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Develop and implement controls for periodically verifying that RO/ADO program managers are implementing FAA's policy for (a) assigning and monitoring grantee risk ratings, as required; (b) performing manual approvals, when required; and (c) performing quarterly reviews and, when applicable, modifying grantee risk ratings according to FAA guidance.

Formally request that OST Delphi system managers modify the wording of the warning message to AIP grantees to specifically state when documentation has not been attached to payment requests and that such documentation is required by FAA policy and the Improper Payments Elimination and Recovery Improvement Act of 2012 (IPERA).

Formally request that OST Delphi system managers implement a function that denies AIP payments to grantees that do not provide the required supporting documentation at the time of the payment request.

Update FAA policy to include the availability of existing Delphi eInvoicing training and communicate the policy revision to all AIP grantees.

Develop and implement a plan to recover the $102,323 in questioned and unsupported costs identified in this report.

Communicate to AIP grantees FAA's policy requirement for maintaining all original documentation that supports grant payments and confirm that all grantees have acknowledged this requirement.

Update AIP payment policy to include a specific requirement that grantees submit payment requests on invoiced costs incurred up to the allowable Federal share, and communicate the revision to all AIP grantees.

Improve existing training for RO/ADO program managers to follow the AIP Handbook requirements for amending grant agreements when expanding project descriptions.

Ensures that the Territory complies with the equipment and real property requirements.

Ensures that the Territory complies with the special tests and provisions requirements.

Recovers $264,077 from the Territory, if applicable.

We recommend that FHWA ensures that the Navajo Nation complies with the equipment and real property requirements.

Ensures that AMTRAK complies with the equipment and real property management requirements.

Ensures that the Republic complies with the equipment and real property management requirements.

Ensures that the District complies with the procurement and suspension and debarment requirements.

Ensures that the Authority complies with the matching requirements.

Recovers $2,787 from the Authority, if applicable.

Ensures that the University complies with the allowable costs/cost principles requirements.

Recovers $8,954 from the University, if applicable.

ensures that the University complies with the allowable costs/cost principles requirements.

Recovers $9,377 from the University, if applicable.

Ensures that the Commonwealth complies with the equipment and real property management requirements.

Ensures that the State complies with the reporting requirements.

Ensures that the State complies with the matching, level of effort, earmarking requirements.

Ensures that the Authority complies with the subrecipient monitoring requirements.

Ensures that the Authority complies with the reporting requirements.

Ensures that the State complies with the matching, level of effort, earmarking requirements.

Ensures that the Confederated Tribes complies with the reporting requirements.

Ensures that the SC DOT complies with proper accounting requirements for accounts receivable and accounts payable.

Ensures that the State complies with the cash management requirements.

Ensures that the State complies with the subrecipient monitoring requirements.

Ensures that the State complies with the activities allowed or unallowed requirements.

Recovers $900,000 from the State, if applicable.

Recovers $143,000 from the State, if applicable.

Ensures that the State complies with the special tests and provisions requirements.

Ensures that the State complies with the reporting requirements.

Ensures that the City complies with reporting requirements.

Ensures that the City complies with subrecipient monitoring requirements.

Ensures that the City and County complies with the activities allowed or unallowed and allowable costs/cost principles requirements.

Recovers $24,080,771 from the City and County, if applicable.

Ensures that the City and County complies with the reporting requirements.

Ensures that the Tribe complies with the cash management requirements.

Recovers $3,077,574 from the Tribe, if applicable.

Ensures that the Tribe complies with the activities allowed/allowable costs and cost principles requirements.

Recovers $22,691 from the Tribe, if applicable.

Ensures that the Tribe complies with the equipment and real property requirements.

Ensures that the Tribe complies with the period of performance requirements.

Ensures that the Tribe complies with the special tests and provisions requirements.

Ensures that the Authority complies with the cash management requirements.

We recommend FTA recovers $30,641 from the Authority, if applicable.

Ensures that the State complies with the subrecipient monitoring requirements.

Recovers $106,181 from the State, if applicable.

Ensures that the Authority complies with the equipment and real property management requirements.

Ensures that the Authority complies with the equipment and real property management requirements.

Ensures that the City complies with the subrecipient monitoring requirements.

Recovers $2,780,059 from the City, if applicable.

Ensures that the State complies with the subrecipient monitoring requirements.

We recommend FTA recovers $99,226 from the State, if applicable.

Ensures that Guam complies with the equipment and real property management requirements.

Update DOT Orders 8000.8 and 8000.5A and make them available to DOT employees.

Require that Operating Administrations align any criminal referral procedures with updated DOT Orders.

Implement an annual mandatory training requirement on DOT employees' responsibility to report fraud, waste, and abuse to the OIG and requirements in DOT Orders 8000.8 and 8000.5A.

Ensures that the Council complies with the special tests and provisions requirements.

Ensures that the Authority complies with the equipment and real property management requirements.

Ensures that the State complies with the special tests and provisions requirements.

Ensures that the Agency complies with the procurement and suspension and debarment requirements.

Recovers $214,494 from the Agency, if applicable.

Ensures that the Authority complies with the reporting requirements.

Ensures that the Authority complies with subrecipient monitoring requirements.

Ensures that the Authority complies with special tests and provisions requirements.

Ensures that the Authority complies with the matching requirements.

Ensures that the State complies with the special tests and provisions requirements.

Recovers $214,516 from the State, if applicable.

Ensures that the Wyoming DOT complies with the reporting requirements.

Ensures that the Commonwealth complies with the subrecipient monitoring requirements.

Ensures that the State complies with the special tests and provisions requirements.

Develop and implement a risk-based process to monitor manufacturers' reporting of recall remedy, scope, and risk information. The process should include taking appropriate steps with manufacturers that are not in compliance, including enforcement actions when necessary, as well as verifying information submitted by manufacturers, and identifying and addressing potential inadequacies of recall remedies and scope.

Develop and implement a risk-based process—with specific timelines—that provides guidance for Office of Defects Investigation staff on identifying recalls with missing communications (e.g., dealer notifications, technical service bulletins), taking appropriate action to resolve the deficiency, and documenting the outcomes in an official recordkeeping system.

In accordance with the Government Accountability Office's Standards for Internal Control in the Federal Government and NHTSA's procedures, develop, implement, and document management controls, including a supervisory review process, for monitoring recall remedies, scope, and risk reporting and oversight of recall implementation.

Develop a training curriculum on staff responsibilities for updated recall monitoring and oversight processes, and provide this training to Office of Defects Investigation and Office of Vehicle Safety Compliance staff.

Update the recall reporting portal and issue written guidance to identify all recall scope, risk, and completion rate information that regulations require manufacturers to submit.

Document lessons learned from the Takata recalls, and develop and implement a plan for applying those lessons to help manufacturers improve completion rates of other recalls.

Conduct an independent review of FAA's oversight of American Airlines' flight operations to determine whether controls are in place and effective in preventing single points of failure; develop and implement corrective actions, if necessary.

Modify the existing tool used to evaluate the objectivity of inspectors to incorporate risk factors such as non-routine operations and the length of time inspectors oversee the same air carrier.

Develop and implement controls requiring oversight office staff to resolve complaints and follow key policy requirements such as directly contacting complainants and documenting investigations.

Establish and implement criteria for evaluating correspondence to ensure safety complaints are routed to FAA's Office of Audit and Evaluation.

Develop and implement inspector guidance on FAA's oversight requirements for flight test operations.

Provide the Allied Pilots Association with a revised response to its complaint based on results from the October 2017 independent assessment of the American Airlines flight test program.

Develop and implement a corrective action plan to address the recommendations made by the October 2017 independent assessment of the American Airlines flight test program.

Update and remediate the completion dates in the plans of action and milestones for SI-02.A and CM07.A.2 to ensure that the confidentiality, integrity, and availability of the system are not at risk.

Determine the impact of new hire training and certification time and fatigue mitigation requirements on technician staffing and incorporate into the maintenance technician staffing process.

Determine the impact of equipment age on workload and maintenance technician staffing needs and incorporate this factor into the staffing model, if found to be statistically significant.

Review and update the Facility, Service, and Equipment Profile policy to require user training and recurring data-validation reviews at the Support Center and national levels at defined intervals prior to running the staffing model.

Develop and implement a process to reduce and standardize codes in the Labor Distribution Reporting (LDR) system to improve accounting for direct maintenance workload.

Determine if the newly standardized LDR data are reliable for direct maintenance workloads in the Technical Operations Staffing Model, and if so, develop and implement an action plan with milestones to replace the workload assessments with LDR data.

Revise the current standard operating procedure, Tier 1/2/3 Staffing Allocations and Tier 1 Watch Coverage Requirements to: a. Define the job series and clarify whether system specialists and System Support Center coordinators are included in the Tier 1, 2, and 3 staffing targets;and b. Require annual review, validation, and updating of staffing allocation targets.

Update the target delivery dates for initiatives that are still in progress, including those without target delivery dates, and implement procedures for continually updating delivery dates and descriptions of initiatives as changes are made.

Develop and include in the monitoring plan quantifiable metrics or other indicators that can measure the effectiveness of the initiatives.

Consolidate duplicate initiatives within the monitoring plan.

Develop and issue comprehensive policy and procedures for the Pipeline Safety Research and Development Program that includes guidance for: a. notifying a wider spectrum of stakeholder representatives about future Research and Development forums, in order to increase their participation; b. addressing how the results of Research and Development forums are incorporated into the program plan; c. conducting all steps in the conflict-of-interest process; and d. following up with researchers on benefits and uses.

Complete upgrades to the conflict-of-interest portion of the Research and Development Management Information System.

Use Performance Improvement Council best practices to update future biennial Update Reports to Congress, to include additional context, such as analyses of current performance metrics and an evaluation of program success, trends, and anomalies.

