, the formal audit-resolution process doesn’t begin until the Department of the Interior’s Office of Inspector General (OIG) issues the final audit report.


4.7 What is a Corrective Action Plan (CAP) and who prepares it?


A. A CAP is a document that deals with recommendations that are in the audit report. It must identify:


(1) The grantee audited,


(2) The years audited, and 


(3) The report number. This information is in the title of the OIG’s final audit report.


B. The CAP must cover all findings and recommendations that are in the final audit report. It must contain, at a minimum:


(1) Auditor’s Findings and Recommendations. These are issues and recommended actions that the auditor included in the audit report.


(2) Service Determination. This documents the Regional Director’s decision to accept or reject each recommendation with the concurrence of the Assistant Director (AD)–WSFR. When we accept recommendations in the final audit report, the CAP must include a corrective action. If we reject an auditor’s recommendation, the CAP includes an explanation of the basis for that determination, including legal citations. 


(3) Corrective Action. This describes what a grantee must do to resolve the issue in a finding. It defines the necessary actions, the target date, and the people responsible for each action. Each recommendation that we accept must have a corrective action.


(4) Resolution. This describes the actions that the grantee takes and the documentation that the grantee gives us to prove that the corrective action(s) is complete.


C. The Regional Director and the grantee discuss the auditor’s recommendations and prepare the CAP for the Regional Director’s approval. The Chief, Division of Administration and Information Management, Headquarters (ChiefAIM/HQ) and staff are available for technical support in preparing the CAP.


4.8 How much time does the Service have to prepare a CAP? We have 90 calendar days from the date that the OIG issues the final audit report to prepare a CAP.


A. The Regional Director has 45 calendar days to prepare the draft CAP and send it to the ADWSFR. The ADWSFR gives a copy to the Chief, Branch of Audits, Headquarters (ChiefAudits).


B. The ADWSFR has 30 calendar days to review the CAP, concur or not concur, and return it to the Regional Director.


C. The Regional Director:


(1) Has 15 calendar days to put the CAP in its final form and send it to the OIG and the grantee. The date the Regional Director sends the CAP to the grantee is the beginning of the 21-day window for appeals described in 417 FW 5.


(2) Gives a copy of the final CAP to the ADWSFR.


D. If the Regional Director and the ADWSFR do not agree on the CAP, they work together to resolve their disagreement. If they cannot resolve the disagreement, they refer the matter to the Director for a decision, and the timeframes change.


E. The ADWSFR or Regional Director may request an extension of the 90-day response time.


4.9 What types of recommendations does OIG refer to the Department?


A. If the Regional Director and the ADWSFR approve a corrective action and the grantee completes it within the CAP period (see section 4.11), then tracking implementation stays within the Service. The Regional Director:


(1) Tracks the CAP and documents when the grantee completes it, and


(2) Keeps the Chief–Audits informed of the CAP’s progress. The ChiefAudits provides status reports on the CAP’s progress to the Service’s audit liaison in the Division of Policy and Directives Management (PDM).


B. The OIG refers three types of recommendations to the Assistant Secretary for Policy, Management, and Budget (PFM) for tracking:


(1) Where the Regional Director and the ADWSFR have not approved a corrective action (see section 4.10);


(2) Where the Regional Director and the ADWSFR have approved a corrective action, but the grantee has not completed the corrective action; and


(3) Where OIG does not agree that the CAP implements the recommendation and cannot resolve the issues with the Regional Director and ADWSFR. In this case, PFM resolves the issues and instructs the Service.


C. PFM tracks recommendations until the grantee completes the corrective actions.


D. The Regional Director monitors all audit recommendations that the OIG refers to PFM and periodically reports progress to the ADWSFR.


4.10 What does the Assistant SecretaryPFM do with a recommendation that does not have a corrective action approved by the Regional Director and the ADWSFR? If the Assistant Secretary receives a recommendation that does not have an approved corrective action, PFM notifies PDM. PDM, working with the ADWSFR and the Regional Director, prepares a CAP for that recommendation. PFM reviews CAPs that it receives in response to this notification and tracks completion of the corrective action.


4.11 How much time does the grantee have to complete the CAP? The grantee and the Service negotiate the deadlines for corrective actions for findings during the preparation of the CAP.


A. If the grantee needs an extension, it sends the Regional Director a written request with justification for additional time to complete the corrective action.


B. The Regional Director:


(1) Responds in writing to the grantee within 10 working days of receiving the grantee’s request,


(2) May consult the ADWSFR and staff as needed, and


(3) Notifies the ADWSFR that he or she concurs or does not concur with the grantee’s request.


C. The ADWSFR notifies PDM of the change.


4.12 What are the requirements for publishing CAPs?


A. The Regional Director may distribute a CAP to the public only after it is in its final form and the grantee has received a copy. A grantee may release a copy of the CAP at its discretion.


B. The ADWSFR, in consultation with the Regional Director, determines whether it is appropriate to post a CAP on the Internet. According to Departmental guidance, if we receive three or more requests from the public for a specific document, we must make the document available on the Internet.


4.13 Does the Service or Department ever change the terms of a final CAP? Yes. The Service or the Department may change the terms of a final CAP in the following situations:


A. If a change in circumstances affects the grantee’s ability to complete a corrective action that the CAP prescribes, the grantee may request a change by sending a proposed CAP amendment to the Regional Director for each recommendation affected.


(1) If the Regional Director agrees with the CAP amendment, he or she sends it to the ADWSFR through the ChiefAudits for concurrence.


(2) If the AD–WSFR concurs with the CAP amendment, he or she sends the CAP amendment to PDM.


(3) If PDM identifies any flaws in the amendment, it will work with the ADWSFR to resolve them. PDM sends the CAP amendment to PFM.


B. If the grantee needs a deadline extension for completing a corrective action, the Regional Director may give written approval without going through the formal amendment process (see section 4.12).


C. The Director or the Secretary may modify the final CAP as the result of an appeal (see 50 CFR 80 and 417 FW 5).


4.14 Is a grantee subject to penalties if it does not resolve audit findings in the CAP? Yes. A grantee is subject to penalties for noncompliance. You can find information about:


A. Potential penalties at 43 CFR 12.83 and 43 CFR 12.962,


B. Penalties associated with special grant conditions at 43 CFR 12.52 or 43 CFR 12.914, and


C. Suspension and debarment at 2 CFR 180 and 2 CFR 1400.


4.15 Who removes recommendations from tracking or closes an audit, and how do they do it?


A. When the OIG does not refer a recommendation to the Assistant SecretaryPFM, the OIG notifies the Service that the Department is not tracking any recommendations and the Department has closed the audit. The Regional Director then notifies the grantee that the Department closed the audit.


B. When the OIG refers recommendations to the Assistant Secretary, PFM tracks recommendations and removes them from tracking or closes an audit when the following occurs:


(1) The Regional Director sends a memorandum to the ChiefAIM/HQ that:


(a) Documents that the grantee completed the corrective action(s), and


(b) Asks PFM to remove the recommendation(s) from tracking or close the audit if the grantee completed all corrective actions.


(2) The ChiefAIM/HQ reviews the documentation, and if he or she concurs, sends the memorandum to the ChiefPDM.


(3) The Chief–PDM reviews the memorandum, and if he or she concurs, sends the memorandum and documentation to PFM.


(4) PFM reviews the memorandum, and if the approving official concurs, notifies us that it is removing the recommendation from tracking. If the grantee completed all corrective actions, PFM’s approving official notifies us that the Department has closed the audit.


(5) The Regional Director notifies the grantee when the Department acknowledges the completion of the corrective action(s) and when it closes an 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.



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