Finding 1140678 (2024-003)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2024
Accepted
2025-06-09

AI Summary

  • Core Issue: Amtrak incorrectly allocated $24,200 in expenses to the Rail and Transit Security Grant Program instead of the correct project, violating federal cost allocation regulations.
  • Impacted Requirements: Non-compliance with 2 CFR 200.405 on allocable costs and 2 CFR 200.1 regarding questioned costs due to ineffective review of manual journal entries.
  • Recommended Follow-Up: Strengthen controls for reviewing funding sources and ensure proper project setup before incurring expenses to prevent future misallocations.

Finding Text

Finding 2024-003: Unsubstantiated Expense Program Name: Rail and Transit Security Grant Program Assistance Listing No. 97.075 Federal Award No.: EMW-2021-RA-00048 Federal Agency: U.S. Department of Homeland Security Criteria The code of federal regulations – 2 CFR 200.405 Allocable costs requires that: A cost is allocable to a Federal award or other cost objective if the cost is assignable to that Federal award or other cost objective in accordance with the relative benefits received. This standard is met if the cost satisfies any of the following criteria: (1) Is incurred specifically for the Federal award; (2) Benefits both the Federal award and other work of the recipient or subrecipient and can be distributed in proportions that may be approximated using reasonable methods; or (3) Is necessary to the overall operation of the recipient or subrecipient and is assignable in part to the Federal award in accordance with these cost principles. The code of federal regulations – 2 CFR 200.1 Definitions defines Questioned costs as: Questioned cost means an amount, expended or received from a Federal award, that in the auditor’s judgment: (i) Is noncompliant or suspected noncompliant with Federal statutes, regulations, or the terms and conditions of the Federal award; The following exceptions to the criteria were observed during the performance of the audit procedures: 1. As part of our procedures relating to the testing requirement of Sections A and B (Activities Allowed or Unallowed and Allowable Costs/Cost Principles), we identified a transaction erroneously included in the expenditure population that did not represent an expenditure allocable to Assistance Listing #97.075 incurred by Amtrak. The $24,200 amount included on the SEFA and in the underlying population related to a project funded by the Assistance Listing #20.315. Cause Amtrak’s control procedures in place as it relates to the review of manual journal entries related to reclassification of expenses between different projects under different funding sources were not operating effectively. The review process failed to identify the correct project to allocate the reclassification journal entry to. Effect Amtrak is in non-compliance with the related grant agreement. Questioned Costs This finding resulted in a total of $24,200 of questioned costs for Assistance Listing #97.075 – Rail and Transit Security Grant Program for Federal Award # EMW-2021-RA-00048. Context We selected 40 AB expenditure transactions, related to Assistance Listing #97.075, for internal control and compliance testing. One exception as described in the Condition section above was noted for matters 1-3 in the Criteria section above, indicating that internal controls were not functioning. Identification as a Repeat Finding Not a repeat finding. Recommendation We recommend that management strengthen the process to identify and review funding sources of underlying expenditures, that support the amounts of the reclassification journal entries. This could include reviewing approved budgets for the federal award in scope at a necessary level of detail to determine appropriateness of allocations in a timely manner. Views of Responsible Officials The invoice identified in this finding was initially charged to the incorrect project code, due to a manual process that was done incorrectly. The charges on the invoice should have been recorded to Amtrak’s annual grant, not the Rail and Transit Security Grant. The Company has moved the charges to the correct project code. The review and approval controls within the procurement process would have normally prevented the assignment of the incorrect project code, but in this situation, the project code was not set up at the time the services were rendered and an incorrect project code was used. This created the requirement for a manual journal entry to reclassify the expenses and at that time the incorrect code was selected. Amtrak will reinforce the need for proper project set up in advance and proper review of project charges once incurred.

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 564233 2024-001
    Significant Deficiency
  • 564234 2024-002
    Significant Deficiency
  • 564235 2024-002
    Significant Deficiency
  • 564236 2024-003
    Significant Deficiency
  • 564237 2024-001
    Significant Deficiency
  • 1140675 2024-001
    Significant Deficiency
  • 1140676 2024-002
    Significant Deficiency
  • 1140677 2024-002
    Significant Deficiency
  • 1140679 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
20.316 Railroad Rehabilitation and Improvement Financing Program $1.12B
20.314 Railroad Development $100.82M
20.315 National Railroad Passenger Corporation Grants $65.24M
20.326 Federal-State Partnership for Intercity Passenger Rail $22.31M
97.075 Rail and Transit Security Grant Program $15.39M
20.323 Fiscal Year 2013 Hurricane Sandy Disaster Relief Grants to the National Railroad Passenger Corporation $8.79M
20.325 Consolidated Rail Infrastructure and Safety Improvements $2.38M
16.922 Equitable Sharing Program $1.49M
20.324 Restoration and Enhancement $1.12M