Implement procedures to ensure the Federal Transit Administration distributes guidance to selected grantee recipients on the importance of accurate submission and proper review of timesheets to improve proper allocation of labor efforts and the identification and retention of required documentation to support a payment as proper in the Emergency Relief Program-Disaster Relief Appropriations Act program.

Work with the Office of Inspector General (OIG) to ensure it provides additional, clear, and precise travel guidance to employees and approving officials on the preparation and proper review of travel vouchers to improve the allocation of travel expenses in OIG-DRAA fund activity.

Work with OIG to ensure it updates its travel guidance to add instructions on how to split or allocate DRAA-related travel expenses to the appropriate accounting codes including codes for indirect costs and trains employees how to use this guidance.

Ensures that the Council complies with the cash management requirements.

Recovers $666,482 from the Council, if necessary.

Ensures the State complies with the period of performance requirements.

Determine the allowability of the $5,824 transaction, then review all construction projects to ensure that expenditures were properly paid within the period of performance, and recover any additional questioned costs, if applicable.

Ensures that the City complies with the reporting requirements.

Ensures that the City complies with the allowable cost/cost principles requirements.

Recovers $21,265 from the City, if applicable.

Ensures that the City complies with the allowable cost/cost principles requirements.

Recovers $37,543 from the City, if applicable.

Ensures that the DART complies with the allowable costs/cost principles requirements.

We recommend FTA recovers $122,558 from the DART, if applicale.

Ensures that the DART complies with the cash management requirements.

Ensures that the Authority complies with the allowable costs/cost principles requirements.

We recommend FAA recovers $38,339 from the Authority, if applicable.

Ensures that the County complies with the equipment and real property management requirements.

Ensures that the Authority complies with the reporting requirements.

Ensures that the NM DOT complies with the activities allowed or unallowed requirements.

Ensures that the NM DOT complies with the subrecipient monitoring requirements.

Ensures that the County complies with the equipment and real property requirements.

Ensures that the Authority complies with the procurement and suspension and debarment requirements.

Ensures that the Authority complies with the subrecipient monitoring requirements.

Ensures that the State complies with the special tests and provisions reqirements.

Ensures that the City complies with the Subrecipient monitoring requirements.

Provide written guidance specifically to grandfathered sponsors on what constitutes a grandfathered payment and how to accurately report grandfathered payments.

Develop and implement an internal control process to verify the accuracy of reports on grandfathered payments.

In accordance with Federal law, consider the State of Hawaii exceeding its statutory limit on the use of revenues for non-airport purposes as a factor in reducing AIP discretionary funds awarded to the State. Implementation of this recommendation could put $509,727 in funds to better use.

Revise and document a standardized data entry and validation process for the Service Areas to follow to help ensure consistent and accurate REMS data entry.

Develop, document, and implement a new lease approval process that will allow for more timely decisions and for improved coordination with Service Area staff on the status of the decisions made during this process. Implementing this recommendation could potentially put $14.6 million in funds to better use due to missed rent reduction opportunities, which timely and coordinated lease efficiency opportunity decisions could have potentially prevented.

Improve and document methods used to share and communicate Headquarters lease policies, guidance, and initiatives to all real estate staff members in the Service Areas.

Revise and document lease policy and templates to clarify that the indefinite holdover clause should only be used in office and warehouse leases where mission-critical safety equipment or functions are housed, and document a process to verify this policy is followed.

Revise, document, and implement a procedure to require and verify that for any office or warehouse lease whose firm-term portion is greater than one year, an analysis showing use of a firm-term lease is advantageous to the Agency is documented in the lease file.

Revise and document the real estate strategic planning process so that it: (1) provides for annual updates and (2) increase Service Area involvement and awareness.

Develop and implement a method for increasing the likelihood that LOBs provide the necessary funding to implement agreed upon lease efficiency opportunities.

Develop, document, and implement controls to (1) reconcile and validate the accuracy of lease payments that are made during the term of the lease and (2) verify that any lease payment made has an active and valid lease associated with it. Implementing this recommendation could potentially put $111,138 in funds to better use for uncollected interest on erroneous lease payments.

Take appropriate action to address the $9,964 in improper payments identified in this report.

Provide additional guidance and/or training to FAA staff to reinforce existing policy regarding: (1) the proper coding of payments captured under each of the various lease-related object class codes in the Agency's accounting system, Delphi; and (2) the requirement for approving officials to ensure the accuracy of accounting codes.

Develop, document, and implement a process to ensure that for any new or succeeding office space lease that does not meet the utilization standard, a justification is developed and documented in the lease file as to why the application of the Agency's space utilization standard is not cost effective.

Revise, document, and implement an internal control process to regularly track and assess the utilization rate for all office space leases in the Agency's current portfolio using data that is updated for accuracy on a regular basis. Implementing this recommendation could potentially put $22.9 million in funds to better use by preventing FAA from paying rent on unneeded space in excess of its utilization standard.

Update policy or develop procedures to place a greater emphasis on prevention in the SAPR training program and incorporate the Centers for Disease Control's elements of a comprehensive prevention program, such as providing bystander intervention training at all levels (students, faculty, staff, and leadership).

Complete a Sexual Assault Review Board review of all Academy policies and procedures, including the Midshipmen Regulations, to identify any gaps or inconsistencies with SAPR messaging and revise the policies and procedures accordingly.

Communicate the revised policies and procedures to all Academy stakeholders.

Establish and formalize in policy or procedures methodologies to evaluate the effectiveness of the SAPR program and its practices, including metrics to evaluate training outcomes.

Revise sexual assault policies and procedures and sexual harassment policies to clearly provide for documenting, tracking, and maintaining reports, such as by cross-referencing to the records maintenance standard operating procedure.

Develop and implement procedures for prioritizing responses to recommendations based on risk and aligning resources accordingly.

Develop and implement controls to ensure staff at all levels and faculty are held accountable for taking actions to support the SAPR program, including completing assigned action items.

Align the investigative reporting practice with the standard operating procedure for investigating an unrestricted report of sexual assault.

Develop and implement a procedure for reporting, investigating, and responding to sexual harassment complaints.

Develop and implement a procedure for validating the Academy's data on reported sexual assault and sexual harassment incidents.

Ensure that the Commission complies with the reporting requirements.

Ensure that the City complies with the reporting requirements.

Ensure that the Authority complies with the procurement and suspension and debarment requirements.

Ensure that the Authority complies with the reporting requirements.

Ensure that the Authority complies with the special tests and provisions requirements.

Ensure that the Authority complies with the procurement and suspension and debarment requirements.

Ensure that the Authority complies with the equipment and real property management requirements.

Ensure that the Authority complies with the special tests and provisions requirements.

We recommend FTA recovers $76,572 from the Authority, if applicable.

Define the projects that are considered pre-implementation (developmental) in the Agency budget guidance and Acquisition Management System policy and validate that developmental projects align with the definition and are funded under the appropriate budget activity.

Develop and implement a quality control checklist with criteria for determining when the use of incremental funding prior to PLA approval is permissible.

Develop and implement a control for enforcing the PMA limits on the assessment of program management fees for various administrative and contract support specified in the Agency's standard operating procedures.

Update PMA standard operating procedures to include a control that ensures project requirements are met before transferring expiring funds into the PMA account.

Amend the PLA close-out process to include the statement of outcomes and statement that work was concluded or if follow-on work is required.

Establish and implement a mechanism for providing oversight of developmental funding, to include records of decision regarding selecting, justifying, and measuring the outcomes of PLAs to ensure FAA is funding the highest priority work.

Revise AMS to include policy or guidance on justifying the use of program management task orders and a process for implementing assessment fees for multiple-award contracts.

Update SE2020's standard operating procedure for competition of SE2020 task orders, including strengthening procedures for follow-on awards.

Strengthen and document procedures to collect and analyze SE2020 task-order timeliness data to sustain improvements in task order award time.

Revise AMS to include policy or guidance for multiple-awards contracts to address acquisition planning, such as estimating contract hours and costs and overall contract estimates.

Strengthen, document, and implement controls for SE2020 invoice review to comply with the Prompt Payment Act. Implementation of this recommendation could put up to $44,000 in funds to better use.

Revise AMS to include policy or guidance for multiple-award contracts to describe the appropriate structure for fee payments in cost plus fixed-fee contracts.

Obtain direct and indirect cost audits for all SE2020 prime contractors for all base contract years, or document the risk assessments performed to justify when cost audits are not performed.

Revise AMS to include policy or guidance for obtaining direct and indirect cost audits for multiple-award cost-reimbursable contracts or to perform risk assessments to justify not obtaining them.

Enhance procedures and controls to require SE2020 staff with responsibility for oversight of task orders to track and document vendor performance through its Performance-Based Contract Monitoring (PBCM) system.

Revise AMS to require FAA's acquisition program office that manages multiple-award contract vehicles to develop and maintain comprehensive program management and governance plans.

Revise AMS to strengthen multiple-award contract oversight and management framework to ensure such multiple-award contracts follow sound business practices and AMS policies and procedures.

Provide detailed guidance for consistent BCA reviews, including whether reviewers should perform research to correct or complete missing information in project applications.

Establish and implement requirements regarding how BCA reviewers should document and maintain support for their reviews.

Define the C&C team's role in the BCA review process to include the necessary steps to carry out a systematic review.

Revise policy and guidance to include the standardized BCA review template and the requirement that a single responsible official finalize BCA reviews.

Allmond recommends NTSB enhance current policies and procedures over the review of year-end accruals by including a look-back analysis which compares disbursements made early in the subsequent fiscal year to the accrual estimated through the current process in order to identify items which should be included in its year-end accrual. In addition, if significant differences are identified, determine the appropriate corrective action necessary to increase the accuracy of its accrual estimation process.

Almond recommends that NTSB redesign the provisioning process to include that the system access request accurately describes the access required for each user and that when access is modified a new system access request form is completed to reflect this change.

KPMG recommends that management document their consideration of any factors that could impact the estimate in the current FY when preparing the annual grant accrual estimate.

