DOI OIG Audit - FWS Friends Program

AUDIT

OFFICE OF

INSPECTOR GENERAL
U.S.DEPARTMENT OFTHE INTERIOR

The U.S. Fish and Wildlife Service
Needs To Improve Oversight of
Its Friends Program

In recognition of Secretarial Order No. 3380, we are providing estimated costs
associated with certain work products. Applying a formula involving prior salary and
benefit expenses, we estimate the cost of preparing this report to be $282,000.

Report No.: 2019-CR-011

September 2020

OFFICE OF

INSPECTOR GENERAL
U.S.DEPARTMENT OF THE INTERIOR

Memorandum
To:

Aurelia Skipwith
Director, U.S. Fish and Wildlife Service

From:

Mark Lee Greenblatt
Inspector General

Subject:

Final Audit Report – The U.S. Fish and Wildlife Service Needs To Improve Oversight
of Its Friends Program
Report No. 2019-CR-011

This memorandum transmits our final audit report on the U.S. Fish and Wildlife
Service’s (FWS’) friends program. We determined that the FWS did not ensure friends
organizations fully accounted for and spent donations and revenues in accordance with
governing laws. Specifically, we found that the FWS did not maintain the information necessary
to manage the friends program. As a result, the program is at risk for misuse and mishandling of
funds, and undetected violations of partnership agreements and program regulations.
We make six recommendations that, if implemented, will help strengthen the FWS’
friends program. Based on the FWS’ response to our draft report, we consider one
recommendation resolved and implemented and the remaining five recommendations resolved
but not implemented. We will refer the recommendations to the Assistant Secretary for Policy,
Management and Budget to track implementation. The FWS’ response also included six
financial and program management control initiatives that should further enhance its oversight of
friends organizations. We commend the FWS for taking extra measures to improve this
important program.
If you have any questions regarding this memorandum or the subject report, please
contact me at 202-208-5745.
The legislation creating the Office of Inspector General requires that we report to
Congress semiannually on all audit, inspection, and evaluation reports issued; actions taken to
implement our recommendations; and recommendations that have not been implemented.

Office of Inspector General | Washington, DC

Table of Contents
Results in Brief ................................................................................................................................1
Introduction......................................................................................................................................2
Objective ......................................................................................................................................2
Background ..................................................................................................................................2
Findings............................................................................................................................................4
The FWS Did Not Maintain Basic Information, Account for Funding, or Monitor Spending
for Friends Organizations.............................................................................................................4
The FWS Did Not Maintain Required Friends Program Documentation....................................6
Conclusion and Recommendations..................................................................................................8
Conclusion....................................................................................................................................8
Recommendations Summary........................................................................................................8
Appendix 1: Scope and Methodology............................................................................................10
Scope ..........................................................................................................................................10
Methodology ..............................................................................................................................10
Appendix 2: Bureau Response.......................................................................................................13
Appendix 3: Status of Recommendations......................................................................................19

Results in Brief
We audited the U.S. Fish and Wildlife Service (FWS) to determine whether it ensured that
donations and revenues collected by friends organizations were accounted for and spent in
accordance with governing laws. The FWS relies on friends organizations and volunteers to help
meet conservation goals that would otherwise be out of reach. These organizations are taxexempt nonprofit groups with a mission of supporting an affiliated FWS site or program and
represent a substantial source of both funding and volunteer labor. In total, FWS friends
organizations annually receive millions of dollars in donations and revenues that they are
required to spend to benefit wildlife refuges and fish hatcheries. Donors reasonably expect that
their money will be spent to benefit the refuge or hatchery they are supporting.
We concluded that the FWS did not ensure its friends organizations fully accounted for and spent
donations and revenues in accordance with governing laws and its own friends program policy.
Specifically, we found that the FWS did not maintain the information necessary to manage the
friends program. As a result, the FWS cannot account for friends organization donations,
revenues, or expenditures. In addition, the FWS was unable to ensure friends organizations had
the necessary documents required to participate in the friends program, such as evidence of
nonprofit status.
We found that the FWS was not aware of the number of friends organizations operating across
the Nation and did not monitor the amount of donations collected and spent. Consequently, the
program is not operating at its full potential, and refuges and hatcheries may not have received
the full benefit of donations.
The friends program is at risk for misuse and mishandling of funds and undetected violations of
partnership agreements and program regulations. By strengthening controls and oversight, the
FWS can bolster the public’s trust in its friends organizations and the critical role they play in
support of the FWS’ sites.
We make six recommendations to address the identified issues and strengthen the friends
program. The FWS concurred with all six recommendations in its response to our draft report.
Based on the FWS’ response, we consider one recommendation resolved and implemented and
the remaining five recommendations resolved but not implemented. Because the FWS stated
these five recommendations will take several months to fully implement, we will refer the
recommendations to the Assistant Secretary for Policy, Management and Budget to track
implementation.
We also note that the FWS’ response included six financial and program management control
initiatives that should further enhance its oversight of friends organizations. We commend the
FWS for taking extra measures to improve this important program.

