Recommendation Dashboard

Verify that each OA has a documented process in place to confirm that required PIV card-related security clauses are included in all applicable DOT contracts prior to award.

Establish, document, and implement a process for the Department to track contractor employees’ PIV cards and record the dates the cards are collected and deactivated.

Designate in writing points of accountability for overseeing the entirety of contractor employee PIV card collection and deactivation processes.

Update or supplement the DOT PIV Card Program Order to define “promptly” in all uses throughout the Order.

Develop and implement required annual training for all staff involved in contractor employee PIV card processes and a procedure to verify the training has occurred. The training attendees should include all staff listed in the DOT PIV Card Program Order who could potentially be involved and anyone else an individual OA assigns to this task.

Update or supplement the DOT PIV Card Program Order to address the deactivation process in all instances where PIV cards are no longer needed. This should include establishing the accountable officials as well as concrete metrics when deactivation should occur from when the card is no longer needed.

Coordinate with impacted OAs to develop a corrective action plan to resolve and close the findings highlighted in this report.

Determine the allowability of the questioned transactions and recover $14,886,138, if applicable.

Establish and implement a maintenance technician workforce plan that considers factors such as average training time, training requirements, and staffing turnover for a period longer than 1 year.

Update and implement a formal process that better defines roles and responsibilities and establishes improved communication and collaboration among the stakeholders responsible for maintenance technician training, including Technical Operations, Technical Training, and the FAA Academy.

Develop and implement a process that includes defined roles and responsibilities for the groups within Technical Training responsible for the management of training solution procurements.

Update and implement a formal process to periodically evaluate training course feedback from maintenance technicians, generate regular reports for FAA Technical Training management’s review, and share the lessons learned to improve future course content and delivery.

Document the process by which key safety decisions, such as a potential grounding of an aircraft fleet, are made when the Agency identifies that urgent action is necessary.

Revise the Transport Airplane Risk Assessment Methodology (TARAM) handbook to incorporate current safety data, including available international data when appropriate.

Review the TARAM handbook’s quantitative safety guidelines to determine if they still meet the Agency’s needs, and implement identified corrections as appropriate.

Formalize training requirements for engineers responsible for completing TARAM analysis, as well as managers responsible for reviewing the analysis.

Review the TARAM and Transport Airplane Safety Manual (TASM), address any identified key differences the two documents, and integrate TASM into TARAM when appropriate.

Incorporate integrated System Safety Assessments into regulations or Agency guidance for future transport category airplane certification projects.

Identify lessons learned related to the application of the 737 MAX recertification and the Continued Operational Safety process that have not yet been addressed and include them into airplane certification and safety evaluation processes.

Require AXI to develop a process to collect and share best practices for investigators in compliance with AXI guidance.

Revise Security and Hazardous Materials Safety Order 1600.20 guidance to avoid overlap or contradiction with similar procedures contained in FAA Order 1600.38.

Revise AXI’s guidance to clarify that investigators should pursue administrative investigations when OIG declines cases for criminal referral.

Develop and publish roles and responsibilities for AXI deputy director position.

Develop and implement procedures for investigators to electronically record interviews in accordance with FAA’s Human Resources Policy Manual requirements.

Develop and implement a management control to credit and account for Agency and non-Agency investigator training courses in AXI’s electronic training system.

Develop and implement an internal control to ensure that only the management official with requisite signature authority signs for investigative reports.

Develop and implement procedures consistent with DOT Order 8000.8A to ensure investigators consistently send criminal cases to the Internal Investigations Division Manager and coordinate with OIG’s Office of Investigations on the referral process.

Develop and implement a management control to require the Internal Investigations Division Manager to track cases that have been rejected by the Internal Investigations Division (AXI-100).

Develop procedures to ensure the Investigations Standards and Policy Division (AXI-200) maintains auditable documentation, in accordance with established Agency retention periods, to support findings identified in its annual reports of AXI-100 investigation procedures.

Develop and implement a management control to ensure AXI-200 complies with its Program Reviewer Guide requirements to (a) prepare annual reports, (b) conduct the required number of annual reviews of AXI investigative operations, (c) use consistent investigative and reporting criteria, and (d) identify investigation case numbers when reporting its evaluation of AXI-100’s investigative operations.

Coordinate with impacted OAs to develop a corrective action plan to resolve and close the findings highlighted in this report.

Determine the allowability of the questioned transactions and recover
$5,538,037, if applicable.

Develop and implement procedures to monitor Operating Administrations’ (OA) compliance with the 30-day registration requirement in accordance with the Transportation Acquisition Manual (TAM).

Update the TAM to require that contractor performance assessments be completed within 120 calendar days in accordance with the Contractor Performance Assessment Reporting System (CPARS) guide.

Develop and implement procedures to ensure those OAs without internal CPARS guidance have them established in compliance with TAM 1242.1503(a)(1).

Update the TAM to require each OA to develop and implement guidance to address turnover in CPARS staff as well as ensure departing personnel complete interim assessments.

Update the TAM to require CPARS role- and function-based training for all users not currently cited, including Alternate Focal Points and Assessing Official Representatives.

Update the TAM to require each OA to develop and implement guidance to assist OA CPARS officials in managing assessment disagreements with contractors.

Adopt a process to conduct periodic assessments to identify shortfalls and projected needs in CPARS training.

Develop and implement procedures to monitor compliance with the 30-day registration requirement.

Update the Acquisition Management System to require CPARS training for all personnel who have CPARS responsibilities.

Conduct an assessment of CPARS user training and develop and implement plans to meet identified needs, including training geared to assisting CPARS officials in developing skills for managing disagreements with contractors.

Develop and implement procedures to verify that airport sponsors have provided evidence satisfactory to FAA that the airport sponsor has or will obtain good title to land, prior to requesting reimbursement for costs associated with noise compatibility land acquisition. Implementing this recommendation could put up to $2,077,796 in funds to better use by requiring that only costs associated with completed noise land acquisitions are reimbursed.

Develop and implement a process to require airport sponsors to certify that noise exposure maps are a reasonable representation of current and/or future conditions at the airport at the time of grant award.

Update the Noise Land Management and Requirements for Disposal of Noise Land or Development Land Funded with AIP policy to establish a reasonable schedule for FAA Airport District Offices and Regional Offices to review Noise Land Inventory and Reuse Plans for accuracy and consistency with FAA policy.

Update and implement procedures to require airport sponsors to maintain Noise Land Inventory and Reuse Plans in electronic format available for FAA review, upon request.

Require all airport sponsors that have acquired noise land to identify noise land eligible for disposal via sale and verify that noise land sales revenues are used in accordance with Federal law. Based on our review of five airports, implementing this recommendation could put up to $38,530,768 in funds to better use by generating revenue that could be reinvested in the program.

Update guidance to clarify for airport sponsors when noise land should be considered no longer needed for eligible current or planned airport purposes and disposed of in accordance with FAA policy.

Update guidance for Noise Land Inventory and Reuse Plans to require that the Noise Land Inventory include original acquisition dates, estimated or final completion dates for proposed or completed methods of disposal, and the date of FAA approval.

Update guidance for Noise Land Inventory and Reuse Plans to require that the Noise Land Inventory include the Federal share of the sale price at the time of sale and how sales proceeds were used. Implementing this recommendation could put up to $66,160 in funds to better use by properly accounting for noise land disposal proceeds in accordance with Federal law.

Require the Rhode Island T.F. Green International Airport, Phoenix Sky Harbor International Airport, and Harry Reid International Airport to develop and submit for FAA’s approval current Noise Land Inventory and Reuse Plans after implementation of recommendations 4, 7, and 8.

Coordinate with impacted OAs to develop corrective action plans to resolve and close current and repeat findings highlighted in this report.

Determine the allowability of the questioned transactions and recover $3,546,767, if applicable.

Allmond recommends that NTSB management enforce the agency’s FPPS user termination process to require the completion and submission of an FPPS User Access Form to the service provider immediately upon separation of all FPPS users from the agency.

Allmond recommends that NTSB management work with the service organization to determine why the termination date for the user accounts did not agree with the effective date of the personnel actions for the employee separations.

Allmond recommends that NTSB management at least quarterly, perform a review of all FPPS users. If any separated employees, or any other system users who no longer need access, are identified in the listing, then work with the service organization to determine why this occurred and what actions are necessary to resolve the issue.

KPMG recommends that FAA management design and implement formal detective controls to log and monitor developer activities in the time and attendance production environment. All programmatic changes to the time and attendance production environment should be reviewed and reconciled from the logs to the approved change tickets.

KPMG recommends that FAA management review and re-certify the FAA procurement system PTA in accordance with FAA policy.

KPMG recommends that FAA management perform a risk assessment to consider the potential impact of discrepancies between vendor-submitted invoice web portal amounts and the vendor-submitted supporting documentation, and respond to the level of risk identified as appropriate.

KPMG recommends that FAA management communicate the importance of its existing financial system goods and services acceptance processes, policies, and procedures with its CORs.

KPMG recommends that FAA management quantify the impact of the non-GAAP assumption and record it as a part of their estimate if deemed material.

KPMG recommends that FAA management update policies and procedures for the environmental remediation estimate to ensure that all methodology assumptions are documented.

KPMG recommends that FAA management clarify its General Property, Plant & Equipment accounting policies for real property improvements to further document management’s criteria and considerations for capitalizing costs relating to building components typically expensed by FAA during the asset lifecycle.

KPMG recommends that FAA management assess the nature of its FIA and Modernization costs incurred to document the specific criteria distinguishing the nature of these programs’ costs from other programs’ costs.

KPMG recommends that FAA management continue to consider the appropriateness of its policies for real property, including improvement criteria, capitalization thresholds, and estimated useful lives, particularly for its fully depreciated real property.

KPMG recommends that FAA management assess the risks associated with recording UCOs with Advance within its business process, and design and implement a control activity to ensure timely and accurate recording of UCOs with Advance for which an advance payment associated with the RA has been received.

KPMG recommends that FAA management design and implement controls to perform a risk assessment for instances in which an AIP grant agreement remains open only for non-financial administrative or compliance requirements and respond to the risk of untimely deobligation of grant UDOs.

KPMG recommends that FAA management design and implement controls to ensure that the population generated to support the disclosure of future minimum lease payments is complete and accurate.

KPMG recommends that FAA management develop policies to define the scope of the lease disclosure.

KPMG recommends that FAA management design and implement control activities to monitor the effective operation of its process controls related to provisioning new payroll shared service center access requests.

KPMG recommends that FAA management develop policies and procedures for maintaining completed and authorized payroll shared service center access forms for new user access requests in a secure centralized location.

KPMG recommends that FAA management design and implement control activities to monitor the effective operation of its process controls related to monitoring FAA employees’ payroll shared service center access.

KPMG recommends that FAA management take measures to ensure that FAA has sufficient control operator personnel available to support the annual recertification of FAA employees with payroll shared service center access within the reporting timeline prescribed by DOT.

KPMG recommends that DOT OCIO management revise the website containing the policy documentation to ensure all documents are consistent and contain the same listing of required controls for moderate-impact systems.