KPMG recommends that management further document their analysis over the lookback review. Management should consider all factors that could result in a variance between the accrual and lookback calculation, make a determination as to the potential impact in the current year accrual calculation and ensuring the documented factors are accurately described and necessary revisions to the methodology are made.

KPMG recommends that management implement controls at the appropriate level of precision to ensure expense transactions are accurate, valid and properly posted to the general ledger.

KPMG recommends that management develop and implement its policies and procedures to ensure invoices are reviewed at the appropriate level of precision to ensure that amounts are properly expensed or capitalized. KPMG also recommends that management require appropriate level of detail from their contractors in order to effectively distinguish capital transactions from expense transactions.

KPMG recommends that the FAA perform a review of the AP accrual, including the procurement samples used for the percentage allocation, at a level of detail or precision to identify errors in order to prevent a misstatement.

KPMG recommends that LCSS implement policies and procedures to ensure LCSS user access is approved prior to the access being granted. In addition, KPMG recommends that LCSS management maintain documentation of the approvals, and ensure that user account request tickets are maintained properly.

KPMG recommends that the LCSS implement the procedures outlined by the LCSS System Security Plan to ensure that terminated and inactive users are removed appropriately and timely.

KPMG recommends that LCSS implement a process to review user access on a periodic basis.

KPMG recommends that the LCSS implement policies and procedures to ensure that periodic access reviews have a defined timeline, frequency, and provide adequate detail for the reviewer to determine if access is appropriate based on the user's roles and responsibilities.

KPMG recommends that FTA enhance its grant accrual retrospective review procedures to include a review, and adjustment, if necessary, of grantee expenditures used in the retrospective review to ensure such data is relevant and reliable.

KPMG recommends FHWA strengthen policies and procedures to ensure that terminated users' access is removed timely from UPACS and the application it supports, in accordance with the DOT Cybersecurity Compendium guidelines.

Finalize a timeline for identifying the remaining STARS requirements, including the additional requirements for the post-implementation enhancements

Implement a process in the FAA Requirements Management Plan to track and document when and how new requirements are validated and prioritized.

Redesign the power supply configuration of STARS rack assemblies to eliminate series connected power strips in the next STARS technical refresh of the 11 TRACONs.

Resolve the electrical configuration issue of the STARS rack assemblies at each of the 11 TRACONs by either: (a) obtaining approval for the configuration from a nationally recognized testing laboratory or (b) assessing and documenting risks posed by the STARS rack assemblies installed at each of the 11 facilities and FAA's acceptance of that risk on air traffic operations.

Collaborate with industry stakeholders to develop and implement a plan to collect and analyze reliable, accurate, and representative data on the frequency and severity of driver detention times.

Determine whether utility obligations are reportable for DATA Act purposes.

Improve controls to ensure that SLSDC excludes its zero dollar invoice related transactions from submissions.

Improve controls to ensure that FAA excludes micro- purchases from submissions.

Require MARAD, NHTSA, OST, and SLSDC to develop and disseminate policies and procedures for their risk management programs that include the appropriate elements such as criteria for making risk based decisions.

Implement controls to verify that information on threat activity has been communicated to senior agency officials and require retention of supporting documentation.

For the COE and FAA, update procedures and practices for monitoring and authorizing common security controls to (a) require supporting documentation for controls continual assessments, (b) complete reauthorization assessments for the controls, (c) finalize guidance for customers' use of controls, and (d) establish communication protocols between authorizing officials and common control providers regarding control status and risks.

Verify that FAA's criteria regarding designation and definition of contractor systems conforms to DOT guidance, and that systems are correctly classified.

Implement controls to continuously monitor and work with components to ensure network administrators are informed and action is taken to disable system accounts when users no longer require access or have been inactive beyond established thresholds.

Complete PIV enablement and requirements for remaining information systems, except those that are subject to exclusions that are documented and approved.

Take action to fully implement mandatory use of PIV cards for VDI access.

Implement processes verifying that personnel performing certain security related roles receive specialized training needed to meet OCIO guidance.

KPMG recommends that FAA Privacy Program conduct a review of its privacy program to identify changes needed to ensure that system's privacy plans are completed in accordance with the DOT Privacy Risk Management Policy.

KPMG recommends that FAA System Owner of System #2 ensure the system Privacy Plan includes all requirements established by the DOT Chief Privacy Officer in the privacy threshold assessment (PTA) and the adjudication statement is implemented.

KPMG recommends that FAA System Owner of System #5 ensure that the encryption protections for data at rest and during transit are implemented in accordance with the DOT Privacy Risk Management Policy.

KPMG recommends that FAA System Owner of System #5 confirm that the session time-out functionality has been implemented.

KPMG recommends that FAA System Owner of System #8 ensure that the encryption protections for data at rest are implemented in accordance with the DOT Privacy Risk Management Policy.

KPMG recommends that FAA System Owner of System #9 provide system specific and/or specialized/role based privacy job aides as needed to personnel who maintain and/or have access to PII data.

KPMG recommends that FAA System Owner of System #9 Ensure the Privacy Plan including all requirements established by the DOT Chief Privacy Officer in the PTA adjudication statement is implemented.

KPMG recommends that FAA System Owner of System #9 implement memoranda of understanding or similar agreements for internal sharing of PII.

KPMG recommends that FAA System Owner of System #9 ensure that encryption protections for data at rest is implemented in accordance with the DOT Privacy Risk Management Policy.

KPMG recommends that FAA System Owner of System #9 ensure that the Plan of Action and Milestones (POA&M) for encryption protections for data at rest is actively monitored and updated as changes occur prior to the estimated closure date of December 19, 2017.

KPMG recommends that Office of the Secretary of Transportation Departmental Chief Privacy Officer establish a continuous monitoring (CM) program for privacy supportive security controls to ensure PII systems remain compliant with DOT Privacy Risk Management policy.

KPMG recommends that Office of the Secretary of Transportation System Owner of System #15 ensure that the encryption protections for data at rest and during transit have been implemented in accordance with the DOT Privacy Risk Management Policy.

Establish a work breakdown structure, consistent with the DOT Earned Value Managment Implementation Guide standard, for investment projects when required by the DOT EVM Policy.

Establish a work breakdown structure, consistent with the DOT Earned Value Managment Implementation Guide standard, for investment projects when required by the DOT EVM Policy.

Ensure that artifacts illustrating implementation and execution of EVM are in accordance with the DOT EVM policy.

Retain evidence of the required EVM artifacts.

Revise the Emergency Relief Manual to include a definition of resilience improvement and identify procedures States should use to incorporate resilience into ERP-funded projects.

Develop and implement a process to identify best practices for improving the resilience of emergency relief projects and share them with Division Offices and State DOTs.

Develop and implement a process to track the consideration of resilience improvements for emergency relief projects and their associated costs.

KPMG recommends OST direct the OCIO to work with OAs' CIOs to conduct the required annual assessment of the DOT's and OA's EA programs against the GAO's EA Management Maturity Model.

KPMG recommends OST supplement the existing DOT EA Policy with operational guidance to clarify EA artifacts required by the DOT EA policy.

KPMG recommends NHTSA formally approve and distribute their OA level EA policy, otherwise the OA will rely on the DOT EA policy.

KPMG recommends FHWA formally approve and distribute their OA level EA policy, otherwise the OA will rely on the DOT EA policy.

KPMG recommends FRA retain evidence of the training provided to individuals with EA IT responsibility.

KPMG recommends FTA retain evidence of the training provided to individuals with EA IT responsibility.

KPMG recommends NHTSA retain evidence of the training provided to individuals with EA IT responsibility.

KPMG recommends PHMSA retain evidence of the training provided to individuals with EA IT responsibility.

KPMG recommends PHMSA produce and maintain evidence of EA reviews of IT investment risks that demonstrate alignment with appropriate DOT EA segments and DOT and OA EA standards.

KPMG recommends OST require that the EA artifacts illustrating implementation and execution of EA are in accordance with DOT EA policy.

KPMG recommends OST retain evidence of the required EA artifacts.

Revise the Safety Assurance System (SAS) risk-assessment tool to include weighted factors for each organizational risk evaluated by inspectors.

Update the scoring system and instructions in the Financial Condition Assessment Decision Aid to reflect that 10 characteristics are being evaluated.

Develop and provide additional guidance and training to inspectors to clarify the differences in the choices (word pictures) provided in the decision aids.

Reevaluate the decision aids to validate that: a. They include the appropriate areas of focus during reviews of the financial condition and transition or growth of regional air carriers; b.The weighting of the focus areas correlates to their potential impact on risks associated with financial distress or rapid growth or downsizing.

Revise validated guidance to emphasize the importance of completing decision aids periodically for baseline comparisons.

Implement a retention policy for completed decision aids so they will be available to inspectors for comparison and analysis during risk assessments.

Develop and provide guidance and training to show inspectors how to detect triggers that require the completion of a decision aid, as well as the importance of using decision aids to adjust surveillance.

Refine policies and procedures for collecting and analyzing safety data and metrics from regional airlines sector-wide and sharing that information with FAA's Flight Standards Offices.

Revise Agency guidance on risk-management processes to recommend adjustments to surveillance when the risk score is identified as high or document a reason for not adjusting surveillance given the risk.

Revise inspector guidance to provide actions inspectors should take after risks are identified through complaints, including reaching out to other offices if necessary and ensuring planned surveillance of the issue is actually completed.

Develop and implement policies and procedures to retain the original data files for purposes of validating the accuracy of the data being used to compute overflight fees.

Develop a timeline that indicates when FAA overflight-fee officials will start using updated software (that meet its system reliability requirements) for computing fees.

Develop and implement internal controls to oversee overflight-fee contractors, specifically, to review and approve flight data before the contractor submits them for billing.

Develop and implement internal controls to oversee Enterprise Services Center employees and require debt-collection training to ensure overflight fees are properly billed.

Establish policies and procedures that require staff to appropriately apply Federal laws and regulations and exclude aircraft users that are exempt or meet exception rules from receiving invoices for overflight fees.

