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Audit Report
OIG-23-028
CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF
PROGRAMS
Audit of Air Carrier Worker Support
Certifications – Ground Services
International, Inc.
June 6, 2023
Office of Inspector General
Department of the Treasury
This Page Intentionally Left Blank
OFFICE OF
INSPECTOR GENERAL
DEPARTM ENT OF THE TREASURY
WASHINGTON, D.C. 20220
June 6, 2023
MEMORANDUM FOR JESSICA MILANO
ACTING CHIEF RECOVERY OFFICER
FROM:
Deborah L. Harker /s/
Assistant Inspector General for Audit
SUBJECT:
Audit of Air Carrier Worker Support Certifications – Ground
Services International, Inc.
Attached is our audit report for the Audit of Air Carrier Worker Support Certifications -
Ground Services International, Inc. (GSI) (OIG-23-028; dated June 6, 2023). Under a
contract monitored by our office, Saggar & Rosenberg, P.C. (S&R), a certified
independent public accounting firm, performed the audit. The objective of this audit
was to assess the accuracy, completeness, and sufficiency of GSI’s sworn financial
statement or other data used to certify the wages, salaries, benefits, and other
compensation amounts submitted and approved by the Department of the Treasury
(Treasury) for the Air Carrier Payroll Support Program (PSP1). The scope of this audit
covered the time period from April 1, 2019 through September 30, 2019 and included
the certified PSP1 Application, sworn financial statements, tax returns, and other
documentation submitted to Treasury.
The GSI PSP1 Application was comprised of four United States-based affiliate
companies. These companies include 1) GSI,1 2) ALX Cargo Center IAH, LLC,
3) 121 Inflight Catering, LLC,2 and 4) 121 At BNA, LLC. 121 Inflight Catering, LLC
and 121 At BNA, LLC are under the same management referred to as Inflight Catering.
GSI and ALX Cargo Center IAH, LLC, are under the same management referred to as
GSI.
In its audit report, S&R found that GSI incorrectly compiled data used for the
Awardable Amounts section of the PSP1 Application. Specifically, the:
1 GSI conducts business under the name dNata.
2 121 Inflight Catering, LLC changed its legal name to dNata US Inflight Catering, LLC on
February 20, 2019.
• Inclusion of GSI’s unallowable corporate officer compensation, resulted in a
overstatement;
• Inclusion of Inflight Catering3 unallowable corporate officer compensation,
resulted in a
overstatement;
• Differences between the PSP1 Application amounts and the actual amounts paid
to company employees for salaries, wages, and benefits, resulted in a
overstatement;
• Data discrepancies related to Inflight Catering’s benefits, resulted in an
overstatement;
• Voluntary exclusion of GSI’s eligible gross pay, resulted in a
understatement; and
• Subsequent to initial application, self-reporting of the inclusion of GSI’s
unallowable corporate officer compensation, resulted in a
understatement.
The net result was $261,799 understatement; as such, GSI did not receive an
overpayment of PSP1 financial assistance. Due to unallowable expenses that were
included in the PSP1 Application, S&R recommends that Treasury’s Chief Recovery
Officer:
• Review GSI and Inflight Catering’s requested amount for unallowable expenses,
under the Payroll Support Program Extension (PSP2)4 authorized by the
Consolidated Appropriations Act, 2021 and the Payroll Support Program 3
(PSP3)5 authorized by the American Rescue Plan Act of 2021, and seek
reimbursement for the overpayment, if applicable.6
Our contract required that the audit be performed in accordance with generally
accepted government auditing standards. In connection with the contract, we
reviewed S&R’s report and related documentation and inquired of its representatives.
Our review, as differentiated from an audit performed in accordance with generally
3 Although Inflight Catering prepared its portion of the PSP1 Application separately from GSI, GSI
assumed responsibility of the entire application by certifying on all affiliates behalf.
4 The Consolidated Appropriations Act, 2021 (P.L. 116-260), enacted on December 27, 2020, created
the Airline Worker Support Extension for passenger air carriers and certain contractors. Treasury
referred to this as Payroll Support Program Extension (PSP2).
5 The American Rescue Plan of 2021 (P.L. 117-2), enacted on March 11, 2021, created the Air
Transportation Payroll Support Program Extension authorizing Treasury to provide additional
assistance to passenger air carriers and contractors that received financial assistance under PSP2.
Treasury referred to this as Payroll Support Program 3 (PSP3).
6 Although the GSI and Inflight Catering applications were merged for PSP1, they applied separately
for PSP2. To be eligible for PSP3, participants must have participated in PSP2.
accepted government auditing standards, was not intended to enable us to express an
opinion on GSI’s compliance with Treasury’s PSP1 policies and procedures. S&R is
responsible for the attached auditor’s report and the conclusions expressed therein.
Our review found no instances in which S&R did not comply, in all material respects,
with generally accepted government auditing standards.
We appreciate the courtesies and cooperation provided to S&R and our staff during
the audit. If you have any questions or require further information, please contact me
at (202) 486-1420, or a member of your staff may contact Lisa DeAngelis, Deputy
Assistant Inspector General for Audit, at (202) 487-8371.
Attachment
cc:
Jason Morrow, Attorney Advisor, Department of the Treasury
Victoria Collin, Chief Compliance and Finance Officer, Office of Recovery
Programs, Department of the Treasury
Jeff Davis, Partner, Saggar & Rosenberg, P.C.
i
Contents
Audit Report
Results in Brief ................................................................................................... 2
Background ........................................................................................................ 4
Treasury Disbursement Process ........................................................ 7
PSP1 Interim Audit Report ............................................................... 7
Ground Services International, Inc. ................................................... 8
Audit Results .................................................................................................... 10
GSI and ALX Cargo ...................................................................... 10
121 Inflight Catering and 121 At BNA ............................................ 11
Finding 1 GSI Did Not Receive an Overpayment of PSP1 Financial Assistance
Despite Partial Non-Compliance with Application Requirements .......... 12
Ground Services International, Inc. ................................................. 12
Inflight Catering ........................................................................... 17
Recommendation .......................................................................... 22
Appendices
Appendix 1: Objective, Scope, and Methodology .................................................. 23
Appendix 2: GSI Management Response .............................................................. 28
Appendix 3: Treasury Management Response ...................................................... 32
Appendix 4: Report Distribution .......................................................................... 35
Abbreviations
CARES Act
Coronavirus Aid, Relief, and Economic Security Act
COVID-19
Coronavirus Disease 2019
DOT
Department of Transportation
GAO
Government Accountability Office
Guidelines
Guidelines and Application Procedures for Payroll Support to Air
Carriers and Contractors
GSI
Ground Services International, Inc. and ALX Cargo Center IAH,
LLC
ii
Inflight Catering
121 Inflight Catering, LLC and 121 At BNA, LLC
IRS
Internal Revenue Service
OIG
Treasury Office of Inspector General
PSP1
Payroll Support Program, CARES Act
PSP2
Payroll Support Program Extension, Consolidated Appropriations
Act, 2021
PSP3
Payroll Support Program 3, American Rescue Plan Act of 2021
SOC 1
System and Organizational Controls
S&R
Saggar & Rosenberg, P.C.