KPMG recommends that DOT OCIO management should document any Department-wide tailoring decisions within the appropriate security documentation, as required by NIST.

KPMG recommends that DOT OCIO management should define and document control tailoring requirements for the Department and its Operating Administrations.

KPMG recommends that DOT OCIO management ensure that the process for provisioning privileged database system administrator accounts supporting the Federal Highway Administration’s grant system is performed in accordance with DOT policies.

KPMG recommends that ESC management create monitoring procedures over the existing management review of the JV control logs monthly reconciliation to ensure the consistent operation of the control, as defined within policy.

KPMG recommends that OST-CFO management revise its accounting process to accrue TIFIA interest each period or document its current process as a non-GAAP policy and perform an annual materiality assessment to determine the annual impact of the unaccrued interest policy.

KPMG recommends that OST-CFO management should perform a review of OST-CFO’s accounting policies and procedures as a control activity over the completeness of non-GAAP policies and procedures and update the non-GAAP listing and assessment accordingly.

KPMG recommends that OST management implement policies and procedures to strengthen their process to timely assess applicable third-party service organization reports such as consistently identifying and documenting the relevant control objectives, related controls, and rationale for non-relevant control objectives and controls.

KPMG recommends that OST management implement policies and procedures to strengthen their process to timely assess applicable third-party service organization reports such as consistently identifying and documenting the relevant complementary end user controls designed and implemented by DOT.

KPMG recommends that OST management implement policies and procedures to strengthen their process to timely assess applicable third-party service organization reports such as consistently identifying and documenting the criteria used by management to evaluate the results of the service organization controls report and related findings.

KPMG recommends that FTA management design and implement controls to track the status of Treasury warrant requests to ensure that the warrants are recorded in the financial system timely when processed.

KPMG recommends that FTA management perform a review for the completeness of the financial statements provided to OST, including reviews for transactions recorded subsequent to the OST reporting date.

Develop and implement, for each discretionary grant program that relies on cost estimates to establish compliance with program requirements and eligibility, a risk-based process for validating cost estimates prior to the execution of grant award agreements, as well as document the Department's review of the cost estimates.

Direct FHWA and FTA to coordinate with grantees to ensure the City of Seattle develops and implements appropriate internal controls to track Federal funds in accordance with 2 CFR 200.302(b)(1) and (3).

Remove $21 million in lapsed funding identified in this report from FHWA's unobligated balances. Implementing this recommendation could put $21 million in funds to better use on other transportation programs.

Advise WSDOT as part of stewardship and oversight activities to include change orders in WSDOT's next project management review of SDOT.

Direct the FHWA WA Division to review WSDOT's established process of reviewing subrecipients' supporting documentation for internal staffing charges (e.g., billing records, invoices, timecards) to ensure compliance with 2 CFR 200.403.

Work with WSDOT to collect adequate supporting documentation for $753,839 in internal staffing costs identified by OIG or recover from WSDOT any portion that is determined to be unallowable or unsupported.

Incorporate change orders as a focus area in FRA’s annual review process.

Develop and implement policy to evaluate whether to deobligate funds when there is a significant reduction in project costs prior to closeout.

Include a sample of SDOT's change orders as part of FTA's triennial reviews. In doing so, FTA could better detect and prevent the risk for paying for unapproved change orders.

Require FTA Region 10 to conduct a review of the City of Seattle's internal controls for supporting documentation of expenditures billed to Federal awards to ensure compliance with 2 CFR 200.403.

Recover the $9,946,977 in costs we identified for which SDOT provided incomplete information or provide a justification for accepting the costs.

Direct FTA Region 10 to notify WSDOT in writing that the $3.6 million in lapsed funds identified in this report have been credited to the State and are available for other eligible transit projects. Implementing this recommendation could put up to $3.6 million in funds to better use.

Require FTA Region 10 to review $3.8 million in inactive funds identified in this report and determine whether they will be used, and if not, deobligated. Implementing this recommendation could put up to $3.8 million in funds to better use.

Implement procedures and related mechanisms to show when unobligated transferred funds are obligated and to what projects.

STB perform a review of all employees’ leave balances to ensure they are accurate and comply with 5 United States Code (U.S.C.) § 6304 requirements.

STB work with its payroll service provider to determine and address the cause of the error.

STB perform a review of the identified employee’s leave balances (i.e., beginning balance, leave accrued/taken, and ending balance) for each year since the error first occurred in order to recalculate the employee’s corrected leave balance.

Management record all equipment purchases that meet its capitalization thresholds as capitalized assets. If the acquired property is not ready to be placed into service, then that property should be classified as Construction in Progress or Other General Property, Plant and Equipment, depending on the circumstances that apply to the purchased items at that time.

Management regularly assess all capitalized property and identify assets that require reclassification, such as when assets are being placed into, or taken out of, service.

Management update its financial reporting and property management policies and procedures to include the recording of new capitalized purchases in accordance with generally accepted accounting principles.

Establish and implement comprehensive written investigative policies and procedures for whistleblower investigations conducted by AAE that address best practice investigation standards in the areas of Qualifications, Independence, Due Professional Care, Planning, Execution, Reporting, and Information Management

Establish and implement a methodology for sufficiency reviews that provides greater tracking and documentation controls.

Hire additional staff, as planned, for the Office of Whistleblower Ombudsman.

Revise FAA Order 1100.167B to readjust duties that are inconsistent with the limitations established by the Aircraft Certification, Safety, and Accountability Act of 2020.

Revise the October 2015 guidance on structures subject to the national tunnel inspection standards to clarify which structures align with the definition of a tunnel and explain how potential non-tunnel structures conflict with the definition.

Issue guidance for FHWA Divisions on how to verify that State DOTs, Federal agencies, and tribal governments have reported all highway tunnels to the national tunnel inventory; and for informing those stakeholders of methods they could employ to identify all structures considered to be highway tunnels.

Implement comprehensive procedures on the processing and publishing of national tunnel inventory data, including controls to reduce data errors.

Issue a report to Congress on the national tunnel inventory and consult with the relevant Congressional committees about the intent of the statutory provision to provide subsequent annual reports.

Identify feasible improvements to the presentation of national tunnel inventory data on the Agency’s website to facilitate the public’s understanding and use of the data, and develop a plan to implement them.

Document the quality control and quality assurance processes, incorporate controls to ensure that all tunnel program compliance determinations adhere to the applicable compliance criteria, and communicate the processes to all relevant program and Division staff.

Assess the process for conducting compliance reviews of other Federal agencies and implement any recommended changes to ensure the reviews are effectively staffed and sufficiently independent.

Implement minimum training requirements for FHWA staff responsible for conducting tunnel safety program compliance reviews.

Update the tunnel safety program compliance review manual to incorporate existing review process flexibilities, such as when unusual or unique circumstances impact tunnel inspection intervals.

As part of the next update to the tunnel safety program compliance review manual, solicit and consider external stakeholder input on the Agency’s review procedures to include States, Federal agencies, and interested and knowledgeable private organizations and individuals.

Update the guidance for the national critical findings database to clarify its scope and incorporate comprehensive controls for ensuring the quality of the reported data. Solicit external stakeholder input in developing the updated guidance and communicate it to all stakeholders.

Communicate noteworthy practices on the critical findings process for tunnels and work with stakeholders to improve the guidance on which structural and safety deficiencies align with the definition of a critical finding.

Establish a plan for evaluating the ATSA's effectiveness.

Develop and implement procedures to comply with the TIFIA statute to issue loan application related notifications no later than 30 and 60 calendar days after receipt.

Develop and implement procedures for timely collection of servicing fees and advisor fees in accordance with TIFIA program requirements.

Develop an accurate reporting system to identify and monitor payments not received on the date they are due.

Reimburse the $200,000 advisor fee overpayment referenced in this report.

Collect the $40,500 in unpaid fiscal year 2019 servicing fees referenced in this report.

Develop and implement a uniform policy identifying what documentation borrowers must submit with requisition request and disseminate to Operating Administrations.

Provide supporting documentation for the transactions related to the $294 million in unsupported costs we identified, and collect all unsupported costs or identify the Bureau’s rationale for accepting them.

Develop and implement a process for revoking access to Bureau systems for separating Bureau employees.

Revoke access to the shared drive for the eight individuals identified in the report.

Assign the responsibility for updating the Bureau’s website to accurately reflect the TIFIA loan portfolio.

STB management should review the current version of the Office of Management and Budget (OMB) Circular A-136 to independently verify that all required footnotes are included and bring any omissions to the service provider’s attention so that errors or omissions can be corrected.

STB management should review the service provider’s Financial Statement and Notes Review Checklist to verify that the checklist is up to date and includes all required elements per OMB and Treasury guidance and then complete the checklist independently. Alternatively, STB management should develop and complete its own review checklist based on current Treasury and OMB reporting requirements.

STB management should request its financial management service provider to: Reevaluate the inclusion of account balances that were excluded in the Other Liabilities footnote, or Disaggregate (i.e., separately report) intragovernmental other liabilities balances reported as a single line item on the balance sheet that are not included in the footnote so that the total amounts reported for Other Liabilities on the Balance Sheet and in the footnote agree.

STB management should ensure that its review process includes procedures to disaggregate material balances reported in the financial statements and footnotes, agree balances to source documents, agree the footnotes to the principal financial statements, and verify the mathematical accuracy of all statements and schedules included in the financial statement package.

STB should perform routine reviews of employee benefit elections and Official Personnel Folders (OPFs) to ensure they are complete and accurate.

STB should address missing or unavailable supporting documentation with its shared service provider to ensure that document retrieval tools are available and are working properly to allow retrieval of all stored documents.

STB should obtain replacement documentation for employee forms and other documentation that has been determined to be incomplete or irretrievable from databases and other electronic sources.

KPMG recommends FAA design and implement procedures to consistently and timely perform and document user account access reviews as required by standards for effective internal control systems and/or internal policy.

KPMG recommends FAA design and implement procedures to consistently and timely notify account administrators of separations as required by internal policy.

Design or redesign control activities for the four risks that have not been fully addressed and that FTA still deems as applicable. These are: a.) Risk of Fraud or Abuse, b.) Recipients May Attempt to Use Funding for a Non-Operating Expense Even Though They Have Furloughed Staff, c.) Private Sector Operators Are Now Eligible to Become Sub-recipients and d.) Limited Capacity of Current Oversight Contracts.

Document the determination that four of the risk areas in the August 2021 Internal Control Plan are no longer risks; therefore, additional controls are not necessary. These are: a. Pace/Speed of Obligations and Disbursements, b. Guidance and Instructions Related to the Use of COVID-19-Relief Funding, c. Risks Between Programs and d. Notification for Large Drawdown Requests.

Establish a process that requires FAA to review the UTM Pilot Program and Field Test results and determine whether the results can inform rulemaking, the final implementation plan, concept of operations documents, and the FAA BEYOND program.

Implement enhanced processes for communicating UTM information to update industry stakeholders on FAA’s plans for UTM implementation as well as ongoing efforts.

Develop milestones for near-term UTM efforts and broader timelines for when FAA expects to implement policies and processes for reviewing and approving UTM technologies and capabilities, and establish a process for measuring and updating progress with achieving the milestones.

