FAA Has Improved Its Oversight of COVID-19 Relief Funds Despite Implementation Inconsistencies (March 12, 2025)
Summary
U.S. Department of Transportation Office of Inspector General report AV2025025, dated March 12, 2025, "FAA Has Improved Its Oversight of COVID-19 Relief Funds Despite Implementation Inconsistencies," from Nelda Smith, Assistant Inspector General for Aviation Audits. It states that the CRRSA Act and ARPA awarded $10 billion in economic relief to eligible U.S. airports and concessions, and that by the end of December 2023 FAA had expended more than $8.5 billion. It states that FAA's revised policies significantly reduced unsupported and questioned costs and improper payments, and that FAA inconsistently implemented the rent relief programs. The report makes no new recommendations.
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Cite this document
“FAA Has Improved Its Oversight of COVID-19 Relief Funds Despite Implementation Inconsistencies (March 12, 2025).”
Original at www.oig.dot.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/dot-oig-faa-has-improved-its-oversight-of-covid-19-relief-funds-despit-2196918a8c/
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FAA Report AV2025025
March 12, 2025
FAA Has Improved Its Oversight of COVID-19 Relief Funds
Despite Implementation Inconsistencies
U.s. Department of Transportation
Office of Inspector General
Highlights
Federal Aviation Administration (FAA)
AV2025025| March 12, 2025
FAA Has Improved Its Oversight of COVID-19 Relief Funds Despite
Implementation Inconsistencies
Self-Initiated
Our Objective(s) What We Found
To assess FAA’s oversight of FAA’s revised policies have resulted in greater adherence to reimbursement
airport sponsors’ compliance requirements.
with the Coronavirus Response
• Our previous review of FAA’s oversight of the COVID-19 relief grant funds
and Relief Supplemental
determined that the Agency’s oversight process regarding supporting
Appropriations (CRRSA) Act and
documentation impacted its ability to monitor program performance.
the American Rescue Plan Act
During that review, we identified $271 million in unsupported costs,
(ARPA) rent relief and economic
$85 million in questioned costs, and $3 million in improper payments.
relief reimbursement eligibility
• We recommended that FAA assess the risk of improper payments for
requirements.
different types of Coronavirus Aid, Relief, and Economic Security Act
(CARES Act) reimbursement requests and revise its policy on supporting
documentation requirements to account for risk level. In response, FAA
revised its COVID grant programs guidance, effective March 27, 2023.
Why This Audit? • With these changes, FAA significantly reduced unsupported and
questioned costs, as well as improper payments.
The CRRSA Act and ARPA
awarded $10 billion in FAA inconsistently implemented the CRRSA Act and ARPA rent relief
economic relief to eligible programs.
U.S. airports and concessions at • To receive rent relief funds, FAA required airport sponsors to complete a
those airports to prevent, Concession Plan. We found that FAA approved 76 percent of Concession
prepare for, and respond to the Plans for the Airport Coronavirus Response Grant Program (ACRGP) and
COVID-19 pandemic. By the end 70 Percent of Concession Plans for the Airport Rescue Grants Program
of December 2023, FAA had (ARGP).
expended more than
• Our review of 60 plans identified some inconsistencies in the program’s
$8.5 billion in concession rent
implementation and an error in FAA’s review, including a nonprofit
relief and economic relief
business receiving rent relief, inconsistent application of airport lounges’
grants. We previously identified
eligibility as concessions, and airport sponsors inconsistently populating
weaknesses in FAA’s policies and
data fields for Concession Plans. Despite these inconsistencies we did not
procedures for monitoring
identify any significant improper rent economic relief payments in our
COVID-19 relief funds. Because
review sample.
of those weaknesses, we
0
initiated this audit.
