ATP audit finds contract-reimbursement practices generally compliant, recommends formal procedures and controls

Internal audit staff reported to the board that a review of contract reimbursements found the organization’s contracting language generally aligns with federal guidance and positions staff to perform thorough invoice review, but identified several opportunities to strengthen controls.

Chief Audit Executive Katie Houston told the board the audit focused on contracts eligible for federal reimbursement and concluded that, broadly, expenditures were reasonable, necessary and potentially allocable to the transit project. "All of that comprehensive guidance says that our expenditures need to be reasonable, necessary, and able to be allocated to the transit project that the FTA may fund," the audit report stated.

Recommendations include: (1) formalizing documented operating procedures and a quality-control review for procurement staff doing invoice reviews; (2) ensuring finding-and-determination memos and critical approval documentation are shared with invoice reviewers and finance; (3) implementing a relocation-approval/control process and a relocation agreement similar to practices at peer agencies; and (4) establishing periodic validation of per-diem/travel expenses by sampling retained backup documentation.

Management concurred with the recommendations and said corrective actions are planned, with certain positions and controls already in process. The audit noted management aims to implement corrective actions by July next year and has already added a quality-control reviewer.