Treasury
Department of the Treasury
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Audit of Air Carrier Worker Support Certifications – Ground Services
International, Inc. (OIG-23-028)
1
June 6, 2023
Jessica Milano
Acting Chief Recovery Officer
Department of the Treasury
This report presents the results of our audit of Ground Services
International, Inc.’s (GSI) certifications made to the Department of
the Treasury (Treasury) as part of its participation in the Air Carrier
Payroll Support Program (PSP1). This audit was mandated by
Title IV, Subtitle B, Air Carrier Worker Support, of the Coronavirus
Aid, Relief, and Economic Security Act (CARES Act).7 Under the
CARES Act, Treasury was to provide $32 billion in financial
assistance to passenger air carriers, cargo air carriers, and certain
contractors to be exclusively used for the continuation of payment
of employee wages, salaries, and benefits, in response to the
economic impact of the Coronavirus Disease 2019 (COVID-19).8
Furthermore, the Treasury Office of Inspector General (OIG) is
required to audit certifications made by passenger and cargo air
carriers that do not report salaries and benefits to the Department
of Transportation (DOT) (hereinafter referred to as non-241 air
carriers)9 and contractors.
Under a contract with OIG, Saggar & Rosenberg, P.C. (S&R)
conducted this audit. Our audit objective was to assess the
accuracy, completeness, and sufficiency of GSI’s sworn financial
statement or other data used to certify the wages, salaries,
benefits, and other compensation amounts submitted and approved
by Treasury for PSP1. The scope of our audit covered the time
period from April 1, 2019 through September 30, 2019 and
included the certified PSP1 Application, sworn financial
7 P.L. 116-136 (March 27, 2020).
8 The financial assistance provided under the CARES Act was split between Passenger Air Carriers
($25 billion), Cargo Air Carriers ($4 billion), and Contractors ($3 billion).
9 Passenger and cargo air carriers that are not required to report salaries and wages to DOT under
14 CFR, Part 241, “Uniform System of Accounts and Reports for Large Certificated Air Carriers”.
Audit of Air Carrier Worker Support Certifications – Ground Services
International, Inc. (OIG-23-028)
2
statements, tax returns, and other documentation submitted to
Treasury on April 3, 2020.10
To accomplish the objective, we reviewed applicable laws and
regulations; and Treasury’s policies and procedures, including but
not limited to, the Title IV, Subtitle B, Air Carrier Worker Support of
the CARES Act, Guidelines and Application Procedures for Payroll
Support to Air Carriers and Contractors (Guidelines), PSP1
Agreement, and Frequently Asked Questions: Application
Procedures for Payroll Support to Air Carriers and Contractors. We
interviewed key personnel from GSI, Treasury, and contracted
consultants engaged by Treasury to evaluate certified company
applications. We conducted our fieldwork from September 2021
through April 2022. Appendix 1 contains a more detailed
description of our objective, scope, and methodology.
Results in Brief
In brief, S&R found that GSI, a contractor, reported correct
information for three of the four sections reviewed on its PSP1
Application.11 These sections are: (1) Applicant Information,
(2) Applicant Type, and (3) Certification. We also found that GSI
reported incorrect information in the Awardable Amounts section,
attributable to both GSI and Inflight Catering portions of the
merged application. Specifically, we found that GSI (1) included
unallowable corporate officer compensation, resulting in an
overstatement of
, and (2) differences between the PSP1
Application amounts and the actual amounts paid to company
employees for salaries, wages, and benefits, resulting in an
overstatement of
. The overstatement was partially offset
by the company’s exclusion of eligible gross pay from the
awardable amount of
, resulting in a net overstatement
10 GSI submitted its PSP1 Application and related supporting documentation on April 3, 2020. GSI’s
application was later merged with three company affiliates: (1) ALX Cargo Center IAH, LLC, (2) 121
Inflight Catering, LLC, and (3) 121 At BNA, LLC. GSI and ALX Cargo Center IAH, LLC are managed
and operated by the same management group (referred to as GSI), while 121 Inflight Catering, LLC
and 121 At BNA, LLC are operated by a separate management group (referred to as Inflight
Catering). GSI certified the PSP1 Application on behalf of all affiliates.
11 The PSP1 Application is comprised of eight sections. Four sections - Financial Institution Information,
Employment Levels, Taxpayer Protection, and Additional Information, were not subject to audit
procedures. Details regarding the sections not reviewed can be found in appendix 1.
Audit of Air Carrier Worker Support Certifications – Ground Services
International, Inc. (OIG-23-028)
3
of
. However, GSI subsequently self-reported to Treasury
the inclusion of unallowable corporate officer compensation
of
, resulting in a net understatement of $1,113,810
for its portion of the merged PSP1 Application.
For Inflight Catering we found (1) the inclusion of unallowable
corporate officer compensation, resulting in an overstatement of
, and (2) data discrepancies related to benefits, resulting
in an overstatement of
. As a result, Inflight Catering
reported a total overstatement of $852,011 for its portion of the
merged PSP1 Application.
The $1,113,810 understatement by GSI’s portion and $852,011
overstatement of Inflight Catering’s portion of the merged PSP1
Application resulted in an aggregate understatement of $261,799.
As a result, GSI did not receive an overpayment of PSP1 financial
assistance. Due to unallowable expenses that were included in the
PSP1 Application, we recommend that Treasury review GSI and
Inflight Catering’s requested amounts for unallowable expenses
under the Payroll Support Program Extension (PSP2)12 authorized
by the Consolidated Appropriations Act, 2021 and the Payroll
Support Program 3 (PSP3)13 authorized by the American Rescue
Plan Act of 2021, and seek reimbursement for overpayment, if
applicable.14
As part of our reporting process, we provided GSI and Inflight
Catering management an opportunity to comment on a draft of this
report. In a written response, GSI management stated that it is in
general agreement with the report findings as they apply to GSI
and believe the report is a fair reflection of the application process
and subsequent events. Specifically, GSI acknowledged that the
speed of reaction needed to make a timely claim and the evolution
of definitions and requirements made verification of the accuracy of
the PSP1 Application difficult. GSI management also stated that
12 The Consolidated Appropriations Act, 2021 (P.L. 116-260), enacted on December 27, 2020, created
the Airline Worker Support Extension for passenger air carriers and certain contractors. Treasury
referred to as Payroll Support Program Extension (PSP2).