Recommendations FAA has reduced
unsupported and questioned costs and improper
payments for ACRGP and ARGP, so we are not
making new recommendations. (p. 12)
www.oig.dot.gov | Contact the Office of Government and Public Affairs at (202) 366-8751
Contents
Memorandum 1
Background 3
FAA’s Revised Policies Have Resulted in Greater Adherence to
Reimbursement Requirements 6
FAA Inconsistently Implemented the CRRSA Act and ARPA Rent Relief
Programs 7
Conclusion 12
Recommendations 12
Agency Comments and OIG Response 13
Actions Required 13
Exhibit A. Scope and Methodology 14
Exhibit B. Organizations Visited or Contacted 16
Exhibit C. List of Acronyms 17
Exhibit D. Major Contributors to This Report 18
AV2025025
U.S. Department of Transportation
Office of Inspector General
Memorandum
Date: March 12, 2025
Subject: INFORMATION: FAA Has Improved Its Oversight of COVID-19 Relief Funds
Despite Implementation Inconsistencies | Report No. AV2025025
From: Nelda Smith
Assistant Inspector General for Aviation Audits
To: Federal Aviation Administrator
The Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act 1
and the American Rescue Plan Act (ARPA) 2 awarded $10 billion in economic relief
to eligible U.S. airports and concessions at those airports to prevent, prepare for,
and respond to the COVID-19 pandemic. To distribute these funds, the Federal
Aviation Administration (FAA) established the (1) Airport Coronavirus Response
Grant Program (ACRGP) for the CRRSA Act and the (2) Airport Rescue Grants
Program (ARGP) for ARPA. Between January 2021 and December 2023, FAA
issued more than 630 airport concession relief grants and more than
4,100 economic relief grants. As of December 2023, FAA had expended more
than $8.5 billion in concession rent relief and economic relief grants to airports
for such purposes as capital expenditures, operating expenses (including payroll
and utilities), debt payments, and concession rent relief.
In a prior audit 3 of FAA’s award and oversight of funds appropriated by the
Coronavirus Aid, Relief, and Economic Security (CARES) Act, 4 we identified
weaknesses in FAA’s policies and procedures for monitoring the relief funds that
we determined contributed to more than $350 million in questioned or
unsupported costs and $3 million in improper payments. Because of those issues
and the importance of promoting effective stewardship of the significant funds
allocated to FAA through the CRRSA Act and ARPA, we initiated this audit to
1 Public Law Number (Pub. L. No.) 116-260 (2020).
2 Pub. L. No. 117-2 (2021).
3 FAA Quickly Awarded CARES Act Funds but Can Enhance Its Oversight Approach To Promote Effective Stewardship
(Office of Inspector General (OIG) Report No. AV2022032), July 18, 2022. OIG reports are available on our website at
https://www.oig.dot.gov.
4 The CARES Act (Pub. L. No. 116-136 (2020)) was the first relief act that Congress passed to provide economic relief in
response to the COVID-19 pandemic.
AV2025025 1
assess FAA’s oversight of airport sponsors’ compliance with CRRSA Act and ARPA
rent relief and economic relief reimbursement eligibility requirements.
Specifically, we looked at the Agency’s policies and procedures to oversee rent
relief and economic relief and if it consistently implemented the rent relief and
economic relief programs. We conducted this audit in accordance with generally
accepted Government auditing standards. Exhibit A details our scope and
methodology. Exhibit B lists the organizations we visited or contacted, and
exhibit C lists the acronyms used in this report.
We appreciate the courtesies and cooperation of Department of Transportation
representatives during this audit. If you have any questions concerning this
report, please contact me or Marshall Jackson, Program Director.
cc: The Secretary
DOT Audit Liaison, M-1
FAA Audit Liaison, AAE-100
AV2025025 2
Background
Enacted in December 2020 and March 2021, the CRRSA Act and ARPA—the
second and third COVID-19 relief acts—collectively provided $10 billion in
funding for immediate disbursement to more than 3,000 airports of various sizes
across the country to prevent, prepare for, and respond to the COVID-19
pandemic. Funds provided within the CRRSA Act and ARPA were allocated to
primary commercial service airports; eligible airport concessions within these
airports; 5 and nonprimary commercial service, general aviation, and cargo
airports. 6 Primary commercial service airports with more than 10,000 annual
passenger boardings received funds under both relief acts. In addition, the acts
provided concessions within these airports funds to relieve rent and minimum
annual guarantees (MAGs) as identified in the contract between the airport
sponsor and the concessionaire. 7 One condition for approving such a grant was
that airport sponsors were required to distribute the relief to each concession
based on its proportional share of the airport’s total rent and MAGs of those
eligible concessions at that airport. Nonprimary commercial service and general
aviation airports were allocated funds based on airport categories, such as
National, Regional, Local, and Basic. 8 See figure 1 for a detailed illustration of the
funding breakdown between the two relief acts.