1

Introduction
Objective
Our objective was to determine whether the U.S. Fish and Wildlife Service ensured that
donations and revenues collected by friends organizations were accounted for and spent in
accordance with governing laws. Appendix 1 contains the scope and methodology for this audit.

Background
U.S. Fish and Wildlife Service (FWS) friends organizations are tax-exempt nonprofit
organizations with a mission of supporting an affiliated FWS site or program. Friends
organizations are an important resource for the FWS, representing a substantial source of both
funding and volunteer labor at wildlife refuges and fish hatcheries. Current estimates from the
FWS show nearly 200 friends organizations comprising about 40,000 members operating across
the Nation. These organizations range in size from a handful of volunteers to more than a
hundred and may serve one or more locations.
Friends organizations collect revenue through the sale of goods and services, solicit or acquire
donations, and apply for project fundraising grants to generate income to benefit the FWS.
Known donations and revenues to friends organizations total in the millions of dollars each year.
In addition, the friends organizations provide volunteer work at refuges and hatcheries and fund
projects such as installing signs, establishing gardens, and constructing visitor centers and
boardwalks (see Figure 1). At some refuges, friends organization volunteers further help the
FWS by assisting visitors.
Figure 1: Wildlife Education Boardwalk Funded by the Friends
Organization at J.N. Ding Darling National Wildlife Refuge

2

The FWS Service Manual (633 FW 1 – 4, effective 2014) provides the official friends program
policy, including guidance and administrative procedures for FWS employees establishing and
working with friends organizations. The FWS wrote the policy to implement specific provisions
of the National Wildlife Refuge System Volunteer and Community Partnership Enhancement
Act of 1998 (Pub. L. No. 105-242) and the National Fish Hatchery System Volunteer Act of
2006 (Pub. L. No. 109-360).

3

Findings
We found that the FWS did not ensure that its friends organizations fully accounted for and spent
donations and revenues they collected on behalf of refuges and hatcheries in accordance with
governing laws and its own friends program policy (633 FW 1 – 4).
The FWS did not compile and maintain information necessary to manage the friends program,
including the total number of friends organizations and their respective donations, revenues,
expenditures, and required documentation. We requested this information during our audit, but
because the FWS does not routinely track the data at the national, regional, or local level, weeks
elapsed as the FWS attempted to respond to our request. Some data, including the revenues,
expenditures, and nonprofit status, required a formal data call to FWS field offices or to the
friends organizations. The FWS was not able to provide summary revenue and expenditure data,
and thus these amounts remain unknown.
As a result, the FWS did not account for friends organization donations, revenues, or
expenditures. In addition the FWS was unable to ensure friends organizations had the necessary
documents required to participate in the program. The friends program is therefore at risk for
misuse and mishandling of funds, and undetected violations of partnership agreements and
program regulations.

