This audit report by the Office of Inspector General summarizes the following:
1) FTA's oversight of NYCT's use of Hurricane Sandy relief funds was insufficient and did not ensure funds were used properly according to FTA requirements.
2) The audit found that NYCT drew down $17.7 million for procurement actions that were deemed ineligible by FTA, and spent the funds on out-of-scope work.
3) FTA's oversight reviews also failed to ensure that most of NYCT's change orders were approved as required by FTA policy, putting remaining relief funds at risk.
This document provides a summary of a proposed loan from the Inter-American Development Bank to the government of Peru to support the "SEDAPAL Water for All Program" being implemented by SEDAPAL, the water and sewer utility company for Lima and Callao. The program aims to expand access to water and sanitation services for low-income groups. Specifically, the $50 million loan would help finance 9 infrastructure projects serving an estimated 1.2 million people. The loan terms and conditions, program details, execution arrangements, and potential risks and benefits are described over the course of the document.
The document discusses the recommendations of the 13th Finance Commission related to disaster management in India. It summarizes the key recommendations, which include merging existing funds into a National and State Disaster Response Fund, allocating funds for mitigation activities and pooled procurement of disaster response equipment, and providing a grant of Rs. 525 crores for capacity building activities like developing disaster management plans. Guidelines were issued by the Ministry of Finance and Home Affairs on the constitution and administration of the National and State Disaster Response Funds based on the 13th Finance Commission recommendations.
Gao defense nuke safety board not transparent gao-15-181PublicLeaks
Until recently, the Defense Nuclear Facilities Safety Board (DNFSB) had few written policies and procedures governing the activities of its Board members and technical staff. It also did not fully document its internal control assessment activities or publicly disclose the results of Board votes. While DNFSB has begun developing new policies and procedures, it did not meet statutory deadlines to obtain an Inspector General to provide independent oversight of its operations.
A boy who bullied the author's friend was made to write that he would never bully anyone again. Their teacher then ensured that no one in the class would bully others or they would be in trouble. The document encourages not bullying others by hurting them with words or actions, as that hurts people's feelings, and instead treating everyone respectfully without trouble.
Natural disasters such as earthquakes, volcanoes, tidal waves, and drought can destroy life and property. Earthquakes are measured by their magnitude on the Richter scale or Modified Mercalli scale, with higher magnitudes causing more damage. Volcanoes form when magma rises up through ruptures in the earth's crust. Tidal waves, also known as tsunamis, are actually not tidal but are instead caused by displacement of water. Droughts are periods of below average precipitation that result in shortages of atmospheric, surface, or ground water supply.
This document provides an overview of various storage technologies and concepts, including:
1) Disk array controllers that manage I/O to improve performance and protect against disk failures. Tape libraries evolved to provide common power and handling for multiple tape drives.
2) Network attached storage (NAS) allows file sharing across a network by making remote files appear local. Storage arrays combine disk arrays and provide common management of storage capacity.
3) Storage area networks (SANs) connect computer systems and storage using a switched network infrastructure, allowing storage access without direct physical connections. Disk and virtual tape libraries use disk arrays for backup and recovery.
This document provides a summary of a proposed loan from the Inter-American Development Bank to the government of Peru to support the "SEDAPAL Water for All Program" being implemented by SEDAPAL, the water and sewer utility company for Lima and Callao. The program aims to expand access to water and sanitation services for low-income groups. Specifically, the $50 million loan would help finance 9 infrastructure projects serving an estimated 1.2 million people. The loan terms and conditions, program details, execution arrangements, and potential risks and benefits are described over the course of the document.
The document discusses the recommendations of the 13th Finance Commission related to disaster management in India. It summarizes the key recommendations, which include merging existing funds into a National and State Disaster Response Fund, allocating funds for mitigation activities and pooled procurement of disaster response equipment, and providing a grant of Rs. 525 crores for capacity building activities like developing disaster management plans. Guidelines were issued by the Ministry of Finance and Home Affairs on the constitution and administration of the National and State Disaster Response Funds based on the 13th Finance Commission recommendations.
Gao defense nuke safety board not transparent gao-15-181PublicLeaks
Until recently, the Defense Nuclear Facilities Safety Board (DNFSB) had few written policies and procedures governing the activities of its Board members and technical staff. It also did not fully document its internal control assessment activities or publicly disclose the results of Board votes. While DNFSB has begun developing new policies and procedures, it did not meet statutory deadlines to obtain an Inspector General to provide independent oversight of its operations.
A boy who bullied the author's friend was made to write that he would never bully anyone again. Their teacher then ensured that no one in the class would bully others or they would be in trouble. The document encourages not bullying others by hurting them with words or actions, as that hurts people's feelings, and instead treating everyone respectfully without trouble.
Natural disasters such as earthquakes, volcanoes, tidal waves, and drought can destroy life and property. Earthquakes are measured by their magnitude on the Richter scale or Modified Mercalli scale, with higher magnitudes causing more damage. Volcanoes form when magma rises up through ruptures in the earth's crust. Tidal waves, also known as tsunamis, are actually not tidal but are instead caused by displacement of water. Droughts are periods of below average precipitation that result in shortages of atmospheric, surface, or ground water supply.
This document provides an overview of various storage technologies and concepts, including:
1) Disk array controllers that manage I/O to improve performance and protect against disk failures. Tape libraries evolved to provide common power and handling for multiple tape drives.
2) Network attached storage (NAS) allows file sharing across a network by making remote files appear local. Storage arrays combine disk arrays and provide common management of storage capacity.
3) Storage area networks (SANs) connect computer systems and storage using a switched network infrastructure, allowing storage access without direct physical connections. Disk and virtual tape libraries use disk arrays for backup and recovery.
Indian monuments represent the outstanding facets of Indian culture through their elaborate architecture and wonderful designs. They showcase unbelievable artistry and craftsmanship from eras past, as seen in landmarks like the Taj Mahal, Red Fort, and temples in Khajuraho. Monuments in India have become pillars of cultural heritage and an inspiration for future generations. The United Arab Emirates both preserves historical traditions in small desert villages and creates modern history through cities like Dubai and Abu Dhabi. UAE monuments commemorate both the past and future in a spirit of pride and possibility rather than as representations of people or events. Visitors are advised to maintain awareness while traveling in the UAE.
Los planes de inmunización pueden servir para obtener sueros con alto contenido de anticuerpos, desarrollar vacunas que generen una respuesta inmune protectora, o producir anticuerpos monoclonales para su uso como reactivos o terapias. Se debe diseñar un protocolo que incluya la vía de administración, dosis, tiempos entre dosis y monitoreo para lograr la respuesta inmune deseada. Los anticuerpos monoclonales ofrecen ventajas como producción ilimitada y estabilidad, aunque también presentan desafíos
This document defines and categorizes different types of polygons. It discusses rectangles, squares, triangles, rhombuses, parallelograms, trapezoids and kites. It further breaks down triangles into isosceles, equilateral and scalene triangles based on their angles. Triangles are also categorized as acute, right or obtuse angled based on the measure of their interior angles. The document was written by Devina Vinay in 4th grade.
La redacción de textos es importante porque ayuda a entender las ideas principales de una lectura, expresar dichas ideas de manera clara y establecer objetivos sobre el tema. La redacción de un texto utilizando herramientas como ensayos, informes y resúmenes permite comprender, analizar y expresar las ideas y conclusiones de una lectura.