5 Federal regulation broadly defines a concession as one or more types of for-profit businesses that serve the
traveling public. These businesses include those (1) located at the airport and engaged in the sale of consumer goods
or services to the traveling public under an agreement with the recipient, another concessionaire, or the owner or
lessee of a terminal, if other than the recipient, or (2) conducting a covered activity, such as electronic advertising,
which takes place on an airport. See Title 49 Code of Federal Regulations (C.F.R.) Part 23 for additional details.
6 Under the CRRSA Act, nonprimary commercial service and general aviation airports shared $45 million based on
their airport categories. Of that amount, sponsors of nonprimary airports participating in the FAA Contract Tower
Program will equally divide not less than $5 million.
7 A MAG is usually based on some percentage of the airport concession’s prior year’s revenue and is intended to
provide the airport sponsor with a revenue floor from these concession contracts.
8 The National Plan of Integrated Airport Systems identifies airport categories and the amounts and types of airport
development eligible for Federal funding under the Airport Improvement Program (AIP).
AV2025025 3
Figure 1. Funding Breakdown Between the CRRSA Act and ARPA for Primary
Commercial Service Airports
Note: For additional details see Exhibit A: Scope & Methodology
Source: Office of Inspector General (OIG) analysis of FAA data
To distribute the funds, FAA used the tools and structure of its existing Airport
Improvement Program (AIP), which it used for CARES Act grants and prior
disaster recovery efforts. FAA’s Office of Airport Planning and Programming
(APP), which administers and oversees AIP grants, also performs the same duties
for the Agency’s COVID-19 relief grants and established ACRGP for the CRRSA
Act and ARGP for ARPA to distribute these funds to airport sponsors. 9 After
offering relief for concessions, airport sponsors then request reimbursement via
the Department of Transportation’s (DOT) Delphi eInvoicing system for payment
requests, for eligible costs such as operational expenses, debt-service payments,
and rent relief and MAGs. FAA reviewers manually assess all payment requests at
Headquarters to ensure the requests meet applicable Federal 10 and Agency
9 An airport sponsor, usually a county or municipality, is the airport’s owner-operator. FAA guidance also refers to AIP
grant recipients as airport sponsors. Sponsors receive grant awards on behalf of the airports while airport personnel
manage day-to-day operations.
10 Participation of Disadvantaged Business Enterprise in Airport Concessions, 49 C.F.R. § 23.3.
AV2025025 4
guidelines 11 for reimbursement (the table below outlines Federal and Agency
guidelines for reimbursement under ACRGP and ARGP). Although FAA previously
required airport sponsors to submit only detailed invoice summaries with their
reimbursement requests, our recent audit 12 prompted the Agency to begin
requiring supporting documentation for all expenses except payroll and
debt-service expenses.
Federal and Agency Guidelines for Reimbursement Under ACRGP
and ARGP
Coronavirus Response and Relief Supplemental Appropriations Act
and
American Rescue Plan Act
• Uniform Guidance at Title 2 C.F.R., Part 200
• Payment Integrity Information Act of 2019
• Policy and Procedures Concerning the Use of Airport Revenue
• ACRGP (CRRSA Act) and ARGP (ARPA) Frequently Asked Questions
• Concessions Rent Relief Grant Review Process Guide
Source: OIG analysis of FAA guidance
Because of the requirements and restrictions unique to ACRGP and ARGP
concession rent relief funds, FAA required airport sponsors to submit separate
Concession Rent Relief Plans (Concession Plans) for each program. These
Concession Plans identified eligible airport concessions operating at airports and
outlined the proportional allocation 13 to be provided. Upon FAA approving a
Concession Plan, APP disbursed ACRGP and ARGP funds to the airport sponsor
for waived rent or as credit to concessionaires.