The FWS Did Not Maintain Basic Information, Account for
Funding, or Monitor Spending for Friends Organizations
The FWS did not compile and track basic information about the friends program and friends
organization operations, which is essential to effective program administration and oversight.
During our audit, the FWS was unable to provide an accurate list of participating friends
organizations and stated totals ranging from 180 to more than 230. The FWS’ final count was
193 friends organizations: 172 at refuges, 19 at hatcheries, and 2 at the national level. However,
we noted an error in this total and therefore could not determine the total number of friends
organizations across the Nation.
In 2016, the FWS attempted to learn more about friends program activities but was only partially
successful. Only 30 percent of the refuges with friends organizations responded to a nationwide
survey the FWS headquarters conducted as a part of the effort. The respondents reported about
15,000 volunteer members and $5 million in funds raised that year. The FWS was unable to
obtain data on the remaining 70 percent of refuges with friends organizations.
Multiple provisions within FWS policy (633 FW 1 – 4) require friends organizations to maintain
information such as administrative and financial records and allow the FWS to collect it upon
request. The FWS, however, is not consistently exercising its authority under its policy and could
not initially provide us with this information. During our audit, the FWS sent a data call to all of
its friends organizations, yet was still unable to provide us with complete information for each of

4

the friends organizations. 1 Without basic friends program information, it is difficult for the FWS
to proactively manage the program, hold friends organizations accountable as necessary, assess
the state of the program, and identify whether emerging problems warrant attention.
Because the FWS did not track or compile basic information on its friends organizations, it was
not aware of the amount of donations or revenues its friends organizations collected and did not
always oversee how its friends organizations spent those donations or revenues. Donations can
be a significant source of income for friends organizations and may exceed hundreds of
thousands of dollars. Even a single donation box may accumulate thousands of dollars. Similarly,
nature stores can also be significant sources of income, as one refuge we visited exceeded
$100,000 in sales revenue annually. Shoppers at such stores and donors to friends organizations
reasonably expect that their money will be spent to benefit the refuge or hatchery they are
supporting. Without accountability for these donations and revenues, however, the FWS is at risk
of accidental loss, theft, and mismanagement of funds.
During our audit, we also could not determine whether certain expenditures we identified
benefited the applicable refuge or hatchery, as required under FWS policy (633 FW 4,
interpreting Pub. L. No. 105-242 § 5 and Pub. L. No. 109-360 § 5). We questioned 25
expenditures of meals and entertainment for friends organization members and FWS employees,
miscellaneous expenses, and awards totaling $7,729 for the friends organization at J.N. Ding
Darling National Wildlife Refuge. For example, the friends organization paid catering services
for multiple meetings and covered costs for a tournament prize. We requested supporting
documentation, but the documentation the friends organization provided did not illustrate how
the refuge benefited from these expenditures. We also questioned 16 expenditures totaling
$2,143 for items such as meals and awards at Arthur R. Marshall Loxahatchee National Wildlife
Refuge. For example, the friends organization used donations for a holiday party and paid for a
nonmonetary award for an FWS employee. Again, the documentation the friends organization
provided did not show how the refuge benefited from these expenditures.
We found similar expenditures at Rocky Mountain Arsenal National Wildlife Refuge, Tualatin
River National Wildlife Refuge Complex, the Northwest National Fish Hatcheries, and the
Columbia River Gorge National Wildlife Refuges. Further, the refuges did not consult the FWS
ethics office for guidance regarding such purchases, which would assist the refuges in ensuring
purchases for meals and entertainment comply with ethics regulations 2 and benefit the refuge.
FWS policy does not specify management controls detailing how the FWS will exercise its
authority to oversee its friends organizations to ensure accountability for donations, revenues, or
expenditures. Instituting basic management controls would greatly enhance the FWS’ ability to
provide oversight for these partnerships, promote accountability for funds, and deter theft or other
misconduct.

1 We specifically requested financial information for the 10 friends organizations we visited or contacted. Initially, the FWS had
this information available for only one of the friends organizations; however, it was able to obtain additional information from
the organizations in some cases. In other cases, we had to go directly to the friends organizations to obtain the remaining
administrative and financial records we requested.
2 5 C.F.R. Subpart B – Gifts From Outside Sources.

