[Final Audit Report on the U.S. Fish and Wildlife Service Federal  Assistance Grants Administered by the Commonwealth of Pennsylvania, Fish and  Boat Commission, from July 1, 2002, through June 30, 2004]
[From the U.S. Government Printing Office, www.gpo.gov]

Report No. R-GR-FWS-0009- 2005

Title: Final Audit Report on the U.S. Fish and Wildlife Service
       Federal  Assistance Grants Administered by the Commonwealth
       of Pennsylvania, Fish and  Boat Commission, from July 1,
       2002, through June 30, 2004

  
Date:  September 1, 2005

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AUDIT REPORT

Memorandum

To:  Director, U.S. Fish and Wildlife Service

From:  Andrew Fedak, Director of External Audits

Subject:  Final Audit Report on the U.S. Fish and Wildlife Service Federal 
Assistance Grants Administered by the Commonwealth of Pennsylvania, Fish and 
Boat Commission, from July 1, 2002, through June 30, 2004 (No. R-GR-FWS-0009-
2005) 

This report presents the results of our audit of costs claimed by the 
Commonwealth of Pennsylvania, Fish and Boat Commission (Commission), under its 
Federal Assistance grants from the U.S. Fish and Wildlife Service (FWS). The 
audit included claims that totaled approximately $28.3 million on FWS grants 
that were open during the Commissionï¿½s fiscal years ended June 30, 2003 and 
2004 (see Appendix 1).  We also reviewed the Commissionï¿½s compliance with 
certain regulatory and other requirements, including those related to the 
collection and use of fishing license revenues and the reporting of program 
income. 

We found that the Commissionï¿½s annual license certifications were not accurate 
because individuals who held more than one fishing license were counted more 
than once. We also found that the Commission did not follow Commonwealth 
guidelines for placing identification tags on computer equipment.

The FWS Region 5 response dated August 12, 2005, concurred with Recommendation 
A regarding license certifications and is gathering additional information from 
the Commission regarding Recommendation B on property tags.  We summarized the 
FWS and Commissionï¿½s responses after the recommendations and added our comments 
regarding the responses.  The status of the recommendations is summarized in 
Appendix 3.

In accordance with the Departmental Manual (361 DM 1), please provide us with 
your written response to the recommendations included in this report by 
December 1, 2005.  Your response should include the information requested in 
Appendix 3.  If you have any questions regarding this report, please contact me 
at 703-487-5345 or Mr. Tom Nadsady, Audit Team Leader, at (916) 212-4164.

cc:  Regional Director, Region 5, U.S. Fish and Wildlife Service

Introduction

The Dingell-Johnson Sport Fish Restoration Act (Act) 1 authorizes the U.S. Fish 
and Wildlife Service (FWS) to provide Federal Assistance grants to states to 
enhance their sport fish programs.  The Act provides for FWS to reimburse the 
states up to 75 percent of the eligible costs incurred under the grants.  It 
also specifies that state fishing license revenues cannot be used for any 
purpose other than the administration of the stateï¿½s fish and game department.

Scope, Objective, and Methodology

We performed our audit at the Pennsylvania Fish and Boat Commission 
(Commission) headquarters in Harrisburg, Pennsylvania. The audit work at the 
Commission included claims that totaled approximately $28.3 million on FWS 
grants that were open during the Commonwealthï¿½s fiscal years (SFYs) ended June 
30, 2003 and 2004 (see Appendix 1).  We also visited a regional office, 3 fish 
hatcheries, 1 maintenance shop, and 17 boat access facilities (see Appendix 2).  
The objective of our audit was to evaluate:
 
> the adequacy of the Commissionï¿½s accounting system and related internal 
controls;   
> the accuracy and eligibility of the direct  and indirect costs claimed under 
the Federal Assistance grant agreements with FWS;
> the adequacy and reliability of the Commissionï¿½s fishing license fees 
collection, certification, and disbursement processes; 
> the adequacy of the Commissionï¿½s asset management system and related internal 
controls with regard to purchasing, control and disposal; and
> the adequacy of the Commissionï¿½s compliance with the Actï¿½s assent legislation 
requirements.

We performed our audit in accordance with the Government Auditing Standards 
issued by the Comptroller General of the United States.  Accordingly, we 
included such tests of records and other auditing procedures that we considered 
necessary under the circumstances. Our tests included an examination of 
evidence supporting selected expenditures charged by the Commission to the 
grants, interviews with employees to ensure that personnel costs charged to the 
grants were supportable, and a review of the Commissionï¿½s use of fishing 
license revenues to determine whether the revenues had been used for the 
administration of the Commission.  We did not evaluate the economy, efficiency, 
or effectiveness of the Commissionï¿½s operations. 