Document FAA’s plan for continued collaboration with NASA and other Federal Agencies regarding ongoing and future UTM activities.

The Department should ensure that adequate resources are made available and are prioritized to validate the accuracy and completeness of asset inventory counts prior to submission to the Department of Homeland Security (DHS) as part of CIO FISMA Metrics.

Coordinate with the components to develop or revise their plans to fully transition the remaining information systems to enable and enforce PIV, except those that are subject to exclusions that are documented and approved.

FAA should develop and implement procedures to perform periodic reviews of mobile devices to ensure non-compliant mobile devices are upgraded to the current operating system release.

Strengthen processes to ensure privileged account reviews are completed and privileged account activities are logged and periodically reviewed, in accordance with DOT policy.

In coordination with the OA system owners, complete DOT’s plans to implement existing solutions where possible and create a plan to address all exceptions where there is not a current solution for encryption of data at rest and in transit.

In coordination with the OA system owners, complete the deployment of DOT’s data loss prevention controls to include the utilization or activation of enhanced DLP features available within existing tools and to develop and implement policies and procedures which eliminate or restrict the ability of users to connect mass storage devices to DOT networks and systems.

Enhance current procedures to implement and require the retention of records to track when computer media are sanitized prior to disposal or reuse and implement procedures to validate the remediation of computer media that have failed media sanitization upon return to DOT.

In coordination with the OA system owners, strengthen DOT’s oversight of the contingency planning processes to ensure contingency planning documentation is developed, updated, and tested in a timely manner, in accordance with policy.

The Director of Bureau of Transportation Statistics complete and implement the DOT Geospatial Standards Implementation Plan in accordance with section 756(b) of the Geospatial Data Act of 2018.

Evaluate the convenience of commerce questions to determine whether they reflect modern commerce-related impacts of time zone changes and, if necessary, update them.

Develop and implement guidance for collecting and validating information on the impact of proposed time zone changes that constitutes the best and most relevant evidence.

Conduct a study and provide a summary of findings to the public on whether non-uniform adoption and observance of time zones and DST is a problem nationwide.

Review time zone and DST-related content on the following DOT websites to identify errors and make corrections.
DOT website “Daylight Saving Time.”
DOT website “Uniform Time.”
BTS website “History of Time Zones.”
BTS website “History of Daylight Savings Time.”

Develop and implement a process for maintaining and, when boundaries in the regulations change, updating a publicly available map and GIS dataset showing precise time zone boundaries.

Provide written procedures and guidance documenting requirements and steps-based on the size and scope of the procurement need-that staff in the Office of the Chief Information Officer (OCIO) should follow when requesting a new or extension of an ITSS award. This documentation should include standard lead times for required steps and submitting complete procurement packages to the contracting staff to help prevent any lapses in contract vehicles.

Implement a process to verify OCIO staff comply with the written procedures and guidance provided in recommendation one.

Implement a process for verifying that an independent government cost estimate is completed prior to the award of an ITSS contract vehicle, in compliance with DOT requirements. Implementing this recommendation could put up to $525 million in Federal funds to better use by improving the Department’s ability to establish ITSS contract vehicle pricing that is fair, reasonable, and realistic.

Provide support for or recover the $956,781 the Department paid on its ITSS contract vehicles based on contractor hours and materials billed without appropriate support.

Provide support for or recover the $132,899 the Department paid based on contractor hours billed that did not align with the ITSS contract vehicle terms.

Recover the $412 improper payment for 5 hours of excessive contractor charges billed and paid under the Non-Core Telecommunications Services ITSS contract vehicle.

Validate the remaining $40,270 in excessive contractor charges billed and paid under the Non-Core Telecommunications Services ITSS contract vehicle, and recover the amount improperly paid.

Implement a process for contracting regular, risk-based reviews of a sample of ITSS vehicle time and material type invoices to verify that contractor charges are accurate and reasonable. This procedure should apply to all ITSS invoices, including those funded directly by DOT Operating Administrations (OA).

Establish and implement written guidance on steps and techniques for reviewing ITSS contract vehicle invoices. The suggested steps and techniques should be tailored to address specific risks associated with the vehicle, including the scope and contract type. This guidance should apply to reviews of all ITSS invoices, including those funded directly by the OAs.

Coordinate with impacted OAs to develop a corrective action plan to resolve and close the findings highlighted.

Determine the allowability of the questioned transactions and recover $7,148,093, if applicable.

Develop and implement procedures to document within Flight Standardization Board reports the experience level of pilots used to establish pilot training recommendations.

Develop and implement a process to evaluate existing Boeing airplane flight manuals to determine whether they contain required normal, non-normal, and emergency procedures that are necessary for the safe operation of the aircraft. Within this process, include methods to determine what corrective actions are needed if deficiencies are identified.

Develop and implement a documented process to identify what information manufacturers must include in airplane flight manuals.

Develop guidance for air carriers to support the development and implementation of automation management policies. Following publication of the guidance, validate that air carriers' policies, procedures, and training are consistent with the new guidance.

Enhance the Fiscal Management Information System or develop an agency-wide data management process to provide FHWA personnel with access to change order information for performing their oversight, which includes identifying and monitoring change orders.

Evaluate and revise as necessary the Agency processes, including Compliance Assessment Program reviews, to include an oversight methodology that can generate accurate, statistically valid, and representative compliance results for change orders.

Develop and implement guidance for use by FHWA and States that a. includes a consistent definition of "change order," b. delineates the differences between a major change and a significant change; and c. further clarifies what may constitute a major change.

Update FHWA's Contract Administration Core Curriculum Manual, dated October 2014, to clearly reflect that FHWA may assign its change order approval responsibilities to State DOTs through Stewardship and Oversight Agreements.

Develop and implement internal guidance for the Agency's Program Review Library to clearly define the terms "formal report" and "substantive report."

Establish clear roles and responsibilities to verify that FHWA Division Offices monitor and track their reports and associated findings and recommendations related to change orders.

Assess the risk of improper payment for debt service, payroll, operating and maintenance expenses, and CARES Act reimbursement requests, and revise FAA's policy on supporting documentation requirements to account for risk level.

Request supporting documentation for the transactions related to the $271 million in unsupported costs we identifed, and collect all unsupported costs or Identify FAA's rationale for accepting them.

Assess transactions related to the $85 million we identified in grant recipients' improper use of funds due to noncompliance with law or ineligible use of funds, and recover unallowable reimbursements.

Recover the $3.3 million for services rendered or payment that was due prior to the allowable period.

Develop and implement a plan to encourage recipients to expend CARES Act funds.

Review workforce retention data provided by sponsors, and update records as needed to ensure compliance with law.

Develop a plan for implementing future workforce retention requirements as a condition of grants-in-aid based practices and lessons learned from prior efforts.

Design and implement controls to confirm that its annual PIIA reporting to the Payment Accuracy website is accurate.

Develop and implement a process to verify that population identification procedures used to create the universe for the statistical sampling of improper payments include adequate information, with detailed instructions to reproduce the same results.

Implement a quality assurance process to verify that population identification procedures are followed.

Coordinate with impacted OAs to develop a corrective action plan to resolve and close the findings highlighted in this report.

Determine the allowability of the questioned transactions and recover $3,534,794, if applicable.

Update and implement Automated Track Inspection Program (ATIP) fleet utilization performance metric(s) and establish a process to monitor ATIP contractor performance.

Document the current ATIP survey prioritization process and establish a schedule for running the prioritization tool with updated data.

Revise the Track and Rail and Infrastructure Integrity Compliance Manual to include specific guidance for inspectors completing ATIP-related inspection reports.

Modify the programming logic of the Railroad Inspection System for Personal Computers so that the system will accept only correct ATIP-related inspection report entries.

Develop and implement training for Track Division specialists and inspectors on how to correctly prepare ATIP-related inspection reports.

Document and implement the track safety inspection planning processes, including guidance to district track specialists and inspectors on data sources that can be used to inform planning (e.g., risk assessment models, planning tools, and ATIP data).

Establish goals, milestones, and performance measures of success for the BEYOND program to guide and track Agency and participants’ progress toward achieving beyond visual line of sight operations.

Communicate to BEYOND stakeholders how program operational, societal and economic benefit data will be used, analyzed, and shared to inform new policies, safety reviews, and rulemaking, including the rule for UAS operations beyond visual line of sight.

Implement a process to periodically assess the data collected during BEYOND—annually at a minimum—to determine if it is providing needed information and make adjustments as necessary.

Provide stakeholders and the general public with non-proprietary information related to BEYOND results via the FAA website or other appropriate means.

Identify intra-agency points of connection and lines of authority responsible for approving and integrating new UAS technologies, evaluate options to improve working across lines of business, and implement the best option based on the Agency’s evaluation.

Evaluate the causes of IPP program manager turnover as well as the communication and transfer of knowledge, policies, and procedures to new program managers in the transition process, and implement actions to address those issues in BEYOND.

Conduct a UAS detection and C-UAS program assessment that includes a determination of future resource needs and organizational structure based on how to best align those resources.

Evaluate the UAS detection and C-UAS coordination request process to identify and correct inefficiencies to improve timeliness in anticipation of future program growth.

Finalize internal UAS detection and C-UAS request processing and document retention guidance.

Designate a single audit accountable official (SAAO) responsible for ensuring that the OAs fulfill all the requirements of the Uniform Guidance and provide the official's name and title to OMB.

Require the SAAO to designate a key management single audit liaison to serve as the Federal awarding agency's management point of contact for the single audit process both within and outside the Federal Government and provide the official's name and title to OMB.

Require the SAAO to develop and implement a policy to ensure Operating Administrations (OA) meet Uniform Guidance's requirements for Federal awarding agencies.

Require the SAAO to develop and implement processes to ensure that OAs confirm its recipients' single audits and reporting packages are completed and timely submitted to the Federal Audit Clearinghouse (FAC).

Require the SAAO to develop and implement processes that ensure OAs download single audit reports from FAC's Image Management System and OAs identify and track single audit findings directly related to their programs.

Require the SAAO to develop and implement processes that ensure OAs issue timely management decisions on all single audit findings affecting their programs.

Require the SAAO to develop and implement processes that ensure OAs follow up on single audit findings and verify that OAs recipients took appropriate and timely corrective actions.

Develop and implement a plan to complete an automated tool for tracking safety profile evaluations.

Conduct a historic analysis and use the results as the basis for timeliness goals for Tier 2 evaluations and Tier 3 inspections in the revised Field Operations Manual .

Develop and implement a plan that updates the interagency agreement for processing approval and special permit applications, including details for conducting Tier 2 evaluations and Tier 3 fitness inspections within the 120-day goal.

Update the various software for processing applications by adding a field for the fitness inspection report number.

Update the Case Management System by adding a field to identify the application tracking number associated with a fitness inspection.

Develop and implement a plan to complete revision of the Field Operations Manual , directing that fitness memorandums include additional information identifying relevant inspections, using quality control items, and conducting risk assessments.

Synchronize the revised Approvals Program Desk Guide and the revised risk-based guidelines for referring foreign cylinder applicants.