5

Recommendations
We recommend that the FWS:
1. Develop and maintain an accurate and complete list of friends organizations
2. Review each friends organization on a regular basis to assess compliance with

friends program policies and procedures, effectiveness of internal controls, and
accountability for donations and expenditures

3. Develop and implement policies to establish accountability of friends

organization donations, revenues, and expenditures to ensure they benefit the
applicable refuge or hatchery (including requiring that friends provide an
annual performance report containing donations, revenues, and expenditures)

4. Develop a management plan, with the assistance of the FWS Ethics Office, to

monitor the program and ensure that money collected in support of the U.S.
Government is spent appropriately (including the use of funds to purchase
meals, entertainment, or other potentially impermissible items)

The FWS Did Not Maintain Required Friends Program
Documentation
We also found that many friends organizations currently operating on refuges and hatcheries do
not have the necessary documents (updated friends partnership agreements and evidence of
nonprofit status) required to participate in the friends program. These organizations are not in
compliance with current FWS policy.
The friends partnership agreement is the formal legal instrument that describes how the FWS and
each friends organization will work together to support the FWS’ mission. We found that the
FWS did not initiate new or convert old partnership agreements for many of its friends
organizations by April 2017 as required under current FWS policy (633 FW 3.3). Although the
policy is undergoing review for possible amendment, which may have delayed new partnership
agreements, we found that agreements existing under previous FWS policies remain in effect. In
addition, FWS policy (633 FW 4.3 B) states that all income-generating activities on FWS
property must be described in a partnership agreement between the FWS and the friends
organization. The FWS reported that 71 out of the estimated 193 friends organizations, or 37
percent, do not have approved current agreements. For example, two of the friends organizations
at refuges we visited—Friends of Northwest Hatcheries and Columbia Gorge Refuge Stewards—
were operating under outdated agreements. 3
FWS policy (633 FW 1.6 A (1)) requires friends organizations to have nonprofit status under 26
U.S.C. § 501(c)(3). The Internal Revenue Service’s website, however, showed that 45 FWS
friends organizations had either a revoked status or that the friends organizations had not
3

We found that the issue is most prevalent in FWS Regions 1, 3, 4, and 5.

6

submitted tax filings to maintain their status. When we followed up on these organizations, the
FWS identified four that were unable to demonstrate valid nonprofit status. We further sampled
10 of the remaining organizations and found 3 additional friends organizations without valid
nonprofit status. Therefore, the number is potentially much higher. Nonprofit status is critical
because it provides such benefits as State and Federal tax exemptions, the ability to receive public
and private donations along with tax benefits to donors, and opportunities to receive grants.
Recommendations
We recommend that the FWS:
5. Ensure that required friends program documents, including friends partnership

agreements and evidence of nonprofit status, are in place for all friends
organizations

6. Establish and implement a policy to periodically review required friends

program documents, including friends partnership agreements and evidence of
nonprofit status, to ensure they remain in force

7

Conclusion and Recommendations
Conclusion
Friends organizations play an important role in the FWS wildlife refuge and fish hatchery
systems and they are a vital component of the FWS’ outreach and volunteer efforts. As such, it is
imperative that the FWS effectively manage its friends program to ensure that these
organizations are functioning at the highest levels of accountability and effectiveness.
We concluded that the FWS did not ensure donations and revenues were fully accounted for and
spent in accordance with governing laws. As a result, the friends program is at risk for misuse
and mishandling of funds, and undetected violations of partnership agreements and program
regulation. By strengthening controls and oversight, the FWS can better ensure that donations to
friends organizations continue to support services at its fisheries and hatcheries.

Recommendations Summary
In response to our draft report, the FWS concurred with all six recommendations and provided
target dates and officials responsible for implementation (see Appendix 2 for the full FWS
response). Based on the FWS’ response, we consider one recommendation resolved and
implemented and five recommendations resolved but not implemented (see Appendix 3 for the
status of our recommendations).
The FWS’ response also included six financial and program management control initiatives that
should further enhance its oversight of friends organizations. These additional actions included
specific target dates and responsible officials. We commend the FWS for taking extra measures
to improve this important program.
We recommend that the FWS:
1. Develop and maintain an accurate and complete list of friends organizations
2. Review each friends organization on a regular basis to assess compliance with friends
program policies and procedures, effectiveness of internal controls, and accountability for
donations and expenditures
3. Develop and implement policies to establish accountability of friends organization
donations, revenues, and expenditures to ensure they benefit the applicable refuge or
hatchery (including requiring that friends provide an annual performance report
containing donations, revenues, and expenditures)
4. Develop a management plan, with the assistance of the FWS Ethics Office, to monitor the
program and ensure that money collected in support of the U.S. Government is spent

