TABLE OF CONTENTS
| Topics | Sections |
| OVERVIEW | 6.1 What is the purpose of this chapter? 6.2 What is the scope of this chapter? 6.3 What is the overall policy? 6.4 What are the authorities for this chapter? 6.5 What is the purpose of the management control program? 6.6 Who is responsible for the requirements in this policy? |
| MANAGEMENT CONTROL PROGRAM ORGANIZATION AND STRUCTURE | 6.7 What are the guidelines for the personal property Management Control Review (MCR) process? 6.8 How does the Service organize its personal property management control program? 6.9 What is the methodology for MCRs? |
| INDICATORS | 6.10 What are the management control indicators? |
| REPORTING AND CORRECTIVE ACTION | 6.11 How do MCR teams report findings? 6.12 How does the Service categorize deficient management controls? 6.13 What are the Service’s requirements for completing Corrective Action Plans? |
| ADDITIONAL INFORMATION | 6.14 Where can employees find additional information about MCRs? |
OVERVIEW
6.1 What is the purpose of this chapter? This chapter describes the U.S. Fish and Wildlife Service’s (Service) personal property management control program, including:
A. The purpose and guidelines for the Service’s personal property management controls and control reviews;
B. The personal property management control indicators, arranged by organization level; and
C. The post-review assessment, reporting, and response requirements.
6.2 What is the scope of this chapter? This chapter applies to all employees involved in the management of personal property that the Service owns or leases.
6.3 What is the overall policy? We implement controls to ensure the personal property program complies with laws, regulations, and policy.
6.4 What are the authorities for this chapter? See 310 FW 1 for a list of authorities for all the chapters in Part 310.
6.5 What is the purpose of the management control program? The management control program analyzes the effectiveness of our personal property program by establishing processes to:
A. Evaluate management of personal property across the Service against a common standard;
B. Establish oversight, evaluation, and internal audit processes to identify and mitigate risk and resolve deficiencies;
C. Identify issues that are beyond the control of those at the local level and require national-level resolution; and
D. Establish a trend review, a causal analysis, and open sharing of lessons learned across the Service.
6.6 Who is responsible for the requirements in this policy? See 310 FW 1 for a list of roles and responsibilities for all the chapters in Part 310.
MANAGEMENT CONTROL PROGRAM ORGANIZATION AND STRUCTURE
6.7 What are the guidelines for the personal property Management Control Review (MCR) process? In accordance with 290 FW 1, 2, and 3, the Assistant Director – Management and Administration or their designee(s) must:
A. Prepare an annual MCR plan, which identifies:
(1) Timeframes for the reviews, and
(2) Officials responsible for performing the reviews.
B. Oversee the MCR program, which includes:
(1) Ensuring the Joint Administrative Operations (JAO) organization reviews all cost centers over the course of a 3-year cycle, and
(2) Assessing MCR findings for trends and potential issues.
C. Establish and update the Service’s annual personal property management MCR priorities;
D. Provide training to conduct MCRs, as needed;
E. Ensure that staff select appropriate sample sizes for reviews as specified in 290 FW 3;
F. Report the status and results of MCRs using summary reports and assurance statements in accordance with Department of the Interior (Department) guidelines; and
G. Monitor corrective actions for progress and timely completion.
6.8 How does the Service organize its personal property management control program? We organize personal property MCRs into two levels, national and local.
A. At the national level, the Management Control Evaluator (MCE) is the JAO Branch Chief, Property Policy, or their designee, and is responsible for:
(1) Leading annual reviews of the personal property management program and Regional property every fiscal year so that every Region is reviewed at least once over the course of a 3-year cycle,
(2) Conducting periodic monitoring of the national-level personal property indicators listed in Table 6-1, and
(3) Notifying Regional leadership of on-site visits no later than 45 calendar days before the start of the review.
B. At the local level, the MCE is the JAO Branch Chief, Property Operations, or their designee, and is responsible for:
(1) Conducting annual reviews of approximately one-third of the cost centers from the targeted Regions from the national review each year,
(2) Reviewing those cost centers that had material weaknesses in the prior year’s review, and
(3) Notifying Regional and field station leadership of on-site local reviews no later than 45 calendar days before the start of the review.
C. MCEs assume primary responsibility for using the management control indicators listed in the annual MCR plan to perform the annual and periodic reviews and issuing a determination of the effectiveness of management controls for the organization they review.
6.9 What is the methodology for MCRs? MCR teams complete annual MCRs by conducting a combination of on-site reviews and remote data assessments. The MCE determines the need to evaluate the specific management control indicators in Table 6-1 remotely or on site.
A. If conducted, on-site assessments must include:
(1) Inspections of personal property to assess compliance with established policies, for example, random physical inventory of personal property assets documenting inventory control numbers, serial numbers, quantity, condition of property, and storage conditions;
(2) Reviews of electronic data found in the Financial and Business Management System (FBMS) and recorded Departmental forms and other documentation for anomalies and trend analysis; and
(3) Interviews to identify internal control weaknesses or best practices as determined by the evaluator.