Ensayo formacion de los alumnos para el futurosjbm29
Este documento discute la importancia de preparar a los estudiantes para el futuro a través de la integración de la tecnología en la educación. Señala que los maestros deben incorporar dispositivos y software educativos en sus programas de enseñanza para que los estudiantes puedan desarrollar las habilidades necesarias para funcionar en una sociedad cada vez más tecnológica. También enfatiza la necesidad de enseñar valores éticos y el uso responsable de la tecnología. Concluye que la formación de los estudiant
Este documento presenta un cuadro comparativo sobre el uso de diferentes medios de comunicación como la radio, la televisión, la prensa, el cine y los videos en las aulas dominicanas. Explica que aunque estos medios tienen un gran potencial educativo y se usan en algunas escuelas, su uso generalmente es limitado debido a falta de recursos o conocimiento sobre cómo integrarlos efectivamente en la enseñanza. Resalta la necesidad de que los maestros aprovechen más estas herramientas para enriquecer el aprendizaje de los estudiantes
Los planes de inmunización pueden servir para obtener sueros con alto contenido de anticuerpos, desarrollar vacunas que generen una respuesta inmune protectora, y producir anticuerpos monoclonales que puedan usarse como reactivos o terapéuticos. Las vacunas se clasifican dependiendo del microorganismo que contengan, ya sea entero, muerto, atenuado, fracciones o subunidades. La inmunización puede ser pasiva a través de sueros hiperinmunes o activa mediante la vacunación.
El documento describe los software educativos, incluyendo su definición como programas para ordenador creados para ser usados como medios didácticos que imitan la labor tutorial de los profesores. Explica que tienen características como adaptarse al ritmo individual de cada estudiante, ser interactivos y fáciles de usar. Además, destaca la importancia de los software educativos para permitir que los estudiantes usen el computador con fines de aprendizaje y para que los maestros integren ejercicios interactivos que motivan a los estudiantes.
The document profiles Tina Winham and her accomplishments. It discusses how she overcame a lack of strong female role models in her childhood and took control of her destiny. She has served in leadership roles for organizations that empower women and children, including the Junior League of Northwest Arkansas and the Northwest Arkansas Women's Shelter. Recently, she was named to the board of directors for the Association of Junior Leagues International, becoming the first woman from Arkansas to serve in this role. Tina is passionate about empowering women and uses her own experiences to be a role model for others.
A very slanted report concocted by the hard-left Democrat Thomas DiNapoli, currently Comptroller in New York State. The partisan "audit"/report is meant to cast doubt on the safety of proposed shale pipelines in the state. It is a transparently, laughable mish mash of innuendo.
TrailBlazer claimed Medicare Part B administrative costs in accordance with Federal requirements. An audit of TrailBlazer's cost proposals for the period of October 2008 through March 2011 found that the $24,425,018 in claimed costs were reasonable, allowable, and allocable based on Federal Acquisition Regulation Part 31 and TrailBlazer's contract with CMS. The audit activities included reconciling cost proposals to accounting records, analytical tests, sampling expenses, and ensuring costs were allowable, allocable, and reasonable.
ARTBA Comments on FHWA/FTA Environmental Review Process Guidance artba
The American Road and Transportation Builders Association (ARTBA) submitted comments in support of the Federal Highway Administration's (FHWA) and Federal Transit Administration's (FTA) revised guidance on the environmental review process. ARTBA represents 6,000 members involved in transportation construction and maintenance. The revised guidance implements changes from the MAP-21 Act to streamline the environmental review process, including setting deadlines, establishing alternative dispute resolution, and penalties for delays. ARTBA supports these changes to reduce the excessive time currently required to complete environmental reviews, which can take over a decade to complete and involves numerous overlapping laws and agencies.
The Hawaii Health Connector's board and management wasted millions of public funds through poor procurement practices and contract administration related to contracts with Mansha Consulting. An audit found the Connector hastily awarded over $21 million in sole-source contracts to Mansha without properly analyzing fees or ensuring Mansha was qualified. It also failed to properly manage the contracts, lacking oversight of Mansha's work and deliverables. This mismanagement constituted an abuse of public funds. The Connector agreed with many of the audit's findings and has worked to improve its procurement and contract management.
Open Government Directive - Spending Transparency 04062010dslunceford
The document provides guidance on improving the transparency of federal spending data. It establishes an October 1, 2010 deadline for agencies to begin sub-award reporting and to improve the quality, completeness and accuracy of spending data on the USAspending.gov website. Agencies will be required to monitor and report on metrics to measure progress in improving data quality over time, with a goal of 100% complete, accurate and timely data by the end of FY2011. OMB will issue additional guidance to help agencies implement sub-award reporting and will work with them to enhance transparency of federal spending information.
The document is a letter submitted by the American Road and Transportation Builders Association (ARTBA) providing comments on the U.S. Department of Transportation's proposed rules for implementing the Moving Ahead for Progress in the 21st Century Act (MAP-21). ARTBA represents 6,000 members involved in planning, designing, constructing, and maintaining transportation infrastructure. The letter makes several recommendations, including that DOT should focus on implementing the specific goals outlined in MAP-21, establish performance measures tied to these goals, improve transparency and accountability in reporting project benefits to taxpayers, and integrate transportation planning with the environmental review process to reduce delays.
Federal Acquistion Regulation Preliminary Regulatory Reform PlanObama White House
The Federal Acquisition Regulatory Council has drafted a preliminary plan for retrospectively analyzing existing acquisition rules as required by Executive Order 13563. The plan outlines the scope, which includes government-wide acquisition rules in the Federal Acquisition Regulation. It discusses opportunities for public input and lists eight initial initiatives for review over the next two years, including examining rules around communications with vendors, reducing sole-source contracts, past performance reviews, and conflicts of interest. The goal is to identify rules that could be simplified, strengthened, or repealed to more efficiently meet objectives of taxpayer value, public trust, and policy goals.
This document discusses social impact bonds (SIBs) and how they relate to public-private partnerships (PPPs) for infrastructure delivery. It notes that while interest in SIBs is growing, only a few are currently operating in the US. It argues that SIBs can help transfer performance risk from the public to private sector, address the "wrong pockets" problem by capturing value across agencies, help build an evidence base for innovative programs, and provide reliable funding for social service providers to scale up. However, it also notes that risk transfer through SIBs may increase costs and constrain future spending. Officials considering SIBs need to carefully analyze each project to ensure public value over traditional delivery. Lessons from PPP
Federal Acquisitionr Regulatory Reform Plan August 2011Obama White House
The document outlines the Federal Acquisition Regulatory Council's final plan for retrospectively analyzing existing procurement rules as required by Executive Order 13563. The plan will involve identifying significant rules that are obsolete, unnecessary, unjustified or excessively burdensome. Public input will be sought to help reform rules and reduce burdens. Current retrospective review efforts already underway include analyzing rules around organizational conflicts of interest, small business contracting, obtaining fair prices, and contract closeout. The plan scope covers government-wide acquisition rules in the Federal Acquisition Regulation.
The Hawai'i Health Connector board's inadequate planning led to an unsustainable health exchange. The board failed to finalize a strategic plan and could not agree on what the exchange should be. As a result, operating costs were too high for Hawai'i's small uninsured population. Additionally, the Connector did not properly procure and manage IT contracts, circumventing procurement policies. This put $204 million in federal grants at risk due to questionable costs and lack of compliance with regulations. The audit found Hawai'i enrolled less than 15% of its enrollment target, ranking it 46th nationally for exchange participation.
Indian monuments represent the outstanding facets of Indian culture through their elaborate architecture and wonderful designs. They showcase unbelievable artistry and craftsmanship from eras past, as seen in landmarks like the Taj Mahal, Red Fort, and temples in Khajuraho. Monuments in India have become pillars of cultural heritage and an inspiration for future generations. The United Arab Emirates both preserves historical traditions in small desert villages and creates modern history through cities like Dubai and Abu Dhabi. UAE monuments commemorate both the past and future in a spirit of pride and possibility rather than as representations of people or events. Visitors are advised to maintain awareness while traveling in the UAE.
Los planes de inmunización pueden servir para obtener sueros con alto contenido de anticuerpos, desarrollar vacunas que generen una respuesta inmune protectora, o producir anticuerpos monoclonales para su uso como reactivos o terapias. Se debe diseñar un protocolo que incluya la vía de administración, dosis, tiempos entre dosis y monitoreo para lograr la respuesta inmune deseada. Los anticuerpos monoclonales ofrecen ventajas como producción ilimitada y estabilidad, aunque también presentan desafíos
This document defines and categorizes different types of polygons. It discusses rectangles, squares, triangles, rhombuses, parallelograms, trapezoids and kites. It further breaks down triangles into isosceles, equilateral and scalene triangles based on their angles. Triangles are also categorized as acute, right or obtuse angled based on the measure of their interior angles. The document was written by Devina Vinay in 4th grade.