Develop and implement a plan to complete an assessment of PHMSA oversight of U.N. Third-Party Packaging Certification Agencies and other independent entities that monitor approval and special permit holders.

Develop and implement guidelines on prioritizing fitness inspections along with other types of inspections.

Develop and implement a mechanism to improve the linking of applicants with incident and enforcement data.

Develop and implement a plan to revise application processing software user guides, with instructions to identify blank automated fitness reports.

Develop and implement a plan to update PHMSA's website on delayed application status with all required data.

Develop and implement a written policy to document the process for adding and removing programs and reporting the names of all the programs tracked in the major system investments performance measure.

Develop and implement a written policy or procedure to establish an internal control mechanism to identify all major transportation projects on the Federal Infrastructure Permitting Dashboard that should be tracked in the environmental performance measure and document reasons why projects are or are not determined to be major transportation projects.

Review and update the definition of the types of projects included in major transportation projects, to ensure all major transportation projects are being tracked under the measure.

Direct the Office of Infrastructure to follow the FHWA Emergency Relief (ER) Manual regarding deallocations of unobligated funds.

Identify any balance of allocated quick release funds older than 6 months, that will not be obligated through the remainder of the fiscal year and that are no longer needed, including the unobligated quick release amounts described in this report, withdraw or deallocate as appropriate in accordance with the ER policy. Implementation of this recommendation could put $5.2 million in funds to better use.

Update the ER Manual's quick release procedures to clarify the documentation needed for funding approval and the responsibilities to maintain sufficient evidence of required approvals for quick release requests submitted in accordance with emergency relief policy and program requirements.

Instruct the FHWA Texas Division to coordinate with the Texas DOT to deobligate the funds the State no longer needs, as discussed in this report. Implementation of this recommendation could put $1,958,064 in funds to better use.

Update the ER Manual to incorporate the requirements in FHWA Order 5182.1, including the routine review of unobligated balances so that funds can be deallocated when no longer needed.

Recover the $176,029.71 in unallowable emergency relief payments identified in this report.

Coordinate with impacted OAs to develop a corrective action plan to resolve and close the findings highlighted in this report.

Determine the allowability of the questioned transactions and recover $5,409,880, if applicable.

KPMG recommends that FAA configure the password length for Windows server accounts within the FAA.gov domain to comply with FAA policy and system requirements.

KPMG recommends that FAA design and implement formal detective controls to log and monitor developer activities in the time and attendance system production environment. All programmatic changes to the time and attendance system production environment should be reviewed and reconciled from the logs to the approved change tickets.

KPMG recommends that FAA design and implement a process to ensure that inventory system application, database and operating system changes are tested, documented, and approved prior to migration into production in accordance with FAA policy; and update the change management ticketing system to capture required approvals and evidence of testing for inventory system application, database or operating system changes.

KPMG recommends that FAA configure the account lockout threshold for the Windows server accounts within the FAA.gov domain to comply with FAA policy and system requirements.

KPMG recommends that FAA update the control to investigate cases removed from the Legal Letter and Contingent Liability Report period over period prior to recording the legal liability.

KPMG recommends that FAA ensure that policies and procedures for revoking access to the shared services center for separated users include:
a. Timely notifying shared services center managers of FAA employees that have separated from the agency to ensure that access is removed; and
b. Enforcing the timeline for removal of separated employees from shared services center, by reviewing active user listings on a periodic basis to ensure that no separated employees still have access.

STB management should review the current version of OMB Circular A-136 to independently verify that all required footnotes are included and bring any omissions to the service provider’s attention so that errors or omissions can be corrected.

STB management should review the service provider’s Financial Statement and Notes Review Checklist to verify that the checklist is up to date and includes all required elements per OMB and Treasury guidance and then complete the checklist independently. Alternatively, STB management should develop and complete its own review checklist based on current Treasury and OMB reporting requirements.

STB management should request its financial management service provider to:
a. Reevaluate the inclusion of account balances that were excluded in the Other Liabilities footnote, or
b. Disaggregate (i.e. separately report) intragovernmental other liabilities balances reported as a single line item on the balance sheet that are not included in the footnote so that the total amounts reported for Other Liabilities on the Balance Sheet and in the footnote agree.

STB should perform routine reviews of employee benefit elections and Official Personnel Folders to ensure they are complete and accurate.

STB should address missing or unavailable supporting documentation with its shared service provider to ensure that document retrieval tools are available and are working properly to allow retrieval of all stored documents.

STB management should work with the service provider to identify, at least quarterly, upward adjustments that have been offset by downward adjustments in the general ledger or perform an independent review of the general ledger activity of both accounts so that manual adjustments can be recorded to properly state the ending balances of both accounts, if needed.

STB management should design and implement policies and procedures which enhance the internal review process for upward and downward adjustment transactions and includes a reconciliation of the UDO balances with the supporting documentation to ensure that transactions have been recorded correctly.

STB should amend its existing policy regarding the review and approval of journal vouchers to include a review of all non-reversing entries recorded during the fiscal year and to review all year-end journal vouchers before they are recorded in the agency’s general ledger.

Implement controls that require that the correct micro-purchase thresholds are assessed before approving SAM waivers.

Review payments made to the non-SAM approved vendor and determine whether the amounts are recoverable in accordance with the Payment Integrity Information Act of 2019.

Document and follow established controls to require that supporting documentation for CDs is obtained in a timely manner and recorded accurately so the system of record properly reflects information related to the CDs.

Develop and implement controls to require that employees are removed from CD accounts when they separate from the corporation and replace with current employees.

Implement procedures to perform periodic reviews of OM&S purchases for valuation accuracy.

Follow up on prior help requests submitted to system support to verify that the OM&S cost corrections have been made.

Work with system support to correct the deficiencies that cause OM&S cost errors.

KPMG recommends that ESC management correct the ESC server inventory list to ensure that all production servers are correctly categorized

KPMG recommends that ESC management implement a quality assurance process to confirm that all servers and systems are included during the semiannual review process.

KPMG recommends that MARAD management develop and implement policies and procedures to timely evaluate and respond to changes in MARAD’s programs or activities prompted by public law or DOT directives that could impact financial reporting objectives and cause revision to its accounting treatment.

KPMG recommends that MARAD management should design and implement processes to timely correct identified errors or account for changes in accounting policies.

KPMG recommends that ESC management update procedures surrounding management’s review of journal entries to ensure journal entries are reviewed at an appropriate level of precision to determine that all manually posted entries are complete, accurate, and adequately supported by documentation.

KPMG recommends that OST management obtain documentation from external borrowers to support the input assumption that the remaining loan value will not be disbursed.

KPMG recommends that OST management maintain a documentation trail that includes support for each current year input in accordance with the TIFIA Loan Subsidy Re- estimates Standard Operating Procedures.

Finalize the report on the NVS contract failure and the program termination, and develop action items to address the failures and a plan for implementing them.  

KPMG recommends that DOT management design and implement procedures to consistently and timely perform and document audit log reviews as required by standards for effective internal control systems and/or internal policy.

KPMG recommends that DOT management design and implement procedures to consistently and timely perform and document user account access reviews as required by standards for effective internal control systems and/or internal policy.

KPMG recommends that DOT management design and implement component-specific system security plan requirements in instances where plans for those areas not addressed in the Departmental system security plan.

KPMG recommends that DOT management design and implement procedures related to the retention of appropriate supporting evidence of internal controls, including but not limited to, access administration, access recertification, audit log review, and patch management.

KPMG recommends that DOT management strengthen its policies and procedures to formalize a complete process to assess and monitor applicable third-party service organizations risk assessment to determine the impact of a timing gap between the issuance of service organization SOC reports and the Department’s fiscal year.

KPMG recommends that DOT management strengthen its policies and procedures to formalize a complete process to assess and monitor applicable third-party service organizations documented review of applicable SOC reports, which includes a consideration of results year over year, implementation of the service organizations’ recommended complimentary user entity controls and monitor such controls for proper design, implementation and operating effectiveness.

KPMG recommends that DOT management strengthen its policies and procedures to formalize a complete process to assess and monitor applicable third-party service organizations review and evaluation of findings identified within the service organization’s SOC report and assess the impact on the Department’s internal control over financial reporting.

KPMG recommends FAA design and implement procedures to consistently and timely perform and document audit log reviews as required by standards for effective internal control systems and/or internal policy.

KPMG recommends FAA design and implement procedures to consistently and timely perform and document user account access reviews as required by standards for effective internal control systems and/or internal policy.

KPMG recommends FAA design and implement component-specific system security plan requirements in instances where plans for those areas are not addressed in the Departmental system security plan.

Coordinate with impacted OAs to develop a corrective action plan to resolve and close the findings highlighted in this report.

Determine the allowability of the questioned transactions and recover $9,236,974, if applicable.

Update the existing written procedure for acting on rulemaking petitions to meet the required 120-day timeline.

Develop and implement a written process for reviewing compliance test reports.    

Develop and implement a training curriculum process for Safety Compliance Engineers.

Implement and communicate guidance on conducting compliance investigations.

Develop and implement a targeted process for reviewing and prioritizing conformity packages to meet the required 30-day timeframe.

Finalize and implement the Import and Certification Division's process to monitor and investigate Registered Importers' compliance with Federal regulations.

Establish and implement a control process to verify compliance with Federal requirements to establish files with complete documentation for all USMMA contracts and ensure that these files are readily accessible to principal users. Implementing this recommendation could put $4.9 million in Federal funds to better use by providing complete documentation to support that MARAD made efficient, compliant, and sound contracting decisions and actions.    

Establish and implement a control process to verify compliance with Department requirements to use contract file checklists for all USMMA contracts.

Require and verify all MARAD acquisition staff attend annual refresher training on Federal, departmental, and MARAD-specific procurement and acquisition workforce requirements. Post training material in a central location that all staff can reference and access.  

Develop and implement standardized contract forms and templates to document completion of procurement requirements when awarding USMMA contracts below the Simplified Acquisition Threshold (SAT).  

For USMMA contracts that exceed the SAT, establish and implement a process(s) to verify compliance with applicable Federal, departmental, and MARAD procurement requirements associated with market research, independent Government cost estimates, source selection strategies, price and cost analysis, acquisition planning, and legal review. Implementing this recommendation could put $52.6 million in Federal funds to better use by improving MARAD's ability to efficiently award USMMA contracts that result in the best value to the Agency and meet its needs.

Establish and implement a control process to verify the Agency’s oversight procedures regarding warrant requirements are correctly and consistently carried out for contract officers (CO) assigned to USMMA contracts.  

Establish and implement a control process to verify compliance with Federal requirements to maintain accurate and complete data in the Federal acquisition system (previously the Federal Acquisition Institute’s Acquisition Training Application System, now Cornerstone OnDemand) for all USMMA contracting officer’s representatives (COR).  

Establish and implement a control process to verify compliance with Federal, departmental, and MARAD requirements to use COR appointment letters and verify that all CORs assigned to USMMA contracts are properly certified.  