13 The American Rescue Plan of 2021 (P.L. 117-2), enacted on March 11, 2021, created the Air
Transportation Payroll Support Program Extension authorizing Treasury to provide additional
assistance to passenger air carriers and contractors that received financial assistance under PSP2.
Treasury referred to as Payroll Support Program 3 (PSP3).
14 Treasury did not merge the GSI and Inflight Catering applications under PSP2. To be eligible for
PSP3, participants must have participated in PSP2.
Audit of Air Carrier Worker Support Certifications – Ground Services
International, Inc. (OIG-23-028)
4
while it did assume responsibility of Inflight Catering’s portion of
the PSP1 Application, GSI had no participation in the Inflight
Catering application and strongly objected that Treasury merged
the PSP1 applications of the affiliates. GSI defers to Inflight
Catering for its formal response to those findings.
In a written response, Inflight Catering management stated that it
holds itself to the highest standards and takes its compliance
obligations seriously. However, Inflight Catering management
believes that the audit report understates the lack of guidance that
was available during the expedited PSP1 Application process, as
well as the evolving definitions of certain items relating to the
PSP1 Application, most importantly that of “corporate officers”.
Inflight Catering management also stated that while they
understand Treasury’s policy to treat individuals with a Vice
President title as corporate officers, the company was undergoing
significant change and rapid growth immediately prior to the
COVID-19 pandemic and many of its new hires were given
honorific Vice President titles. Additionally, Inflight Catering
management stated that in some situations these individuals were
not responsible for policy or executive-level decision making and
they did not consider the employees to have authority over
business units.
GSI and Inflight Catering management’s responses are included as
appendix 2 of this report.
In a written response, Treasury management concurred with our
recommendation and stated that management will review
awardable amounts requested under PSP2 and PSP3 and seek
recoupment where appropriate. Treasury management will need to
record an estimated completion date for these actions in the Joint
Audit Management Enterprise System (JAMES). Management’s
planned corrective actions meet the intent of our recommendation.
Treasury management’s response, in its entirety, is included as
appendix 3 of this report.
Background
Title IV, Subtitle B, of the CARES Act, Air Carrier Worker Support,
requires Treasury to provide financial assistance to air carriers and
Audit of Air Carrier Worker Support Certifications – Ground Services
International, Inc. (OIG-23-028)
5
contractors that must exclusively be used for the continuation of
payments of employees’ wages, salaries, and benefits. Financial
assistance is to be provided to:
(1) passenger air carriers, in an aggregate amount up to
$25 billion;
(2) cargo air carriers, in an aggregate amount up to $4 billion;
and
(3) contractors, in an aggregate amount up to $3 billion.
According to the CARES Act, Treasury is required to provide
financial assistance to air carriers that report salaries and benefits
to the DOT (referred to as 241 carriers),15 in an amount equal to
the salaries and benefits reported to DOT for the period
April 1, 2019 through September 30, 2019. For air carriers that do
not report such data to DOT (referred to as non-241 air carriers),
and contractors, financial assistance is required to be in an amount
that the air carrier or contractor certifies using sworn financial
statements or other appropriate data as the amount of wages,
salaries, benefits, and other compensation paid to employees
during the period of April 1, 2019 through September 30, 2019.
The amounts submitted on the application to Treasury were
considered sworn financial statements. To be eligible for payments,
air carriers and contractors must enter into agreements with
Treasury certifying that they meet certain required assurances,
terms, and conditions.
On March 30, 2020, Treasury posted on its website the
Guidelines, which included the PSP1 Application. The PSP1
Application is comprised of eight sections:
1. Applicant Information ─ (1) applicant name; (2) taxpayer
identification number and address; and (3) contact person’s
name, title, phone number, and email address.
15 14 CFR, Part 241 “Uniform System of Accounts and Reports for Large Certificated Air Carriers”
defines “Air carrier, large certificated” as an air carrier holding a certificate issued under 49 U.S.C
41102, as amended, that: (1) operates aircraft designed to have a maximum passenger capacity of
more than 18,000 pounds; or (2) conducts operations where one or both terminals of a flight stage
are outside the 50 states of the United States, the District of Columbia, the Commonwealth of
Puerto Rico, and the U.S. Virgin Islands. These air carriers are required to report financial information
to DOT. GSI is not a Large Certificated Air Carrier.
Audit of Air Carrier Worker Support Certifications – Ground Services
International, Inc. (OIG-23-028)
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2. Applicant Type ─ selection of applicant type whether it is
passenger air carrier, cargo air carrier, or contractor.
Additionally, if the applicant is a contractor, this section would
identify the contractor’s service functions and the name of the
air carrier or airport to which services are provided. Finally, this
section includes affiliate and parent company information.
3. Financial Institution Information ─ (1) the applicant’s account
number and routing number; and (2) the financial institution’s
name, address, and telephone number.
4. Employment Levels ─ applicant’s average number of employees
for 2019 and involuntary reductions after March 1, 2020.
5. Awardable Amounts ─ applicant’s sworn financial statement
consisting of salaries, wages, benefits, and other compensation
for the period April 1, 2019 through September 30, 2019.
6. Taxpayer Protection ─ a table that outlines in detail the
proposed financial instrument to be issued to Treasury.
7. Additional Information ─ applicant’s verification of submitting its
Internal Revenue Service (IRS) Form 941 – Employer’s Quarterly
Federal Tax Return16 covering the period April 1, 2019 through
September 30, 2019 along with the PSP1 Application submitted
to Treasury.
8. Certification ─ names, titles, and signatures of two certifying
officials17 and the applicant name and application submission
date.
On April 18, 2020, Treasury published a sample PSP1 Agreement
on its website, which provided definitions, terms, and conditions
for participation in PSP1, and required applicants to submit
completed applications by April 27, 2020. After Treasury reviewed
and approved an application, both parties were required to sign the
PSP1 Agreement.
16 IRS Form 941 is a tax form that businesses file quarterly to report income taxes, Social Security
taxes, and Medicare taxes they withheld from employee paychecks.
17 The certifying officials attested under penalty of perjury that the information and certifications provided
in the application and it attachments are true and correct.
