The National Wildlife Refuge Association and Coalition of Refuge Friends and Advocates hosted a discussion with U.S. Fish and Wildlife Service (USFWS) on the Federal Register notice about collecting information from Friends groups and updating of the Friends policy on January 5, 2021.
One component of updating the USFWS’ Friends Policy is ensuring that the USFWS has approval from the Office of Management and Budget (OMB) to collect information from Friends groups. While the updated policy will describe what information the USFWS may collect, this process ensures we have the approval to do so. The two processes are occurring simultaneously.
Obtaining OMB approval is a public process that requires input from those affected by the information collection. The proposed information collection was announced in a Federal Register notice and comments were accepted through January 8, 2021.
Why the Office of Management and Budget (OMB) approval is needed,
What types of information collections are proposed,
The overall process,
How to comment on the proposal,
History of the Friends policy (how we got to where we are),
Broad changes addressed in the draft policy, and
How USFWS will distribute the draft policy and how to comment
Here is a recording of the webinar and supporting materials.
The US Fish and Wildlife Service (FWS) has numerous policies that provide guidance and administrative procedures for FWS employees partnering with Friends organizations. These policies are the bases for the Friends Partnership Agreement and affect the roles and responsibilities of the partners.
CORFA has compiled a list of the policies we are aware of and suggest Friends board members review them to enhance your knowledge of the policies guide FWS employees.
Coalition of Refuge Friends and Advocates (CORFA) and the National Wildlife Refuge Association (NWRA) urge Friends to respond to the notice in the Federal Register about collecting documentation from their organizations. Friends input is necessary to guide the US Fish and Wildlife Service (USFWS) in the collection of information in support of our mutual goals and objectives. They may also influence revisions to the Friends policy and Friends Partnership Agreement (FPA).
These revisions would be the result of the Office of Inspector General (OIG) audit report of the USFWS Friends program. A finding of the OIG implies that FWS does not know if Friends are using donations appropriately. FWS agreed to take corrective actions to improve oversight of the program. These actions will include revising the policy and FPA to:
Establish accountability with respect to donations, revenues, and expenditures to ensure they benefit the applicable refuge or hatchery;
Require Friends to provide an annual performance report including donations, revenues, and expenditures, and
Periodically review the FPA and evidence of nonprofit status.
The revisions to the policies and FPA have the potential of impacting Friends organization’s practices and procedures.
Reflect your understanding of the documentation FWS is requesting,
List documentation Friends can provide FWS to assure them that funds raised for the benefit of your site are being properly accounted for,
Indicate how Friends would document the value to your refuge/hatchery of your programs and activities,
Assess the accuracy of FWS’ estimate of the time it will take to collect the documentation,
Describe ways to enhance the quality of the information, and
Suggest how to minimize the burden of providing the information.
The CORFA and NWRA have drafted comments to submit and Friends are welcome to review and borrow them. We do, however, want any comments submitted by Friends groups and members to be unique and particular to your specific refuge or hatchery—comments submitted through Federal Register requests are ore highly ranked if they are not the same as the other comments.
The deadline to comment is January 8, 2021.
Reference OMB Control Number “1018-Friends” in the subject line of your comments. The easiest and most direct way to submit your comments is to email comments directly to: Info_Coll@fws.gov.
You can also mail your comments to the Service Information Collection Clearance Officer, U.S. Fish and Wildlife Service, MS: PRB (JAO/3W), 5275 Leesburg Pike, Falls Church, VA 22041-3803 (mail)
*There is a direct link to submit comments in the Federal Register announcement, but this link does NOT work.*
We urge Friends groups and members of their board to submit comments. Every Friends group, FWS site, and partnership in the Friends community is unique. Your comments need to represent your unique circumstance. FWS wants to hear from you!
Regards, Coalition of Refuge Friends and Advocates National Wildlife Refuge Association
As a Friend board member are you ready to protect your organization’s assets? Every member of the board has the fiduciary responsibility to treat the nonprofit organization’s assets and other resources with the same care with which they would treat their own resources. This is part of a board member’s legal Duty of Care.
Willem Stoeller’s webinar on financial management and record-keeping for Friends organizations, with annual revenues of less than $50,000, takes the mystery out of this subject. Below you will find the recording and supporting documents: