NATIONAL WILDLIFE REFUGE ASSOCIATION

DEPARTMENT OF THE INTERIOR National Wildlife Refuge Systems Enhancements - CFDA No. 15.654 2019-002 - Building Relevance for the National Wildlife Refuge System Award No.F15AC00246 Grant period: September 1, 2015 through March 31, 2019 - Criteria: The Uniform Guidance (section 200.331 of Subpart D) requires all pass-through entities to clearly identify to the subrecipient at the time of the subaward that the funds are a subaward of federal funds, applicable award information, and compliance requirements. - Condition: The grant documents provided to subrecipients did not include information regarding the CFDA title and number, award name and number, name of the federal awarding agency, and compliance requirements.- Cause: Grant funds were provided to subrecipients and they were notified of the applicable criteria verbally, but it was not documented in the grant documents provided - Effect: Communicating the required information verbally could lead to a subrecipient unaware the grant is federal funds. If the subrecipient organization changes staff or doesn't properly inform individuals working on the grant then they could be unaware of the requirements. - Context: The Refuge Association awarded seven subrecipients grant awards within the major program during the fiscal year. All of these expenditures were selected during the test of compliance. In all instances, required information was missing from the grant documents. - Recommendation: We recommend that all subrecipient award documents include the CFDA title and number, award name and number, name of the federal awarding agency, and compliance requirements. We recommend that the subrecipient signs the document acknowledging they are aware of the federal requirements and agree to the terms before funds are disbursed. The Refuge Association should consider developing a standardized grant agreement template required for all subrecipient awards. - Views of Responsible Officials: Awards to subrecipients were properly recorded using signed financial agreements with required accounting of how funding received was used. We agree with the finding and have amended procedures to communicate when funding is federal to subrecipients.

FINDINGS - FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF THE INTERIOR SIGNIFICANT DEFICIENCY 2019-002 ? National Wildlife Refuge System Enhancements ? CFDA No. 15.654 Recommendation: We recommend that all subrecipient award documents include the CFDA title and number, award name and number, name of the federal awarding agency, and compliance requirements. We recommend that the subrecipient signs the document acknowledging they are aware of the federal requirements and agree to the terms before funds are disbursed. The Refuge Association should consider developing a standardized grant agreement template required for all subrecipient awards. Action Taken: The National Wildlife Refuge Association has updated the subrecipients Memorandum of Understanding (MOU) template to include the name of the federal agency the funds originate from and the CFDA number. Moving forward, this template will be utilized for all subrecipients MOU?s.