Audit of Air Carrier Worker Support Certifications – Ground Services
International, Inc. (OIG-23-028)
7
Treasury Disbursement Process
In an effort to disburse PSP1 payments to contractor applicants as
quickly as possible and prior to the application deadline of
April 27, 2020, Treasury applied an initial estimated pro rata rate
of 69.7 percent to the awardable amounts because not all
applications had been submitted at the time. After the application
deadline, Treasury determined the total amount requested by all
contractors was approximately $4.1 billion, which exceeded the
$3 billion available financial assistance. Because its initial estimated
pro rata rate was low, Treasury calculated an additional
20.3 percent, the top-off amount, for contractors making the final
pro rata rate 90 percent. Treasury explained that 17 contractors
did not accept the top-off amount; as such, the final awardable
amount for those contractors was 69.7 percent. Treasury
disbursed an initial lump sum payment of one-third of the
awardable amount, followed by four equal subsequent payments to
ensure it provided sufficient and timely financial assistance
corresponding to the applicants’ payroll schedule. In instances
where Treasury needed to perform additional follow-up with
contractors or needed additional time to approve applications,
Treasury compressed the payment schedule on a case by case
basis. Generally, Treasury disbursed the top-off amounts for
contractors in February 2021. Treasury officials told us that if
recoupment was necessary for an applicant’s inclusion of
unallowable expenses such as corporate officer compensation and
employer-side payroll taxes in the application, the recoupment
method was dependent on timing. If the need for recoupment was
known prior to the top-off distribution then the recoupment was
offset from the top-off payment. For recoupment amounts not
known until after the top-off payment, Treasury has not made a
decision how those funds will be collected and whether those
funds will be reallocated at a later date.
PSP1 Interim Audit Report
In a prior audit report,18 OIG identified two recurring issues
affecting the payment amounts administered to all PSP1 recipients
for non-241 air carriers and contractors. Specifically, employer-side
18 OIG-21-025, Interim Audit Update – Air Carrier and Contractor Certifications for Payroll Support
Program (Interim Audit), March 31, 2021.
Audit of Air Carrier Worker Support Certifications – Ground Services
International, Inc. (OIG-23-028)
8
payroll taxes and corporate officer compensation were included in
the awardable amounts for some recipients. Treasury management
acknowledged that the recipients audited included unallowable
employer-side payroll taxes or corporate officer compensation in
their calculation of the “awardable amounts” on their PSP1
applications and agreed to (1) review payments issued under PSP1
to ensure awarded amounts are allowable per the CARES Act and
Treasury guidance; and (2) remedy the incorrect amounts awarded
under PSP1.
Ground Services International, Inc.
GSI,19 a contractor, is headquartered in Orlando, Florida and
provides aircraft ground handling and cleaning services for many
international and domestic airlines at a number of airports across
the United States.
The GSI PSP1 Application was comprised of four United States-
based affiliate companies. These companies include 1) GSI, 2) ALX
Cargo Center IAH, LLC, 3) 121 Inflight Catering, LLC,20 and 4) 121
At BNA, LLC. GSI and ALX Cargo IAH, LLC are managed and
operated by the same management group referred to as GSI, while
121 Inflight Catering, LLC and 121 At BNA, LLC are operated by a
separate management group referred to as Inflight Catering.
Initially, GSI, ALX Cargo, and Inflight Catering submitted separate
PSP1 applications to Treasury; however, those applications were
later merged under GSI.21 The GSI portion of the application was
reduced by
prior to the certification of the merged
applications. Table 1 illustrates a breakdown of the initial
applications submitted to Treasury.
19 GSI conducts business under the name dNata.
20 121 Inflight Catering, LLC changed its legal name to dNata US Inflight Catering, LLC on
February 20, 2019.
21 Inflight Catering’s initial application included merged amounts for 121 Inflight Catering, LLC and 121
At BNA, LLC. Although Inflight Catering prepared its portion of the PSP1 Application separately from
GSI, GSI assumed responsibility of the entire application by certifying the merged PSP1 Application’s
awardable amount to Treasury.
Audit of Air Carrier Worker Support Certifications – Ground Services
International, Inc. (OIG-23-028)
9
Table 1: PSP1 Application Requests
Company
Initial PSP1
Application
Revisions Prior to
Merged
Certification
Final Merged
Application
GSI
ALX Cargo
Inflight
Catering
TOTAL
Source: Initial PSP1 Applications submitted to Treasury
GSI submitted its PSP1 Application on April 3, 2020. After the
application merger with its affiliates, the revised PSP1 Application
totaled
. However, prior to Treasury’s final top-off
disbursement in February 2021, GSI self-reported to Treasury that
the amount requested on the PSP1 Application contained
unallowable corporate officer compensation totaling
,
effectively reducing the merged application amount
to
. GSI received the contractor top-off for a total
award of $61,029,852, or 90 percent of the company’s requested
amount. Treasury’s disbursements to GSI were as follows:
• July 13, 2020 - $24,025,181.56
• August 03, 2020 - $12,020,793.44
• September 4, 2020 - $12,015,324.00
• February 16, 2021 - $12,968,552.86
In addition to PSP1, Treasury awarded GSI $15,324,430 under
PSP2 and $15,324,430 under PSP3. These amounts do not include
financial assistance awarded to Inflight Catering, as Treasury
separated the GSI and Inflight Catering applications for PSP2 and
PSP3. Treasury awarded Inflight Catering $5,025,490 under
PSP2 and $5,025,490 under PSP3. PSP2 and PSP3 were not the
subject of this audit.
Audit of Air Carrier Worker Support Certifications – Ground Services
International, Inc. (OIG-23-028)
10
Audit Results
We found that GSI reported correct information for three of the
four sections reviewed on its PSP1 Application. These sections are:
(1) Applicant Information, (2) Applicant Type, and
(3) Certification.22 We compared information provided in each
section of the PSP1 Application to supporting documentation
including contracts with air carriers, airport permits, general ledger
data, company sworn financial statements, IRS Form 941,
executive-level business charts, payroll registers, and third-party
benefit invoices.
We also found that GSI reported incorrect information in the
Awardable Amounts section, attributable to both GSI and Inflight
Catering’s portions of the merged application. In aggregate,
the $1,113,810 understatement by GSI’s portion and $852,011
overstatement of Inflight Catering’s portion of the merged PSP1
Application resulted in a net understatement of $261,799. As a
result, GSI did not receive an overpayment of PSP1 financial
assistance.