La redacción de textos es importante porque ayuda a entender las ideas principales de una lectura, expresar dichas ideas de manera clara y establecer objetivos sobre el tema. La redacción de un texto utilizando herramientas como ensayos, informes y resúmenes permite comprender, analizar y expresar las ideas y conclusiones de una lectura.
Ensayo formacion de los alumnos para el futurosjbm29
Este documento discute la importancia de preparar a los estudiantes para el futuro a través de la integración de la tecnología en la educación. Señala que los maestros deben incorporar dispositivos y software educativos en sus programas de enseñanza para que los estudiantes puedan desarrollar las habilidades necesarias para funcionar en una sociedad cada vez más tecnológica. También enfatiza la necesidad de enseñar valores éticos y el uso responsable de la tecnología. Concluye que la formación de los estudiant
Este documento presenta un cuadro comparativo sobre el uso de diferentes medios de comunicación como la radio, la televisión, la prensa, el cine y los videos en las aulas dominicanas. Explica que aunque estos medios tienen un gran potencial educativo y se usan en algunas escuelas, su uso generalmente es limitado debido a falta de recursos o conocimiento sobre cómo integrarlos efectivamente en la enseñanza. Resalta la necesidad de que los maestros aprovechen más estas herramientas para enriquecer el aprendizaje de los estudiantes
Los planes de inmunización pueden servir para obtener sueros con alto contenido de anticuerpos, desarrollar vacunas que generen una respuesta inmune protectora, y producir anticuerpos monoclonales que puedan usarse como reactivos o terapéuticos. Las vacunas se clasifican dependiendo del microorganismo que contengan, ya sea entero, muerto, atenuado, fracciones o subunidades. La inmunización puede ser pasiva a través de sueros hiperinmunes o activa mediante la vacunación.
El documento describe los software educativos, incluyendo su definición como programas para ordenador creados para ser usados como medios didácticos que imitan la labor tutorial de los profesores. Explica que tienen características como adaptarse al ritmo individual de cada estudiante, ser interactivos y fáciles de usar. Además, destaca la importancia de los software educativos para permitir que los estudiantes usen el computador con fines de aprendizaje y para que los maestros integren ejercicios interactivos que motivan a los estudiantes.
The document profiles Tina Winham and her accomplishments. It discusses how she overcame a lack of strong female role models in her childhood and took control of her destiny. She has served in leadership roles for organizations that empower women and children, including the Junior League of Northwest Arkansas and the Northwest Arkansas Women's Shelter. Recently, she was named to the board of directors for the Association of Junior Leagues International, becoming the first woman from Arkansas to serve in this role. Tina is passionate about empowering women and uses her own experiences to be a role model for others.
A very slanted report concocted by the hard-left Democrat Thomas DiNapoli, currently Comptroller in New York State. The partisan "audit"/report is meant to cast doubt on the safety of proposed shale pipelines in the state. It is a transparently, laughable mish mash of innuendo.
TrailBlazer claimed Medicare Part B administrative costs in accordance with Federal requirements. An audit of TrailBlazer's cost proposals for the period of October 2008 through March 2011 found that the $24,425,018 in claimed costs were reasonable, allowable, and allocable based on Federal Acquisition Regulation Part 31 and TrailBlazer's contract with CMS. The audit activities included reconciling cost proposals to accounting records, analytical tests, sampling expenses, and ensuring costs were allowable, allocable, and reasonable.
ARTBA Comments on FHWA/FTA Environmental Review Process Guidance artba
The American Road and Transportation Builders Association (ARTBA) submitted comments in support of the Federal Highway Administration's (FHWA) and Federal Transit Administration's (FTA) revised guidance on the environmental review process. ARTBA represents 6,000 members involved in transportation construction and maintenance. The revised guidance implements changes from the MAP-21 Act to streamline the environmental review process, including setting deadlines, establishing alternative dispute resolution, and penalties for delays. ARTBA supports these changes to reduce the excessive time currently required to complete environmental reviews, which can take over a decade to complete and involves numerous overlapping laws and agencies.
The Hawaii Health Connector's board and management wasted millions of public funds through poor procurement practices and contract administration related to contracts with Mansha Consulting. An audit found the Connector hastily awarded over $21 million in sole-source contracts to Mansha without properly analyzing fees or ensuring Mansha was qualified. It also failed to properly manage the contracts, lacking oversight of Mansha's work and deliverables. This mismanagement constituted an abuse of public funds. The Connector agreed with many of the audit's findings and has worked to improve its procurement and contract management.
Open Government Directive - Spending Transparency 04062010dslunceford
The document provides guidance on improving the transparency of federal spending data. It establishes an October 1, 2010 deadline for agencies to begin sub-award reporting and to improve the quality, completeness and accuracy of spending data on the USAspending.gov website. Agencies will be required to monitor and report on metrics to measure progress in improving data quality over time, with a goal of 100% complete, accurate and timely data by the end of FY2011. OMB will issue additional guidance to help agencies implement sub-award reporting and will work with them to enhance transparency of federal spending information.
The document is a letter submitted by the American Road and Transportation Builders Association (ARTBA) providing comments on the U.S. Department of Transportation's proposed rules for implementing the Moving Ahead for Progress in the 21st Century Act (MAP-21). ARTBA represents 6,000 members involved in planning, designing, constructing, and maintaining transportation infrastructure. The letter makes several recommendations, including that DOT should focus on implementing the specific goals outlined in MAP-21, establish performance measures tied to these goals, improve transparency and accountability in reporting project benefits to taxpayers, and integrate transportation planning with the environmental review process to reduce delays.
Federal Acquistion Regulation Preliminary Regulatory Reform PlanObama White House
The Federal Acquisition Regulatory Council has drafted a preliminary plan for retrospectively analyzing existing acquisition rules as required by Executive Order 13563. The plan outlines the scope, which includes government-wide acquisition rules in the Federal Acquisition Regulation. It discusses opportunities for public input and lists eight initial initiatives for review over the next two years, including examining rules around communications with vendors, reducing sole-source contracts, past performance reviews, and conflicts of interest. The goal is to identify rules that could be simplified, strengthened, or repealed to more efficiently meet objectives of taxpayer value, public trust, and policy goals.
This document discusses social impact bonds (SIBs) and how they relate to public-private partnerships (PPPs) for infrastructure delivery. It notes that while interest in SIBs is growing, only a few are currently operating in the US. It argues that SIBs can help transfer performance risk from the public to private sector, address the "wrong pockets" problem by capturing value across agencies, help build an evidence base for innovative programs, and provide reliable funding for social service providers to scale up. However, it also notes that risk transfer through SIBs may increase costs and constrain future spending. Officials considering SIBs need to carefully analyze each project to ensure public value over traditional delivery. Lessons from PPP
Federal Acquisitionr Regulatory Reform Plan August 2011Obama White House
The document outlines the Federal Acquisition Regulatory Council's final plan for retrospectively analyzing existing procurement rules as required by Executive Order 13563. The plan will involve identifying significant rules that are obsolete, unnecessary, unjustified or excessively burdensome. Public input will be sought to help reform rules and reduce burdens. Current retrospective review efforts already underway include analyzing rules around organizational conflicts of interest, small business contracting, obtaining fair prices, and contract closeout. The plan scope covers government-wide acquisition rules in the Federal Acquisition Regulation.
The Hawai'i Health Connector board's inadequate planning led to an unsustainable health exchange. The board failed to finalize a strategic plan and could not agree on what the exchange should be. As a result, operating costs were too high for Hawai'i's small uninsured population. Additionally, the Connector did not properly procure and manage IT contracts, circumventing procurement policies. This put $204 million in federal grants at risk due to questionable costs and lack of compliance with regulations. The audit found Hawai'i enrolled less than 15% of its enrollment target, ranking it 46th nationally for exchange participation.