Establish and implement a process for maintaining and tracking progress on USMMA Capital Improvement Program (CIP) projects, analyzing how changes to Academy plans will impact the cost and schedule of existing and planned CIP projects and contracts, and confirming that congressionally appropriated CIP funds are efficiently expended.  

Establish and implement a requirement that any project change(s) to an approved CIP, Long Range Strategy, or other facilities-related Academy plan be submitted to and approved by the Office of the Secretary of Transportation before the change becomes final.  

Develop and communicate an organization wide Supply Chain Risk Management strategy and implementation plan to guide and govern supply chain risks.

Undertake a strategic analysis of the Inspector General FISMA Metrics and the weaknesses identified in the audit, to develop a multi-year strategy and approach to include objective milestones, and resource commitments by the Department and the CIO that address the corrective actions
necessary to show steady, measurable improvements towards an effective information security program.

Work with the Federal Aviation Administration’s CIO and Federal Motor Carrier Safety Administration’s Information Security System Manager(ISSM), to investigate and remediate cross-site scripting vulnerabilities identified in public facing web applications.

Work and coordinate with system owners to identify and remediate weak and default authentication mechanisms within their systems and the Common Operating Environment.

Develop and implement a process to facilitate centralized monitoring, oversight (by ISSMs and their alternates) and escalation efforts to ensure the timely completion of required security awareness training and role based training for all DOT personnel leveraging an automated integrated solution(s) and dashboards.

Develop and implement root cause analysis training for inspectors more in line with training in the aviation industry.

Develop and implement a management control to ensure that inspectors maintain the link between the compliance action and the corrective action validation inspection within its inspection databases.

Develop and implement a management control to ensure inspectors require air carriers to provide written root cause analyses and that these analyses do not specifically identify human factors issues as root causes.

Develop and implement a management control to ensure that inspectors do not send compliance action close out letters until the corrective actions have been completed and validated.

Develop and implement a team inspection approach in order to periodically assess the air carrier's Safety Management System.

Develop and implement Safety Management System training for inspectors that is specifically designed to aid inspectors in evaluating air carrier risk assessments.

Revise the Safety Management Systems data collection tool to allow inspectors to perform more detailed reviews and accurately document the results of these reviews.

Select and implement security control-process isolation to protect its financial management systems (FMS and ECHO-Web) against risk.

Perform an assessment of its financial management systems (FMS, ECHO-Web, and TrAMS) security controls that at a minimum reflect the correct security control types and update each system’s system security plan with the correct control types.

Update the security assessment documents for its financial management systems (FMS, ECHO-Web, and TrAMS) to properly reflect the results of all security controls (e.g., common, hybrid, and system-specific) for selection, implementation, and assessment, per DOT requirements.

Obtain and assess all up-to-date security authorization documents associated with its financial management systems (FMS, ECHO-Web, and TrAMS) inherited controls (e.g. common, hybrid) to determine and monitor the effectiveness of its inherited controls and risk per NIST & DOT security requirements.

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Implement secure configuration settings for its financial management systems (FMS and ECHO-Web) databases in accordance with Federal and DOT policies.

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Develop and implement a plan that ensures continuity of federal workforce and contractual resources to fulfill contingency responsibilities for its financial management systems (FMS and ECHO-Web) to maintain continued operations should an emergency event incapacitate the primary personnel.

Conduct, document, and communicate the results of its annual incident response and data breach plan testing for financial management systems before authorization to operate (ATO); to ensure effectiveness in the event of a security incident or data breach is discovered within FTA or an external party (e.g. FTA recipient, common control provider).

Establish, document, and implement a security incident reporting process and procedures for its recipients to report incidents that affect their login credentials.

Require the FTA Information System Security Manager (ISSM)/ Privacy Officer to adhere to its Incident and Data Breach Response Plan to report recipient cybersecurity incidents involving FTA information systems or user accounts.

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Change the passwords for the compromised web servers to strong passwords that meet DOT's Cybersecurity Compendium requirements.

Restrict access to administrator login pages to only verified administrators and computers.

Identify and remove all malware that was uploaded to FMCSA's web servers.

Develop and implement stronger malicious code protection and detection controls.

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Change the passwords for FMCSA's compromised databases.

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Validate whether production data is being used on other preproduction databases that FMCSA hosts.

Establish and implement security safeguards for the protection of PII in accordance with DOT policy. Implementing this recommendation could put up to $570,367,559 of funds to better use by avoiding the cost of credit monitoring for affected individuals.

Implement monitoring controls and alerts to identify when database admin accounts log in from non-authorized IP addresses.

Implement real time security monitoring tools and alert features to monitor FMCSA web servers and databases for access from unauthorized IP addresses.

Develop and implement a plan to remediate all identified critical, high, and medium vulnerabilities on FMCSA devices older than October 8, 2019.

Implement and document a formal quarterly review process to ensure that any nonfatal warnings related to cross-validations of Files C, D1, and D2 at the OA level are investigated, and actions to address the warnings are clearly documented.

Develop a complete inventory of DATA Act data element sources and definitions that exist within their systems and establish controls to ensure that the inventory is updated in response to relevant changes to DOT systems or DAIMS guidance.

Implement a control to ensure that transaction level information is reported in File C in accordance with the data standards.

Implement and document an internal oversight review process for financial assistance awards to ensure that controls are in place to verify recipients are registered in SAM at the time of financial assistance award.

Develop an enterprise architecture that includes information security considerations and the resulting risk to the Agency, as well as incorporates STB’s existing cyber security architecture.

Identify and define all software programs that are not authorized to execute on STB information systems.

Establish and implement procedure to manage hardware asset inventory connected to STB’s network.

Review all open Plan Of Actions & Milestones and assign scheduled completion dates which account for the required resources and corrective actions, including milestones, to manage and mitigate the identified risk.

Develop a Supply Chain Risk Management strategy and supporting policies and procedures to ensure that products, system components, systems, and services of external providers are consistent with the organization’s cybersecurity and supply chain risk management requirements.

Develop a process to make improvements to its baseline configuration, secure configuration, and flaw remediation policies and procedures through the use of lessons learned.

Implement documented processes for configuration management changes as required by STB policies and procedures.

Evaluate deviations from Center for Internet Security benchmarks and determine if the associated configurations should align with best practices or if deviations should be risk accepted.

Update vulnerability management procedures to support implementation of STB’s Vulnerability Disclosure Policy.

Update the Access Recertification Process document to align with STB’s existing practices to ensure users complete all required training and onboarding forms.

Develop and implement a written policy or procedure to establish an internal control mechanism to identify all major transportation projects on the Federal Infrastructure Permitting Dashboard that should be tracked in the environmental performance measure and document reasons why projects are or are not determined to be major transportation projects.

Develop a process to make improvements to the effectiveness of its Identity, Credential, and Access Management policy, strategy, and road map.

Define procedures to review and remove unnecessary PII collection on an organization defined frequency.

Perform the review of Privacy Threshold Analysis for STB General Support System, At Hoc, and Dynamic Case Management system on an annual basis.

Implement data protection policies and procedures for Data at Rest, prevention and detection of untrusted removable media, and destruction or reuse of media containing PII or other sensitive agency data.

Address the knowledge, skills, and abilities gaps identified during the FY 2020 skill gap assessment through training or talent acquisition.

Complete the transition from traditional three (3) year authorizations to ongoing authorizations for STB-LAN.

Implement documented processes for collecting and reporting performance metrics at the organization and system level to assess the effectiveness of Information Security Continuous Monitoring program.

Develop a process to make improvements to the effectiveness of its ISCM program through the collection and reporting of quantitative and qualitative performance metrics, and lessons learned.

Define the performance metrics for measuring the incident response capability.

Update STB Incident Response Plan to include requirements for the technologies utilized to support Incident Response processes.

Define the frequency for the performance of Post Incident activities.

Update STB Incident Response plan containment strategies to reflect the current agencies risk prioritization processes.

Implement documented processes for Incident Response resolutions of tickets in consistent manner, as required by STB policies and procedures.

Define the frequency for the performance of system level Business Impact Analyses (BIA).

Review the organization wide BIA on an annual basis.

Conduct a tabletop exercise of the General Support System’s information system contingency plan (ISCP) on an annual basis.

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Establish and implement an effective process for: (i) identifying and tracking the Agency's acquisition workforce (such as Contracting Officers (COs), Contracting Officer's Representatives (CORs) and Program/Project Managers (P/PMs) ) and (ii) collecting and maintaining their certifications and related training records. Data collected via this process and maintained in repositories should be complete, accurate, and readily accessible.

Identify, remove, and/or rectify those COs, CORs, and P/PMs—currently assigned to a contract or program—that lack the required training or certification to fulfill their designated role.

Develop and implement training and guidance related to the Agency’s replacement of FAITAS. This training and guidance should address acquisition certification requirements, documentation, and application processes under the new system.

Implement performance and certification metrics for CORs and P/PMs.

Revise AMS to reflect FAA’s decision to delegate approval authority for COR certifications to the Acquisition Career Manager.  

Strengthen the process for nominating CORs to include completing, issuing, and storing COR Delegation Letters and Nomination Forms in the contract file.  

Strengthen quality assurance procedures to verify accuracy when identifying and reporting the acquisition P/PMs assigned to OMB Major Programs.

Establish a timeline to implement and verify compliance with the requirement that all P/PMs assigned to OMB Major Programs obtain and maintain a FAC P/PM Information Technology Certification.  

Coordinate with impacted OAs to develop a corrective action plan to resolve and close the findings highlighted in this report.

Determine the allowability of the questioned transactions and recover $32,153,264, if applicable.

Analyze and document the justification for the FAA Contract Tower (FCT) Program's minimum staffing requirements.

Develop and implement an internal process to periodically review, and maintain supporting records for FCT controller staffing minimums.

Develop and implement an internal process—including roles and responsibilities, timeframes, and criteria—to ensure contract requirements are met, and overpayments made to contractors are recovered.

Recover overpayments to contractors, estimated minimum of $2.64 million and minimum of $2.5 million.

Institute a process that compares the inspector staffing model estimates to actual staffing levels. The process should identify the reasons for the differences between the two figures, establish performance measures that help assess the accuracy of the model's results, and actions taken to improve future forecasting.

Finalize the demand-driven metrics and determine how they will be used in conjunction with the inspector staffing model.

Develop and implement a plan with milestones for completing the air carrier and general aviation staffing models, including information on how the Agency plans on using them in conjunction with the current staffing model, the process by which the business rules are updated, and the results of the most recent review of the business rules.

Produce inspector staffing estimates and actual staffing levels at the functional and field office levels. Include these figures in the Agency's annual safety workforce plan.

Reinstitute the process in which Flight Standards office managers review their staffing estimates.

Track progress on implementing the Office Workload List, including milestones to show when the Agency anticipates using information from the system to assist with inspector staffing decisions.

Update information regarding implementation of the Designee Management System, including milestones to show when FAA anticipates fully integrating individual designees into the system and how it intends to use the system's data to determine whether to adjust its inspector workforce staffing levels and responsibilities.

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Establish and implement written policies and procedures to accurately communicate allocated amounts over time through FTA's documents, such as notices, memoranda, and letters; the grant management system; and external reports.