GSI and ALX Cargo
GSI and ALX Cargo (collectively referred to as GSI), included
(1) unallowable corporate officer compensation, resulting in an
overstatement of
, and (2) differences between the PSP1
Application amounts and the actual amounts paid to company
employees for salaries, wages, and benefits, resulting in an
overstatement of
. However, the overstatement was
partially offset by the company’s exclusion of eligible gross pay
from the awardable amount of
, resulting in a net
overstatement of
.
On February 5, 2021, after the submission of the merged PSP1
Application, GSI self-reported to Treasury that unallowable
corporate officer compensation of
was included in the
22 As GSI took ownership of the PSP1 Application, it only used GSI information for the Applicant
Information, Applicant Type, and Certification sections of the application.
Audit of Air Carrier Worker Support Certifications – Ground Services
International, Inc. (OIG-23-028)
11
awardable amount on the PSP1 Application.23 In aggregate, GSI
reported an understatement of $1,113,810 for its portion of
salaries, wages, and benefits, as described in Table 2 below.
Table 2. Aggregate Understatement
Description
Amount
Compensation Paid to Corporate Officers
Voluntary Deductions not Requested
Data Discrepancies
Self-Reported Corporate Officer Inclusion
TOTAL - Aggregate Understatement
$1,113,810
Source: S&R Calculation of Awardable Amounts
121 Inflight Catering and 121 At BNA
121 Inflight Catering and 121 At BNA (collectively referred to as
Inflight Catering), included (1) unallowable corporate officer
compensation, resulting in an
overstatement, and
(2) data discrepancies related to benefits, resulting in a
overstatement. Table 3 illustrates a monthly breakdown of Inflight
Catering’s overstated amounts.
23 GSI discovered the unallowable compensation during an internal company audit prior to applying for
PSP2, and Treasury reduced GSI’s final top-off payment under PSP1. GSI derived the self-reported
amount from weekly estimates, not actual amounts paid.
Audit of Air Carrier Worker Support Certifications – Ground Services
International, Inc. (OIG-23-028)
12
Table 3. Inflight Catering Overstatement
Month
PSP1 Application
S&R Re-
calculated
Amount
Total
Overstatement
April 2019
May 2019
June 2019
July 2019
August 2019
September
2019
Total
$(852,011)
Source: S&R Calculation of Awardable Amounts
Finding 1
GSI Did Not Receive an Overpayment of PSP1 Financial
Assistance Despite Partial Non-Compliance with
Application Requirements
Ground Services International, Inc.
Corporate Officer Compensation
Both the CARES Act and Treasury’s Guidelines define “employee”
as “an individual, other than a corporate officer, who is employed
by an air carrier or contractor in the United States (including its
territories and possessions).” In addition, the signed PSP1
Agreement, effective July 10, 2020, subsequently defines a
corporate officer as, “with respect to the Recipient, its president;
any vice president in charge of a principal business unit, division, or
function (such as sales, administration or finance); any other officer
who performs a policy-making function; or any other person who
performs similar policy making functions for the Recipient.
Executive officers of subsidiaries or parents of the Recipient may
be deemed Corporate Officers of the Recipient if they perform such
policy-making functions for the Recipient.”
We identified fifteen GSI executives through discussions with
management and review of GSI’s 2019 organizational chart. Six of
Audit of Air Carrier Worker Support Certifications – Ground Services
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those executives met the definition of a corporate officer per the
PSP1 Agreement. GSI included unallowable corporate officer
compensation, resulting in an overstatement of
. The
company included
paid to six corporate officers in its
initial application, but reduced it by
, to account for
estimated corporate officer compensation, prior to the certification
of the merged applications. The six executives were the Chief
Executive Officer, Chief Financial Officer, Senior Vice President of
Safety and Training, Executive Vice President of Central Region,
Senior Vice President of Cargo, and head Legal Counsel. Table 4
illustrates GSI’s inclusion of corporate officer compensation.
Table 4. Corporate Officer Inclusion
Category
Overstatement
Compensation Paid to Corporate Officers
Less: Initial Application Officer Reduction
Total Overstatement
Source: S&R Calculation of Awardable Amounts
GSI management stated that the definition of a corporate officer
was initially unclear and that the term was not defined in the
application guidance procedures. Management stated that it had
reduced the initial application by
in a “good faith”
attempt to estimate corporate officer compensation, but this
amount was not the actual amounts paid to the company officers.
Application Compilation Assumptions for the Awardable Amounts
Treasury’s Guidelines define wages, salaries, benefits, and other
compensation as “remuneration paid by the applicant to its
employees for personal services and includes salaries, wages,
overtime pay, cost-of-living differentials, and other similar
compensation, as distinguished from per diem allowances or
reimbursement for expenses incurred by personnel for the benefit
of the applicant.” In addition, the Guidelines defines the Awardable
Amounts as “an amount that such contractor certifies, using sworn
financial statements or other appropriate data, as the amount of
wages, salaries, benefits, and other compensation that such
contractor paid its employees during the time period.”
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GSI made several assumptions in the application process that
ultimately reduced the overall awardable amount. These
assumptions led to (1) an overstatement of
due to
differences between tax filings, payroll register data, benefit
invoices general ledger data used to prepare the Awardable
Amounts table, and (2) an understatement of
due to
reducing the awardable amount by the employee portion of
voluntary withholdings.
Compensation Differences
We found differences between the PSP1 Application amounts and
the actual amounts paid to company employees for salaries,
wages, benefits, and other compensation, resulting in a
overstatement. Table 5 illustrates the amount and description of
each difference.
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Table 5. Compensation Differences Due to Data Discrepancies
Category
Amount
Description
Salaries and
Wages
Compensation per company payroll register
data exceeded the amounts reported on the
“Wages, tips and other compensation” line
on the Quarter 2 2019 IRS Form 941 by
and Quarter 3 2019 Form 941 by
which were used to prepare the
PSP1 Application. However, the total
amount requested on the PSP1 Application
exceeded the cumulative amount of the
Quarter 2 and Quarter 3 Form 941 by
.
Benefits
The “Benefits” amount requested on the
PSP1 Application, which was generated
from the company financial accounting
system for medical benefit premiums,
exceeded the amount supported by third
party benefit invoices from April 1, 2019
through September 30, 2019.
Other
Compensation
The “Other Compensation” amount
requested on the PSP1 Application, which
represents the company portion for 401(k)
matching payments and is derived from the
company financial accounting system,
exceeded the amount supported on company
payroll register data from April 1, 2019
through September 30, 2019.