The Department of the Treasury released a plan for retrospectively analyzing existing rules in accordance with Executive Order 13563. The plan calls for an annual opportunity for public input on specific regulations that should be updated. Treasury bureaus will evaluate public suggestions and prioritize review projects, selecting some for a fast-track review. The plan covers regulations and guidance from Treasury bureaus including the IRS, FinCEN, and U.S. Mint. Treasury is already undertaking regulatory reforms through IRS paperwork reduction initiatives and ensuring electronic payments of federal benefits that are estimated to save over $120 million annually.
Contract monitoring is a continual process that ensures compliance with the terms and conditions of a contract arrangement. It typically consists of administrative, fiscal, and program components. Effective contract monitoring is important for ensuring proper expenditure of funds and accountability. It requires establishing standards for reviewing subcontractors, conducting regular scheduled and unscheduled reviews, and integrating internal and external review processes.
The document proposes establishing a Government Investment Enterprise (GIE) to create a national foreclosure mitigation program. The GIE would hold equity investments in single-family residences to help restore the mortgage market. It would use existing TARP and GSE funds, without requiring new funding. The current foreclosure crisis is prolonged due to inefficiencies in programs like HAMP that often do not find an optimal solution for all parties. The proposed GIE aims to better match borrower ability with holder criteria to find a balanced solution and stabilize the housing market.
Running head EXERCISE 4-15 CAFR OKLAHOMA1EXERCISE 4-15 CAFR.docxcowinhelen
Running head: EXERCISE 4-15 CAFR OKLAHOMA 1
EXERCISE 4-15 CAFR 7
Exercise 4-15
Kerry Bolander
Dec. 9th, 2016
Oklahoma State
Governmental Activities
Governmental activities increased the state's net position by $1.3 billion. Tax revenues were down in four of the five major types. Total revenues for governmental activities were down by $449.5 million, or 2.3%, in 2015. The state showed a $147.9 million increase in individual income taxes, a $45.0 million decrease in sales taxes, a $51.0 million decrease in corporate income taxes, a $93.5 million decrease in Federal Grant revenue, and a $79.0 million decrease in gross production taxes during 2015 (Adams, Potter, Singh, & York, 2016).
These activities are normally recorded and reported in different column when it comes to the financial statements which may be in terms of General commitment bonds, directed by the state treasurer, are approved and issued principally to give assets to state-possessed capital upgrades, including office structures for state agencies. The state has promised 100% of cigarette expenses gathered under these bond issues. General commitment bonds are supported by the full confidence and credit of the state, including the state's energy to impose extra expenses to guarantee reimbursement of the bonds.
Asset and liability in the Oklahoma Department of Transportation (ODOT) has issued several arrangements of Grant Anticipation Notes with the end goal of financing certain qualified government help transportation extends in the state. The notes are secured by government income got from the Federal Highway Administration (FHWA) and have a last development in 2019. Add up to income got from the FHWA in monetary year 2015 was $622,566,000with a bit of that sum, $51,079,000, held as security for the notes. Current year note commitments for vital and intrigue totalled $18,605,000. ODOT likewise reported defeased notes payable, exceptional at June 30, 2015, totalling $114,387,000 for foremost, intrigue and trustee charges (Souder, 2016).
In information on government expenses can be in state of capital leases where the state has gone into understandings to rent hardware. Such understandings are, in substance, buys (capital rents) and are accounted for as capital rent commitments. Capital rent commitments are accounted for those leases where the equitable estimation of the rented resource at beginning of the rent is $25,000 or more.
General fund
When it comes to general fund a number of statements and schedules come up in different ways and means. The differences between the original budget and the final amended budget amounted to $102.0 million with $53.6 million (52.5%) coming from budget carryovers from fiscal year 2014, and the remaining $48.4 million (47.5%) was attributable to supplemental appropriations. The difference between the final budget and the actual collections amounted to $192.5 million less than the budget. Based on a review by the budget departme ...
The document provides information on the Transitional Funding Mechanism (TFM) established by the Global Fund Board to replace Round 11 funding due to inadequate resources. Key points:
1) TFM will provide limited, temporary funding to prevent disruption of essential health services in countries with existing Global Fund grants until new funding is available.
2) Applications are due by March 31, 2012 and will be approved on a rolling basis depending on available resources.
3) Eligibility criteria and processes from prior funding rounds still apply, with some adjustments for TFM. Funding will prioritize continuity of essential prevention, treatment, and care services.
The document provides information on the Transitional Funding Mechanism (TFM) established by the Global Fund Board to replace Round 11 funding due to inadequate resources. Key points:
1) TFM will provide limited, temporary funding to prevent disruption of essential health services in countries with existing Global Fund grants until March 2014.
2) Funding amounts cannot be guaranteed and will depend on donations. Commitments may be staggered and varied to best utilize available resources.
3) Eligibility criteria and application/review processes have been modified for TFM, focusing on continuation of core prevention, treatment, and care services.
Frequency of lawsuits has increased dramatically in recent periods, with over 50% more in the last two quarters than in the three previous review periods combined, accounting for 12% of all actions in the last year. This trend of financial institutions refusing to settle and forcing regulators to sue is evident in several high-visibility suits.
ARTBA Comments on the Federal Accounting Standard Board’s Disclosure Requirem...artba
The American Road & Transportation Builders Association (ARTBA) submitted comments in response to the Federal Accounting Standards Advisory Board's (FASAB) proposed disclosure requirements for public-private partnerships (P3s). ARTBA represents over 6,000 members involved in transportation infrastructure and advocates for P3s. While agreeing that transparency is important, ARTBA expressed concerns that the proposal did not sufficiently define key terms like "significant exposure" and included disclosing remote contingencies and business risks. ARTBA suggested revising the standards to address these issues and clarifying the definition of P3s to reflect key features like long-term agreements and performance-based payments in transportation projects. ARTBA also disagreed with permitting aggregated disclosures,
Pennsylvania Public Utility Commission Act 13/Impact Fees Audit by PA Auditor...Marcellus Drilling News
A biased look at how 60% of impact fees raised from PA's shale drilling are spent, by the anti-drilling PA Auditor General. He chose to ignore an audit of 40% of the impact fees, which go to Harrisburg and disappear into the black hole of Harrisburg spending. The Auditor General claims, without basis in fact, that up to 24% of the funds are spent on items not allowed under the Act 13 law.
HPD Audit: Processing Deficiencies In The 9/11 Residential Grant ProgramAngie U. Leung
This HPD audit report of Lower Manhattan Development Corporation (2003) emphasized the deficiencies and incompetence of the company where I worked. It states how each department is responsible, and for the lack of duties, had crippled and disabled the entire community of their grant funds. There was under-payment, double-payment, over-payment and even non-payment. I've now finally solved the "Biggest Clue Game" I've ever engaged through these pages.
As I write as one of the workers behind the scenes- It was because of the negligence, the uncooperative different departments and miscommunication through chain of command, and problems were found yet unsolved for it fell on deaf ears, 9/11 LMDC Residential Grant left many immobilized and many happier. Eventually, HPD and Homeland Security became troublesome!
Now I understand why my job was so hard no matter how much I tried or how long I worked, my skill in problem solving has even helped catch a few fraud cases- but I am only one person and my authority is limited. I was also bombarded by countless phone-calls from applicants asking the whereabouts of their grant money but I did my best I could. Sadly, I finally "get it" upon reading this audit report after all these years.
