Media Kit: DCNR Ignored its Internal Policies and Procedures When Awarding Grants for Conservation Projects
Auditor General Timothy L. DeFoor’s recent audit of the Pennsylvania Department of Conservation and Natural Resources’ (DCNR) Community Conservation Partnerships Program (C2P2) highlighted that the agency has not consistently followed its own policies and procedures when awarding grants.
The audit found that although the C2P2 program was advertised as competitive, certain grants were not competitively awarded. Auditors also found that there were some inconsistencies with the monitoring of a federally funded program.
Our auditors did find that DCNR improved in some aspects from our prior 2013 audit. However, more work needs to be done. Overall, the department made seven recommendations to DCNR to help them enhance the program in Pennsylvania.
Audit
Objectives of the Audit
The audit had three objectives:
- Determine whether DCNR complied with applicable laws, regulations, internal policies, guidelines, and manual relevant to the awarding of C2P2 grant monies;
- Determine whether the C2P2 funds and grant expenditures are accurate, adequately supported, and used for their intended purpose; and
- Ensure that DCNR adequately monitored each grantees’ performance, ensured proper submission of progress reports, and performed post-completion site inspections required for certain C2P2 projects as stipulated by applicable laws, regulations, program requirements, guidelines and manuals.
Audit Findings
Finding 1: While DCNR claims its C2P2 grant award process is competitive, certain grants were not competitively awarded. Opportunities exist to enhance accountability and transparency in DCNR’s grant award process.
We found that although the C2P2 grant program is structured and advertised as a competitively awarded grant process, not all C2P2 grants were awarded based on the project evaluation scoring and the ranking process set forth in the program guidelines. Our review of 40 selected projects found instances where DCNR did the following: accepted grant applications submitted late and awarded grants for those projects; awarded grants to lower-ranked projects instead of projects ranked higher; and executive management awarded grants for certain projects regardless of the BRC recommendations and project rankings, suggesting other factors may have impacted those decisions, such as outside influence or pressure.
We offer two recommendations to DCNR: (1) improve the C2P2 grant award process to ensure grants are competitively awarded by only considering applications submitted prior to the application submission deadlines and amending its grant manual to more accurately reflect the actual awarding process by including any other factors, such as targeted priorities that DCNR intends to apply during the grant application evaluation process; and (2) changing the current practices to eliminate the appearance of outside influence or pressure during the project selection process, such as removing the legislative districts from the list of projects recommended/not recommended for selection.
Finding 2: DCNR improved its monitoring of C2P2 grant expenditures and should continue to evaluate its procedures to identify and implement changes that strengthen its grants process.
We found that DCNR’s conversion to a new electronic records system improved its oversight of C2P2 grant expenditures. We found that for projects completed after the conversion, DCNR properly maintained all required records within the electronic grant project files in the Recreation and Conservation Electronic Records System (RACERS) database. However, we discovered that DCNR lacked certain documents in the hardcopy files maintained for older grants that closed during the audit period. DCNR also updated its standard operating procedures (SOPs) to require grantees to upload certain documents through RACERS, but only for certain project types. Grantees may submit only summary lists of expenditures for other project types.
We offer two recommendations to DCNR: (1) amend the grant project management SOPs and grant agreements to require grantees to electronically submit sufficient documentation to support all grant expenditures, and (2) ensure project files are complete with all required documentation.
Finding 3: Despite some monitoring improvements with LWCF-funded C2P2 grant projects, DCNR failed to adequately oversee inspection, documentation, and reporting requirements.
We found that DCNR failed to provide adequate oversight of LWCF-funded C2P2 grant projects, which resulted in noncompliance with federal inspection and reporting requirements. DCNR’s inadequate oversight of its LWCF monitoring activities resulted in the failure to conduct post-completion site inspections within the required five-year timeframe for 47 LWCF projects, report 85 LWCF post-completion site inspections to the U.S. National Park Service (U.S. NPS) and maintain adequate LWCF post-completion site inspection documentation.
We offer three recommendations to DCNR: (1) improve oversight of LWCF post-completion site inspections to ensure all inspections are conducted timely, (2) ensure that all LWCF post-completion site inspections are reported annually according to U.S. NPS policy, and (3) document the supervisory review process over LWCF post-completion site inspections to improve accountability and accuracy of inspection records required to be maintained consistent with DCNR policy.
Appendices
Appendix D: DCNR C2P2 Grant Application Scoring Guidelines
The scoring guidelines are included in Appendix D of this audit.
Appendix F: C2P2 Grants Awarding Processes
The Community Conservation Partnerships Program (C2P2) grants awarding process at the Pennsylvania Department of Conservation and Natural Resources (DCNR) begins with electronic application submissions during the specified submission period. After the submission deadline, the Bureau of Recreation and Conservation (BRC) evaluates each grant application/project and assigns a score using BRC’s project scoring guidance documents. It ranks the projects by type and score. According to the C2P2 grant manual, the highest scored projects will be selected for funding until available funds are exhausted.
BRC prepares a comprehensive list of projects indicating which it recommends for a grant and which it does not recommend based on rankings and available funding. BRC consults with DCNR’s executive management to finalize a list of approved projects with the proposed grant award amounts. DCNR receives the Governor’s approval before publicly announcing the grants awarded. The following flowchart summarizes the grant awards process from application submission to the public grant awards announcement. The results of our review of DCNR’s C2P2 grant awarding process are presented in Finding 1.
C2P2 Grant Awards Process Chart
Answers to FAQs
What is the C2P2 program?
The Community Conservation Partnerships Program (C2P2) provides recreation opportunities for Pennsylvanians while improving and protecting the commonwealth’s natural resources. The program is administered by the Department of Conservation and Natural Resources (DCNR) and provides grants to municipalities, non-profit organizations, and other community-based organizations.
What did the audit find?
The findings include:
- While DCNR claims its C2P2 grant award process is competitive, certain grants were not competitively awarded;
- DCNR improved its monitoring of C2P2 grant expenditures and should continue to evaluate its procedures to identify and implement changes that strengthen its grants process; and
- Despite some monitoring improvements with Land and Water Conservation Fund (LWCF)-funded C2P2 grant projects, DCNR failed to adequately oversee inspection, documentation, and reporting requirements.
How can DCNR improve the program?
The audit report outlined seven recommendations for DCNR to implement to improve the program in Pennsylvania.
When was the audit period?
The audit period was July 1, 2021, through June 30, 2023.
What is an objective?
An objective outlines the specific goals or purpose of an audit.
What is a finding?
A finding explains what the auditor learned through the examination. A finding has five parts:
- 1) Condition: What is the issue or problem the auditor found?
- 2) Cause: Why did the issue or problem happen?
- 3) Criteria: What is our reason for flagging the issue or problem?
- 4) Effect: What’s the impact and why is it important?
- 5) Recommendation: How can the issue or problem be solved?
Have additional questions? Visit our Answers to FAQs webpage.
Press Conference Resources
Press Release
Access the official press release announcing this audit.
Photos
Commonwealth Media Services offers photos from the press conference on their website: PAcast.com
Audio/Video
Commonwealth Media Services offers audio and video clips, as well as a full recording of the press conference, on their website: PAcast.com
Contact
Gabrielle Alberigi Ernst, Deputy Director of Communications at the Pennsylvania Department of the Auditor General: 717-787-1381 or news@paauditor.gov