Sneak Preview: OIG Urges NPS To Maintain Award Documents

July 15, 2016 | By Jerry Ashworth | Post a Comment

xsass_bookshot(The following was excerpted from a recent article in the Single Audit Information Service.) The National Parks Service (NPS) did not maintain numerous required oversight documents in its grant files, and also failed to conduct pre-award risk assessments, relating to a cooperative agreement to clean up damage caused by Hurricane Sandy at the National Parks of New York Harbor, according to a recent Department of Interior (DOI), Office of Inspector General (OIG) audit.

In 2012, Hurricane Sandy affected 15 NPS sites in New York and New Jersey, including the National Parks of New York Harbor, which includes the Gateway National Recreation Area, Statue of Liberty and Ellis Island. In response to the disaster, NPS allocated funding under the Disaster Relief Appropriations Act of 2013 for cleanup projects to provide young people with educational and work opportunities. The NPS provided $1.65 million to Student Conservation Association, Inc., through an existing “master cooperative agreement” arrangement the nonprofit association received from NPS in 2009.

A master cooperative agreement is one with a recipient in which more than one project is anticipated. The master cooperative agreement is not funded, but establishes the overarching terms and conditions agreed to by NPS. Projects based on the master agreement’s terms are funded through “task agreements,” which are issued under the applicable legal authority documented in the master agreement. The master cooperative agreement with the Student Conservation Association for Hurricane Sandy cleanup had three task agreements — the first funded project planning, development and recruitment in 2013; the second funded further recruitment and the placement of volunteers to begin cleanup in 2013; and the third funded cleanup efforts in 2014.

To ensure that DOI awards meet Office of Management and Budget (OMB) requirements and DOI regulations and policies, the agency requires NPS officials to complete a checklist of key documentation to be kept with the grant file.

“Including key documentation in the grant file and using an internal review process serves as controls that aid in verifying compliance with policies and procedures,” OIG stated.

The OIG, however, found NPS’s Northeast Region Grants Office did not adequately implement such controls. It found numerous instances in which documentation in the files was incomplete. The missing documentation ranged from NPS’s lack of obtaining required signatures to its failure to document that it performed pre-award risk assessments. In other cases, NPS did not maintain documentation that it conducted a budget analysis. “By failing to maintain accurate award files, the potential may exist for increased opportunities of fraud, waste and mismanagement of federal funds,” OIG added.

(The full version of this story has now been made available to all for a limited time on Thompson’s Grants Compliance Expert site.)

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