Similar to FTA Oversight of Hurricane Sandy Relief Funds_Final Report^7-21-16 (20)
HPD Audit: Processing Deficiencies In The 9/11 Residential Grant Program
FTA Oversight of Hurricane Sandy Relief Funds_Final Report^7-21-16
1. Office of Inspector General
Audit Report
FTA CAN IMPROVE ITS OVERSIGHT OF
HURRICANE SANDY RELIEF FUNDS
Federal Transit Administration
Report Number: ZA-2016-077
Date Issued: July 21, 2016
2. MemorandumU.S. Department of
Transportation
Office of the Secretary
of Transportation
Office of Inspector General
Subject: INFORMATION: FTA Can Improve Its
Oversight of Hurricane Sandy Relief Funds
Federal Transit Administration
Report Number ZA-2016-077
Date: July 21, 2016
From: Mary Kay Langan-Feirson
Assistant Inspector General for
Acquisition and Procurement Audits
Reply to
Attn. of: JA-60
To: Federal Transit Administrator
In October 2012, Hurricane Sandy caused widespread damage to the
transportation infrastructure in the mid-Atlantic and northeastern United States. In
response, the President signed the Disaster Relief Appropriations Act (DRAA) in
January 2013, which appropriated $10.9 billion to the Federal Transit
Administration’s (FTA) Public Transportation Emergency Relief Program (ERP)
for Sandy-related recovery, relief, and resiliency programs. As of
November 30, 2015, FTA had obligated nearly $4.6 billion and disbursed
$1.16 billion. FTA’s top four grantees1
received $1.14 billion of the $1.16 billion
in disbursed funds. The Metropolitan Transportation Authority (MTA) received
$821 million, or 70 percent, of those funds. Of MTA’s subsidiaries, New York
City Transit (NYCT) holds the majority of MTA’s DRAA-funded contracts.2
DRAA directs our office to support oversight of FTA’s Hurricane Sandy relief
funds. Accordingly, we conducted this audit to determine whether FTA provides
effective oversight of grantees’ contracting practices using DRAA funds. We
focused our review on NYCT because it was one of the largest recipients of
MTA’s Hurricane Sandy relief funds.
We conducted this audit according to generally accepted Government auditing
standards. To conduct our work, we used a risk-based approach to select 9 out of
37 DRAA-funded NYCT contracts to review NYCT’s procurement practices and
1
The other grantees are New Jersey Transit, the Port Authority of New York/New Jersey (PANYNJ), and the Port
Authority Trans Hudson (a subsidiary of PANYNJ).
2
For the purposes of this document, we will refer to MTA and its subsidiary, NYCT, collectively as NYCT where
appropriate.
3. 2
FTA’s oversight.3
These 9 contracts represented $190 million—or 86 percent—of
the 37 NYCT contracts, valued at $220 million. We reviewed Federal
requirements, FTA guidance, and MTA and NYCT policies and procedures. We
also interviewed FTA, MTA, and NYCT personnel. Exhibit A further details our
scope and methodology.
RESULTS IN BRIEF
FTA’s oversight practices do not fully ensure that NYCT uses DRAA funds
properly and in compliance with FTA procurement requirements. While FTA
responded quickly and effectively to Hurricane Sandy by assessing the damage
and assisting impacted transit agencies, our review identified two areas of concern
with FTA’s oversight. Specifically, FTA lacks the needed controls to verify that
NYCT only uses DRAA funds for eligible expenditures and does not ensure that
NYCT obtains approval for change orders per FTA policy. For two of the nine
contracts we reviewed, NYCT drew down $17.7 million in DRAA funds for
procurement actions that were ineligible for inclusion in a grant. NYCT made
these drawdowns even after FTA had determined they were not eligible. In
addition, NYCT spent these DRAA funds on out-of-scope work, which is not
permissible under FTA policies. FTA was unaware that the funds had been drawn
because it lacks processes to follow up on potential risk items, such as
expenditures denied for grant inclusion, as they become known. We notified FTA
of our findings, and FTA officials issued a letter to NYCT requesting that it return
the $17.7 million in improper payments.
FTA’s oversight reviews also did not prevent or detect most of the non-compliant
change order approvals we identified. Of the 205 change orders we reviewed,4
valued at $49 million, 154 change orders, valued at about $25 million,5
were not
approved per FTA policy. Proper approval by the recipient’s authorized officials is
required to ensure that all additional work and incurred costs are authorized before
work begins.6
However, we found instances in which NYCT (1) directed the
contractor to begin work on change orders without prior management approval, (2)
lacked documentation in change order approvals to show compliance with FTA
policy, and (3) issued a blanket approval for multiple change orders.7
Although
MTA’s integrity monitors and FTA periodically review NYCT’s change orders,
these reviews do not focus on whether the authorized official approved the change
3
As of October 31, 2014.
4
From the 9 NYCT contracts we selected, we reviewed all of the Hurricane Sandy-related change orders, which
amounted to 205 change orders totaling $49 million.
5
Of these change orders, 56 change orders, totaling $14.5 million, are part of the $17.7 million that NYCT drew down,
which FTA determined to be ineligible for inclusion in a grant.
6
According to FTA grant policy, an authorized grantee official must approve all change orders before they are issued.
FTA Circular 4220.1F, II(2)a1.
7
FTA policy requires appropriate approval before issuing any change order. Though FTA policy does not explicitly
restrict blanket approvals, it does not explicitly allow them either.
4. 3
orders before issuance as required by FTA policy. In general, these reviews focus
on scope, reasonableness, and work justifications. As a result of these oversight
gaps, FTA risks future improper payments of the remaining Hurricane Sandy relief
funds.
We are making recommendations to improve FTA’s oversight of NYCT’s
contracting practices using DRAA funds.
BACKGROUND
In April 2013, FTA issued an ERP Toolkit for FTA staff to use as a reference to
ensure successful obligation and expenditure of relief funds. These tools stress
performing risk assessments, enhancing oversight that is tailored to specifically
identified risks, and reviewing grantee payments (drawdowns). The Toolkit
includes FTA’s Hurricane Sandy Disaster Relief Oversight Plan, which outlines a
risk-based oversight framework for allocating oversight resources and tools. Key
goals in FTA’s Hurricane Sandy Disaster Relief Oversight Plan include ensuring
FTA has adequate internal controls to detect improper payments and ensuring that
grantees comply with Federal requirements.
According to the FTA Sandy Oversight Plan, grantees receiving over $100 million
in DRAA funds are required to establish integrity monitors to conduct several
project monitoring activities including periodic forensic reviews of payments and
change orders.8
To meet this requirement, MTA established the MTA Independent
Monitoring Implementation Plan in November 2013. According to MTA
representatives, MTA divided integrity monitoring duties, based on the dollar
amount associated with the change orders, between its Office of Audit Services
and Office of the MTA Inspector General.9
Our initial report on FTA’s oversight of ERP and Hurricane Sandy relief funds,
issued in December 2013, recognized that FTA responded quickly and effectively
to Hurricane Sandy by assessing the damage, assisting impacted transit agencies,
and developing oversight plans.10
However, we noted that FTA’s Hurricane Sandy
Disaster Relief Oversight Plan lacked specificity in key areas and that FTA needed
to put into practice its risk-based framework, outlined in the Hurricane Sandy
Disaster Relief Oversight Plan, to ensure relief funds were properly distributed and
spent. We made nine recommendations, which FTA has since resolved. In June
2015, we reported that FTA had not fully implemented the processes and internal
8
FTA’s Federal Register Notice, Second Allocation of Public Transportation Emergency Relief Funds in Response to
Hurricane Sandy: Response, Recovery & Resiliency, March 29, 2013.
9
Specifically, MTA Inspector General personnel review change orders valued between $100,000 and $1 million, while
MTA Office of Audit Services personnel review change orders over $1 million.
10
Initial Assessment of FTA’s Oversight of the Emergency Relief Program and Hurricane Sandy Relief Funds (OIG
Report Number MH-2014-008), Dec. 3, 2013. OIG reports can be found on our Web site at: https://www.oig.dot.gov/.
5. 4
controls it established for the award and oversight of Hurricane Sandy funds in
response to DRAA and Federal guidelines.11
We also noted that several factors
slowed the pace of fund awards and grantee expenditures. FTA is addressing our
recommendations from the June 2015 report.
FTA’S OVERSIGHT PRACTICES DO NOT FULLY ENSURE THAT
NYCT USES DRAA FUNDS PROPERLY AND IN COMPLIANCE
WITH FTA PROCUREMENT REQUIREMENTS
FTA’s oversight practices do not fully ensure that NYCT uses DRAA funds
properly and in compliance with FTA procurement requirements. FTA lacks
sufficient controls to verify that NYCT only uses DRAA funds for eligible costs.
In addition, FTA oversight does not verify that NYCT’s change orders are
approved per FTA policy. As a result, FTA risks future improper payments of the
remaining Hurricane Sandy relief funds.