Prior Audit Coverage

On November 4, 2002, we issued audit report No. 2003-E-0002, ï¿½Advisory Report 
on Costs Claimed by the Commonwealth of Pennsylvania Fish and Boat Commission, 
under Federal Aid Grants from the U.S. Fish and Wildlife Service from January 
1, 1996 through December 31, 1997.ï¿½   We followed up on all significant 
recommendations and found that all recommendations were resolved and 
implemented. 

In addition, the Commonwealth of Pennsylvania Office of the Budget, Comptroller 
Operations, issued a Single Audit report on the Commonwealth of Pennsylvania 
for SFY 2003.  The Sport Fish Restoration Program was not considered a major 
program and none of the reported findings impacted the Commissionï¿½s Federal 
Assistance grant program. 

Results of Audit

We found that:

> The Commissionï¿½s accounting system and related internal controls adequately 
and accurately accounted for grant and license fee receipts and disbursements. 
> The direct and indirect costs were accurately reported and claimed.
> Except for the issue in finding A, the Departmentï¿½s fishing license fees 
collection, certification, and disbursement processes were adequate and 
reliable.
> Except for the issue in finding B, the asset management system was adequate 
for identifying and tracking personal and real property with regard to 
acquisition, control, and disposal.
> The State had adequate legislation that assented to the provisions of the Act 
and prohibited the use of license fees for anything other than the 
administration of the Commission.
 
However, we found that:

A.  The Commissionï¿½s annual license certifications to FWS were not accurate 
because individuals who held more than one fishing license were counted more 
than once.
B.  The Commission did not apply identification tags on its computer equipment, 
as required by the Commonwealth regulations.  


A.  License Certifications

The numbers of fishing license holders reported by the Commission in its 
license certifications for license years 2001 and 2002 were likely overstated 
because individuals who purchased more than one fishing license during the year 
were counted more than once.

According to 50 CFR ï¿½ 80.10 (c) (5), ï¿½The State fish and wildlife director, in 
certifying license information to the [U.S. Fish and Wildlife Service] 
Director, is responsible for eliminating duplication or multiple counting of 
single individuals in the figures which he certifies.ï¿½  In addition, the FWS 
Manual section 522, paragraph 2.7(1) provides, ï¿½States may use a statistical 
survey to eliminate duplicate counting of licenses that they may issue to a 
person.  They should conduct a new survey at least every 5 years, or sooner if 
there has been a change in the license structure.ï¿½

We found that the Commission did not have a process for identifying individuals 
who had purchased more than one fishing license during the year and ensuring 
that those individuals were counted only once in the license certifications. 
For example, an individual who purchased two 3-day ï¿½touristï¿½ licenses and 
subsequently an annual nonresident license for the remainder of the year would 
likely be counted as three license holders.  

A Commission official stated that he misinterpreted the regulations and 
considered each license sale unique, and that although the Commission did not 
count reissued licenses for those that were lost, they believed multiple sales 
to a single individual was not duplication.  In addition, the Commissionï¿½s 
manual process for managing license sales cannot readily be used to identify 
duplicate license holders, and the Commission has not developed a statistical 
method to eliminate duplicate holders. 

The calculation of the annual state apportionment of FWS Sport Fish Restoration 
Program funds is based, in part, on the number of license holders.  Therefore, 
accurate counts are necessary to assure that each state receives its fair share 
of funds.

Recommendation

We recommend that FWS require the Commission to develop and implement 
procedures for the elimination of duplicate or multiple license holders. 

Commission Response

The Commission stated that past audits and reviews have determined that the 
frequency of repeat buyers is extremely low and that it would not be cost 
effective or economically feasible to identify a handful of duplicate license 
buyers.  The Commission anticipates implementing an automated license sales and 
distribution system by the 2008 license season.

FWS Response

FWS stated that it concurs with the recommendation.

OIG COMMENTS

The Commissionï¿½s response did not include documentation supporting its comments 
on the frequency of repeat buyers and costs effectiveness of performing a 
statistical survey.  Although FWS concurred with the recommendation, additional 
information is needed concerning the actions taken or planned to resolve the 
finding and implement the recommendation.  This information should be included 
in the corrective action plan.    


B.  Property Tags

The Commission did not follow Commonwealth guidelines on assigning agency 
property tag numbers and placing them on computer equipment.  Based on our 
interviews of Commission officials and our review of the computer inventory 
listing, we determined that the inventory listing generally did not contain 
identification numbers to identify a specific item on the list as Commission 
property.