8

appropriately (including the use of funds to purchase meals, entertainment, or other
potentially impermissible items)
5. Ensure that required friends program documents, including friends partnership
agreements and evidence of nonprofit status, are in place for all friends organizations
6. Establish and implement a policy to periodically review required friends program
documents, including friends partnership agreements and evidence of nonprofit status, to
ensure they remain in force

9

Appendix 1: Scope and Methodology
Scope
We audited the U.S. Fish and Wildlife Service’s (FWS’) oversight of its friends program from
fiscal years 2015 through 2019.

Methodology
We conducted this performance audit in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions
based on our audit objective. We believe that the evidence obtained provides a reasonable basis
for our findings and conclusions based on our audit objective.
To accomplish our objective, we:
•

Gained a basic understanding of the FWS' management of its friends program by
reviewing the following:
•

Relevant laws, policies, and procedures

•

Budget, annual strategy, and program-related information

•

Partnership agreements between the FWS and friends organizations

•

Financial statements of the 10 FWS friends organizations we visited or
interviewed

•

Conducted high-level analysis of performance data related to the FWS friends program

•

Performed site visits and telephone interviews as necessary to familiarize ourselves with
the FWS friends program

•

Interviewed program officials and staff personnel; observed processes, as applicable; and
identified internal controls

•

Identified potential promising practices

•

Determined if the FWS has received prior audit coverage from external and internal
auditors related to its friends program.

Friends organization donations are classified as either direct or indirect. The FWS maintains and
expends direct donations (averaging $168,000 annually), while friends organizations maintain and

10

expend indirect donations (averaging millions of dollars annually). We tested both types of
donations and did not find issues with the directly donated funds. The findings described in this
report apply only to the indirect donations.
We visited the following wildlife refuges, fish hatcheries, and FWS regional offices:
•

Rocky Mountain Arsenal National Wildlife Refuge

•

Two Ponds National Wildlife Refuge

•

Leadville National Fish Hatchery

•

Arthur R. Marshall Loxahatchee National Wildlife Refuge

•

J.N. Ding Darling National Wildlife Refuge

•

Florida Panther National Wildlife Refuge

•

Steigerwald Lake National Wildlife Refuge

•

Tualatin River National Wildlife Refuge Complex

•

FWS Pacific Region (1), Portland, OR

•

FWS Mountain-Prairie Region (6), Denver, CO

We also contacted and interviewed personnel from:
•

FWS National Friends Organizations Program Office

•

FWS Fish and Aquatic Conservation Program, specifically the National Fish Hatchery
System

•

FWS Migratory Bird and Duck Stamp Program

•

FWS Urban Wildlife Conservation Program

•

FWS Ethics Program

•

U.S. Department of the Interior, Office of the Solicitor

•

FWS Regions 2, 3, 4, 5, 7, and 8

•

Leavenworth Fisheries Complex

•

Deep Fork National Wildlife Refuge

11

We also visited and reviewed documentation from the following friends organizations:
•

Founders & Friends of Two Ponds National Wildlife Refuge

•

Two Ponds Preservation Foundation

•

Friends of the Front Range Wildlife Refuges

•

Friends of the Leadville National Fish Hatchery

•

Columbia Gorge Refuge Stewards

•

“Ding” Darling Wildlife Society

•

Friends of the Florida Panther Refuge, Inc.

•

Friends of Loxahatchee National Wildlife Refuge

We contacted and reviewed documentation from the following friends organizations:
•

Friends of the Tualatin River National Wildlife Refuge

•

Friends of Northwest Hatcheries

We tested the operation of internal controls over the friends program related to our objective.
The FWS provided computer-generated data related to the program, which we used and tested
for completeness and accuracy.
During the audit, we used nonstatistical sampling to test the allowability of friends organization
expenditures. The sample helped us assess whether the transactions were incurred for the benefit
of the refuge or hatchery and were supported with source documentation. We did not project the
results of the tests to the total population of recorded transactions or evaluate the economy,
efficiency, or effectiveness of friends organization operations.