FTA Lacks Sufficient Controls To Verify That NYCT Only Uses DRAA
Funds for Eligible Costs
NYCT drew down $17.7 million in DRAA funds for procurement actions even
after FTA determined the actions were not eligible to be included in a grant. In
addition, NYCT spent these DRAA funds on out-of-scope work, which is not
permissible under FTA policies.
Key goals in FTA’s Hurricane Sandy Oversight Plan include ensuring that FTA
has adequate internal controls to detect improper payments and that grantees
comply with Federal requirements. FTA has taken actions to oversee NYCT’s use
of DRAA funds. These include conducting triennial, financial management
oversight, and procurement system reviews and requiring grantees to establish
integrity monitors to review payments and change orders. FTA’s oversight
reviews have found NYCT to be a high-risk grantee in the areas of financial
management, procurement, grants management, project management, and
construction management.12
However, until our review, FTA was unaware that NYCT had used these DRAA
funds for ineligible procurement actions. This is because—even when alerted to a
potential risk item as in this case—FTA lacks sufficient controls to follow up on
potential risk items, such as expenditures that have been denied for grant
inclusion, as they become known. This puts FTA at risk of making improper
payments with the remaining Hurricane Sandy relief funds.
11
FTA Has Not Fully Implemented Key Internal Controls for Hurricane Sandy Oversight and Future Emergency Relief
Efforts (OIG Report Number ST-2015-046), June 12, 2015.
12
Hurricane Sandy Disaster Relief: Grantee Risk Assessment, New York Metropolitan, October 1, 2013, and 2013
NYCT Grant Oversight Assessment, July 26, 2013.
6. 5
NYCT Drew Down DRAA Grant Funds for Procurement Actions That FTA
Did Not Approve for Grant Inclusion
In February 2013, FTA issued a Federal Register Notice announcing its intention
to reimburse grantees for Hurricane Sandy-related contractual commitments made
before January 29, 2013—even if grantees did not comply with FTA procurement
requirements.13
The waiver of FTA procurement requirements was intended to
allow grantees to complete response and recovery projects expeditiously.
However, for commitments made after this date, FTA procurement requirements
apply, and grantees are required to submit requests for waivers, which require
FTA approval.14
Yet, for two of the nine15
contracts we reviewed, NYCT drew
down $17.7 million in DRAA funds for procurement actions that FTA had
determined were ineligible for inclusion in a grant.
Specifically, in December 2013, NYCT asked FTA to determine whether
$17.7 million in procurement actions for work done after January 29, 2013, was
eligible for inclusion under a pending DRAA grant. NYCT asserted that the work
was eligible for inclusion because it involved continuations of projects initiated
before January 29, 2013. However, FTA did not approve these procurement
actions because NYCT did not provide sufficient support to show the actions were
eligible. According to FTA officials, NYCT agreed to remove the ineligible
actions from the pending DRAA grant application after discussions with FTA.
In January 2014, FTA awarded the DRAA grant to NYCT, which FTA officials
stated did not include the ineligible actions. Nevertheless, NYCT drew down
$17.7 million for the ineligible actions in 2014 and 2015. According to NYCT
officials, the funds were drawn down in error because the procurement actions had
not been removed from the project tasks linked to the grant in NYCT’s accounting
system. We notified FTA of our findings, and FTA officials issued a letter to
NYCT requesting that it return the $17.7 million in improper payments. NYCT
repaid the funds in full on April 26, 2016, along with $325,000 in interest. NYCT
also plans to review its internal grant controls to identify other weaknesses and
improper payments.
NYCT Spent DRAA Grant Funds on Out-of-Scope Work
Even though FTA determined that the $17.7 million was ineligible for grant
inclusion, NYCT drew down the DRAA funds and used them for out-of-scope
work on two contracts that were awarded before Hurricane Sandy. According to
FTA, NYCT could not demonstrate a commitment for the work under those
13
FTA’s Federal Register Notice, Notice of Availability of Emergency Relief Funds in Response to Hurricane Sandy,
Feb. 6, 2013.
14
FTA’s Federal Register Notice, Allocation of Public Transportation Emergency Relief Funds in Response to
Hurricane Sandy, Mar. 29, 2013.
15
These nine contracts were valued at $190 million, as of October 2014.
7. 6
contracts prior to January 29, 2013, the period when FTA procurement
requirements were waived. FTA also told us that had NYCT requested that FTA
consider these activities as eligible under FTA’s normal procurement rules, FTA
would have rejected that request since NYCT would have been in violation of
FTA procurement rules.16
NYCT’s procurement actions, which were unrelated to
the contracts’ original purpose, are known as cardinal changes and would not have
been permissible under FTA grant management policy. Furthermore, the
$17.7 million worth of work under these two contracts occurred after
January 29, 2013, when Federal rules would have fully applied, which would have
required recipients to process a new procurement for cardinal changes.
Specifically, out of the $17.7 million,
• NYCT drew down $15.1 million for a contract for small construction repairs,
which limited work orders to a maximum of $1.5 million. Yet, under one work
order, NYCT ordered $53 million of emergency cleanup and rebuild work
unrelated to the original contract—such as $16 million for railroad embankment
work. Moreover, NYCT used some of the $15.1 million to correct a contractor’s
error requiring additional steel sheet piles17
on the embankment work. Per FTA
policy, a contractor error is an activity ineligible for reimbursement.18
NYCT
officials and other contract file documents provided varying, contradictory
reasons for why the project needed additional sheet piles as well as varying
explanations for the amount paid for the sheet piles.19
• NYCT drew down the remaining $2.6 million for a pre-Hurricane Sandy
contract for the Lexington Avenue Line in Manhattan. The contract was for
electrical signal system enhancement and track reconstruction. Yet, NYCT used
the $2.6 million for 42 change orders that involved emergency repairs for the
Rockaway line in Queens.
FTA Oversight Does Not Ensure That NYCT’s Change Orders Are
Approved per FTA Policy
FTA’s current oversight reviews are inadequate to verify that NYCT’s change
orders comply with FTA change order approval policy. We reviewed 205 change
16
When we brought this to FTA’s attention, Agency representatives said that because FTA determined that the
$17.7 million was not an eligible Sandy expense, FTA did not evaluate these procurement actions to determine if they
adhered to Federal procurement policy.
17
The embankment project included a 12,000-foot steel sheet pile wall. According to a NYCT contract document, as
the sheets were driven into the ground, they “folded slightly and reduced the overall length.” As a result, 450 feet of
additional sheet piles were required to complete the wall.
18
FTA Circular 5010.1D.
19
According to various NYCT file documents and communications with NYCT representatives, NYCT may have paid
around $386,000 to $477,000 for the sheet piles. However, NYCT officials have not provided documentation to us to
explain the cost discrepancies.
8. 7
orders and found that 154, totaling $25 million,20
were not approved in accordance
with FTA policy (see table 1).21
As a result, NYCT issued non-compliant change
orders that created the risk of unapproved work and costs.
Table 1. NYCT Change Orders That Were Not Properly Approved
Problem resulting in improper
approval of change orders
Number of
improperly
approved
change orders
Percentage
of improperly
approved
change orders
Dollar value of
improperly
approved
change orders
NYCT directed the contractor to begin
work without prior approval
68 44% $8 million
NYCT could not demonstrate whether
it complied with FTA policy to obtain
proper management approval
27 18% $910,000
NYCT issued a blanket approval for
multiple change orders
59 38% $16.4 million
Total 154 $25.3 million
Source: OIG analysis of FTA and MTA change order data
According to FTA policy, the recipient’s authorized official must approve all
change orders before they are issued.22
Proper change order approvals are
important to ensure that all additional work and incurred costs are authorized
before the contractor begins the work. NYCT also has its own change order
approval policies, such as requiring dated signatures, which helps provide
evidence that approvals occurred before the change orders were issued.
FTA and MTA Reviews Lack the Procedures Needed To Prevent Non-
Compliant Change Order Approvals
While MTA’s integrity monitors and FTA are responsible for conducting periodic
reviews of NYCT’s change orders, these reviews did not prevent or detect the
majority of the non-compliant change order approvals we identified.