The Governorï¿½s Office Manual M245.4, Policy for Personal Computer and Network 
Chapter III states, ï¿½All hardware must have an agency inventory identification 
tag.ï¿½  Department officials stated they were not aware of this requirement and 
that they used the equipment serial number as an alternative. However, serial 
numbers were only documented for 33 of the 353 items on the computer inventory 
and serial number do not meet the requirement to identify the owning agency. 
The use of property identification numbers and tags is an important internal 
control for managing personal property effectively.

Recommendation

We recommend that FWS ensure that the Commission has adequate inventory 
controls in place for managing its computer equipment which conform to the 
requirements in the Governorï¿½s Manual and/or the Commissionï¿½s procedures, as 
appropriate, based on a determination of whether the Commission is subject to 
the Governorï¿½s Office Manual. 

Commission Response

The Commission stated that it is an independent commission and is not subject 
to the policies and management directives issued by the Governorï¿½s office.  The 
Commission also stated that it has its own hardware and inventory control 
system.

FWS Response

FWS stated that it is gathering additional information from the Commission 
regarding the recommendation.

OIG COMMENTS

Based on the Commissionï¿½s comment that the Governorï¿½s Office Manual does not 
apply to the Commission, we have revised the recommendation. As such, the 
finding is considered unresolved and the recommendation unimplemented.  
Additional information is needed concerning the Commissionï¿½s response. This 
information includes support for the statement that the Commission is not 
subject to the requirements in the Governorï¿½s Office Manual and a detailed 
description of the Commissionï¿½s own inventory management system, including the 
controls in place to ensure the integrity of that system. This information 
should be included in the corrective action plan, which should also identify 
the actions taken or planned to resolve the finding and implement the 
recommendations.  

Appendix 1

PENNSYLVANIA FISH AND BOAT COMMISSION
FINANCIAL SUMMARY OF REVIEW COVERAGE
JULY 1, 2002 THROUGH JUNE 30, 2004

Grant
Number

Grant
Amount

Claimed
Costs*





F-30-D-39
$1,942,000
$1,750,198
F-30-D-40
2,112,000
1,905,428
F-30-D-41
2,208,000
1,867,280
F-57-R-25
4,111,950
5,320,145
F-57-R-26
5,048,000
4,715,299
F-57-R-27
5,200,000
4,724,897
F-61-T-22
1,360,000
1,438,041
F-61-T-23
1,415,000
1,367,029
F-61-T-24
1,326,000
1,424,005
F-69-E-14
480,000
459,305
F-69-E-15
446,000
381,599
F-69-E-16
425,000
483,124
F-71-R-13
286,000
286,535
F-71-R-14
294,000
300,806
F-71-R-15
298,000
280,918
F-74-D-12
2,100,000
998,398
F-74-D-13
2,584,000
599,087

$31,635,950
$28,302,094

? Includes the amounts recorded during the audit period, including indirect 
costs.


Appendix 2


PENNSYLVANIA FISH AND BOAT COMMISSION
SITES VISITED

Regional Offices
Pleasant Gap   

Fish Hatcheries
Benner Springs  
Huntsdale   
Pleasant Gap     

Maintenance Shop
Maintenance Area IV, Speedwell Forge

Boat Access Facilities   
Auburn Dam Access 
Bald Eagle Creek Access  
Falmouth Access  
Five Locks Access
Frenchville Station Canoe Access Area
Good Hope Access
Hyner Hand Launch Area   
Long Pine Reservoir Access  
Marietta Access
Muskrat Spring Access Area
North Bend Access   
PA State Flaming Foliage Canoe Access
Speedwell Forge Lake   
Susquehanna River Access (Columbia)  
Thompsontown Access Area
Walker Access Area
Wrightsville Access   


Appendix 3


PENNSYLVANIA FISH AND BOAT COMMISSION
STATUS OF AUDIT FINDINGS
AND RECOMMENDATIONS 


Recommendations
:  A


Status:  Management Concurs; Additional Information Needed


Action Required:  Provide a corrective action plan that identifies the actions 
taken or planned to resolve the finding and implement the recommendation.  The 
plan should also include the target date and the official responsible for 
implementation of the recommendation.  If the recommendation is not implemented 
at the end of 90 days (after December 1, 2005), it will be referred to the 
Assistant Secretary for Policy, Management and Budget for resolution and/or 
tracking of implementation. 


Recommendation:  B

Status:  Finding Unresolved and Recommendation Not Implemented

Action Required:  Provide a corrective action plan that identifies the actions 
taken or planned to resolve the finding and implement the recommendation, as 
well as the basis for any disagreement with the recommendation.  The plan 
should also include the target date and the official responsible for 
implementation of the recommendation.  If the recommendation is not implemented 
at the end of 90 days (after December 1, 2005), it will be referred to the 
Assistant Secretary for Policy, Management and Budget for resolution and/or 
tracking of implementation.