12

Appendix 2: Bureau Response
The U.S. Fish and Wildlife Service’s response follows on page 14.

13

United States Department of the Interior
FISH AND WILDLIFE SERVICE

In Reply Refer To:
FWS/MA/PERMA/RM/BP0354 79

August 3, 2020

Ms. Kimberly Elmore
Assistant Inspector General for Audits, Inspections, and Evaluations
U.S. Department of the Interior
Office of the Inspector General
1849 C Street, NW, MS 4428
Washington, DC 20240

Dear Ms. Elmore:
We greatly appreciate the draft OIG audit report and have worked closely with OIG staff to
provide the information requested. As noted in the draft audit report, Friends groups can play a
role in helping leverage capacity, serving as ambassadors to the public, and perfom1ing other
authorized functions. The Service's goal is to ensure these groups fulfill that role properly and in
accordance with laws, regulations, and policies.
The Service takes the recommendations provided by the OIG very seriously, and concurs with
and will build on the six OIG recommendations and implement significant financial management
and program management controls so that we will be able to account for donations, revenues and
expenditures and ensure these groups have the validated tax-exempt status they need. The
Service will develop and implement stringent new rep01iing and accountability standards to
measure program performance and work effectively with the Friends groups.
In addition to addressing the six OIG recommendations, the Service has made additional
commitments to ensure strong program management, oversight and accountability (enclosed).

Aurelia Skipwit
Director
U.S. Fish and Wildlife Service
Enclosure

14

OIG Recommendations:
1. Develop and maintain an accurate and complete list of Friends organizations.
Response: Concur. The Service recognizes that an accurate and complete list of participating
Friends organizations is essential to effective program administration and oversight.
Corrective Action: By August 1, 2020, the Service will update the inventory of participating
Friends organizations currently operating on refuges and hatcheries and confirm the status of the
necessary documents (updated Friends Partnership Agreements and evidence of nonprofit status)
required to participate in the program. By September 30, 2020, the Service will formally notify
any Friends organization that does not have the necessary documents in place that they must
comply with current policy or risk tennination of their operational relationship with the Service.
By December 31, 2020, the Service will tenninate its relationship with any Friends organization
not in compliance with current policy.
Responsible official: Chief, National Wildlife Refuge System
2. Review each Friends organization on a regular basis to assess compliance with Friends
program policies and procedures, effectiveness of internal controls, and accountability for
donations and expenditures.
Response: Concur. The Service recognizes that without collecting and reviewing basic program
information from its Friends organizations, it is difficult to proactively manage the program, hold
Friends organizations accountable as necessary, assess the state of the program and identify
whether emerging problems warrant attention.
Corrective Action: By August 30, 2020 the Service will initiate an infonnation collection
clearance from the Office of Management and Budget (0MB) to gather the detailed program
information requested. By September 30, 2020, the Service will draft revised policy to address
all recommendations. The policy will outline requirements for quarterly reviews at the station
level and more detailed annual reviews of select organizations by Service Headquarters. By
December 31, 2020, the Service will meet (either virtually or in-person) with the Board of
Directors of every participating Friends organization to review current agreements, share audit
findings and set expectations for future operating requirements. By March 1, 2021, the Service
will finalize revised policy.
Responsible official: Chief, National Wildlife Refuge System
3. Develop and implement policies to establish accountability of Friends organization donations,
revenues, and expenditures to ensure they benefit the applicable refuge or hatchery (including
requiring that friends provide an annual perfonnance report containing donations, revenues, and
expenditures).
Response: Concur. The Service recognizes the importance of having clear policies that allow
the Service to manage its Friends program to ensure that Friends organizations are functioning at
the highest level of accountability and effectiveness.