FTA complied with its Hurricane Sandy oversight requirement to conduct
quarterly change order reviews for NYCT.23
Between April 2014 and October
2014, FTA reviewed nine NYCT change orders as part of its triennial review but
20
Fifty-six of these change orders are part of the $17.7 million NYCT drew down, which FTA determined to be
ineligible for inclusion in a grant.
21
From the 9 NYCT contracts we selected, we reviewed all of the Hurricane Sandy-related change orders, which
amounted to 205 change orders totaling $49 million.
22
FTA Circular 4220.1F, II(2)a1.
23
FTA Circular 4220.1F, Third Party Contracting Guidance, Rev. 4, Mar. 18, 2013; FTA Circular 5010.1D, Grant
Management Requirements, Rev 1, Aug. 27, 2012. Specifically, during the period we reviewed, FTA was required to
review at least one change order over $100,000 or 20 percent of the change orders submitted for a grant (whichever is
greater) to test for compliance with FTA requirements. As of March 31, 2016, FTA will review all change orders over
$100,000 for major capital projects.
9. 8
did not identify issues with the grantee’s change order approvals. However, our
change order review (of 205) included 7 of the change orders that FTA reviewed,
and we found that 3 of these had been issued under a blanket approval. FTA’s
reviews did not detect these issues in part because they do not focus on blanket
approvals or on whether an authorized official approves change orders before
issuance as required by FTA policy. Instead, FTA’s reviews focused on scope,
reasonableness, and work justifications.
MTA’s integrity monitors are responsible under FTA’s oversight framework for
conducting periodic forensic reviews of NYCT’s change orders. The integrity
monitors use review checklists to conduct the change order reviews. As of
September 2015, they reviewed 44 NYCT change orders and identified
5 improperly approved change orders. However, our change order review included
38 of these change orders and found that 28 were improperly approved. MTA’s
integrity monitor reviews did not detect the improperly approved change orders in
part because its review checklists do not include evaluating whether change orders
are approved per FTA policy. Specifically, the checklists ask whether the
appropriate personnel signed the change order documents but do not ask if the
documents were properly approved prior to issuance per FTA policy. Instead, the
checklists focus on questions regarding estimates, scope, work justifications, and
cost documentation. The five change orders flagged by MTA’s integrity monitors
for improper approvals were not identified under the checklist items but rather
through additional handwritten notes by the reviewers.
Another reason that MTA’s integrity monitors may not have found as many issues
as we did is that the change orders they reviewed were in process and not
complete at the time of their review. After reviewing completed documents for the
five change orders flagged by MTA’s integrity monitors, we found that some were
not dated, and, in one instance, the contractor had signed the change order before
NYCT managers had approved it.
Noncompliance with procurement policy and ineffective oversight creates an
ongoing risk that Federal dollars, such as DRAA funds, may be used to pay for
unauthorized work on future projects. As detailed below, our review of the 205
Hurricane Sandy-related change orders identified numerous examples of such
weaknesses resulting from insufficient oversight. These include instances in which
NYCT (1) directed the contractor to begin work on change orders without prior
management approval, (2) lacked documentation in change order approvals to
show compliance with FTA policy, and (3) issued a blanket approval for multiple
change orders.
10. 9
NYCT Directed the Contractor To Begin Work on Change Orders Without
Prior Management Approval
According to NYCT’s procedures, management approval is required before the
agency can issue directions to authorize the contractor to begin work. However,
for 68 of the 205 change orders, totaling $8 million, NYCT directed the contractor
to begin work without prior management approval.24
For example:
• For one change order, totaling $238,000, NYCT’s management official did not
sign the direction to proceed until 17 days after the contractor acknowledged
receipt of the direction for the additional work.
• For another change order, totaling $250,000, NYCT’s management official did
not sign the direction to proceed until 126 days after the contractor
acknowledged receipt of the direction for the additional work.
NYCT representatives informed us that it is their unwritten practice to give
directions to proceed to contractors for signature before management approves
them, out of concern the contractor could alter the directions while countersigning.
However, inappropriate alteration could occur at any point in the execution. By
allowing work to begin before management approval, NYCT did not comply with
its own or FTA’s change order approval policy.
NYCT Could Not Demonstrate Whether It Complied With FTA Policy To
Obtain Management Approval
NYCT omitted dates from the approval signatures for 27 change orders, totaling
$910,000—even though FTA policy requires proper management approval prior to
issuance and NYCT’s procedures require management approvals to be dated.
Without dated signatures, it was unclear whether management approvals were
granted before or after these orders were issued. For example, for one change
order, valued at $99,000, NYCT documented the date the change order was issued
but did not include a date next to the management official’s approval signature.
NYCT Issued a Blanket Approval for Multiple Change Orders
In November 2012, NYCT issued a blanket approval memorandum to approve
emergency restoration work on the Rockaway Line and used the memorandum to
authorize 59 change orders, totaling $16 million.25
According to FTA policy, an
authorized official must approve any proposed change order before issuance.
While FTA policy does not explicitly restrict blanket approvals, it also does not
24
Of these change orders, 21 change orders, totaling $2.5 million, are part of the $17.7 million NYCT drew down
which FTA determined to be ineligible for inclusion in a grant.
25
Of these change orders, 35 change orders, totaling $12 million, are part of the $17.7 million NYCT drew down,
which FTA determined to be ineligible for inclusion in a grant.
11. 10
explicitly allow them or provide parameters for their use. When we brought this
to FTA’s attention, Agency representatives told us that if State procurement
requirements allow blanket procurements, FTA will allow their use. However,
NYCT policy also does not clearly address the use of blanket approvals.
NYCT officials stated that individual approval memos would not have been
helpful in this case because the executive in charge consistently monitored work
and kept senior officials apprised of progress. However, individual approvals may
have helped management detect and prevent the out-of-scope change orders we
identified.
In addition, NYCT continued to issue change orders under the blanket approval
memorandum after its stated purpose was met. According to the blanket approval
memorandum, the work was needed to restore service on the Rockaway Line. The
November 2012 memo estimated the work to be completed in about 12 weeks,
which we estimate would have been in January 2013. Although service was
restored on the Rockaway line in May 2013, NYCT continued using the blanket
approval memorandum until March 2014—issuing 22 of the 59 changes orders,
valued at $3 million after service was restored to the Rockaway line.
CONCLUSION
Recognizing an urgent need for Hurricane Sandy recovery work, FTA responded
quickly to assist impacted transit agencies such as NYCT. FTA has taken actions
to strengthen its oversight of ERP and Hurricane Sandy relief funds since our 2013
report—such as putting into practice its Hurricane Sandy Disaster Relief Oversight
Plan’s risk-based framework. However, our work shows that FTA’s oversight does
not fully ensure that NYCT’s practices comply with FTA’s and NYCT’s
procurement requirements—resulting in an increased risk that DRAA funds are
improperly used. As FTA’s recipients continue to use DRAA funds, FTA’s current
oversight practices will inhibit the Agency’s ability to ensure that its recipients use
emergency funds in accordance with FTA regulations. By improving its oversight
procedures to follow up on identified risk items and directing its grantees to
implement procedures to ensure proper approval of change orders, FTA will be
better positioned to ensure proper use of Federal funds.
12. 11
RECOMMENDATIONS
We recommend that the Federal Transit Administrator:
1. Recover the $17.7 million in ineligible DRAA funds.
2. Implement oversight procedures to follow up on identified risks, such as
expenditures denied for inclusion in a grant.
3. Implement procedures to ensure change order reviews conducted by FTA and
integrity monitors include steps to evaluate whether change orders are
approved in accordance with FTA policy.
4. Direct MTA and NYCT to implement procedures to ensure that change
orders have documented management approvals and dated signatures before
they are issued, per FTA policy.
5. Revise FTA’s change order approval policy to address the use of blanket
approvals to clearly state whether they are allowable or not. If allowable,
establish parameters for their use.
AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL
RESPONSE
We provided FTA with our draft report on June 8, 2016, and received its response
on July 8, 2016, which is included as an appendix to this report. FTA concurred
with all five of our recommendations and proposed appropriate planned actions
and completion dates. As stated in our report, on April 26, 2016, FTA recovered
$17.7 million in improper payments from MTA with an additional $325,000 in
interest. Accordingly, we consider recommendation 1 closed. For recommendation
2, FTA proposed an alternative action—a Financial Management Oversight review
of MTA’s internal controls related to the improper drawdowns identified in our
draft report. Completion of this review will meet the intent of our
recommendation. FTA concurred with recommendations 3, 4, and 5 as written.
We consider recommendations 2, 3, 4, and 5 as resolved but open pending
completion of FTA’s planned actions.
We appreciate the courtesies and cooperation of FTA representatives during this
audit. If you have any questions concerning this report, please call Mary Kay
Langan-Feirson, Assistant Inspector General for Acquisition and Procurement
Audit, at (202) 366-5225 or Kenneth Prather, Program Director, at (202) 366-
1820.
#
cc: DOT Audit Liaison, M-1
FTA Audit Liaison, TBP-30
13. 12
Exhibit A. Scope and Methodology
EXHIBIT A. SCOPE AND METHODOLOGY
We conducted this audit between December 2014 and June 2016 in accordance
with generally accepted Government auditing standards. Those standards require
that we plan and perform the audit to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings and conclusions based on our audit
objective. We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objective. Our audit objective was
to determine whether FTA provided effective oversight of grantees’ contracting
practices using DRAA funds.
To conduct our work, we analyzed data provided by MTA of its subsidiaries that
received DRAA funds, to identify a universe of contracts. Our audit universe
consisted of 37 Sandy funded NYCT contracts—whose contract values totaled
$220 million. From the universe, we selected a risk-based,26
non-random selection
of 9 contracts27
with a contract value of $190 million—representing 86 percent of
the NYCT’s universe amount. In addition, from these 9 contracts we reviewed all
of the 205 Sandy related change orders with DRAA funds, valued at $49,220,841.
We validated the accuracy of the data provided by NYCT by comparing the
contract numbers and award amounts against those in the contract files and
excluded from review any change orders which did not include Sandy funds. We
found that the contract numbers of the files matched those identified in our sample
and determined that the data was reliable enough for our audit purposes.
Lastly, we tested FTA’s internal controls for determining effective oversight of
grantees’ contracting practices by conducting field visits and interviews. We
compared those practices to FTA and NYCT criteria.28
Also, we interviewed FTA
acquisition officials in Washington, D.C. and New York City (Region 2) to
determine what oversight policies and procedures were in place for DRAA funds;
conducted site visits at MTA's headquarters in New York City to review contract
files including change orders, cost estimates, and approvals. We also interviewed
contract personnel regarding actual procedures and practices for DRAA oversight.
For file reviews, we developed and used a standardized checklist of criteria to
compare the contents of contract files to the requirements for contract file
documentation; conducted follow-up interviews with the contracting personnel
responsible for administering our sample contracts to verify that we obtained all
26
We selected MTA and one of its four subsidiaries because they received the largest proportion of DRAA funds.
27
Seven contracts were selected based on highest dollar amounts, and two additional contracts were selected based on a
potential conflict of interest.
28
Such criteria includes (1) FTA’s Federal Register Notice, Notice of Availability of Emergency Relief Funds in
Response to Hurricane Sandy, Feb. 6, 2013 ; (2) FTA’s Federal Register Notices, Allocation of Public Transportation
Emergency Relief Funds in Response to Hurricane Sandy, Mar. 29, 2013; (3) FTA Circular 5010.1D, Grant
Management Requirements, Rev 1, Aug. 27, 2012; (4) FTA Circular 4220.1F, Third Party Contracting Guidance, Rev.
4, Mar. 18, 2013; and (5) MTA Independent Monitoring Implementation Plan for FTA Emergency Relief Program.
14. 13
Exhibit A. Scope and Methodology
supporting documentation and explanations; and compared the practices that we
observed to Federal requirements and FTA’s policies, procedures, and
guidance. During this audit, we did not evaluate MTA’s integrity monitors
beyond reviewing MTA’s Office of Audit Services reports and MTA’s Office of
the MTA Inspector General change order reviews.
15. 14
Exhibit B. Major Contributors to This Report
EXHIBIT B. MAJOR CONTRIBUTORS TO THIS REPORT
Name Title
Kenneth Prather Program Director
Aisha Evans Project Manager
Jerri Bailey Senior Auditor
Paul Stark Senior Analyst
Teena Curry Analyst
Daniel Fox Analyst
Amy Berks Senior Counsel
Rodolfo Pérez Engineer Advisor
Andrea Nossaman Senior Writer
Christina Lee Writer-Editor
Susan Neill Writer-Editor
16. 15
Appendix. Agency Comments
APPENDIX. AGENCY COMMENTS
Memorandum
U.S. Department
of Transportation
Federal Transit
Administration
Subject: INFORMATION: Management Comments – Office of
Inspector General (OIG) Draft Report—FTA Can
Improve Its Oversight of Hurricane Sandy Relief Funds
Date: July 8, 2016
From: Carolyn Flowers
Acting Administrator
Federal Transit Administration
Reply to
Attn. of:
Natalie Wowk
202-366-2514
To: Mary Kay Langan-Feirson
Assistant Inspector General for Acquisition and Procurement Audits
The Federal Transit Administration (FTA) has helped transit agencies recover from Hurricane
Sandy by successfully implementing its Public Transportation Emergency Relief Program
(ERP). The program helps States and public transportation systems pay for protecting,
repairing, and replacing equipment and facilities that may suffer or have suffered serious
damage as a result of an emergency including floods, hurricanes, and tornadoes. Under the
Disaster Relief Appropriations Act (DRAA)1
enacted in January 2013, Congress provided an
unprecedented $10.9 billion, which was subsequently reduced to $10.1 billion due to
sequester, transfers, and administrative oversight, for FTA’s ERP recovery, relief, and
resilience efforts in areas affected by Hurricane Sandy. In the three years since Hurricane
Sandy, FTA has taken the following actions to ensure that affected transit systems are fully
restored and protected from future disasters:
• Allocated the approximately $10.1 billion available in multiple tiers for response,
recovery, and resilience, including $5.2 billion solely for response and recovery, of
which approximately 75 percent has been obligated and 25 percent has been
liquidated through payments to grantees.
• Allocated $4.9 billion for resilience, to reinforce existing infrastructure necessary to
support public transportation systems damaged by Hurricane Sandy, while also
providing a process for recipients to use available resilience funds for recovery
1
Public Law 113–2
17. 16
Appendix. Agency Comments
expenses if needed.
• Implemented a robust grant review process and also developed a risk-based oversight
approach, including examining risks associated with each grantee and associated grant
or project;
• Completed damage assessments of the affected transit agencies immediately after the
disaster struck, and updated those damage assessments in the summer of 2015;
• Issued a Memorandum of Agreement with the Federal Emergency Management
Agency (FEMA) which outlines responsibilities and the means of collaboration for
each agency during and after a declared emergency or disaster;
• Published an Emergency Relief Manual which provides guidance for states and transit
agencies about FTA's ERP and information on other disaster relief resources available
through FTA and FEMA; and,
• Issued a Final Rule on the requirements of the ERP.
Based upon our review of the draft OIG report, FTA concurs with recommendation 1 and
requests that the OIG close the recommendation. On April 26, 2016, FTA recovered $17.7
million in improper payments from the Metropolitan Transportation Authority (MTA) with an
additional $325,000 in interest. We provided supporting documentation to the OIG on May
23, 2016. FTA also concurs with recommendations 3, 4, and 5 as written, and plans to
complete all actions for these recommendations by September 30, 2016.
Regarding recommendation 2, FTA concurs with the intent of the recommendation and
proposes the following alternative to address the finding: since MTA’s improper payments
indicated a failure in MTA’s internal controls processes, FTA plans to conduct a Financial
Management Oversight (FMO) review of MTA’s internal controls related to the improper
drawdowns identified in the draft report. FTA will complete the FMO review by July 30,
2017.
We appreciate this opportunity to comment on the OIG draft report. Please contact Natalie
Wowk, Audit Liaison, at (202) 366-2514, with any questions.