Complete the planned update to FTA’s Assistance Listings internal guidance to include procedures to ensure the Agency complies with the Office of Management and Budget assistance listing requirements that are intended to make obligation information readily identifiable on USASpending.gov.  

Improve current requirements for States to record, track, and maintain paper-based convictions sent and received via mail by incorporating its standardized method for States to aggregate paper-based convictions to facilitate FMCSA's evaluation of State performance.

Finalize and implement standardized operating procedures for conducting annual program reviews and for supervisory quality control reviews of completed annual program reviews.

Modify the annual program review checklist to require reviewers to address key factors and determine whether:  a. sampled out-of-State convictions were posted to driver records within the required 10 days; b. results from a review of in-State convictions and paper notifications of out-of-State convictions were documented; c. sample testing was conducted of the greater of 2 percent of electronic transactions in a month or a total of five transactions, in accordance with FMCSA’s 2016 policy memorandum; d. States are sending convictions either electronically or via mail but not using both methods; e. States begin disqualification periods on or after the date the out-of-State conviction is received; and f. States that are offering administrative appeals for out-of-State disqualifications and permitting them to be overturned are identified.    

Finalize and implement a standard operating procedure for determining when a State is not making a good faith effort to timely mitigate compliance issues and when to impose sanctions on noncompliant States.

Complete the Agency's review of the State Compliance Records Enterprise system and implement identified improvements for managing States' compliance issues.

Develop and implement a process to segregate non-CDL holder convictions from all Commercial Driver's License Information System reports and workbooks utilized to evaluate State's compliance with CDL regulations.

Develop and implement a plan for coordinating with the American Association of Motor Vehicle Administrators to mitigate risks when States transition to new software systems. 

Revise FAA's process for identifying excess, obsolete, or unserviceable inventory toinclude consideration for the quantity of repairable parts on hand, and theexpected future demand for those parts.

Develop and implement an interim process for receiving, sorting, and disposing of excess, obsolete, or unserviceable inventory items at the Thomas Road Warehouse that includes the tracking of individual inventory parts from receipt through to final disposition.

Implementan oversight process for core due-ins that includes continuous tracking as wellas following up on any core due-ins that are not returned within 30 days.

Evaluate and revise the Advance Due-In Report to maximize its effectiveness in accurately tracking actual due-ins from the field.

Research,identify, and account for the due-ins identified in the Advance Due-in Reportand request that parts be returned. If unreturned, bill NAS customersaccordingly. Implementation of this recommendation could put over $38 million infunds to better use.

Document and implement FAA's process forconducting monthly exchange and repair inventory value calculations.

Develop and implement a plan to continuously track,reconcile, and reduce the inventory quantity discrepancies that currently existbetween the Logistics Center Support System and the Warehouse ManagementSystem.

Develop a plan with milestones for completing the remaining eight applicable recommendations.

Track implementation of the plan with milestones.

Establish and implement measurable goals and metrics for assessing the effectiveness of the oversight program.

Complete and implement procedures for systematically tracking issues identified through reviews of Amtrak's use of Federal funds and compliance with cooperative agreements.

Finalize and implement procedures for taking action to address Amtrak’s noncompliance with cooperative agreement terms and conditions.  

Implement the plan to complete information system improvements and centralize Amtrak oversight data in accordance with established milestones.

Revise the Acquisition Management System (AMS) to include policy and guidance covering the BAA and BAP laws and requirements, specifically on the application of clauses, exceptions, and waivers, as well as when to obtain contractor certifications. Implementing this recommendation could put $127 million to better use by reducing the risk of FAA improperly procuring foreign-made supplies and products.  

Develop and implement formal training that focuses on the application of FAA’s BAA and BAP requirements, contract clauses, and waivers, as well as on obtaining and retaining required vendor certifications.  

Revise AMS to include policy and guidance for FAA’s Electronic Document Storage record-keeping system to include the retention of BAA and BAP documents in the official contract file.  

Revise AMS to include guidance and procedures on how to monitor post-award compliance with the BAA requirements, including actions to take when acquisition clausesâ€"such as vendor certification requirementsâ€"are incomplete or erroneously omitted.    

Revise the National Acquisition Evaluation Program evaluation form and procedures to require evaluators to review and document Buy American compliance, e.g., by listing the categories of Buy American clauses as separate entries and including procedures that show evaluators how to test and document compliance.

Enhance existing quality control procedures to require acquisition personnel to enter FAA domestic content data (i.e., place of manufacture codes) accurately in the Federal Procurement Data Systemâ€"Next Generation.  

Develop and implement procedures for collecting, tracking, analyzing, and reporting on FAA’s use of the BAP waivers and the BAA exceptions.  

Develop and implement procedures to ensure FAA posts information on its existing use of BAP blanket waivers, as well as any newly executed waivers, for direct contracts on a public website.  

Coordinate with impacted Operating Administrations (OA) to develop a corrective action plan to resolve and close the findings highlighted in this report.

Determine the allowability of the questioned transactions and recover $8,008,786, if applicable.

Notify communities of their right to petition the Department about issues with basic essential air service.    

Conduct periodic reviews of the level of basic essential air service in accordance with Federal regulations.

Publish metrics that measure performance of NextGen improvements across the NAS. 

Develop and implement a process that incorporates interim adjusted benefit projections and interim implementation analyses to support prioritization of NextGen programs and deployment locations. 

Update and provide stakeholders a risk adjusted NextGen benefit projection. 

Develop and implement models based on criteria to prioritize requests for ASIAS safety information across the ASIAS communities. 

Disseminate ASIAS aggregated, confidential national-level metrics, such as known risk monitoring, on a regular basis to the Safety Analysis and Promotion Division and principal aviation safety inspectors. 

Determine if the ASIAS non-confidential information is beneficial to Flight Standards inspectors, and if so, implement guidance to field-level personnel so that inspectors have an understanding of how, when, and why they should use the system.

Document and implement a risk management process to analyze program risk, including risk identification, likelihood and consequence, mitigation strategy, and monitoring activities. This documented process should also include steps for monitoring, tracking, and updating risks throughout the life of the program. This recommendation should be completed prior to the start of full-scale vessel construction.

Obtain, review, and approve complete versions of each of the following VCM oversight plans: the Configuration Design and Technical Management Plan; Quality Assurance, Risk Management, and Metrics Plan; and Test and Evaluation Plan. This recommendation should be completed prior to the start of full-scale vessel construction.

Update the Changed Product Rule to address the integration of technological advances and exceptions.

Evaluate criteria for determining whether a system meets the definition of a "novel or unusual design feature," add specificity, and implement identified improvements.

Require applicants to submit failure probability analysis and key assumptions in certification deliverables.

Assess and update Advisory Circular 25.1309 guidance related to engineering assumptions regarding pilot actions, pilot reaction times, and failure mode testing.

Establish and implement processes for manufacturers to officially notify FAA certification engineers of any changes made to System Safety Assessments, including after FAA flight testing has begun.

Establish and implement communication and coordination procedures between Boeing and FAA, and within FAA among flight test, certification, and Flight Standards.

Establish and implement policies and procedures for the AircraftEvaluation Group related to its role in the certification process that require,at a minimum: formal documentation of approvals; documentation of operationalflight test parameters, procedures, and outcomes; expanded written guidance onthe FSB process; and improved consistency of procedures between AEG offices.

Incorporate lessons learned from the Boeing 737 MAX accidents into the ODA oversight process guidance implementing a risk-based approach.

Clarify priorities, roles, and responsibilities for FAA engineers regarding oversight and certification work, including the timing of when oversight should be performed.

Perform a workforce assessment at FAA’s Boeing Aviation Safety Oversight office to determine engineer resource and expertise needs, particularly in the areas of systems engineering, human factors, and software development, to both perform certification and oversight work, and take action as necessary. 

Conduct an assessment to determine how frequently unit members serve as both the company engineer involved in a design as the applicant and also find compliance on FAA's behalf on that same design. Based on the results of this assessment, revise ODA guidance to strengthen controls in this area.

Revise ODA program requirements to ensure ODAs have internal controls in place and are organized in a way that prevents interference with ODA unit members.

Determine if Boeing has met the requirements of the 2015 Settlement Agreement, including reporting metrics, given the deadline of December 31, 2020 and take further actions as necessary.

Complete the ongoing rulemaking project that proposes requiring manufacturers to implement Safety Management Systems, including setting and publishing expected timeframes.

Revise FAA policy to include equitable review of projects funded by discretionary and entitlement funds, and perform regular formal assessments of Block Grant States' (BGS) adherence to Federal requirements for project selection.

Revise FAA's policy on documenting project-approval decisions to ensure that BGS adhere to project prioritization.

Revise and implement FAA's process for resolving instances of insufficient documentation as support for reimbursement to BGS.

Request supporting documentation for the transactions related to the $5.7 million in unsupported project costs we identified in Wisconsin, and collect all unsupported costs or identify FAA's rationale for accepting them.

Assess the claims related to the $12,835 in unsupported Cash Management Improvement Act reimbursements we identified in Michigan, and review similar transactions within the SBGP for unsupported costs. Develop an action plan to collect all unsupported costs or identify FAA's rationale for accepting them.

Develop and implement a procedure for monitoring BGS adherence to requirements for Airport Improvement Program (AIP) expenditures at regular and frequent intervals.

Revise guidance for all AIP stakeholders to reinforce the required sequence in which different types of AIP funds are to be expended.

Require Airport District Offices (ADO) and Regional Offices to comply with grant closeout requirements for BGS. Implementation of this recommendation could put $115.7 million in funds to better use.

Develop and implement a procedure to verify the accuracy of BGS data submissions. Implementation of this recommendation could put $5.7 million in funds to better use by improving FAA's grant management oversight.

Formalize and implement minimum training requirements for BGS officials, and give BGS access to all FAA-conducted, AIP-related online and in-person training.

Finalize the draft Memorandum of Agreement outlined in the SBGP Advisory Circular and implement it for all 10 current BGS and any future program entrants.

Finalize and implement an SBGP-wide audit plan in accordance with FAA's SBGP Advisory Circular, and include a requirement to document resolution of findings.

Ensure compliance or implementation of FAA's procedure to share resolutions of Single Audit Report recommendations with the ADOs and Regional Offices that oversee the BGS.

Coordinate with impacted Operating Administrations (OA) to develop a corrective action plan to resolve and close the findings highlighted in this report.

Determine the allowability of the questioned transactions and recover $5,130,999, if applicable.

Redesign the agency's personnel action process to ensure  that the submission of a Request for Personnel Action form immediately is  processed promptly upon the notification of an employee's separation or termination.

Redesign the agency's FPPS user termination process to require the completion and submission of a FPPS User Access Form to the service provider immediately upon separation of a FPPS user from the agency.

NTSB perform a review of its Reimbursable Agreements Summary report to verify that the open balance amount for each agreement is correct. 

NTSB perform a review of agreements for which goods or service have been provided to ensure that billing and collection procedures have been completed or initiated 

NTSB record an accrual for earned revenue that has not been collected as of the end of the reporting period. 

Perform a review of the user's system access immediately  after each OFF User Access Form is processed by DOI IBC to ensure that only the  permissions requested were granted.