Develop and implement policies and procedures to ensure that overflight-fee collection activities comply with Department of the Treasury requirements, such as:a. Ensuring debtors are given due process; implementation of this recommendation could put $1.48 million in funds to better use.b. Assessing late charges on all delinquent debts; implementation of this recommendation could put $9.3 million in funds to better use.c. Making timely referrals of delinquent overflight fees to Treasury; implementation of this recommendation could put $7.98 million in funds to better use.

Develop a comprehensive workforce plan by implementing the existing Human Capital Framework in accordance with the Department's Workforce Planning Guide.

Include in the workforce plan an assessment of whether the Agency should use retention incentives and, if appropriate, a plan for seeking authority to use retention incentives at levels above the fiscal year 2010 cap.

Include in the workforce plan an assessment of whether the Agency should use a special rate of pay for general engineers (series 0801) and, if appropriate, a plan for seeking authority to establish a higher rate of basic pay.

KPMG recommends that management continue to refine the EC&D estimation methodology to ensure that the methodology is based on relevant, sufficient, and reliable data that is supported by sufficient appropriate audit evidence.

KPMG recommends that management review any refinements to the methodology to ensure that the estimate is presented and disclosed in the financial statements in conformity with applicable accounting principles.

KPMG recommends that management establish appropriate communication channels with personnel outside of the Financial Statements and Reporting Division to ensure proper communication and coordination related to the calculation of material financial statement information

KPMG recommends that management perform an adequate review and approval of the accounting estimates, including: 1) Review of sources of relevant factors; 2) Review of development of assumptions; 3) Review of reasonableness of assumptions and resulting estimates; and 4) Consideration of changes in previously established methods to arrive at accounting estimates.

KPMG recommends that DOT establish a review control, with the appropriate level of precision, over the cash flow projections to ensure that the inputs are relevant and reliable.

KPMG recommends that DOT review the overall cash flow model functionality and implementation to ensure that all assumptions are properly applied, documented, and supported in the execution of the cash flow projections.

KPMG recommends that DOT consider automating the calculations that are performed manually to reduce the risk of misapplication of assumptions due to human error.

KPMG recommends that the Department complete the internal reviews currently planned or being performed, and properly report the results in compliance with the ADA, if necessary.

STB and its accounting service provider should implement accounting processes for estimating and recording the value of goods and/or services provided by vendors for open obligations, with and without an advance.

Develop written policies to: obtain invoices supporting the value of goods and services provided by vendors with advances so permanent reductions can be made to reduce the value of individual advances, close out advances where all services have been provided, and recoup all unused advance funding; including those currently outstanding.

Strengthen monitoring controls of financial management operations performed by the agency's accounting service provider. Develop policies, procedures and review checklists to ensure that monitoring processes are performed consistently and documented as required by GAO internal control standards.

Work with the accounting service provider to strengthen the service provider's quality control processes, and obtain documented assurances that quality control reviews have been performed on financial statements presented to the agency for audit

Determine the reasons that abnormal general ledger account balances were not identified, researched, and corrected, as appropriate despite the assurances provided in response to the same issues reported in the FY 2016 financial statement audit report. Implement additional controls to ensure abnormal account balances are properly identified, researched, and appropriate corrective actions are taken.

KPMG recommends that management continue to refine the EC&D estimation methodology to ensure that the methodology is based on relevant, sufficient, and reliable data which is properly supported by sufficient appropriate audit evidence.

KPMG recommends that management review any refinements to the methodology to ensure that the estimate is presented in conformity with applicable accounting principles and that the related disclosure is adequate.

KPMG recommends that management e stablish appropriate communication channels with personnel outside of the Financial Statements and Reporting Division to ensure proper communication and coordination related to the calculation of material financial statement information.

KPMG recommends that management perform an adequate review and approval of the accounting estimates, including: 1) Review of sources of relevant factors; 2) Review of development of assumptions; 3) Review of reasonableness of assumptions and resulting estimates; and 4) Consideration of changes in previously established methods to arrive at accounting estimates.

KPMG recommends that management develop and implement policies and procedures to ensure that only assets that exist and that may require future decommissioning and cleanup activities are included in the EC&D liability estimate.

Improve and implement reconciliation (walkthrough) procedures during the financial statement preparation process to ensure information included in its financial statements is supported by underlying accounting records and transactions.

Develop and implement accounting policies and procedures to recognize and record SLSDC's share of activities related to the operation of the South Channel Span of the Seaway International Bridge.

Develop and implement accounting policies and procedures to recognize and record SLSDC's expense activity associated with executed bridge repair service job orders.

Develop and implement accounting policies and procedures to recognize and record SLSDC's liabilities with SIBC for open service job orders.

Establish controls to ensure the appropriate useful lives of assets are recorded in the accounting system when new assets are placed into service.

Establish controls to review the nature and scope of projects prior to closure and conversion to PP&E to ensure that assets are properly recorded in the PP&E records.

Update asset disposal policy to better define procedures for disposal and establish specific parameters for timely completion.

Enhance certificates of disposal to include asset ID numbers to expedite disposal actions.

Perform a complete physical inventory of PP&E as required by SLSDC policy and research any differences identified.

Update the property records to include the serial numbers for buoys.

Coordinate with the Department of the Treasury to determine the appropriate treatment and custody of its funds currently held by SIBC.

Complete implementation of policies and procedures for: a. Risk management, including a risk management plan and assessment, b. System authorization, and c. Plans of actions and milestones.

Complete the system reauthorization of the STB LAN.

Complete service level agreements or similar documents that permit STB or its auditor to perform tests and/or obtain supporting documentation to demonstrate that cloud systems are properly authorized to operate.

Define specifications and acquire an automated solution to assist with the risk management program.

Develop policies and procedures for the implementation of an information security architecture.

Modify existing procedures to fully address identification, reporting, and resolution of information system flaws, including timely patch installation.

Incorporate missing elements into its enterprise-wide configuration management plan such as a change control board charter.

Modify identity and access management policies and procedures to adequately address: a. Reviews of as-is states, desired states and a transition plan. b. Processes for assigning personnel risk designations prior to granting access to its systems.c. Processes for developing, documenting, and maintaining access agreements for individuals with system access. d. Requirements for remote access

Conduct a needs assessment to formally determine the organization's awareness and training needs, including but not limited to developing and implementing a formal process for assessing the skills, knowledge, and abilities of its workforce.

Develop and implement a formal process for measuring the effectiveness of its security awareness and training program.

Modify the training plan to include missing elements such as funding, goals and use of technology.

Develop and implement an ISCM program that, at a minimum provides awareness of threats and vulnerabilities.

Modify its policies and procedures to address missing components such as incident detection and analysis; incident prioritization, containment, eradication, and recovery; coordination, information sharing, and reporting; incident response training and testing, and considerations for major incidents.

Implement its contingency planning policy by performing business impact analyses, updating or completing system contingency plans, testing contingency plans, performing necessary backups and obtaining an adequate alternate processing site, it needed.

Develop and implement written policies and procedures for establishing new Centers or making adjustments to existing ones—including determining each Center's initial financial resource needs, changes to funding levels, locations, geographic areas of coverage, and small business/client populations.

Conduct a baseline program needs assessment of current funding levels, locations, geographic areas of coverage, and small business/client populations to be served—and take corrective actions as needed to meet determined needs.

Develop and implement an action plan for increasing future competition for Center operation.

Develop and implement performance measures for cooperative agreement requirements that assess how well the Centers achieve program objectives and desired outcomes

Implement policies and procedures to ensure OSDBU personnel comply with existing monitoring requirements for conducting annual performance evaluations and site visits

Recover the $69,312.00 in improper payments for unallowable labor charges

Implement policies and procedures to ensure that OSDBU's financial management practices comply with appropriation law, Federal regulations, and the Department's Financial Assistance Guidance Manual. Implementing this recommendation could potentially put $1,168,907 in funds to better use.

Take action to correct the $346,927 in improper payments related to OSDBU's financial management practices identified in this report.

Deobligate the $57,758 remaining on cooperative agreements that have ended, as identified by this audit as funds that could have been put to better use

Develop and implement a process to perform periodic financial assistance management reviews of OSDBU to ensure that OSDBU is informed about and complies with existing financial management assistance laws, regulations, and guidance.

Ensures that the City complies with period of availability requirements.

Recovers $23,598 from the City, if applicable.

Ensures that Amtrak complies with equipment and real property management requirements.

Ensures that the Authority complies with period of performance requirements.

Recovers $44,589 from the Authority, if applicable.

Develop and implement policies and procedures, including a standard identification method, for tracking other transaction agreements (OTA).

Develop and implement criteria that: a. Describe when an OTA should be used rather than a contract or grant; b. Require awarding officials to document their rationale for using OTAs rather than contracts or grants.

Develop and implement policies and procedures to state when Acquisition Management System guidance, FAA financial assistance policies, and other requirements and guidance such as requirements for Independent Government Cost Estimates, including OTAs in Single Audits, and conflicts of interest analysis apply to OTAs.

Develop and implement policies to report OTA awards that involve Federal funds to USASpending.gov.

Establish documentation requirements for all types of OTAs, and develop and implement policies and procedures for maintaining complete files for the agreements, including evidence of legal reviews.

Develop and implement policies and procedures to ensure that OTAs are awarded and administered by properly authorized (warranted) officials, including: a. Creating and regularly maintaining a comprehensive list of awarding officials, the various types of agreements (e.g., contract, grant, OTA, reimbursable agreement, interagency agreement) they are authorized to sign, dollar limits (if any), and the dates the authority began and ended when applicable; b. Clarifying the Acquisition Management System to specify when it is appropriate to use an OTA that is also an interagency agreement or reimbursable agreement, and to specify what warrant authorities are required for officials signing these agreements.

Assess whether OTAs signed by individuals without proper authorization represent unauthorized commitments, and take appropriate corrective actions.