11 The Agency developed Frequently Asked Questions (FAQs) for ACRGP and ARGP to explain to airport sponsors how
funds were allocated, how funds can be used, the grant application process, invoicing and payment processes, and
the concession rent relief process. Additionally, grantees were required to adhere to FAA’s Policy and Procedures
Concerning the Use of Airport Revenue, 64 Federal Register 7696 (February 16, 1999).
12 We recommended that FAA assess the risk of improper payments for CARES Act reimbursements and revise the
Agency’s policy on supporting documentation requirements to account for risk level. FAA Quickly Awarded CARES Act
Funds but Can Enhance Its Oversight Approach to Promote Effective Stewardship (OIG Report No. AV2022032),
July 18, 2022.
13 An airport sponsor must provide this relief to each airport concession in an amount that reflects each eligible
airport concession’s proportional share of the total amount of rent and MAG of all eligible airport concessions at the
airport. This is a set of ratios of each eligible concession’s contribution to the total amount of rent and MAG income
remitted to the airport by all members of the eligible population of remitting concessions.
AV2025025 5
FAA’s Revised Policies Have Resulted in Greater
Adherence to Reimbursement Requirements
FAA assigns each AIP grant recipient a payment-risk level, which then determines
the level of supporting documentation the recipient must submit and the
approval process for reimbursement. 14 To mitigate the significant risks associated
with CARES Act funds, the Agency categorized payment requests from these
funds to be a higher risk than most AIP requests. 15 FAA also required a manual
review of all COVID-19 relief reimbursement requests—a process typically
reserved only for AIP recipients assigned an elevated level of risk—and required
COVID-19 relief grant recipients to submit all underlying documentation in
support of reimbursement requests. 16
In 2022, we reviewed FAA’s oversight of the CARES Act grants and determined
that although leveraging the AIP allowed the Agency to quickly award and
distribute funds, changes in the Agency’s oversight process regarding loosening
supporting documentation requirements impacted its ability to monitor program
performance. 17 At the time of our review in July 2022, this change contributed to
more than $271 million in unsupported costs, $85 million in questioned costs,
and $3 million in improper payments. 18 As a result, we recommended that FAA
assess the risk of improper payments for different types of CARES Act
reimbursement requests and revise its policy on supporting documentation
requirements to account for risk level. In response, FAA revised its payment policy
to require grantees’ payment requests to include individual invoices, except for
reimbursement of payroll and debt service for which the previous policy of an
invoice summary and retaining supporting documentation would remain the
14 The three risk levels—nominal, moderate, or elevated (lowest to highest)—pertain solely to the risk associated with
submitting grant payments and may differ from the risk level assigned to the recipient for other grant administration
activities.
15 According to FAA, most AIP grant recipients are considered nominal risk, which requires them to provide only
minimal supporting documentation in reimbursement requests. Airport District Office/Regional Office staff do not
have to review or approve that documentation, and successfully submitted requests are processed automatically for
reimbursement (manual reviews are performed for the final 10 percent of funds on a grant).
16 According to FAA guidance, underlying payment request documentation means payroll receipts, janitorial contract
invoices, debt-service payments, etc.
17 FAA’s initial guidance for CARES Act grant recipients, dated April 13, 2020, directed airport sponsors to “continue
the current [AIP] practice of submitting underlying payment request documentation.” The Agency amended this
requirement to only require “summary invoices” in guidance it issued on December 3, 2020.
18 An improper payment is a payment that should not have been made or that was made in an incorrect amount
(including overpayment or underpayment) under statutory, contractual, administrative, or other legally applicable
requirements.
AV2025025 6
requirement. 19 FAA implemented changes for all three programs—CARES Act,
CRRSA Act, and ARPA—on March 27, 2023.
We found that after implementing these changes, FAA significantly reduced
unsupported and questioned costs and improper payments for ACRGP and
ARGP. We reviewed 141 payments, totaling more than $3.4 billion,20 across both
programs and found only one instance of an improper payment. Specifically,
ARGP guidance states that FAA will reimburse sponsors for debt-service
payments directly related to an airport that were due on or after March 11, 2021.
