Pre-and-Post-Payment Transportation Auditing

1. Pre-and-Post-Payment Transportation Auditing May 15, 2012

2. Agenda • Audits Overview • Mission/Vision • Transportation Audits Division Branches • What’s Mandated • Pre-Payment Requirements • Post Payment Requirements • On-going Initiatives

3. Mission of Transportation Audit Division • MISSION: GSA identifies and recovers Transportation Service Provider (TSP) overcharges and other debts relating to transportation bills paid by agencies around the world. • VISION: A resource center providing current, efficient, and accurate audits for customer agencies as well as traffic management advice and reviews and the single most robust Transportation Audits Electronic Library in the world.

4. Transportation Audits Division Division is comprised of 3 branches… AuditPolicy&Review Accounts&Collections DisputesResolution GSA Audits Division

5. Accounts and Collections Branch • Initiates actions to collect debts owed to the U.S. Government by TSPs • Directs TSP payments and deposits • Tracks debt collection through automated internal processes and systems • Processes and collects unused/expired airline tickets for federal agencies • Assists the Department of Justice in bankruptcy and other circumstantial related debts

6. Audit Policy and Review Branch • Serves as Contracting Officer Representative for pre-payment and post-payment audit contracts • Resolves complex transportation issues • Prepares legal and technical reports for use in prosecuting or defending lawsuits by or against an agency • Reviews agency policies, programs, and procedures • Manages the Agency Review and Assistance Program (ARAP) • Manages the Transportation Electronic Audit Library • Maintains the Tariff and Tender Library • Manages repository for all paid transportation documents • Represents the US Government and submits opinions to the Civilian Contract Board of Appeals

7. Disputes Resolution Branch • Oversees pre-payment and post-payment audits of transportation bills • Produces transportation service provider (TSP) Notice of Overcharge (NOC) • Reviews/settles post-payment audit claims • Approves/declines TSP protests • Provides agencies Management Information and Reporting from billing documents • Represents the US Government in cases of bankruptcies

8. What’s Mandated

9. 31 U.S.C. 3726 requires all agencies to establish a prepayment audit program and obtain approval from GSA: • Submit plans to: audit.policy@gsa.gov; subject: “Agency PPA” • An acceptable audit program must: • Verify all transportation bills against filed rates and charges before payment • Comply with the Prompt Payment Act • Require your agency’s paying office to offset debts, if directed by GSA’s Audit Division, from amounts owed to TSP within 3 years • Be approved by the GSA Audit Division • Complete accurate audits of transportation bills and notify TSP of any adjustments within 7 calendar days of receipt • Forward documentation monthly to GSA Audit Division, which will store paid transportation bills for 10 years Prepayment Audit Requirements

10. All agencies must send all quotations, tenders, or contracts with a TSP to GSA: • General Services Administration, Transportation Audit Division (QMCA), Crystal Plaza 4, Room 300, 2200 Crystal Drive, Arlington, VA 22202, SDDCrates@gsa.gov • If you utilize TMSS or DPS, GFM (DOD), it is not necessary to send copies of rates to GSA Prepayment Audit Requirements

11. All entities conducting prepayment audit must submit a monthly report to GSA: • General Services Administration, Transportation Audit Division (QMCA), Crystal Plaza 4, Room 300, 2200 Crystal Drive, Arlington, VA 22202, audit.policy@gsa.gov, subject: PPA Monthly Report • At a minimum, the report must include: • Federal Agency (to include Agency Location Code) • Type or mode of transportation bills • Count (number of bills reviewed) • Billed amount • Dollar savings to the Federal agency • Fees Prepayment Audit Requirements

12. All agencies are required to submit hard copy and electronic “paid” transportation billing documents to: • General Services Administration, Transportation Audit Division (QMCA),Crystal Plaza 4, Room 300, 2200 Crystal Drive, Arlington, VA 22202, QMCATariffs@gsa.gov, subject: Post Pay Docs • If you utilize TMSS/TMS (Civilian Agencies) or DPS, GFM (DOD) or an approved Third Party Payment System it may not be necessary to provide copies of paid invoices Post Payment Requirements

13. Ongoing Initiatives • Fully deploy deductions in Syncada (DOD HHG Offset) • Moving TARPS to the Web • Customer outreach

14. Agenda • Post Payment Update • Post Payment Audits • Top Issues • Audit Process • Appeal Process • Unused Ticket Refund Procedures • Points of Contact

15. Postpayment Audits • GSA performs audits on freight and passenger transportation vouchers paid by the government in order to recover excess charges from the Transportation Service Providers. Our commercial audit firms, under contract to GSA, continue to identify millions of dollars in excess transportation charges.