Develop and implement policies and procedures to standardize and enforce provisions of Tower Operating Agreement OTAs as a condition of providing air traffic control services, including: a. A procedure to provide for periodic inspections of the tower environment to detect problems that have an impact on FAA contract controllers and respond to them; b. Requiring all airport sponsors to sign Tower Operating Agreements.

Renegotiate tower leases requiring rent payments to airport sponsors to secure no-cost leases. Implementation of this recommendation could put $2.2 million in Federal funds to better use.

Recover the $19,000 overpayment to an OTA tower construction recipient, determine whether FAA overpaid other recipients on its tower construction agreements, and recover any overpayments and interest not applied to the construction projects.

Develop and implement policies and procedures for tower construction OTAs that at a minimum address aligning payments to actual needs and disposing of leftover funds and interest earned on advanced funds.

Develop a business case for the award of a new OTA, or an extension of the current OTA, to conduct research at and manage the Florida Test Bed that includes the potential for competition and a cost-benefit analysis that examines facility utilization (whether onsite or via remote access) and potential for cost sharing.

Follow DOT's cybersecurity policy, and track access and usage of OTA-covered information systems, including those at the Florida Test Bed.

Update the Financial Assistance Guidance Manual and other policies to reflect current authorities and oversight needs for OTAs, and clarify which provisions of the manual and other policies apply to these agreements.

Update the Financial Assistance Guidance Manual and other policies to reflect current authorities and oversight needs for OTAs, and clarify which provisions of the manual and other policies apply to these agreements.

Revise and implement policies and procedures for conducting pre-award reviews that assess the price reasonableness of each OTA.

Designate in writing which officials are authorized to award OTAs.

Ensures that the City complies with special test and provisions-wage rate requirements.

Ensures that the State complies with allowable cost principles requirements.

Recovers $176,050 from the State, if applicable.

Ensures that the State complies with subrecipient monitoring requirements.

Recovers $438,118 from the State, if applicable.

We recommend FTA ensures that the Division complies with reporting requirements.

Ensures that the County complies with cash management requirements.

Ensures that the County complies with procurement, suspension and debarment requirements.

Ensures that the County complies with special tests and provisions-wage rate requirements.

Ensures that the State complies with matching, level of effort, earmarking requirements.

Recovers $252,644 from the State, if applicable.

Ensures that the State complies with activities allowed or unallowed requirements.

Recovers $60,800 from the State, if applicable.

Ensures that the District complies with special tests and provisions-wage rate requirements.

Ensures that the Tribe complies with activities allowed or unallowed and allowable costs/cost principles requirements.

Determine an amount of questioned costs and recover from the Tribe, if applicable.

Ensures that the State DOT complies with subrecipient monitoring requirements.

Ensures that the State DOT complies with subrecipient monitoring requirements.

Ensures that the County complies with allowable costs/costs principles requirements.

Recovers $84,365 (2013-020 ($4,385) and 2013-022 ($79,980)) from the County, if applicable.

Ensures that the Authority complies with special tests and provisions-revenue diversion requirements.

Recovers $1,611,898 from the Authority, if applicable.

Ensures that the Authority complies with equipment and real property requirements.

Ensures that the State complies with special tests and provisions requirements.

Recovers $118,713 from the State, if applicable (Finding 2016-043).

Ensures that the State complies with special tests and provisions - wage rate requirements (Finding 2016-047).

Ensures that the Government of Guam complies with equipment and real property management requirements.

Ensures that the Government complies with equipment and real property management requirements.

Ensures that the Government complies with Special tests and provisions-wage rate requirements.

Ensures that the County complies with period of performance requirements.

Recovers $21,025 from the County, if applicable.

Ensures that the Authority complies with procurement, suspension, and debarment requirements.

Ensures that the Authority complies with allowable costs/cost principles requirements.

Ensures that the Authority complies with equipment and real property management requirements.

Ensures that the Territory complies with equipment and real property management Requirements.

Ensures that the City complies with cash management requirements.

Recovers $66,667 from the City, if applicable.

Ensures that the Authority complies with equipment and real property management requirements.

Require the contactor to report on all seven technical performance measures to provide FAA with the ability to determine whether all performance requirements are being met and contractually required products and services are being received.

To disclose the total cumulative costs for the contract, identify and report the potential range or maximum value of incentive fees payable under the contract, about $78 million, when reporting to managers, Congress, and other stakeholders.

Modify the contract to clearly identify the differences between critical service specifications for ADS-B and the technical performance measures for ADS-B services that are used for computing incentive awards.

Conduct and document a review of incentive fee implementation to ensure that it motivates the contractor to exceed the contract specifications and also minimizes performance violations as stated in the H.7 clause. Consider adjustments to the incentive fee implementation as a result of the review.

Enforce the H.33 clause to reveal capital asset cost and gain necessary pricing information for use in negotiating additions and enhancements to the ADS-B contract as has occurred on at least nine occasions previously.

Conduct and document an analysis to determine whether or not duplicate subscription fee payments are being made due to radio stations that support multiple service volumes.

Strengthen future acquisitions by adding or modifying guidance to AMS to incorporate concepts from the OMB Capital Programming Guide on considering the use of successive or incrementally priced contract, orders, or contract line items when acquiring or developing systems spanning many years. This guidance may be incorporated into planned guidance regarding the use of modular contracting concepts.

Strengthen future acquisitions by expanding guidance in the AMS or the FAA Pricing Guide to: (1) better describe the process for (a) evaluating price reasonableness and (b) determining cost realism when evaluating proposals, to include a review of quantities and types of hardware proposed; and (2) include in existing oversight processes a check to ensure that independent government cost estimates and life cycle cost estimates are not established based solely on the awardee's proposal.

Strengthen future acquisitions by requiring that contracting officers and specialists in the Surveillance Contracting Branch keep hard and/or electronic back-up copies of contract file information in the contract file; keep the contract up to date, including modifications or changes such as partial acceptance, methodology for partial acceptance, pricing matrix adjustments, and other agreements created by correspondence outside the contract; and ensure that in Agency computers, a complete and accurate record of all contract actions and supporting documentation is established and maintained in real time.

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Ensures that the State complies with subrecipient monitoring requirements.

Ensures that the County complies with Allowable Costs/Costs Principles requirements.

Recovers $171,265 from the County, if applicable.

Ensures that the City and County complies with special tests and provisions - wage rate requirements.()

Ensures that the State complies with procurement and suspension and debarment requirements.

Recovers $466,262 from the State, if applicable.

Ensures that the State complies with special tests and provisions requirements.

Recovers $78,578 from the State, if applicable.

Ensures that the District complies with special tests and provisions - wage-rate requirements.

Ensures that the State complies with activities allowed or unallowed requirements.

Ensures that the State complies with special tests and provisions requirements.

Ensures that the State complies with procurement and suspension and debarment requirements.

Ensures that the State complies with special tests and provisions requirements.

Update OCIO-WCF billing procedures to ensure billings are accurately and consistently applied to intra-agency agreements for products and services, within specified scopes of work and periods of performance.

Document OCIO's process for preparing cost estimates that support its cybersecurity budget request and maintaining support documentation justifying the basis of estimates.

Implement the DOT Enterprise Program Management Review Framework and procedures for maintaining support documentation that complies with OMB design and planning requirements to justify its IT investments, including the Virtual Desktop Infrastructure and the Continuous Monitoring Software, and require the use of planning tools such as cost-benefit analyses to monitor the costs, schedule, and performance goals.

Develop and manage a business case consistent with OMB guidance for cybersecurity investments, and ensure that Continuous Diagnostic and Mitigation program is incorporated into that investment for reporting of costs, and other criteria as required by OMB.

Develop and implement a process specifying how OCIO prioritizes its cybersecurity IT investments, and follow through on its plan to develop separate plans that include which cybersecurity projects it plans to focus on to address near-term threats, important tactical cybersecurity goals, and remediation challenges.

Develop a plan with milestones to evaluate how FMCSA establishes baseline parameters for its quality assurance tools.

Update information systems to capture the explicit identification of compliance reviews as either comprehensive or focused, and the Behavior Analysis and Safety Improvement Categories assigned and reviewed.

Finalize the Agency's grants management manual and include controls to document that all grant management steps have been accomplished before a grant is awarded or closed, as well as steps to address alleged prohibited uses of Technical Assistance Grant funds.

Finalize the Technical Assistance Grant program's Business Process Documentation.

Revise the grant agreement template for Technical Assistance Grants to include the statutory language prohibition against using program funds for direct advocacy.

Develop and implement a process for field level inspectors to coordinate with TSA on programs with closely related safety and security responsibilities, such as results of air carrier cockpit access program audits.

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Publish an FAA Notice to inspectors that communicates the existence of AC 120-110 and RTCA Report DO-329, highlights the blocking methods orchestrated by the Special Committee, and directs inspectors to communicate this information to the carriers they oversee.

Require air carriers to conduct a Safety Risk Assessment (under FAA’s Safety Management System) of their current secondary barrier methods using all information from the 2011 RTCA report on secondary barriers, either as a stand-alone Notice or incorporated into another Notice recommended above.

Meet with air carriers and TSA to discuss best practices that may be used to enhance cockpit security and reduce crew complacency.

Conduct outreach to industry and DHS to assess flight attendant concerns on additional training needed to better prepare for emergency situations, such as a crewmember lockout from the cockpit.

Ensures that the DOT complies with Internal Control Requirements.

Ensures that the City complies with Allowable Costs/Cost Principles Requirements. ()

Recovers $147,515 from the City, if applicable.

Ensures that the City complies with Reporting Requirements.

Ensures that the City complies with Reporting Requirements.

Ensures that the Agency complies with Allowable Costs/Cost Principles Requirements.

Recovers $9,189 from the Agency, if applicable.

Ensures that the Agency complies with Allowable Costs/Cost Principles Requirements.

Recovers $26,665 from the Agency, if applicable.

Ensures that the Authority complies with Special Tests and Provisions Requirements.