Redesign the OFF quarterly review process to include areview of each employee's system permissions to verify that all users' access permissions granted do not exceed the permissions requested and least privilege guidelines.

We recommend that the Office of Chief Financial Officer  (OCFO) enhance its existing internal control procedures over the review and  approval of journal vouchers to ensure that the basic pay data used to compute imputed costs is complete and accurate and all cost factors are included in the calculation.

Enforce existing manual controls for disabling inactive accounts after the specified period of inactivity and enable an information system to automatically disable inactive accounts after a specified period of inactivity, as required by NIST.

Identify and resolve discrepancies between the FAA ISPP and Center for Internet Security Benchmarks specific to the procurement system’s password configurations.  

If changes are needed, update the procurement system’s security documentation to reflect the database password requirements.  

Ensure that database password settings are in compliance with FAA ISPP.  

Review and update security documentation to ensure that database dependency on the general ledger and the related control deviation is documented and approved by the AO, as required by FAA policy.

Update application password settings to ensure compliance with the FAA ISPP.

Coordinate with the appropriate resources to ensure the implementation of an appropriate separation of duties process for system administrators and developers.

Update password settings to ensure compliance with the FAA ISPP.

Design and implement a process to ensure that the inventory application, database, and operating system changes are tested, documented, and approved prior to migration into production and update the change management ticketing system to capture required approvals and evidence of testing for application, database, or operating system changes, in accordance with FAA ISPP.

Configure the account lockout threshold for the Windows server accounts within the FAA.gov domain to comply with FAA policy and system requirements.

Design and implement controls to validate that all employee FEGLI elections are accurately recorded in the records of the shared service center.

Perform an annual review of existing sites to identify those that may be in dispute, and solicit input from legal counsel to determine and document whether these sites should be included in the environmental remediation liability, as defined by generally accepted accounting principles.

Ensure that existing procedures over the review of journal entries are performed, at an appropriate level of precision, to determine that all posted manual entries are complete, accurate, and adequately supported by documentation.

Update the Journal Voucher Processing standard operating procedures to explicitly document and define the responsibility of the control operator to annotate any variances identified in the JV control log reconciliation with the actions taken and resolution obtained.

Update policies and procedures to clarify when acceptance should be recorded for a transaction.

Develop and implement guidance to formally document its assessments and recognition decisions, in accordance with SFFAC No. 5, as related to assets and liabilities of exchange transactions.

Update the standard operating procedures to define the triggering events for which the serviceable unit cost should be revalued in accordance with applicable accounting standards. 

Design and implement control activities to ensure that serviceable unit costs are only revalued as a result of valid triggering events which occur during the current period. 

Develop policies and procedures to ensure that judgments that inform accounting estimates are based on the best available information at the time of calculating and recording the CARES Act grant accrual estimate in the financial statements.

Develop procedures to document the period in which user access is granted and terminated to support the operating effectiveness of the shared service center’s user access controls. 

KPMG recommends that FTA management revise the existing configuration management plans for the grant financial management application and the clearing house system to include procedures for source code access administration and required privileges, source code maintenance and storage, the process for source code deployment into the production, and any version control software utilized to support the systems.

KPMG recommends that FTA management reconfigure the grants management application to automatically remove roles that are not recertified annually.

KPMG recommends that FTA management reconfigure the application that supports the grants management system to automatically disable accounts after 60 days of inactivity.

KPMG recommends that FTA management update the grants management system platform's system security plan to reflect the configuration considerations in place.

KPMG recommends that FTA management ensure that new users are properly authorized by all required parties prior to the administration of access to FTA systems.

KPMG recommends that FTA management design and implement policies and procedures that establish a formal process to assess applicable third-party SOC reports that includes reviewing the SOC 1, 2, 3 reports, reviewing and comparing reporting updates year-over-year, and reviewing findings and their impact on the grants management system.    

KPMG recommends that FTA management design and implement policies and procedures that establish a formal process to assess applicable third-party SOC reports that includes implementing the service organization's recommended complimentary user entity controls and monitoring these controls for proper implementation and operating effectiveness.  

KPMG recommends that FHWA management update its security documentation and system security plan, in accordance with Department requirements, to capture any control deviations and compensating controls used in lieu of automatically disabling inactive accounts.  

KPMG recommends that ESC management should provide a training refresher to contracting program managers and access control officers related to the separation process for contractors.    

KPMG recommends that OST management design and implement policies and procedures to evaluate the impact of known changes in TIFIA loan cash flow projections between the re-estimate date and the issuance of the financial statements on the subsidy re-estimate to then be considered for subsequent event disclosure.

KPMG recommends that MARAD management design and implement a process for recording donated PP&E from other federal entities to ensure these transactions are accurately recorded and in accordance with generally accepted accounting principles.

KPMG recommends that ESC management update the Journal Voucher Processing Standard Operating Procedures to explicitly document and define the responsibility of the control operator to annotate any variances identified in the journal voucher control log reconciliation with the action taken and resolution obtained.

KPMG recommends that ESC management update procedures surrounding management's review of journal entries at ESC to ensure that journal entries are reviewed at an appropriate level of precision to determine that all posted manual entries are complete, accurate, and adequately supported by documentation.

KPMG recommends that FHWA and ESC management design and implement a control that is sufficiently precise to detect and correct UDO reconciliation discrepancies in the correct fiscal year in which they occur.      

Implement Agency plans for eliminating the backlog of driver examination results held by medical examiners.

Develop a plan to allocate resources to the Medical Programs Division to fully implement requirements for medical examiner eligibility audits and random selection performance monitoring.

Update Agency processes for conducting periodic medical examiner eligibility audits and random selection performance monitoring as needed to incorporate upgraded National Registry tools.

Reinstate the conduct of eligibility audits and random selection performance monitoring of medical examiners.

Describe the responsibilities and tasks necessary to develop and continuously promote a positive safety culture at PHMSA, such as a training plan on safety culture. Then clearly assign those responsibilities to leadership.  

Establish a method to track and monitor the status of initiatives related to safety culture. 

Notify all travel card program participants that advance written approval must be obtained prior to incurring any travel expenses.

Develop and implement a plan for Agency/Organization Program Coordinator to identify travel authorizations that were not submitted or approved prior to the incurrence of official travel-related expenses. The plan should include follow-up with cardholders and approvers on instances where noncompliance is identified.

Update DOT’s travel card management policy, DOT Order 15006.b, and DOT travel card training to include guidance on how cardholders should recover travel card account overpayments.

Develop and implement a control that will allow the Department to identify questionable travel card transactions outside of the delinquency report review that is performed by the operating administrations.

Expand existing training for managers and Approving Officials to incorporate a proper voucher review.  

Notify all travel cardholders that cash withdrawals must not occur more than 3 days prior to an authorized trip.

Strengthen current cash-advance controls to test cardholder compliance with cash advances and require follow-up with cardholders when instances are detected.

Design and implement a control to test that cardholders are using the travel card to pay only for official travel expenses as required. The control should include follow-up with cardholders when charges unrelated to official travel are detected.

Modify training materials to emphasize the required use of the travel card for all expenses related to official travel.  

Develop and implement controls to require that refresher training is administered timely in electronic learning management system, and require that cardholders complete refresher training in a timely manner.

Modify the current travel card application process to include a manager certification as required by the DOT travel card management policy.

Issue a Notice of Proposed Rulemaking and a final rule, if found to be in the public interest, that address operations using supplemental passenger restraint systems.

Require all supplemental passenger restraint system applications to be reviewed using a standardized evaluation checklist that defines which information must be included on the request form for authorization.   

Define minimum certification standards that meet aviation-specific load factors for supplemental passenger restraint systems.

Revise the supplemental passenger restraint system authorization procedures so applications are routed through local oversight offices to notify inspectors which operators are requesting and subsequently authorized for supplemental restraint use.

Develop and incorporate supplemental passenger restraint inspection criteria—such as frequency of inspections, review of harness authorization documentation, and maintenance of harnesses into inspector guidance for both Part 135 and Part 91 surveillance.

We recommend that DOT coordinate with the impacted OAs to develop a corrective action plan to resolve and close the findings identified in this report.

We recommend that DOT determine the allowability of the questioned transactions and recover $25,838, if applicable.

KPMG recommends that DOT management design and implementprocedures to consistently and timely perform and document audit log reviews asrequired by standards for effective internal control systems and/or internalpolicy.

KPMG recommends that DOT management design and implementprocedures to consistently and timely perform and document user account accessreviews as required by standards for effective internal control systems and/orinternal policy.

KPMG recommends that management design and implementcomponent-specific system security plan requirements in instances where plansfor those areas not addressed in the Departmental system security plan.

KPMG recommends that management design and implement procedures related to the retention of appropriate supporting evidence of internal controls including, but not limited to, access administration, access recertification, audit log review, and patch management.

KPMG recommends that DOT management maintain a documentation trail which demonstrates completion of each step in the performance of their input validation control in accordance with the TIFIA Loan Subsidy Re-estimates standard operating procedures.    

KPMG recommends that FTA management perform a documentedrisk assessment and develop a tailored grant accrual methodology for each newgrant accrual category in which the expected costs incurred but not recordedmay differ based on the characteristics of the grant funding. To the extentcontradictory evidence or actual incurrence does not align with the initialassumptions developed, management should refine the methodology accordingly.

KPMG recommendeds that FTA management establish a documented review process to clearly demonstrate the historical disbursement days for all grant accrual categories have been reviewed prior to recording the grant accrual.   

KPMG recommended that FAA management design and implement procedures to consistently and timely perform and document audit log reviews as required by standards for effective internal control systems and/or internal policies.

KPMG recommended that FAA management design and Implement procedures to consistently and timely perform and document user account access reviews as required by standards for effective internal control systems and/or internal policies.

KPMG recommended that FAA management implement component-specific system security plan requirements.

Require OST to either start utilizing the CSAM tool for its security control assessments or develop its own risk assessment policies and procedures as required by DOT's Cybersecurity Compendium.

Work with OAs to update privacy risk management procedures to ensure the completion, tracking, review, and approval of privacy plans and compliance documentation prior to system authorization or reauthorization. Components should engage the Departmental Chief Privacy Officer as appropriate.

Work with the Departmental Chief Privacy Officer to establish processes and procedures to notify Component Privacy Officers of systems scheduled for reauthorization so that required privacy risk management plans may be completed as required by policy.

Work with the Departmental Chief Privacy Officer to establish processes and procedures to determine Component compliance with Departmental policy requiring Privacy Risk Management plans be established prior to system authorization or reauthorization.

Coordinate with appropriate offices within the Office of Secretary to develop and implement a strategy and solution(s) to ensure that supervisors, contracting officers, and contracting officer representatives enforce personnel onboarding and off boarding procedures, completion of the DOT Rules of Behavior and other IT requirements prior to being granted access to DOT networks, systems, and information, or have existing access revoked upon separation, in accordance with DOT policy.

Strengthen its oversight of the configuration management processes performed by OAs to ensure configuration management plans are developed, kept up-to-date, and document requirements for each system.