However, we identified a transaction involving two invoices, totaling $26,672,
paid to the airport sponsor that predated March 11, 2021. We contacted FAA
regarding this transaction in July 2024. The Agency confirmed in August 2024
that the predated invoices were not eligible for reimbursement. Upon further
inspection, FAA determined that program officials had previously identified the
ineligible expense in August 2023 during the grant closeout process and required
the funds be credited back to the grant. This action resolved our concerns.
FAA Inconsistently Implemented the CRRSA Act
and ARPA Rent Relief Programs
To receive rent relief funds, FAA required airport sponsors to complete a
Concession Plan. Because this type of relief was new to airport sponsors and
because FAA wanted to better assure the information necessary to validate
eligibility was collected, the Agency developed and distributed templates to each
eligible airport sponsor. Agency guidance stated that the completed Concession
Plans should primarily identify (1) eligible airport concessions operating at an
airport and (2) the proportion of an airport’s total award that would be provided
to each eligible concession. 21 Additionally, FAA’s template provided room for
sponsors to include the concessionaire business’s legal name (if different from
concession name), CRRSA Act or ARPA rent relief provided to the concessionaires
(if applicable), concessionaire participation in the Small Business Administration’s
(SBA) Paycheck Protection Program (PPP), and the airport sponsor’s required
19 FAA determined payroll and debt-service expenses to be the lowest risk because of their recurring and predictable
nature.
20 We reviewed 19 ACRGP payments totaling more than $400 million, followed by an additional sample of
39 transactions representing more than $140 million in economic relief. We also sampled 20 ARGP payments totaling
$539 million and an additional 63 payments totaling $1.3 billion.
21 FAA, Airport Coronavirus Response Grant Program Frequently Asked Questions (March 27, 2023); FAA, Airport Rescue
Grants Frequently Asked Questions (March 27, 2023).
AV2025025 7
consultation with Airport Concession Disadvantaged Business Enterprises. 22 At
the time of our review, we found that FAA approved 199 of the 260 Concession
Plans for ACRGP (76 percent) and 143 of the 204 Concession Plans for ARGP
(70 percent).
Once received, FAA:
• reviewed each Concession Plan for completeness of information,
• examined the legal business name of each concessionaire,
• assessed rent income to the airport during the qualifying baseline period,
• identified concessionaires ineligible for rent relief funds, and
• validated that concessionaires did not use the SBA’s PPP Second Draw
funds for rent or MAG payments using PPP Loan Database Lookup Tool
(see figure 2).23
22 49 C.F.R. Part 23 defines an Airport Concession Disadvantaged Business Enterprise as “a firm seeking to operate as a
concession that is a for-profit small business that is at least 51 percent owned by one or more individuals who are
both socially and economically disadvantaged . . . and whose management and daily business operations are
controlled by one or more of the socially and economically disadvantaged individuals who own it.”
23 The SBA Second Draw PPP allowed certain eligible borrowers who previously received a PPP loan to apply for a
second loan. Similar to First Draw PPP Loans, Second Draw funds could be used to help fund payroll costs, including
benefits, or to pay for mortgage interest, rent, or utilities.
AV2025025 8
Figure 2. FAA’s Sample PPP Loan Database Lookup Tool
Source: FederalPay.org Paycheck Protection Program Data Lookup, with redaction
added by OIG to remove extraneous identifying information
AV2025025 9
According to FAA program officials, FAA attempted to provide airport sponsors
as much guidance as possible to help them complete their Concession Plans. The
Agency published and updated its guidance, as needed; hosted webinars that
were later posted on its website for public review; and frequently met directly
with airports to address any concerns. Airport sponsors we spoke with found FAA
responsive to their inquiries and helpful throughout the process.
However, our review of 60 Concession Plans 24 identified some inconsistencies in
the program’s implementation and an error in FAA’s review.
