Management Control for Quarters

TABLE OF CONTENTS

OVERVIEW

7.1 What is the purpose of this chapter? This chapter describes the U.S. Fish and Wildlife Service’s (Service) requirements and policies for the quarters management control program, including:

A. The purpose and guidelines for the Service’s quarters management controls and control reviews;

B. The quarters management control indicators, arranged by organization level; and

C. The post-review assessment, reporting, and response requirements.

7.2 What is the scope of this chapter? This chapter applies to all employees involved in the management of quarters that the Service owns, leases, or manages through other means (e.g., service level agreements).

7.3 What is the overall policy? We implement controls to ensure the quarters program is in compliance with laws, regulations, and policy.

7.4 What are the authorities for this chapter? See 371 FW 1 for a list of authorities for all the chapters in Part 371.

7.5 What is the purpose of the management control program? The management control program serves to analyze the effectiveness of the quarters program by establishing processes to:

A. Evaluate quarters across the Service against a common standard;

B. Establish oversight, evaluation, and internal audit processes to identify, mitigate, and resolve deficiencies;

C. Identify issues that are beyond the control of those at the local or Regional level and require national-level resolution;

D. Establish a trend review, a causal analysis, and open sharing of lessons learned across the Service; and

E. Establish standard Servicewide functional checklists to consistently assess the effectiveness of Service quarters personnel and the processes they use to manage the quarters.

7.6 Who is responsible for the requirements in this policy? See 371 FW 1 for a list of roles and responsibilities for all the chapters in Part 371.

QUARTERS MANAGEMENT CONTROL PROGRAM

7.7 What are the guidelines for the quarters Management Control Review (MCR) process? In accordance with 290 FW 1, 2, and 3, the Chief, Division of Contracting and General Services (CGS) or their designee 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 that Headquarters reviews all Regions, and that Regions review all of their field stations 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 quarters MCR priorities;

D. Provide training to conduct MCRs, as needed;

E. Ensure that national and Regional 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.

7.8 How does the Service structure its quarters management control program? We organize quarters MCRs into the following levels:

A. National reviews of Servicewide quarters management practices,

B. Regional reviews of Regional quarters management practices, and

C. Local reviews of field stations’ quarters management practices.

7.9 When does the Service perform quarters MCRs? We conduct quarters MCRs annually so that each Region and field station is reviewed at least once every 3 fiscal years. The Service also performs periodic monitoring of national-level quarters performance indicators.

7.10 How does the Service perform annual quarters MCRs? We perform MCRs at each level using MCR teams.

A. MCR teams, led by a Management Control Evaluator (MCE), evaluate the management control indicators listed in the management control plan.

B. National and Regional managers appoint MCEs to lead MCR teams. MCEs bear primary responsibility for issuing a determination of the effectiveness of management controls for the organization they review. MCEs are appointed as follows:

(1) For national reviews, the Chief, CGS, or their designee (other than the National Quarters Officer [NQO]) is the MCE,

(2) For Regional reviews, the NQO is the MCE, and

(3) For local reviews, the RQO or other designated CGS and program personnel serve as the MCE as described in the annual plan.

7.11 How does the Service perform periodic monitoring of national-level quarters management indicators?

A. MCR teams periodically monitor macro-level quarters management indicators. The Chief, CGS, or their designee periodically monitors the national indicators in Table 7-1, and the NQO periodically monitors the Regional indicators in the table.

B. MCR teams evaluate five categories of management control indicators:

(1) Determining the need for quarters,

(2) Adding quarters to the inventory,

(3) Managing quarters,

(4) Managing tenants, and

(5) Disposing of quarters.

7.12 What is the methodology for MCRs? MCR teams complete annual MCRs by conducting a combination of on-site and remote assessments and virtual data analysis. The MCE determines whether to evaluate the specific management control indicators in Table 7-1 on-site or remotely.

