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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.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

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/, SHA-256 fe049cf7f53b5fb470c0c3ddbd7057f4168e38ceed1f2fe61f55588dd3a24add.

Full text

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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