TOTAL
Net Overstatement
Source: S&R Calculation of Awardable Amounts
GSI management stated that the discrepancies for salaries and
wages were due to unintentional oversight or differences between
payroll register data and quarterly IRS Form 941 tax filings used to
prepare the PSP1 Application. In addition, management stated that
it prepared the PSP1 Application using accrual-based data from its
financial accounting system for benefits and other compensation
because the information was readily available and served as a
rational basis for its financial assistance request.
Employee Voluntary Deductions
GSI reduced the “Salaries and Wages” amount on the PSP1
Application by
. This amount represents voluntary
Audit of Air Carrier Worker Support Certifications – Ground Services
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deductions24 from gross pay that were withheld from employees’
paychecks and are eligible for PSP1 financial assistance, but not
claimed on the PSP1 Application. Specifically, we found that GSI
omitted eligible compensation related to employees’ contribution to
their individual 401K retirement plans totaling
, and
employees’ portion of vision benefit premiums25 totaling
.
Table 6 illustrates a monthly breakdown of the understated
amounts.
Table 6. Voluntary Deductions Not Requested
Month
401K Employee
Withholding Amount
Employee Vision
Premiums
Total
Understatement
April 2019
May 2019
June 2019
July 2019
August 2019
September 2019
Understatement
Source: S&R Calculation of Awardable Amounts
GSI management stated since it used the quarterly IRS Form 941
tax returns as a basis for its portion of the PSP1 Application,
non-taxable compensation categories were excluded from the
awardable amount.
In total for GSI, the net overstatement reported on its portion of
the merged PSP1 Application was
, stemming from
the
overstatement of unallowable corporate officer
compensation,
overstatement for compensation
differences, and
understatement from voluntary
employee deductions.
24 Employees may choose to have more money taken out of their paycheck to cover the cost of
various benefits. These are known as voluntary payroll deductions and they can be withheld on
a pretax basis (if allowed under Section 125 of the Internal Revenue Code) or post-tax basis.
25 GSI did not request financial assistance for Vision benefits.
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However, on February 5, 2021, subsequent to the merged PSP1
Application submission to Treasury, GSI self-reported
for non-compliance with PSP1 requirements related to the inclusion
of corporate officer compensation in its portion of the combined
Awardable Amounts. This amount was derived from weekly
personnel compensation averages from the financial accounting
system, not actual amounts paid,
, between
April 1, 2019 and September 30, 2019. The amount self-reported
exceeded the amount paid to corporate officers by
.
Treasury deducted the self-reported amount of
from
GSI’s final top-off payment on February 16, 2021. Overall, the self-
reported amount offsets GSI’s PSP1 overstatement of
and results in an aggregate understatement of $1,113,810 for its
portion of the PSP1 Application.
Inflight Catering
Corporate Officer Compensation
Both the CARES Act and Treasury’s Guidelines define “employee”
as “an individual, other than a corporate officer, who is employed
by an air carrier or contractor.” In addition, the signed PSP1
Agreement, subsequently defines a corporate officer as, “with
respect to the Recipient, its president; any vice president in charge
of a principal business unit, division, or function (such as sales,
administration or finance); any other officer who performs a policy-
making function; or any other person who performs similar policy
making functions for the Recipient. Executive officers of
subsidiaries or parents of the Recipient may be deemed Corporate
Officers of the Recipient if they perform such policy-making
functions for the Recipient.”
We identified eleven Inflight Catering executives through
discussions with management and review of Inflight Catering’s
2019 organizational chart. Nine of those executives met the
definition of a corporate officer per the PSP1 Agreement. Inflight
Catering included unallowable compensation of
paid to
all nine executives. These executives were the Chief Executive
Officer, Chief Marketing Officer, Chief of Compliance and
Regulatory Officer, Vice President of Operations, Commercial Vice
President, Culinary Vice President, VIP Vice President, Vice
President of Finance, and Vice President of Human Resources.
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Table 7 illustrates a monthly breakdown of Inflight Catering’s
overstated awardable amounts for corporate officer compensation.
Table 7. Corporate Officer Inclusion
Month
Unallowable Corporate Officer
Compensation in the PSP1 Application
April 2019
May 2019
June 2019
July 2019
August 2019
September 2019
TOTAL
OVERSTATEMENT
Source: S&R Calculation of Awardable Amounts
Inflight Catering Management stated that the definition of a
corporate officer was unclear and that the term was not defined in
the application guidance procedures. Further, management stated
that they did not always consider individuals with a title of “Vice
President” as a corporate officer. Management stated that some of
its employees were given honorific titles, but those individuals
were not policy makers nor did they have authority over any
business units.
Data Discrepancies
Treasury’s Guidelines defines wages, salaries, benefits, and other
compensation as “remuneration paid by the applicant to its
employees for personal services and includes salaries, wages,
overtime pay, cost-of-living differentials, and other similar
compensation, as distinguished from per diem allowances or
reimbursement for expenses incurred by personnel for the benefit
of the applicant.” In addition, the Guidelines defines the Awardable
Amounts as “an amount that such contractor certifies, using sworn
financial statements or other appropriate data, as the amount of
Audit of Air Carrier Worker Support Certifications – Ground Services
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wages, salaries, benefits, and other compensation that such
contractor paid its employees during the time period.”
Inflight Catering’s financial assistance request for benefits included
several data discrepancies that overstated the awardable amount.
Specifically, we found that the amounts requested on the PSP1
Application, which were derived from the company financial
accounting system, exceeded the actual benefit compensation paid
on behalf of company employees between April 1, 2019 and
September 30, 2019 by
, as described in Table 8 below.
These differences stemmed from (1) data discrepancies for Life
Insurance, Other Company Benefits, Transportation Benefits,
Workers Compensation, and 401K employer matching payments,
(2) excluding current period invoice adjustments for Medical
Insurance, and (3) unsupported Flex Savings Plan and Consolidated
Omnibus Budget Reconciliation Act26 medical administration fees.
Table 8. PSP1 Application Request Differences
Benefit Category
Benefits Per
Application
S&R Re-
calculated
Amount
Difference
Medical Insurance
Life Insurance
Other Company Benefits
Transportation Benefits
Workers Compensation
Flex Savings
Administration Fee
Consolidated Omnibus
Budget Reconciliation
Act Medical
Administration Fee
401K Employer Match
TOTAL
OVERSTATEMENT
Source: S&R Calculation of Awardable Amounts
Inflight Catering management stated that data discrepancies in the
application process were due to unintentional oversight. In addition,
26 P.L. 99-272 (April 7, 1986).
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management stated that it prepared the PSP1 Application using
accrual-based data from its financial accounting system for benefits
because the information was readily available. Specific to workers
compensation premiums, management stated that they believe the
amount requested at the time of the application was correct,
however, the final amounts paid were subsequently adjusted based
on final billings.
