Audit 403187

FY End
2024-09-30
Total Expended
$3.79M
Findings
4
Programs
4
Organization: Commonwealth Ports Authority (MP)
Year: 2024 Accepted: 2026-06-07

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
1216741 2024-004 Material Weakness Yes F
1216742 2024-005 Material Weakness Yes N
1216743 2024-004 Material Weakness Yes F
1216744 2024-005 Material Weakness Yes N

Contacts

Name Title Type
XGK1P65NW429 Sheryl Sizemore Auditee
6702376500 James N. Whitt Auditor
No contacts on file

Notes to SEFA

CPA was established as a public corporation by the CNMI by Public Law 2-48, effective November 8, 1981. All significant operations of CPA are included in the scope of the Single Audit. The U.S. Department of the Interior’s Office of the Inspector General has been designated as CPA’s cognizant agency for the Single Audit.
The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal award activity of CPA under programs of the federal government for the year ended September 30, 2024. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of CPA, it is not intended to and does not present the financial position, changes in net position or cash flows of CPA.
Matching Requirements In allocating project expenditures between the federal share and the local share, a percentage is used based upon local matching requirements, unless funds are specifically identified to a certain phase of the project. Basis of Accounting Expenditures reported on the Schedule are reported on the accrual basis of accounting. All expenses and capital outlays are reported as expenditures. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through entity identifying numbers are presented where available.
CPA does not elect to use the de minimis indirect cost rate allowed under Uniform Guidance.

