Amtrak agrees with the recommendation to redesign key controls to help ensure that the monitoring of the observations happens on a preventive basis to help identify any exposure to non-compliance before it occurs. 1. Amtrak has completed on-time its Phase I engagement with an outside consulting fi...
Amtrak agrees with the recommendation to redesign key controls to help ensure that the monitoring of the observations happens on a preventive basis to help identify any exposure to non-compliance before it occurs. 1. Amtrak has completed on-time its Phase I engagement with an outside consulting firm that delivered a baseline assessment of Amtrak?s enterprise asset management program and high-level corrective action plans to address observations that were identified across the equipment life cycle. Corrective action plans (CAPs) were developed across process areas with key impact recommendations to address policy and governance around single auditable assets; the people and processes needed for a complete lifecycle oversight of equipment management; and the technology needed to support more robust internal controls, compliance, and timely audits. Amtrak is currently in discussion with this firm for Phase II that involves the implementation of these CAPs. 2. The Asset Management team will pursue enterprise-wide governance through new policies, procedures, and controls throughout the equipment lifecycle. For instance, the Asset Management team, as of February 2023, has been added as an approver to the PR workflow whenever a requester indicates that the PR contains equipment greater than or equal to $5,000 per unit as defined in the Equipment Control policy 3.19. This has helped to ensure that an asset record is created in the asset management system, that it is purchased using a capital code, and it has provided visibility to help ensure that once a purchase order has been created and the asset is received, the asset number that is physically placed on the asset is the same as what was created for the PR. 3. The Asset Management team will train and assist the Capital Accounting team to be able to detect issues with our equipment at the time the asset is placed in service. One goal of this training is to help ensure that at the time the asset is placed in service, it has a complete record, including, but not limited to the asset?s condition and location. We expect to complete this training by July 2023. 4. A technology solution needs to be adopted to better track and locate Amtrak?s assets, as well as support field personnel in ensuring compliance with federal regulations. Amtrak plans to utilize existing tracking technology on assets whenever possible and is exploring adding tracking technology to asset classes, such as yard equipment (e.g., forklifts and golf carts) that currently have no technology in a risk/cost effective manner at an enterprise level, and subsequently integrate with the existing systems to the maximum extent possible. Asset Management is also coordinating with the Company?s Digital Technology department to prioritize the development of a mobile application to help field personnel with performing audits. In the short-term, Asset Management has developed a SharePoint site to support other departments and divisions in completing and submitting audits specifically for single auditable assets. Currently, Procurement and the Automotive group utilize this SharePoint site for completing audits. Asset Management will be expanding this to the Operations & Transportation and Engineering departments. The Company expects to complete this roll out to these departments by June 2023. The Asset Management team is also working on enhanced reporting specific to the Mechanical department to assist with their observations. This new reporting is expected to be completed by September 2023. 5. Since June 2022, the Asset Management team has consistently been working with Capital Accounting to improve the non-compliant single audit equipment report. The Asset Management team is in the process of automating the Capital Accounting report. The team is managing the distribution of the report and assisting with data review. 6. Additionally, over this same period the Asset Management team has worked with the various departments that are responsible for single audit equipment. These actions have reduced the out of compliance assets in each of the departments. The Asset Management team will continue to actively work with the departments that manage these assets and assist these departments with ensuring their assets are physically inspected, tracked for location, and listed in the appropriate condition within the Company?s systems of record for asset tracking. 7. The Asset Management team is actively engaged with the various departments and divisions and continues to go on site visits to perform, as well as assist the equipment managers in performing, observations and audits of equipment and vehicle assets. The contacts for this item are Ian Hinke, AVP Supply Chain Management, and Carol Hanna, VP Controller. The Company anticipates the implementation of the above procedures, along with continual process monitoring and refinement, will fully remediate this finding by June 2026.