Determine their portion of the $ 29,116 in Questioned Costs and recovers from the Authority, if applicable.

Ensures that the Authority complies with Equipment and Real Property Management Requirements.

Ensures that the Authority complies with Reporting Requirements.( )

Ensures that the Authority complies with Cash Management Requirements.

Ensures that the City complies with Allowable Costs/Cost Principles Requirements.

Recovers $41,494 from the City, if applicable.

Ensures that the Authority complies with Procurement and Suspension and Debarment Requirements.

Ensures that the Borough complies with Allowable Costs/Costs Principles Requirements.

Recovers $191,777 from the Borough, if applicable.

Ensures that the City complies with Cash Management Requirements.

Recovers $36,579 from the City, if applicable.

Ensures that the Department complies with Subrecipient Monitoring Requirements.

Ensures that the Department complies with Subrecipient Monitoring Requirements.

Ensures that the State DOT Highways Division complies with Special Tests and Provisions-Wage Requirements.

Ensures that the State DOT Highways Division complies with Subrecipient Monitoring Requirements.

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Modify periodic training provided to FAA inspectors to include information on the importance of verifying check pilot qualifications prior to approval.

Clarify inspector guidance on performing and documenting APD training and observations to ensure authorization requirements are fulfilled.

Modify internal audit policies to ensure FAA audits provide accurate and thorough assessments of APD oversight at each office.

Develop and implement guidance requiring inspectors, or their designees, to verify that check pilots have met training requirements prior to performing recurrent observations.

Modify requirements within the risk-based oversight tool (SAS) for inspectors to ensure a sufficient number of check pilot records are evaluated to assess the accuracy of air carrier training.

Clarify surveillance requirements and the inspectors' role overseeing check pilots under AQP.

Develop and implement a training program on how to approve and oversee check pilots under AQPs for inspectors assigned to carriers using those programs.

Develop guidance and provide training to Hotline employees on how to accurately record specific data about Suspected Unapproved Parts (SUP) in FAA's database.

Develop a management control to ensure that all SUPs reports received by local inspection offices are submitted to the Hotline for processing.

Develop a management control to ensure FAA Hotline employees conduct trend analyses in accordance with the Hotline's guidance.

Develop a management control to ensure inspectors adhere to guidance when conducting SUPs investigations.

Revise FAA's risk-based oversight system to incorporate a risk indicator for manufacturers where unapproved parts have been found.

Require FAA Headquarters officials to forward all confirmed SUPs cases to Federal law enforcement agencies, whether or not criminal activity is suspected, in accordance with the letter agreement.

Coordinate with DOT's Office of Inspector General to determine the need for its investigators to receive all improper maintenance cases, including those initially reported as SUPs as well as those reported directly to FAA.

Require FAA Headquarters officials to provide quarterly SUPs investigation reports to Federal law enforcement agencies, in accordance with the letter of agreement.

Develop a management control to ensure inspectors issue UPNs consistently when notifying the aviation industry about unapproved parts.

Develop a management control to ensure inspectors follow existing guidance requiring operators to remove unapproved parts from use and their inventories.

Include a "best practice" in the SUPs Advisory Circular to encourage industry to register to receive automated notifications about unapproved parts.

Implement procedures to ensure selected Federal Aviation Administration employees receive additional guidance on procure-to-pay procedures needed to support Facilities and Equipment - Disaster Relief Appropriation Act program payments as proper.

Implement procedures to ensure the Federal Railroad Administration provides training to select grant recipients regarding the root causes of administrative errors and the identification and retention of required documentation to support a payment as proper in the High-Speed Intercity Passenger Rail program.

Implement procedures to ensure the Federal Transit Administration distributes guidance to grant recipients on the proper procedure for submitting payments that adhere to the grant agreement terms in the Formula Grants and Passenger Rail Investment and Improvement Act program.

Establish and implement controls to ensure the FMOCs meet contractual requirements to include in all Financial Capacity Assessment reports:a. Complete project ratings that are in accordance with all elements of FTA's rating criteria; andb. Sensitivity testing performed.

Require that FMOCs include in their Financial Capacity Assessment reports the rationales for all testing decisions and parameters selected for testing.

Establish and implement controls to ensure FTA regional staff follow the existing Federal Financial Report review procedures which require reviewing the reports and documenting the reviews.

Complete a financial analysis of all SFMTA's Federal expenditures incurred on the Central Subway project, including its indirect expenses, as reported in the Federal Financial Reports to quantify the amount of Federal funds to be reimbursed to FTA. Implementation of this recommendation could put at least $37 million in Federal funds to better use.

Revise FTA's policy guidance to include requirements identifying which project's third party agreements are critical versus those that are not, and which agreements are required to be completed and in place prior to FFGA approvals, to mitigate risks to project cost and schedule due to uncompleted third party agreements.

Develop and implement a process to require contracting officers to re-verify and document a firm's small/disadvantaged eligibility prior to awarding each individual procurement awarded under an eFAST master ordering agreement. Implementation of this recommendation could put $314 million in funds to better use by awarding those dollars to firms whose small/disadvantaged eligibility status was verified at the time of individual procurement award.

Develop and implement a process to periodically verify that justifications required by AMS section T3.2.4.A.6(c) are documented for each time and material type procurement awarded under an eFAST master ordering agreement, and that the justification addresses each of the four elements required (including explanations for why any of the individual elements were not addressed).

Strengthen guidance on utilizing performance-based contracting methods in service contracting, and train contracting and program staff how to use these methods in procurements awarded under an eFAST master ordering agreement.

Develop and implement a process to periodically verify that eFAST contracting officers are tracking contracting officer representatives' certifications and documenting them in the procurement files.

Develop and implement a process to promote regular communication between eFAST contracting officers and contracting officer representatives during the period of performance for procurements awarded under an eFAST master ordering agreement.

Develop and implement a process to promote contracting officer representatives to document and follow oversight plans for procurements awarded under an eFAST master ordering agreement, tailoring each plan to the procurement's unique risks and circumstances.

Develop and implement a process requiring contracting officer representatives to determine and document how they will validate that statement of work acceptance criteria have been met for each procurement awarded under an eFAST master ordering agreement.

Develop and implement a process requiring contracting officer representatives to maintain documented evidence of oversight for each procurement awarded under an eFAST master ordering agreement in either the official procurement files on FAA's eFAST Knowledge Services Network workspace, or in a format that is also accessible at any time to the eFAST office

Update reporting guidance so users can more efficiently and accurately identify reporting requirements for different accident and incident types and better understand the definitions of terms used on reporting forms.

Implement routine or Web-accessible training or other outreach to improve how information is provided to railroad reporting officers and enhance their understanding of key reporting requirements and common reporting errors.

Develop and implement a standard method for identifying and listing railroads in each FRA Region subject to 49 CFR Part 225 requirements.

Develop and implement procedures for tracking 49 CFR Part 225 audits of non-Class I railroads and identifying entities exempt from 49 CFR Part 225 reporting requirements.

Establish a risk-based prioritization for auditing non-Class I railroads every 5 years. Part of the prioritization process should include determining whether any higher-risk non-Class I railroads should be audited more frequently.

Formalize the 49 CFR Part 225 audit process with written guidance that identifies basic procedures, standards of evidence, and common sources of information, along with a process to update these standards and reevaluate audit priorities or scope when necessary.

Develop and initiate regular training to FRA staff responsible for 49 CFR Part 225 audits and establish a procedure to update the training when necessary.

Ensure the Tribe complies with Procurement, Suspension and Debarment Requirements.

Recover $25,646 from the Tribe, if applicable.

Ensure that Amtrak complies with Equipment and Real Property Management Requirements.

Ensure the Commission complies with Reporting Requirements.

Ensure the City complies with Cash Management Requirements.

Ensure that the Association complies with the Allowable Costs/Cost Principles Requirements.

Ensure that the Association complies with the Reporting Requirements.

Ensure that the Government complies with the Equipment and Real Property Management Requirements.

Ensure that the Government complies with the Special Tests and Provisions - Wage Rate Requirements.

Ensure the Academy complies with the Subrecipients Monitoring Requirements.

Ensure the Academy complies with the Subrecipients Monitoring Requirements.

Ensure the Academy complies with the Subrecipients Monitoring Requirements.

Ensure that the County complies with the Cash Management Requirements.

Ensure that the County complies with the Davis-Bacon Act Requirements.

Recover $293,899 from the County, if applicable.

Ensure that the County complies with the Procurement and Suspension and Debarment Requirements.

Ensure the City complies with the Allowable Costs/Cost Principles Requirements.

Recover $26,820 from the City, if applicable.

Ensure the Authority complies with the Procurement, Suspension and Debarment Requirements.

Recover $129,378 from the Authority, if applicable.

Ensure that the Authority complies with the Equipment and Real Property Requirements.

Require Division Offices to have documentation substantiating how each innovative technology and practice meets eligibility requirements for the projects under Section 1304 at the time of approval.

Develop and implement an oversight mechanism to periodically evaluate the effectiveness of State environmental review performances that assume DOT's environmental review responsibilities under Section 1313.

Finalize a plan for collecting and tracking data on CEs to meet mandatory reporting requirements for Section 1323.

Establish target completion dates for the remaining planned actions for MAP-21 Subtitle C provisions that are in progress.

Update the policy and FHWA Website to clearly reflect and convey the most current requirements for the use of Project and Program Action Information System (PAPAI).

Develop a system to individually track applicants through the hiring process, which will maintain the integrity of the data supplied by the medical and security clearance processes.

Establish a process to address applicants that receive a tentative offer letter but fail to initiate the medical and/or security clearance processes.

Develop controls to prevent the same FHWA official from signing lines 2 and 3 on project agreements and modifications and develop a plan, procedures, and time frame for FHWA from its headquarters office to monitor Division Offices' authorization processes and verify that they comply with FHWA authorization policy.