Finding Details

Finding No.: 2024-004 Federal Agency: U.S. Department of Transportation AL Program: 20.106 Airport Improvement Program Federal Award Nos.: All AIP Grants Area: Equipment and Real Property Management Questioned Costs: Undeterminable Criteria: In accordance with 2 CFR section 200.313(b), a State must use, manage and dispose of equipment acquired under a Federal award by the State in accordance with State laws and procedures. SOP 216.1 and 216.6: • A physical inventory of the property must be taken and the results reconciled with the property records annually. SOP 215.1 and 215.2: • Adequate maintenance procedures must be developed to keep the property in good condition. Condition: 1. CPA does not maintain an equipment listing that designates which federal program the assets belong to. 2. Of twelve equipment tested, aggregating $13,328,054 of a total population of $13,952,859 as of September 30, 2024, we noted deficiencies, as follows: a. One (or 8%) listed the item to be in fair condition in the physical count; however, the custodian represented that item is currently non-operational due to breakage and damage, which occurred in February 2024. b. One (or 8%) was not recorded in the physical inventory count. CPA’s reconciliation, however, acknowledged for it to be corrected. Further, it was represented during field work that the item is in very poor condition and is currently inoperable since May 2023. Finding No.: 2024-004, continued Federal Agency: U.S. Department of Transportation AL Program: 20.106 Airport Improvement Program Federal Award Nos.: All AIP Grants Area: Equipment and Real Property Management Questioned Costs: Undeterminable Condition, continued: c. One (or 8%) failed to show the item in blue color, indicating it is a federal asset as designated in its asset listing legend. Further, fields including purchase order, vendor, or serial number showed item was unknown. Moreover, item was not operational until December 2025. d. One (or 8%) did not submit log sheets or maintenance records to confirm that maintenance work was performed during FY2024. It was also represented that the asset was not in use since October 2025. Cause: CPA does not maintain an effective method of tracking U.S. Federally funded assets as the only method of tracking is through manually designating the asset in a different color within the listing generated from the fixed assets register for CPA as a whole. This manual process is subject to potential errors when produced on an annual basis as part of the audit process. Finding No.: 2024-004, continued Federal Agency: U.S. Department of Transportation AL Program: 20.106 Airport Improvement Program Federal Award Nos.: All AIP Grants Area: Equipment and Real Property Management Questioned Costs: Undeterminable Effect or potential effect: The completeness and accuracy of the program assets could not be determined. Identification as a Repeat Finding: Finding 2023-003. Recommendation: CPA should implement a formal asset tracking system or enhance its existing fixed asset register to clearly identify assets acquired with U.S. Federal grant funds (e.g., through dedicated fields or tagging within the system). This will eliminate reliance on manual color-coding and reduce the risk of errors. Additionally, CPA should establish standardized procedures for maintaining and periodically updating this information to ensure accuracy, completeness, and consistency in tracking federally funded assets. Views of Responsible Officials: Management states agreement with the findings. Refer to separate Corrective Action Plan.
Finding No.: 2024-005 Federal Agency: U.S. Department of Transportation AL Program: 20.106 Airport Improvement Program Federal Award Nos.: All AIP Grants Area: Special Tests and Provisions – Revenue Diversion Questioned Costs: $-0- Criteria: In accordance with 64 FR 7696, all revenues generated by a public airport must be expended for the capital or operating costs of the airport, the local airport system, or other local facilities that are owned or operated by the owner or operator of the airport and are directly and substantially related to the actual air transportation of passengers or property. Condition: CPA has two divisions – airport and seaport. Certain costs are shared by both the airport and the seaport. The shared costs include management fees, salaries, legal fees, advertising, and administrative expenses. The airport pays for shared costs that are attributed to the costs of the seaport operations. The airport records the seaport’s allocation of the shared cost as ‘Due from seaport division’ and conversely, the seaport records ‘Due to airport division’. The seaport division normally settles amounts due to the airport division within 90 days. We observed that: • The airport division paid $615,140 of the seaport division’s shared costs during the fiscal year ended September 30, 2024. • As of September 30, 2024, the airport division’s receivable from the seaport division amounted to $120,582. CPA management asserts that use of airport revenues to pay operating costs of the seaport division is acceptable as the seaport division normally reimburses the airport division within 90 days. As such, CPA management believes this does not constitute a diversion of airport revenues. CPA did not provide documentation from the grantor agency to acknowledge that the grantor agency has approved the use of airport revenues to pay for the costs of the seaport operations. Finding No.: 2024-005, continued Federal Agency: U.S. Department of Transportation AL Program: 20.106 Airport Improvement Program Federal Award Nos.: All AIP Grants Area: Special Tests and Provisions – Revenue Diversion Questioned Costs: $-0- Cause: CPA did not effectively seek grantor guidance over compliance with Special Tests and Provisions on revenue diversion on shared costs between its airport and seaport divisions. Effect or potential effect: CPA is in noncompliance with Special Tests and Provisions – Revenue Diversion. No questioned costs are presented as we are unable to quantify the extent of noncompliance. Identification as a Repeat Finding: Finding 2023-004 Recommendation: CPA should seek approval from the grantor agency regarding use of the airport revenues to pay for operating cost of its seaport division. Views of Responsible Officials: Management disagrees with the finding. All costs incurred by the Seaport paid initially by the Airport are reimbursed in a timely manner. For purposes of efficiency, this method is used as to reduce the number of payments to vendors being made. The Airport Division has been fully reimbursed. CPA received grantor acceptance of the use of this method even though this practice of recordkeeping has been in place for more than 20 years. Refer to separate Corrective Action Plan. Auditor Response: The Federal Aviation Administration (FAA) reviewed and approved the corrective action plan in response to the FY2023 revenue diversion finding. Under this plan, beginning in FY2026 (effective October 1, 2025), all seaport and airport costs, except for payroll, will be paid separately, with no more interdivision reimbursements allowed. Finding No.: 2024-005, continued Federal Agency: U.S. Department of Transportation AL Program: 20.106 Airport Improvement Program Federal Award Nos.: All AIP Grants Area: Special Tests and Provisions – Revenue Diversion Questioned Costs: $-0- Auditor Response, continued: For payroll costs, the Seaport’s calculated share is prepared beforehand and is transferred to the Airport before pay date, with the Airport issuing a receipt of funds the next day. This prepayment arrangement is to avoid any semblance of Airport funds being used to fund Seaport operations. While the FAA has accepted CPA’s corrective action plan, its implementation does not take effect until October 1, 2025. In the absence of documented grantor approval authorizing the arrangement to use airport revenues for seaport-related expenditures to be repaid within a 90 day period and given the continued occurrence of the condition in FY2024, the finding remains unresolved and is reported as a repeat finding.