• Nonprofit Business Received Rent Relief. An airport sponsor certified
that all concessions within its Concession Plans for ACRGP and ARGP were
eligible for rent relief. FAA approved the Concession Plans for that
sponsor, but our review identified that the sponsor provided rent relief
totaling more than $25,000 to a concession within the plan that was a
nonprofit trust. However, the ACRGP and ARGP requirements state that a
sponsor can only be reimbursed for rent relief provided to “for-profit”
entities. 25 When we asked FAA about this matter in July 2024, Agency
officials said the airport sponsor self-certified the concession’s eligibility
to receive rent relief when creating the Concession Plans. We considered
the rent relief payments made to this nonprofit trust to be an improper
payment as the trust was an ineligible recipient. 26 The Agency agreed with
our finding and requested that the sponsor revise its Concession Plans
and redistribute rent relief funds provided to this concession to eligible
concessions at the airport. The sponsor provided FAA a revised
Concession Plan redistributing the previously allotted funds to all eligible
concessionaires later that same year.
• Airport Lounge Eligibility of Concessions. Although Federal regulations
do not define airport lounges differently than any other airport
concession, when requesting rent relief payments from FAA, airport
sponsors treated airport lounges differently through ACRGP and ARGP.27
For example, some airports included airport lounges in their Concession
Plans, while others did not. FAA officials told us that “some airports were
incredibly generous” with rent relief but added that charging rent for
airport lounges is not an FAA decision but an internal decision made by
24 We sampled 33 ACRGP and 27 ARGP concession grants.
25 This FAA guidance in conformance with the CRRSA Act and ARPA requires that the eligible concessions meet the
definition established under 49 C.F.R. Part 23. Per definition, a concession is one or more of the types of for-profit
businesses, listed in the C.F.R., that serve the traveling public.
26 The Payment Integrity Information Act of 2019 (Pub. L. No. 116-117 (2020)) states that an improper payment
includes any payment that should not have been made, such as payment made to ineligible recipients.
27 Our review focused on airport lounges that had direct contractual agreements with the airport and not those that
were affiliated with airports via an airline.
AV2025025 10
the airport based on the contractual relationship between the
concessionaire and the airport. We identified one airport sponsor that
included an airport lounge in its Concession Plans, but officials
representing that lounge informed the airport sponsor that it does not
take “Federal funds directly or indirectly.” However, we found that this
concessionaire, which operates lounges in 15 U.S. airports, received
Federal funds for rent relief from ACRGP and ARGP totaling more than
$1 million at 3 airports. A different airport sponsor informed us they had
the same concessionaire but said FAA advised them that the
concessionaire did not qualify for rent relief.
• Airport Sponsors Did Not Populate Data Fields for Concession Plans.
We identified two airport sponsors that did not submit ACRGP Concession
Plans in accordance with FAA guidance. One airport sponsor identified the
name of the concession but did not identify the legal business names for
its concessionaires. For FAA officials to validate sponsor certified data,
Agency reviewers need the concessionaires’ legal business names—which
the airport sponsor did not provide—to verify SBA PPP loan information.
Another airport sponsor provided the legal business name for the
concessionaires but did not identify some of the concessionaires’
tradenames. By not providing these data points, FAA could not effectively
research and analyze SBA PPP loan data for some of these
concessionaires, as required by ACRGP guidance.
Although program officials reviewed each Concession Plan to ensure compliance
with Federal laws and requirements, we found these issues occurred because FAA
required airport sponsors to certify many aspects of the plans. According to the
Pandemic Response Accountability Committee,28 the most common root cause
that agencies report for improper payments is reliance on self-reported
information or inability to authenticate eligibility. 29 When relief funds are
provided to ineligible applicants, it reduces the amount of funds available to
eligible airport concessions that have suffered economically due to the pandemic.
28 The Pandemic Response Accountability Committee—established in March 2020 by the CARES Act—is a Committee
of the Council of the Inspectors General on Integrity and Efficiency that coordinates and supports oversight of the
covered coronavirus funds and the Federal Government’s coronavirus response and identifies major risks that cut
across program and agency boundaries.