Revise existing controls to require more than one State DOT official signature on project agreement and modification requests consistent with Federal Internal Control Standards.

Develop and implement internal controls to prevent FHWA authorization of construction projects after State DOT advertisement for bid or contract award to ensure compliance with Federal regulations. Implementation of internal controls could have put an estimated $1.1 billion in Federal funds to better use.

Add mandatory data fields for project end dates, CFDA numbers, and indirect costs to FMIS as quickly as possible to ensure compliance with Uniform Guidance.

KPMG recommends that FTA revise its policies and procedures for monitoring obligations in order to more timely identify and de-obligate stale obligations by periodically monitoring grants that become inactive during the current fiscal year.

KPMG recommends that DOT develop and implement guidance to formally document its assessments and recognition decisions, in accordance with Statements of Federal Financial Accounting Concepts (SFFAC) No. 5 Definitions of Element and Basic Recognition Criteria for Accrual-Basis Financial Statements , as it relates to liabilities of exchange transactions, specifically those decisions to depart from GAAP based on materiality.

KPMG recommends that FTA and ESC management revise procedures to ensure manual JVs are reviewed, by the designated FTA approver, within the timeframe established by existing policies.

KPMG recommends that FHWA management develop and implement procedures and processes that require periodic reviews of the audit logs generated by the application. In accordance with the DOT Cybersecurity Compendium requirements, the procedures should include the items being reviewed and the frequency within which the reviews should occur.

KPMG recommends that FHWA management update the System Security Plan to reflect the new requirements for audit log reporting and reviews.

KPMG recommends that FHWA management configure the system to send automated activity alerts that would notify the appropriate individuals and allow them to track suspicious activities within the system. Identify alerts that need to be generated by the system application, and develop mechanisms to generate automated alerts to notify the appropriate individuals to perform actions if an alert is generated.

KPMG recommendes that FHWA strengthen policies and procedures to ensure that terminated users' access is removed timely, in accordance with the DOT Cybersecurity Compendium guidelines.

KPMG recommends that FHWA update policies and procedures to restrict programmer's access from production libraries and datasets to ensure appropriate segregation of duties

KPMG recommends that OST management develop and implement privileged service account review procedures to ensure that privileged service accounts are reviewed, at least semi-annually, for continued appropriateness, based on the principle of least privileged.

KPMG recommends that the ITSS enhance data center review policy and procedures to ensure all access is reviewed for appropriateness timely, in accordance with DOT Cybersecurity Compendium guidelines.

KPMG recommends that FAA Management revise procedures to ensure manual journal vouchers are reviewed timely and within the timeframes established by the policies.

KPMG recommends that FAA perform an analysis to determine the materiality of the expense transactions currently not included in the accounts payable accrual. If the amount is determined to be immaterial, management should develop and implement guidance to document its assessment and recognition decisions, in accordance with SFFAC No. 5, as it relates to liabilities for non-grant expense transactions and specifically decisions to not accrue for certain transactions. If the amount is determined to be material, management should revise its accounts payable policies to include all material payables in the accrual at year-end.

KPMG recommends that FAA refine its policies and procedures to ensure purchase orders and invoices are reviewed at the appropriate level of precision to ensure that amounts are properly expensed or capitalized.

KPMG recommends that FAA management properly document and implement procedures to update policies and procedures over physical access to the data center to be in compliance witht he DOT Cybersecurity Compendium.

KPMG recommends that FAA management properly document and implement procedures to maintain accurate and detailed user listing of individuals granted access to the data center.

KPMG recommends that FAA management properly document and implement procedures to perform periodic reviews of access rights for existing data center users.

Update the current list of active certifying authorities for each State Unified Certification Program and implement procedures for regularly maintaining and publishing the list.

Issue guidance to certifying authorities on steps to take to ensure compliance with the regulatory requirements for the timely processing of all applications for certification.

Require FAA, FHWA, and FTA to develop and implement a joint plan and schedule for reviewing certifying authorities within the 52 UCPs. Include within the joint plan an assessment of whether required timeframes for processing certification applications are being met and whether mandatory certification training is being completed.

Establish procedures to periodically review, update, and publish the mandatory certification training program required by the FAA Modernization Reform Act of 2012.

Issue guidance to certifying authorities on the steps they must take to ensure persons performing certification functions or involved in the certification process are properly trained prior to being allowed to approve applications.

Institute procedures for maintaining a current list of certification staff who need and have completed the mandatory training.

Develop and implement an advanced training program on topics requested by certifying authorities, identified in compliance reviews, determined by DOCR, or identified in this report (i.e., the examination of business structures/affiliations, reviews of personal net worth, verification of ownership and control, detailed site-visit reports, and fraud awareness).

Develop and implement a train the trainer program for the three Operating Administrations to deliver consistent guidance and training to their recipients on all aspects of the DBE program.

Publicize best practices such as those identified in this report relating to certification practices.

Implement a process to periodically monitor, analyze, and report to DOCR on significant or noteworthy changes in DBE participation at the large and medium hub airports. As part of this process, include a requirement that FAA's reports to DOCR identify the reasons noted by recipients for drops in participation and recommend actions to address them, as appropriate.

Require certification reviews to assess whether the certifying authority is (a) meeting required timeframes for processing instate and interstate applications and (b) ensuring staff have completed mandatory certification training.

Develop and implement a policy requiring annual contingency plan training for en route and terminal controllers that includes procedures for managing airspace divestment and the loss of communications and/or surveillance capabilities.

Develop and implement an internal control to test and certify the function of emergency equipment, including "power-fail" phones, flashlights, and other communication equipment at all air traffic facilities semiannually to ensure the equipment operates as intended.

Convene NextGen program officials to evaluate, expedite, and complete a report on how planned NextGen capabilities can enhance the resiliency and continuity of NAS operations and mitigate the impact of future air traffic control disruptions.

Establish a process and requirement to validate airspace divestment plans annually to ensure the plans can be executed and technical requirements are up-to-date based on current technology.

Develop airspace divestment plans for oceanic airspace, and develop and implement the technical requirements needed to support all new plans.

Update the Automated Contingency Tool (ACT2) or develop and implement a new automated tool that complies with FAA Order 1900.47 to collect, manage, and disseminate operational contingency plans and lessons learned documentation to all air traffic facilities.

Establish a process for developing baseline contingency metrics, analyzing contingency trends and root causes, and annually disseminating the results to Air Traffic Organization personnel.

Develop a procedure to include aviation industry stakeholders in post-contingency events at the FAA Command Center to discuss lessons learned and explore possible solutions to mitigate the impact of future air traffic disruptions.

Establish minimum documentation requirements for FPFs and STIPs in guidance to Division Offices.

Develop and implement an oversight process to monitor and provide feedback to Division Offices on their review and approval of STIPs, and ensure Division Offices comply with Federal regulations, especially in regard to verifying fiscal constraint and the States' cost estimation processes.

Establish a centralized relational database to collect FPF information from the Division Offices and track recommendations and related corrective actions.

Complete the update of the MOAs on coordination with FTA.

Identify best practices of FHWA Division and FTA Regional Offices on coordination for development of Title VI plans, and distribute the best practices agency-wide.

Establish specific milestones to update and maintain UAS guidance to keep pace with technological developments and incorporate inspector feedback.

Develop comprehensive and updated training for safety inspectors on UAS technologies and Agency rules and guidance related to UAS oversight.

Initiate a periodic process to perform inspections of commercial UAS operators based on operational factors (e.g., location, number of operations, and type of activity) to verify knowledge of and compliance with FAA requirements and to inform the development of a risk-based oversight plan.

Design and implement a risk-based and prioritized oversight plan for UAS to help ensure safe operations of UAS.

Develop and implement a process to coordinate existing disparate UAS databases within FAA to facilitate data mining and safety analysis.

Implement a process to share UAS data with field oversight offices to assist inspectors in risk-based and proactive oversight of civil UAS operations.

Implement an internal control procedure requiring an independent review to be performed over the OPM imputed cost calculation to ensure the calculation is accurate and the appropriate basic pay amounts are used.

Communicate to airspace users the potential changes coming to the flight service program, including how future services may be delivered, estimated timeframes for the changes, and steps users can take to prepare for the changes.

Develop a list of FAA orders and oversight processes that will require modification due to the planned flight service program changes.

Develop an oversight framework that is commensurate with program changes before awarding the next flight services contract and implement the framework shortly after the program changes are put into effect.

KPMG recommends that the Chief Information Officers of DOT and FTA develop policies, procedures and controls to address the provisioning of IT access, vulnerability management, system audit log review and change management control deficiencies identified in the FTA financial IT systems.

KPMG recommends that the Chief Information Officers of DOT and FTA monitor progress to ensure that procedures and controls are appropriately designed, implemented, and maintained.

KPMG recommends that the Chief Information Officers of DOT and FTA establish procedures and controls, at the appropriate level of precision, for unusual or infrequent events (e.g. system implementations) by establishing an IT steering committee that is composed of management from all relevant stakeholder functional areas, including the IT office, program office, and financial reporting office to ensure that system implementation meets the needs of all users and that policies, procedures, and system controls are appropriately redesigned, as necessary, to respond to the process changes resulting from the system implementation.

KPMG recommends that the Chief Information Officer of FTA execute a Service Level Agreement with all external service providers that defines the level of service expected from the service provider and appropriately identifies and delineates the roles and responsibilities of the service provider and the end user entity.

KPMG recommends that the Chief Information Officer of FTA d esign and implement policies and procedures to formally request, obtain, and review the external service provider's SSAE No. 16 report, and evaluate any deficiencies and end user considerations noted in the report.

KPMG recommends that the Chief Information Officer of FTA document the required procedures for assessing the impact of identified deficiencies, noted in the external service provider's SSAE No. 16 report, which may impact FTA, to ensure appropriate end user controls are in place to mitigate those noted deficiencies.