In total for Inflight Catering, the net overstatement reported on its
portion of the merged PSP1 Application was $852,011, stemming
from the
overstatement of unallowable corporate officer
compensation, and
overstatement from data
discrepancies.
Although GSI and Inflight Catering each included corporate officer
compensation and inaccurate data in their portions of the merged
PSP1 Application, ultimately the actual eligible compensation
amounts exceeded requested amounts. As such, GSI did not
receive an overpayment of PSP1 financial assistance, as illustrated
in Table 9 below.
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Table 9. Aggregate Understatement
Description
Amount
GSI
Compensation Paid to Corporate Officers
Voluntary Deductions not Requested
Data Discrepancies
Self-Reported Corporate Officer Inclusion
GSI Total - Understatement
$1,113,810
Inflight Catering
Compensation Paid to Corporate Officers
Data Discrepancies
Inflight Catering Total - Overstatement
$(852,011)
Merged
TOTAL - Aggregate Understatement
$261,799
Source: S&R Calculation of Awardable Amounts.
To remedy the findings listed in the prior OIG audit report,27
Treasury required PSP2 applicants to re-certify their PSP1
awardable amounts. Although the GSI and Inflight Catering
applications were merged for PSP1, they applied separately for
PSP2 and PSP3. GSI properly certified to Treasury under PSP2,
that its portion of the PSP1 Application did include corporate
officer compensation. However, Inflight Catering certified to
Treasury under PSP2, that its portion of the PSP1 Application did
not include corporate officer compensation. Treasury stated it relies
on applicants’ certifications that they did not include unallowable
expenses (i.e. corporate officer compensation and employer-side
payroll taxes) and no further validation checks were performed.
Due to instances of non-compliance in both GSI and Inflight
Catering’s portions of the PSP1 awardable amounts, both
27 OIG-21-025, Interim Audit Update – Air Carrier and Contractor Certifications for Payroll Support
Program (Interim Audit), March 31, 2021.
Audit of Air Carrier Worker Support Certifications – Ground Services
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companies may have potentially included unallowable expenses in
their PSP2 and PSP3 financial assistance requests.
Recommendation
S&R recommends that Treasury’s Chief Recovery Officer:
1. Review GSI and Inflight Catering’s requested amounts for
unallowable expenses, under PSP2 and PSP3, and seek
reimbursement for the overpayment, if applicable.
Management Response
Treasury will review awardable amounts requested under PSP2
and PSP3 and seek recoupment where appropriate.
S&R Comment
Management’s planned corrective actions meet the intent of our
recommendation. Treasury management will need to record an
estimated completion date for these actions in JAMES.
* * * * * *
We appreciate the courtesies and cooperation provided to our staff
during the audit. A distribution list for this report is provided as
appendix 4.
Appendices
Saggar & Rosenberg, P.C. /s/
Audit of Air Carrier Worker Support Certifications – Ground Services
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Appendix 1: Objective, Scope, and Methodology
Our objective was to assess the accuracy, completeness, and
sufficiency of Ground Services International, Inc.’s (GSI) sworn
financial statements or other data used to certify the wages,
salaries, benefits, and other compensation amounts submitted and
approved by the Department of the Treasury (Treasury).
The scope of our audit covered the time period from April 1, 2019
through September 30, 2019 and included the certified Payroll
Support Program (PSP1) Application, sworn financial statements,
tax returns, and other documentation submitted to Treasury on
April 3, 2020.28
To accomplish this objective, Saggar & Rosenberg, P.C. (S&R)
performed the following activities during audit fieldwork conducted
remotely, due to the Coronavirus Disease 2019 (COVID-19)
pandemic from September 2021 through April 2022:
•
Reviewed applicable Federal laws, regulations, and guidance,
including:
o Title IV, Subtitle B, Air Carrier Worker Support, of the
Coronavirus Aid, Relief, and Economic Security Act
(CARES Act);29 and
o 14 CFR, Part 241,30 Uniform System of Accounts and
Reports for Large Certificated Air Carriers,
August 12, 2022.
28 GSI submitted its PSP1 Application and related supporting documentation on April 3, 2020. GSI’s
application was later merged with three company affiliates: (1) ALX Cargo Center IAH, LLC (2) 121
Inflight Catering, LLC and (3) 121 At BNA, LLC. GSI and ALX Cargo Center IAH, LLC are managed
and operated by the same management group (referred to as GSI), while 121 Inflight Catering, LLC
and 121 At BNA, LLC are operated by a separate management group (referred to as Inflight
Catering).
29 P.L. 116-136 (March 27, 2020).
30 14 CFR, Part 241 “Uniform System of Accounts and Reports for Large Certificated Air Carriers”
defines “Air carrier, large certificated” as an air carrier holding a certificate issued under 49 U.S.C
41102, as amended, that: (1) operates aircraft designed to have a maximum passenger capacity of
more than 18,000 pounds; or (2) conducts operations where one or both terminals of a flight stage
are outside the 50 states of the United States, the District of Columbia, the Commonwealth of
Puerto Rico, and the U.S. Virgin Islands. These air carriers are required to report financial information
to the Department of Transportation. GSI is not a Large Certified Air Carrier.
Appendix 1: Objective, Scope, and Methodology
Audit of Air Carrier Worker Support Certifications – Ground Services
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•
Reviewed Treasury’s policies, procedures, and guidance related
to PSP1:
o Guidelines and Application Procedures for Payroll Support
to Air Carriers and Contractors (Guidelines), which
included the PSP1 Application, March 30, 2020;
o PSP1 Agreement;
o Question and Answer: Payroll Support to Air Carriers and
Contractors, (April 2, 2020, April 3, 2020 and
April 20, 2020 versions); and
o Frequently Asked Questions: Application Procedures for
Payroll Support to Air Carriers and Contractors,
April 3, 2020.
•
Performed 100 percent testing for four of the eight sections of
the PSP1 Application; specifically, the Applicant Information,
Applicant Type, Awardable Amounts, and Certification sections.
The other four sections were not reviewed because the
Taxpayer Protection section generally applied to 241 air
carriers, with exceptions; the Employment Levels, Financial
Institution Information, and Additional Information sections had
no impact on Treasury’s determination of recipients’ award
amounts.
•
Interviewed key Treasury personnel and contracted consultant
personnel engaged by Treasury to aid in its evaluation of the air
carriers’ and the contractors’ certified applications and other
data.