A. On-site assessments include:

(1) Inspections of quarters to assess compliance with established policies;

(2) Reviews of electronic data found in the internet Quarters Management Information System (iQMIS) and the Financial and Business Management System (FBMS) for anomalies and trend analysis; and

(3) Interviews to identify internal control weaknesses as determined by the evaluator.

B. Remote assessments include:

(1) Reviews of electronic data found in iQMIS and FBMS for anomalies and trend analysis;

(2) Phone or email interviews to collect information or identify internal control weaknesses as determined by the evaluator; and

(3) Reviews of locally provided photos/video images of building exteriors and interiors documenting building type, number of rooms, accommodations, and conditions.

C. Virtual data analysis includes reviews of electronic data found in iQMIS and the FBMS for anomalies and trend analysis.

NATIONAL, REGIONAL, AND LOCAL REVIEWS AND THE MANAGEMENT CONTROL INDICATORS

7.13 What are the management control indicators? The quarters management control indicators are listed in Table 7-1. The table denotes what indicators are considered at the national, Regional, and local levels and whether the indicators are evaluated annually or periodically.

Table 7-1: Management Control Indicators at the Local Level

7.14. How does the Service structure national reviews? The Chief, CGS (or their designee) serves as the MCE for national-level MCRs for the Service’s quarters program and is responsible for:

A. Leading annual reviews of quarters personnel at the national level, and

B. Conducting periodic monitoring of national-level quarters indicators listed in Table 7-1.

7.15 How does the Service structure Regional reviews? The NQO serves as the MCE for all Regional-level MCRs and is responsible for:

A. Leading annual reviews for three Regions every fiscal year so that every Region is reviewed at least once over the course of a 3-year cycle,

B. Conducting periodic monitoring of Regional-level quarters indicators listed in Table 7-1, and

C. Notifying Regional leadership of on-site visits no later than 45 calendar days before the start of the review.

7.16 How does the Service structure local reviews? The RQO serves as the MCE for local level reviews.

A. RQOs conduct annual reviews of approximately one-third of their Regions’ field stations each year, focusing on those stations that had material weaknesses in the prior year’s review.

B. The NQO may conduct joint reviews with RQOs in the Regions where they are performing Regional reviews:

(1) For field stations receiving a routine review on a 3-year cycle, and

(2) For a select number of stations with material weaknesses in the prior year’s review.

C. The RQOs must notify field station leadership of on-site Regional and local reviews no later than 15 calendar days before the start of the review.

REPORTING AND CORRECTIVE ACTION

7.17 How do MCR teams report findings from annual MCRs? An MCE issues an initial MCR report during the MCR, an MCR out-brief on the last day of the review, and a final MCR report after completing the review.

A. The MCR team provides an initial MCR report to field station leadership at the beginning of the MCR. The initial report includes:

(1) An overview of the MCR process,

(2) The testing approach and sampling technique used, and

(3) A summary of the controls that will be reviewed.

B. The MCR team provides an out-brief to the Project Leader/supervisor on the last day of the on-site MCR. The Project Leader/supervisor must meet with the MCE and review the MCR out-brief 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 MCR team completes the final MCR report within 5 business days after approval of the MCR out-brief and sends the final report to the reviewed location’s Project Leader/supervisor. 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 to be completed by field station management.

7.18 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 MCR visit.

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 visit in the following annual review period.

7.19 What are the Service’s requirements for completing Corrective Action Plans (CAP)? In accordance with 290 FW 3, field stations must:

A. Develop a comprehensive CAP within 180 days of the MCR or by the alternate time frame 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 3-2147, Certification of Completed Corrective Action;

C. Provide supporting documentation for the corrective actions for material weaknesses (although we encourage Project Leaders/supervisors 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 MCR the following year.

ADDITIONAL INFORMATION

7.20 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.

7.21 Who should employees contact with questions about quarters MCRs? Employees may contact their RQO or the NQO with additional questions about the quarters MCR program.