29 Pandemic Oversight, “Self-certification procedures may increase fraud risk in pandemic response programs,”
(Nov. 13, 2020), https://www.pandemicoversight.gov/news/articles/self-certification-procedures-may-increase-fraud-
risk-pandemic-response-programs (last visited Nov. 18, 2024).
AV2025025 11
Other Matters
FAA guidance states that FAA will reimburse sponsors for monthly payments into
a debt-service reserve fund (also called a debt-service sinking fund), which is
directly related to the airport, and the airport sponsor must ensure that these
payments are restricted to only debt-service payments. Typically, airports transfer
revenues to these accounts on a regular basis as identified by local laws,
regulations, or agreements with the actual airport owners. However, during our
review, we found an airport sponsor had transferred funds from its improvement
fund and therefore returned funds to that account upon reimbursement from
FAA. When we asked officials from the airport sponsor why they had made the
transfer from the improvement fund instead of the sinking fund, they indicated
that the reduction in travel as a result of COVID-19 lockdowns had impacted
revenues, and the airport trust agreement required that they make the deposits
monthly. We found no evidence that the funds were misused by the airport
sponsor, but we have concerns that by placing the funds in an improvement fund
instead of a sinking fund, the sponsor may have violated FAA policies, such as its
Airport Sponsors Grant Assurances or its Revenue Use Policy. APP officials we
spoke with explained that this was a unique situation that fell outside their scope
and that they would need to converse with FAA’s Office of Financial Compliance.
Conclusion
Since our prior audit, which identified more than $350 million in financial
discrepancies, FAA has strengthened its oversight of COVID-19 relief programs
and demonstrated an improvement in managing the funds. The CRRSA Act and
ARPA allocated $10 billion in funds to eligible U.S. airports and concessions at
those airports to prevent, prepare for, and respond to the COVID-19 pandemic,
with FAA overseeing the distribution of these funds. As FAA closes out these
grants and prepares for potential future relief programs, continuing to strengthen
these processes is crucial to ensuring proper allocation of Federal funds to the
Nation’s airports.
Recommendations
With the implementation of the recommendations from our CARES Act audit,
FAA has significantly reduced unsupported and questioned costs and improper
payments for ACRGP and ARGP. For this reason, we are making no
recommendations.
AV2025025 12
Agency Comments and OIG Response
We provided FAA with our draft report on February 11, 2025. We received FAA’s
technical comments without a formal written response on February 25, 2025. This
report incorporates FAA’s technical comments as appropriate.
Actions Required
We are not making recommendations, and no action is required.
AV2025025 13
Exhibit A. Scope and Methodology
This performance audit was conducted between January 2024 and February 2025.
We conducted this 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 objectives. We believe that the
evidence obtained provides a reasonable basis for our findings and conclusions
based on our audit objectives.
To assess FAA’s oversight of airport sponsors’ compliance with the CRRSA Act
and ARPA requirements, we tested FAA’s grant files for compliance with Federal
laws and regulations, as well as FAA guidance, policies, and procedures such as
the Agency’s FAQs. To address our objectives, we developed a standardized
checklist to evaluate payments that we sampled in accordance with Agency
guidance. We also contacted or interviewed APP officials and conducted site
visits to four airport sponsors to understand the Agency’s oversight activities for
the CRRSA Act and ARPA.
We reviewed ACRGP and ARGP payments for operations, maintenance, payroll,
debt service, and concession rent relief. 30 Our review focused on primary airports
because they received 99 percent of the CRRSA Act and ARPA funds, and it
excludes CRRSA Act obligations to nonprimary commercial service, general
aviation airports, and nonprimary airports participating in the FAA Contract
Tower program, as well as ARPA obligations for the Federal share of airport
development grants and nonprimary airports. Using a two-stage sampling
methodology with probability proportional to size of the expended amount, we
selected a statistical sample of 58 payments representing more than $550 million
(28 percent) of all economic relief and 33 concession grants representing more
than $111 million (73 percent) of all concession grants obligated under ACRGP.
Similarly, for ARGP, we statistically sampled 83 transactions representing more
than $3 billion (54 percent) of all economic relief grants and 27 concession grants
representing more than $365 million (74 percent) of all concession grants.