KPMG recommends that FTA enhance the grant accrual retrospective review policies, procedures, and controls to ensure that the retrospective review is performed at the appropriate level of precision, using relevant and reliable data inputs (complete and accurate FFR data);

KPMG recommends that FTA establish procedures and controls over the completeness and accuracy of the data inputs used in the grant accrual calculation.

KPMG recommends that FTA enhance the methodology and consider creating a user checklist of each of the program elements and appropriation codes that should be selected as inputs.

KPMG recommends that FTA establish policies and procedures for handling deviations from the standard methodology, including maintaining the evidence to support the deviation.

KPMG recommends that FTA establish a review control, with the appropriate level of precision, over the grant accrual calculation.

KPMG recommends that FTA perform an analysis and calculate an independent grant accrual for abnormalities in grantee spending patterns, in particular when a grantee is placed on suspension or restricted drawdowns as the billing cycle days for such grantees are not indicative of the true accrual period for that expenditure category.

KPMG recommends that FHWA establish a review control, with the appropriate level of precision, over the cash flow projections to ensure that the inputs to the Subsidy Calculator are relevant and reliable.

KPMG recommends that FHWA review the overall cash flow model functionality and implementation to ensure that all assumptions are properly applied, documented, and supported in the execution of the cash flow projections.

KPMG recommends that FHWA consider automating the calculations that are performed manually to reduce the risk of misapplication of assumptions due to human error.

KPMG recommends that DOT follow established policies and procedures designed to prevent Anti-Deficiency Act violation.

KPMG recommend that DOT increase training and communications with personnel responsible for performing the established policies and procedures.

KPMG recommended that DOT improve its general information technology controls at FTA, as noted above (under Section A - Lack of Sufficient General Information Technology Controls at FTA), to ensure that DOT's financial management systems comply with the requirements of the FFMIA.

Should consider implementing additional procedures to monitor the activity of the funds held at Seaway International Bridge Corporation, Ltd. (SIBC) on their behalf for future bridge repair and operations, throughout the fiscal year.

The Saint Lawrence Seaway Development Corporation (Corporation) should implement procedures to record the activity of funds held at Seaway International Bridge Corporation, Ltd. (SIBC) within the financial records of the Corporation on a more frequent basis.

Establish procedures and controls, at the appropriate level of precision, for unusual or infrequent events (e.g. system implementations, changes in accounting principles, or implementation of new accounting standards) in order to prevent or detect and correct a misstatement to the financial statements. Specifically for IT system implementations, establish an IT steering committee that is composed of management from all relevant stakeholder functional areas, including the IT office, program office, and financial reporting office to ensure that system implementation meets the needs of all users and that policies, procedures, and system controls are appropriately redesigned, as necessary, to respond to the process changes resulting from the system implementation

Establish policies, procedures, and controls over the periodic review of inventory unit values and develop the process for extracting the necessary reports and recording the adjustments in LCSS.

Establish policies, procedures, and controls to ensure that the inventory values assigned by LCSS are appropriate based on the asset condition.

Establish policies, procedures, and controls to reconcile the inventory items that exist in the warehouse and are recorded in WMS with the inventory items recorded in LCSS.

Perform an analysis of inventory by accounting groups and condition classifications to ensure that assets are recorded in LCSS with the appropriate condition code and the appropriate value

Provide training to the repair shop technicians on the new process of applying costs to LCSS shop orders to ensure repair costs are completely and accurately recorded.

Revise its policies and procedures to ensure that all assets, regardless of whether or not the assets were capitalized into PPE or expensed, that may require future decommissioning and cleanup activities are included in the liability.

STB officials should ensure that unfunded FECA liabilities and FECA actuarial liabilities are calculated and included in year-end financial statements and related footnotes.

STB officials should ensure that significant abnormal general ledger balances are researched and corrected prior to preparation of financial reports.

Develop and implement Agency-wide guidance for a uniform approach to segmentation that provides a common format to aid the management of multiple, complex, and interrelated programs needed to achieve NextGen capabilities for transforming the NAS.

Take action to work with all OAs to complete expired authorizations and reinforce or strengthen policy requiring systems be reauthorized prior to their expiration dates.

Take action to work with all OAs to perform a thorough CSAM quality review to ensure system documentation matches what is entered into CSAM. At a minimum, the review should verify that: (1) system authorization dates in CSAM match what is approved by the authorizing official; (2) POAMs are created and reported once a security weakness is found; and (3) authorizing officials are provided accurate documentation on all risks accepted.

Take action to work with FAA, FHWA, FMCSA, FTA, MARAD, NHTSA, and OST to develop risk acceptance memos for the expired systems identified in this report.

The Deputy Secretary, or his designee, take action to work with OST COE, FTA, and FAA, the common control providers, to report and update risk acceptance for shared controls that are not implemented in DOT's Repository (e.g., CSAM) per FISMA, OMB, and DOT requirements.

Take action to work with FAA and require them to review CSAM POA&M entries, and identify and correct cases where multiple weaknesses were entered as one.

Perform a review of CSAM POA&Ms and assess if the entries are compliant with DOT policy. For deficient data, require OAs to provide a corrective action plan.

The Deputy Secretary, or his designee, take action to identify and document OST COE compensating controls when used to address security weaknesses in CSAM and system authorizations.

The Deputy Secretary, or his designee, take action to report/update OST COE security weaknesses found during vulnerability assessments in DOT's Repository (e.g., CSAM) per FISMA, OMB, and DOT requirements.

Implement protocols or practices to identify DOT employees outside FAA who are missing nondisclosure forms and have each of these employees complete the agreement.

Implement protocols or practices to reinforce guidance on the marking of classified documents and to periodically assess compliance.

Dedicate additional resources to oversee FAA's self-inspection program.

Implement protocols or practices to identify FAA employees who are missing nondisclosure forms and have each of these employees complete the agreement.

Implement protocols or practices to reinforce guidance on the marking of classified documents and to periodically assess compliance.

Identify all employees whose duties significantly involve the creation, handling, or management of classified information, and update any performance plan that is missing a critical element on management of classified information.

Implement protocols or practices to enhance the quality of self-inspection reports and to periodically assess compliance.

Finalize and issue policies and procedures for assuming direct safety oversight authority, including criteria and decision-making processes, and communicate the policies and procedures within the Agency.

Communicate the policies and procedures for assuming direct safety oversight to the rail transit industry.

Finalize and issue policies and procedures for relinquishing oversight authority to ensure an efficient transition of responsibilities back to the SSOA and communicate the policies and procedures within the Agency.

Communicate the policies and procedures for relinquishing direct safety oversight to the rail transit industry.

Finalize a plan with milestones to create a data-driven, risk-based safety oversight system.

Update FTA's methodology to meet the triennial SSOA audit requirement for all SSOAs.

Finalize a plan with milestones for periodically updating the National Safety Plan.

Develop and issue an agency-wide policy for implementing mandates and recommendations. The policy should, at a minimum, establish: a) Specific roles, responsibilities, and authorities of the Chief Counsel, Chief Safety Officer, and the Associate Administrators for Pipeline and Hazardous Materials Safety; b) Requirements for developing a plan to address each mandate and recommendation; c) Requirements for assigning responsibilities to each team member, in particular to team leads, for carrying out this policy; d) Requirements for retaining documentation in accordance with the Department of Transportation records management policy; and e) Management controls including oversight processes for the implementation of mandates and recommendations.

Develop and implement a rulemaking prioritization process that requires assessment of risk.

Develop written agreements with the FAA, FMCSA, and FRA on appropriate coordination for rulemaking and the international standards development process. At a minimum, the agreements should cover roles and responsibilities, communication protocols, and required documentation on decisions.

Provide guidance to OHMS on implementing its written agreements with other Operating Administrations.

Develop and implement an internal policy on the dispute resolution process that includes criteria and timeframes for when to use the process.

Enforce DOT's current policy for incident monitoring to ensure the Cyber Security Management Center's access to FAA's NAS systems and departmental cloud systems, or update the policy to reflect the unique reporting structures between DOT and FAA.

Establish policy and controls for the use of maintenance data terminals to reduce the incidence of malware on these terminals

Implement a ranking method for incidents.

Require OAs to provide their network maps to the Cyber Security Management Center.

Ensure the TAPS complies with the Special Tests and Provisions Requirements.

Ensure TAPS complies with Activities Allowed or Unallowed, Allowable Costs/Cost Principles Requirements.

Ensure TAPS complies with Cash Management Requirements.

Ensure TAPS complies with Equipment and Real Property Management Requirements.

Ensure TAPS complies with Matching, Level of Effort, and Earmarking Requirements.

Ensure TAPS complies with Procurement and Suspension and Debarment Requirements.

Ensure TAPS complies with Reporting Requirements.

Ensure the State complies with the Allowable Costs/Cost Principles Requirements.

Ensure the State complies with the Special Tests and Provisions Requirements. (Findings 2015-069 (Wage Rate requirements) & 2015-072 (Construction Materials Sampling and Testing)).

Ensure the State complies with the Special Tests and Provisions Requirements. (Finding 2015-069 (Wage Rate requirements).

Ensure the State complies with the Subrecipient Monitoring Requirements.

Ensure the State complies with the Information System Requirements.

Ensure the State complies with the Information System Requirements.

Ensure the State complies with the Information System Requirements.

Ensure the State complies with the Reporting Requirements (Finding 2015-073).

Ensure the State complies with the Reporting Requirements (Finding 2015-073).

Ensure the State complies with the Reporting Requirements (Finding 2015-073 & 2015-074).

Ensure TAPS complies with the Special Tests and Provisions Requirements.

Ensure TAPS complies with Activities Allowed or Unallowed, Allowable Costs/Cost Principles Requirements.

Ensure TAPS complies with Cash Management Requirements.

Ensure TAPS complies with Equipment and Real Property Management Requirements.

Ensure TAPS complies with Matching, Level of Effort, and Earmarking Requirements.

Ensure TAPS complies with Procurement and Suspension and Debarment Requirements.

Ensure TAPS complies with Reporting Requirements.