•
Interviewed GSI and Inflight Catering representatives
responsible for the completion and submission of the sworn
financial statements in the Awardable Amounts section of the
PSP1 Application.31
•
Reviewed sworn financial statements and documents to support
the requested payroll support amount. The documentation
included general ledger data, company payroll registers, benefit
invoices, organizational hierarchy, Internal Revenue Service
31 Although Inflight Catering prepared its portion of the PSP1 application separately from GSI, GSI
assumed responsibility of the entire PSP1 Application by certifying the merged PSP1 Application
totals to Treasury.
Appendix 1: Objective, Scope, and Methodology
Audit of Air Carrier Worker Support Certifications – Ground Services
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(IRS) Form 941 – Employer’s Quarterly Federal Tax Return,32
and 2019 IRS Form 851 – Affiliation Schedule.33
•
Reviewed Government Accountability Office’s (GAO) Standards
for Internal Control in the Federal Government34 to identify the
components of internal control that are significant to the audit
objective. Understanding internal control within the context of
an entity’s internal control framework can help auditors
determine whether internal control deficiencies exist. We
concluded that one of the five internal control components,
Control Activities, as related to GSI and Inflight Catering payroll
systems, was significant to the audit objective.35 This
component states that control activities are the actions
management establishes through policies and procedures to
achieve objectives and respond to risks in the internal control
system, which includes the entity’s information system. To
assess the controls over GSI and Inflight Catering’s payroll
systems, we examined GSI and Inflight Catering response to
Data Supplier Questionnaires,36 reviewed two System and
Organizational Controls 1 (SOC 1),37 and interviewed GSI and
Inflight Catering management responsible for generating and
using the data. Additional details regarding our assessment of
the reliability of the data is reported in the sections below.
•
Reviewed GAO’s Assessing Data Reliability38 guidance, which
states that a data reliability determination does not involve
attesting to the overall reliability of the data or database. For
this audit, the audit team has only determined the reliability of
the specific data sources needed to support the findings,
32 IRS Form 941 is a tax form that businesses file quarterly to report income taxes, Social Security
taxes, and Medicare taxes they withheld from employee paychecks.
33 IRS Form 851 is a tax form that a parent corporation of an affiliated group files with its consolidated
income tax return to (1) identify the common parent corporation and each member of the affiliated
group; (2) report the amount of overpayment credits, estimated tax payments, and tax deposits
attributable to each corporation; and (3) determine that each subsidiary corporation qualifies as a
member of the affiliated group.
34 GAO-14-704G (September 2014).
35 The five components of internal control are Control Environment, Risk Assessment, Control
Activities, Information and Communication, and Monitoring.
36 A Data Reliability Assessment is completed to assess the reliability of data originating from a system
to determine if it is reliable for the purposes of the audit. The Data Supplier Questionnaire would be
one of the tools used during the Data Reliability Assessment.
37 SOC 1 reports address a company’s internal control over financial reporting, which pertains to the
application of checks-and-limits. Essentially, it is the audit of a third-party vendor’s accounting and
financial controls.
38 GAO-20-283G (December 2019).
Appendix 1: Objective, Scope, and Methodology
Audit of Air Carrier Worker Support Certifications – Ground Services
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conclusions, or recommendations in the context of the audit
objective.
Ground Services International, Inc.
GSI prepared its portion of the PSP1 Application using “Wages,
tips, and other compensation” amounts from the IRS Form 941
from April 2019 through September 2019, which included
information developed from the company payroll system for
Salaries and Wages and information from the company financial
accounting system for Benefits and Other Compensation. S&R
compared payroll details generated from payroll registers at the
individual employee level, as well as third-party vendor benefit
invoices from April 1, 2019 through September 30, 2019 to
GSI’s portion of the amounts presented in the Awardable
Amounts section of the PSP1 Application.
To assess data reliability of these sources, we examined GSI’s
response to the Data Supplier Questionnaires for the payroll and
financial accounting systems, reviewed the SOC 1 for the
payroll system, and interviewed GSI management responsible
for generating and using the data. Based on our assessment, we
determined that the data was sufficiently reliable to support the
findings and conclusions to answer the objective of this audit.
Inflight Catering
Inflight Catering prepared its portion of the PSP1 Application
using information from the company payroll system for Salaries
and Wages, and information from the company financial
accounting system for Benefits and Other Compensation. S&R
compared payroll details generated from payroll registers at the
individual employee level, as well as third-party vendor benefit
invoices from April 1, 2019 through September 30, 2019 to
Inflight Catering’s portion of the amounts presented in the
Awardable Amounts section of the PSP1 Application.
To assess data reliability of these sources, we examined Inflight
Catering’s response to Data Supplier Questionnaires for the
payroll and accounting systems, reviewed the payroll system
SOC 1, and interviewed Inflight Catering management
responsible for generating and using the data. Based on our
assessment, we determined that the data was sufficiently
reliable to support the findings and conclusions to answer the
objective of this audit.
Appendix 1: Objective, Scope, and Methodology
Audit of Air Carrier Worker Support Certifications – Ground Services
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We conducted this performance audit in accordance with generally
accepted government auditing standards. Those standards require
that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and
conclusions based on our audit objective. We believe that the
evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objective.
Audit of Air Carrier Worker Support Certifications – Ground Services
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Appendix 2: GSI Management Response
Response from Ground Services International Management
Audit of Air Carrier Worker Support Certifications – Ground Services
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Audit of Air Carrier Worker Support Certifications – Ground Services
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Audit of Air Carrier Worker Support Certifications – Ground Services
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Response from Inflight Catering Management
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Appendix 3: Treasury Management Response
Audit of Air Carrier Worker Support Certifications – Ground Services
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Audit of Air Carrier Worker Support Certifications – Ground Services
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Audit of Air Carrier Worker Support Certifications – Ground Services
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Appendix 4: Report Distribution
Department of the Treasury
Treasury Secretary
Deputy Secretary
Treasury Audit Liaison
Office of Strategic Planning and Performance Management
Office of the Deputy Chief Financial Officer, Risk and Control
Group
Ground Services International, Inc.
Chief Financial Officer
Legal Counsel
Inflight Catering, LLC.
Chief Executive Officer
Chief of Compliance and Regulatory
Office of Management and Budget
OIG Budget Examiner
United States Senate
Committee on Homeland Security and Governmental Affairs
Committee on Finance
Committee on Banking, Housing, and Urban Affairs
Committee on Commerce, Science, and Transportation
Committee on Appropriations
Committee on the Budget
United States House of Representatives
Committee on Oversight and Reform
Committee on Financial Services
Committee on the Budget
Committee on Transportation and Infrastructure
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