Work with the FAA CIO to complete the revision of FAA Order 1800.66, Configuration Management Policy.

Work with OAs to implement oversight to address configuration change weaknesses and to ensure configuration changes to the information systems are properly documented and tracked through implementation, and undergo a post-implementation review to verify procedures are followed.

Ensure that baseline configuration deviations are monitored and deviations are approved to ensure that baseline compliance reports demonstrate a consistent and accurate application of baseline standards.

Consolidate to the enterprise Tenable Nessus system to ensure accessibility of baseline compliance and/or vulnerability assessment capabilities.

Ensure that missing security patches are either applied in accordance with DOT policy or that vulnerable software is otherwise remediated on the affected endpoints. In addition, ensure that missing security patches attributable to specific mission/business requirements are identified, control weaknesses are appropriately documented in POA&Ms, and that the authorizing official is aware of and has accepted risk for the associated weaknesses.

Document and implement a process to identify software end of life dates and require the development of implementation plans to eliminate unsupported software.

Work with FAA to secure a reliable funding stream for background reinvestigations.

DOT should devise strategies, consistent with Federal policies and guidance, to overcome the logistical challenges of fingerprinting during a pandemic or other events and circumstances which prevent the timely completion of background reinvestigations.

Work with the FAA CIO to review all systems listed in Appendix B of the FAA Air Traffic Operations (ATO) Information Security Continuous Monitoring (ISCM) Plan for NAS and Mission Support (MS) Systems to ensure the FAA ISCM plan is complete and accurate, making updates as needed.

Work with the OST IT Director to ensure an alternate processing site (including necessary agreements) is more clearly described within the contingency plan to permit the transfer and resumption of information system operations for essential missions/business functions consistent with recovery time objectives when the primary processing capabilities are unavailable, for those systems in accordance with the requirements of the Cybersecurity Compendium and NIST guidance.

Work with the PHMSA CIO to ensure an alternate storage site (including necessary agreements) is described within contingency plans to permit the transfer and resumption of information system operations for essential missions/business functions consistent with recovery time objectives when the primary processing capabilities are unavailable, for those systems in accordance with the requirements of the Cybersecurity Compendium and NIST guidance.

Strengthen its oversight of the contingency planning processes performed by FMCSA, OST COE, OST VOLPE, FAA, FRA, and MARAD to ensure contingency planning documentation is developed, updated and tested in a timely manner, in accordance with policy.

Update the National Geospatial Data Asset (NGDA) Theme plan with the processes to identify, assess, and develop NGDA standards based on the Act.

Develop and implement a process to track the financial resources necessary to manage the National Geospatial Data Asset (NGDA) Transportation data theme.

Develop, publish and implement DOT’s strategy for geospatial data-related activities as defined in its Geospatial Information System Strategic Plan.

Work with the Chief Data Officer to verify that all Operating Administrations (OAs) designate an appropriate individual as a geospatial information officer.

Work with Operating Administration (OA) records officers to  verify that FAA, FTA, MARAD, NHTSA, OST, and PHMSA allocate appropriate  resources to complete file plans and record schedules development activities  through submission to the DOT Records Management Office.

Track and monitor FRA's, MARAD's, NHTSA's and PHMSA's  allocated resources to meet the responsibilities of effective geospatial data  collection, production, and stewardship.

Develop, disseminate, and implement a uniform process for all Operating Administrations to perform a quality review of geospatial data to verify compliance with Department of Transportation’s (DOT) information quality guidelines. This process should include a method of ensuring recipients of DOT funds for geospatial data collection meet appropriate quality standards, as well as an assessment of stakeholder and peer reviews in order to validate the quality of all disseminated information.

Update, disseminate and implement Department ofTransportation's internal data inventory policy to address how the Operating  Administrations should verify that geospatial data and metadata does not  inappropriately disclose personally identified information to external parties  and include guidelines on tracking and maintaining geospatial data asset  inventory and validating that inventories are complete.

Develop a process to verify that the Operating Administrations are aware of and apply the Department of Transportation Privacy  Risk Management Policy, requiring privacy risk management activities to be completed for geospatial information systems prior to next system  reauthorization.

Develop and implement a procedure that documents and tracks  all responsibilities outlined in the Geospatial Policy on Reducing Duplication  are implemented to include Department of Transportation and Operating  Administrations' implementation of geospatial clearinghouse searches to  validate no duplication of funds.

Develop and maintain a process to verify that all geospatial metadata meets quality standards that strengthen the internal control process to improve the quality of metadata reported on DOT’s enterprise data inventory.

Establish, document and implement a process for ongoing monitoring of its strategy for advancing geospatial information and related geospatial data and activities appropriate to its mission in accordance with requirements of the Federal Internal Control Standards.

Working with the Operating Administrations, require that all  geospatial information systems maintain authorization status in accordance with departmental cybersecurity policies.

Implement documented processes for granting and removing user access in a consistent manner, as required by STB policies and procedures.

Implement processes for conducting, documenting, and maintaining Position Risk Designations in a consistent manner, as required by STB policies and procedures.

Develop a process for ensuring that the completion of rolebased training is tracked and maintained.

Consistently implement the process to ensure all new users complete the mandatory security awareness training requirements prior to being granted access to STB systems.

Fully develop the ISCM Strategy and all information system ISCM plans to include the required criteria documented in the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-137 such as: a. Considerations at the organization/business process level; b. Considerations at the information system level; and c. Processes to review and update the ISCM program and strategy.

Define the process to ensure the timely collection of established metrics across its operational systems and reporting evaluation process to assist ISCM Stakeholders to make informed decisions.

Develop and implement a procedure for reviewing and tracking new and updated railroad conductor certification programs.

Finalize the Operating Practices Compliance Manual chapter on conductor certification compliance and enforcement and distribute it to inspectors; include a process an inspector can use to notify FRA Headquarters about a problem with a railroad's conductor certification program.

Develop and implement a plan for systematically conducting Part 242 compliance audits of all railroads to which the regulations apply.

Modify the Railroad Inspection System for Personal Computers (RISPC) to capture data that specifies the types of Part 242 oversight activities inspectors are recording.

Develop and issue instructions on the proper entry of Part 242 activity codes in RISPC.

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Develop and implement a systematic process to regularly collect and analyze data on emergency evacuations to determine whether evacuation standards need to be revised or updated based upon current risks. 

Develop a policy or procedures to maintain and analyze a  record of critical data from aircraft manufacturers' evacuation demonstrations  and analyses to identify risks and ensure data used in analyses and computer  modeling are accurate and up to date.

In consultation with its ACI partners, identify the resources needed to meet the current schedule for achieving ACI’s remaining priorities, and how they should be allocated. Revise the current schedule as necessary to reflect the resources that are available.

Conduct a risk assessment of the issues related to valid driver's licenses and use of State-licensed physicians noted in this report, and implement processes to mitigate any identified risks. Include the results of this risk-assessment in the required report on the safety impact of BasicMed to Congress.

Develop and implement a process to collect pilot flight hours, or an alternative process that allows a meaningful assessment of the safety impact of pilots operating under BasicMed compared with pilots operating with a medical certificate.

Coordinate with impacted Operating Administrations (OA) to develop a corrective action plan to resolve and close the findings highlighted in this report.

Determine the allowability of the questioned transactions and recover $3,440,165, if applicable.

Develop an action plan with schedule milestones forcompleting the assessment, test, and mitigation of the new securityrequirements for ERAM to successfully meet a high impact system categorization.

Develop and implement a plan with a timeline that identifies when critical, high, and medium vulnerabilities in STARS will be mitigated and implemented at the 11 largest TRACON facilities and includes a patch management program to ensure that the security patches for all operating systems, software, and applications are up to date; and timeline when FAA will implement security-relevant software updates for critical, high, and medium vulnerabilities, in accordance with requirements.

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Direct STARS officials to prioritize mitigation efforts to resolve the security weaknesses for the 27 security controls identified in this report; develop a Plan of Action and Milestones that realistically reflects resources and timeframes for the completion of these actions; and report on these actions in the Department's Cybersecurity Assessment and Management monitoring system.

Update the STARS incident response policy to include the missing elements from the National Institute of Standards and Technology.

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Develop and implement an internal control that ensures that Agency staff follow requirements for access control in accordance with the STARS Security Handbook.

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Update the 2012 policy manual to address all statutory and regulatory requirements. 

Develop and implement procedures that direct MARAD to obtain and document all application related materials required by statute and regulation. 

Develop and implement procedures that require program staff to adhere to MARAD’s program policy and statutory and regulatory requirements.  

The Bureau of Transportation Statistics issue a Reporting Directive clarifying that air carriers are to include booking fees, along with any/all fees required to board the aircraft, in the fare line item reported to the Office of Airline Information’s Origin and Destination Survey.     

The Office of Aviation Analysis develop a process to regularly collect, maintain, and use information from airlines' website disclosures of all fees charged for optional or ancillary services as a screening mechanism for significant changes in these fees. For each mainline carrier and posted fee, this information should include—but not necessarily be limited to—identification of the type of each service and its price (or price range).

The Secretary request a Revenue Ruling or policy statement from the Department of Treasury regarding the taxation of airline booking fees and, if appropriate, that the Department of Treasury take action to assess the relevant tax. If the Department of Treasury finds that these fees are taxable—and assuming no change in the conditions underlying our calculation of their impact on the Airport and Airway Trust Fund in 2019—this could conservatively result in $60.6 million in funds put to better use in every year following the determination.

Update and implement FHWA's guidance for risk-based project involvement to clarify the requirements for its project risk-assessment process, including expectations for conducting and documenting the risk assessment and criteria to guide the reevaluation of project risks.

Identify and notify Divisions about sources of information that can inform the project risk-assessment process, such as the quarterly reports required by the grant agreement for the Florida International University project.

Update and issue a procedure within the Florida Division for conducting and documenting complete project risk assessments in accordance with FHWA's national guidance.

Update and implement FHWA's guidance for risk-based project involvement to clarify how the link between elevated risks and associated oversight activities, changes to oversight actions, and the results of its risk-based involvement should be documented in project oversight plans.

Develop and implement guidance for documenting, in risk-based project oversight plans and associated materials, the scope of FHWA's risk-based involvement, such as through the use of checklists or standardized forms.

Develop and implement guidance that establishes criteria for the content of risk-based project oversight plans to maintain consistency and avoid creating multiple redundant plans. Include examples of complete project oversight plans that can be used as a reference, and clarify the role and purpose of the oversight plan for major projects.

Update and issue a procedure within the Florida Division for documenting complete risk-based project oversight plans in accordance with FHWA's national guidance.

Develop and implement a process to routinely monitor the implementation and evaluate the effectiveness of FHWA’s risk-based project involvement.

Coordinate with impacted Operating Administrations (OA) to develop a corrective action plan to resolve and close the findings highlighted in this report.

Determine the allowability of the questioned transactions and recover $2,227,535, if applicable.

Develop and implement written procedures for reviewing and approving railroads' Part 219 compliance plans, to include an oversight control, such as a supervisory or second-level review, to validate results.

Develop and implement a formal written process for tracking all Part 219 audits.