B. Remote assessments may include:
(1) Reviews of electronic data found in FBMS and recorded Departmental forms and other documentation for anomalies and trend analysis;
(2) Phone or email interviews to collect information or identify internal control weaknesses as determined by the evaluator;
(3) Reviews of locally provided photo/video images of personal property assets documenting inventory control numbers, serial numbers, quantity, condition of property, and storage conditions; and
(4) Identifying and recording best practices across the field.
INDICATORS
6.10 What are the management control indicators? The personal property management control indicators are in Table 6-1. All categories are evaluated at the national and local level; review cycles vary.
Table 6-1: Management Control Indicators
| Category | Control Indicator |
| Determining the need for personal property | · Is the organization operating with the minimum investment in assets, consistent with the organization's needs? |
| Adding personal property to FBMS | · Is the organization following the property receiving process in accordance with established policy? · Are they completing Form DI-102, Receiving Report, and Form DI-105, Receipt for Property, to ensure acquisition information is accurate, complete, and entered into FBMS within the established timeframe? |
Managing personal property | · Is availability of appropriate and comprehensive personal property policies and procedures established? · Is staffing sufficient with proper organizational structure structure · Has the organization established a comprehensive training program appropriate for the duties of staff at all organizational levels? · Is there established oversight of the personal property function at an appropriate level to adequately monitor and review personal property management practices? · Is the portfolio of property assets in a condition to support mission requirements and provide a quality workplace? · Does the organization have a designated Accountable Property Officer and Custodial Property Officer to manage system-controlled personal property? Are their FBMS roles appropriate and up to date? · Is the organization performing an annual physical inventory using the FBMS inventory report? Does the process identify items that are not properly accounted for or asset candidates for disposition? · Does the organization use existing automated Service tools (e.g., FBMS) to file asset transactions (receipt, transfer, disposals) affecting their inventory and designation letters? · Does the organization have established procedures to manage new property issues and property clearance for incoming and departing employees? |
Disposing of personal property | · Is the organization conducting a utilization assessment to identify asset disposal requirements? · Is the organization filing disposal supporting records (Forms DI-103, Report of Survey; DI-103A, Certificate of Unserviceable Property; and DI-104, Transfer of Property, etc.) within FBMS such that the disposition method can be identified with all pertinent signatures? · Is the organization processing disposals within allocated timelines? · Is the organization properly disposing of excess personal property? |
| Performance review and improvement program | · Is the organization reviewing acquisition, disposal, and management documents to ensure compliance with policy and guidance? · Is the organization conducting interviews to ensure personnel are adhering to policy and guidance? · Is the organization reviewing property documents to identify deficiencies, and is it establishing trend profiles? |
REPORTING AND CORRECTIVE ACTION
6.11 How do MCR teams report findings? An MCE issues an initial report during the out-brief on the last day of the review and a final report after completing the review.
A. The initial report includes:
(1) An overview of the process,
(2) The testing approach and sampling techniques used, and
(3) A summary of the management control indicators reviewed.
B. The team provides an out-brief to the Regional office representative, Project Leader, or Accountable Property Officer on the last day of the on-site MCR before the site visit is considered complete. MCR out-briefs include:
(1) A list of all management control deficiencies identified, and
(2) An overview of suggested corrective actions.
C. The team completes the final report within 10 business days after the out-brief. The final MCR reports include:
(1) A detailed evaluation of the management control indicators reviewed,
(2) An assessment of management controls considered deficient based on guidance in 290 FW 3, and
(3) A list of corrective actions and a goal timeline that the cost center managers/leadership must complete.
6.12 How does the Service categorize deficient management controls? We categorize deficient management controls into three levels based on their severity in accordance with 290 FW 3:
A. Minor nonmaterial weaknesses are control deficiencies that can be corrected on the spot and do not need to be included in MCR out-briefs.
B. Significant nonmaterial weaknesses are control deficiencies that require more than on-the-spot correction. They should be included in MCR reports and out-briefs, but do not require a follow-up review.
C. Material weaknesses are control deficiencies that affect critical functions of the reviewed organization. They should be included in MCR reports and out-briefs and require a follow-up review in the following annual review period.
6.13 What are the Service’s requirements for completing Corrective Action Plans (CAP)? In accordance with 290 FW 3, cost centers must:
A. Develop a comprehensive CAP within 90 calendar days of the MCR or by the alternate timeframe specified in the report. The CAP includes information on who is responsible for each action item based on weaknesses listed in the final report;
B. Report completed corrective actions using FWS Form 3-2545, Personal Property Management Control;
C. Provide supporting documentation for the corrective actions for material weaknesses (although we encourage Project Leaders or Accountable Property Officers to use supporting documentation for corrective actions for nonmaterial weaknesses, it isn’t required); and
D. Demonstrate that all material weaknesses have been corrected in a follow-up review the following year.
ADDITIONAL INFORMATION
6.14 Where can employees find additional information about MCRs? The chapters in Part 290 of the Service Manual have more information about the Service’s management control program.