Issues Identified with State Practices in Subaward Administration for Wildlife and Sport Fish Restoration Program Grants

Under the Wildlife and Sport Fish Restoration Program, the U.S. Fish and Wildlife Service (FWS) provides grant funds to eligible States to conserve, restore, and manage wildlife and sport fish resources. States may provide Program funds to other non-Federal entities to accomplish or support grant-related activities. State officials must use judgment in determining whether these partnerships align more closely with the characteristics of a subaward of financial assistance to a subrecipient or of procurement from a contractor. Depending on the States’ determination, non-Federal entities are subject to differing criteria for accountability, profit taking, asset management, revenue management, and the treatment of indirect costs under Federal Uniform Grant Guidance. During our Program grant audits, we found instances in which the States did not apply Federal Uniform Grant Guidance consistently and accurately when providing Program funds to non-Federal entities. We also found that a number of States had not conducted or documented risk assessments for subrecipients, nor publicly reported major subawards. We make three recommendations to help the FWS promote consistency in how States administer Program funds and improve conformance with Federal regulations.