16. Our Audit Covers the Travel of People & Property • General Commodities • Motor • Rail • Steamship • Pipelines • Passenger • Air • Bus • Train • Personal Property • Household Goods

17. Top Issues

18. Audit Process – Upon receipt of the bill • Examination process, critical elements are verified, which includes, but are not limited to: • TSP SCAC is identified • Mode of transportation • Pick up and Delivery dates • Commodities and weight are determined • Various statutes, rules, and regulations are followed

19. Bills are Audited on an Individual Basis • Some bills are received without the information needed to effectively perform an audit. • In those cases, if there is a means of obtaining further documentation to substantiate the billings, those documents may be requested. • Audit procedures include, (but are not limited) to checking for other errors such as extension errors, correct mileage applications, duplicate billings.

20. Findings • If it is determined that an overcharge exists, a notice of overcharge (NOC) is issued to the Transportation Service Provider (TSP) stating that a debt is owed to the Federal Government for which it did provide service. • TSPs have a right to dispute the NOC

21. Notice of Overcharge

22. Acknowledgement of Claim or Protest • Acknowledgement Letter of • Protest • Claim

23. Claim Action Letter of Offset

24. Claim Action • Claim (term used after a Notice of Overcharge is collected) • Direct Settlement • Supplemental Billing • Pre-Audited Bill

25. Protest Action TSP disputes the audit action taken by GSA Transportation Audits Division! Charges Incorrect! NOC wrong TSPs have 60 days to protest audit action before collection from TSP is initiated by GSA, Transportation Audit Division.

26. Postpayment Audit Process • Notice of Overcharge • Review of TSP protest (no collection effected/delays offset process) • Review claims/ audit supplemental and prepayment audit claims • Issue Certificate of Settlement (certification of payment) • Issue Settlement Certificate (denial)

27. Appeal Process • Claim denied by the Audit Division • Claim presented to the Board within 6 months • Docketed • Referred to the Director of the Audit Division • Assigned to the Audit Policy and Review Branch for review and response within 30 days

28. Unused Ticket Refund Procedures

29. Statute of Limitations on Unused Tickets • Pursuant to American Airlines, Inc. v. Austin, 75 F.3d 1535 (Fed Cir 1996) refunds for unused tickets may be recovered by GSA for up to ten (10) years from the date of purchase

30. Refundable Ticket reasons • Ticket purchased never used • Travel terminated • Return portion not used • Service furnished different from service authorized

31. Agency’s Responsibility • Establish (and provide to employees) agency procedures for collecting unused, partially used, downgraded and exchanged tickets (see FTR 41 CFR §301-72.101) • Promptly process all unused tickets

32. Notes • Account for all unused tickets – paper and electronic • Make sure you/agency receives credit/money • Only the airlines can tell whether a ticket has been used • Ticket must not be a non-refundable ticket • Refunds (process by TMC/CTO) must be within one year of ticket issuance • Partial refund may be prorated • The Audits Division has ten years to recover unused tickets

33. Contacts – Transportation Audits Division Donna Jack Audit Policy and Review Branch Chief (703) 605-3488 donna.jack@gsa.gov George Thomas, Jr. Branch Chief Disputes Resolution George Thomas, Jr. 703-603-8188 george.j.thomas @gsa.gov Vacant TSP Claims Status Inquiry (703)605-9435 Mary Bates Director (703) 605-9402 mary.bates@gsa.gov Joyce Clark Deputy Director (703) 605-9420 joyce.clark@gsa.gov Annie Scott Accounts & Collections Branch Chief (703) 605-9425 annie.scott@gsa.gov

34. Questions?