15

Corrective Action: By August 30, 2020 the Service will initiate an information collection
clearance from 0MB to gather the detailed program information requested. By September 30,
2020, the Service will draft revised policy to address all recommendations. The policy will
include requirements for each Friends organization to provide an annual performance report
cataloging donations, revenues and expenditures. By March 1, 2021, the Service will finalize
revised policy.
Responsible official: Chief, National Wildlife Refuge System
4. Develop a management plan, with the assistance of the Department of the Interior Ethics
Office in the Office of the Solicitor (DOI SOL Ethics Office), to monitor the program and ensure
that money collected in support of the U.S. Government is spent appropriately (including the use
of funds to purchase meals, entertaimnent, or other potentially impermissible items).
Response: Concur. The Service recognizes the importance of ensuring that donations, revenues
and expenditures are fully accounted for and spent in accordance with governing laws.
Corrective Action: By October 31, 2020, the Service will work with our assigned ethics officials
from the DOI SOL team to develop a draft management plan.
Responsible official: Chief, National Wildlife Refuge System
5. Ensure that required friends program documents, including Friends Partnership Agreements
and evidence of nonprofit status, are in place for all Friends organizations.
Response: Concur.
Corrective Action: Incorporated into corrective action #1.
Responsible official: Chief, National Wildlife Refuge System
6. Establish and implement a policy to periodically review required Friends program documents,
including Friends Partnership Agreements and evidence of nonprofit status, to ensure they
remain in force.
Response: Concur. The Service recognizes the importance having clear policy that requires
Friends organizations to have and maintain the necessary documents required to participate in
the program.
Corrective Action: By September 30, 2020, the Service will draft revised policy to address all
recommendations. The policy will include requirements for annual reviews of Friends program
documents and appropriate actions for non-compliance. By March 1, 2021, the Service will
finalize revised policy.
Responsible Official: Chief, National Wildlife Refuge System

16

Additional Service Commitments:
1. The Service will update its organic Friends Group policies and procedures to address the
six OIG recommendations mentioned above, as well as the additional Service
commitments below. The Service will develop draft policy for internal review by
September 30, 2020 and final policy by March 1, 2021.
Responsible Official: Chief, National Wildlife Refuge System
2. The Service will bring in robust analytics capability to track financial information
consistently and in a unified platfonn (current practice relies on paper copies maintained
at individual field stations or regions) and establish a centralized monitoring and tracking
system. By December 1, 2020, the Service will develop a platform for tracking financial
information.
Responsible Official: Chief, National Wildlife Refuge System
3. By August 30, 2020, the Service will establish an Executive Oversight Team with the
Deputy Director, Policy and Programs, ChiefNWRS, Assistant Director for Business
Management Operations, Senior Ethics Advisor from the DOI SOL office, and 2
Regional Directors to oversee all management improvement efforts, particularly the
financial management and reporting requirements.
Responsible Official: Deputy Director, Policy and Programs
4.

The Chief, NWRS will realign staffing to provide dedicated full-time program
management to support the Executive Oversight Team commitments. This support will
come from the full-time Friends National Coordinator, a position filled on March 16,
2020.
Responsible Official: Chief, National Wildlife Refuge System

5. Beginning on August 1, 2020, Chief, NWRS will provide monthly updates to the Deputy
Director who will then report to the Director to track progress on all commitments and
corrective actions.
Responsible Official: Chief, National Wildlife Refuge System
6. Beginning on September 30, 2020, to ensure transparency, the Director will provide
quarterly updates to the Assistant Secretary for Fish and Wildlife and Parks as well as a
final status report.
Responsible Official: Director

17

cc:

Assistant Secretary, Fish and Wildlife and Parks
Deputy Director, Policy and Programs
Deputy Director, Operations

18

Appendix 3: Status of Recommendations
In its response to our draft report (see Appendix 2), the U.S. Fish and Wildlife Service concurred
with all six recommendations. We consider one recommendation resolved and implemented and
the remaining five recommendations resolved but not implemented. Based on the response, we
will refer these five recommendations to the Office of Policy, Management and Budget (PMB)
for implementation tracking.
Recommendation

Status

Action Required

1

Resolved and
implemented

No additional action is required.

2–6

Resolved but not
implemented

We will refer these recommendations
to the PMB to track implementation.

19

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