To obtain an overall understanding of ACRGP and ARGP, we interviewed FAA
officials to determine their roles and responsibilities in reimbursing funds to
airport sponsors and to learn about the program’s guidance, award process,
relevant data, expenditures and reimbursements, and compliance reviews.
30 ACRGP and ARGP concession rent relief payments were lump-sum payments from FAA to the airport sponsor,
making these payments equivalent to a single payment.
Exhibit A. Scope and Methodology 14
To assess the effectiveness of FAA’s CRRSA Act and ARPA grant management
policies and procedures, we obtained access to FAA’s System of Airports
Reporting and Delphi and independently reviewed and validated CRRSA Act and
ARPA data, grant files, and related documentation. This access allowed us to
assess FAA’s oversight of grantee compliance with applicable Federal laws and
regulations. We retrieved grant files—including grant agreements, annual
financial reports, and closeout reports—from both databases. We reviewed each
document for clarity, correctness, and overall completion to identify any issues
with grant issuance, acceptance, and compliance. Access to these systems also
enabled us to:
• Download reimbursement requests and supporting documentation from
Delphi. We reviewed this material for compliance with the CRRSA Act,
ARPA, 2 C.F.R. Part 200, and FAA’s FAQs and Revenue Use Policy.
• Determine questioned costs. In line with the definition of “questioned
costs” in the Inspector General Act of 1978, we determined which costs
were not supported by adequate documentation to address conflicting
information, such as date incurred, date due, or date paid.
• Determine unsupported costs (e.g., costs that lacked sufficient or any
documentation) to show whether related payments were proper or
improper.
• Determine improper payments. Per Federal and Agency guidance,
operational expenses incurred prior to January 20, 2020, were ineligible
for reimbursement under both Acts. Federal and Agency guidance also
limited eligibility of debts to those incurred before December 27, 2020, for
CRSSA Act funds and those incurred before March 11, 2021, for ARPA
funds.
Exhibit A. Scope and Methodology 15
Exhibit B. Organizations Visited or Contacted
Federal Aviation Administration Facilities
FAA Headquarters
Other Organizations
City & County of San Francisco, California
Lee County Port Authority, Florida
Miami-Dade Aviation Department, Florida
San Diego County Regional Airport Authority, California
Exhibit B. Organizations Visited or Contacted 16
Exhibit C. List of Acronyms
ACRGP Airport Coronavirus Response Grant Program
AIP Airport Improvement Program
APP Office of Airport Planning and Programming
ARGP Airport Rescue Grants Program
ARPA American Rescue Plan Act
CARES Act Coronavirus Aid, Relief, and Economic Security Act
C.F.R. Code of Federal Regulations
COVID-19 Coronavirus Disease 2019
CRRSA Act Coronavirus Response and Relief Supplemental
Appropriations Act
DOT Department of Transportation
FAA Federal Aviation Administration
FAQs Frequently Asked Questions
MAGs Minimum Annual Guarantees
OIG Office of Inspector General
PPP Paycheck Protection Program
Pub. L. No. Public Law Number
SBA Small Business Administration
Exhibit C. List of Acronyms 17
Exhibit D. Major Contributors to This Report
MARSHALL JACKSON PROGRAM DIRECTOR
DOMINIQUE LIPSCOMB PROJECT MANAGER
KAZI HASSAN SENIOR ANALYST
VEVE MONFORT ANALYST
ALEXANDER SCHULTZ ANALYST
CHELSEA ARLANTICO ATTORNEY ADVISOR
GEORGE ZIPF SUPERVISORY MATHEMATICAL
STATISTICIAN
SHAWN SALES SUPERVISORY VISUAL
COMMUNICATIONS SPECIALIST
KIMBERLY BALDERSON SUPERVISORY WRITER-EDITOR
Exhibit D. Major Contributors to This Report 18
OUR MISSION
OIG enhances DOT’s programs and
operations by conducting objective
investigations and audits on behalf
of the American public.
1200 New Jersey Ave SE
Washington, DC 20590
www.oig.dot.gov
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