Audit Report - Oig 24 038 Coronavirus Disease 2019 Pandemic Relief Programs Audit Of Air Carrier
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- Oig 24 038 Coronavirus Disease 2019 Pandemic Relief Programs Audit Of Air Carrier
Summary
Audit Report OIG-24-038 of the Department of the Treasury Office of Inspector General, dated September 26, 2024, on the Air Carrier Payroll Support Program (PSP1) certifications of passenger air carrier Flight Group Corporation. Saggar & Rosenberg, P.C. performed the audit under contract, covering April 1, 2019 through September 30, 2019, with fieldwork from July 2023 through November 2023. It finds the company reported correct information in each of the four application sections reviewed and that its eligible compensation exceeded the amount certified to Treasury by $130,388, so it did not over-request PSP1 assistance. The report describes the PSP1 application, Treasury's final pro-rata rate of 78.2 percent for passenger air carriers and a March 2022 recertification process. Company management agreed with the results, and Treasury management noted that no amounts were overpaid.
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Audit Report
OIG-24-038
CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF
PROGRAMS
Audit of Air Carrier Worker Support
Certifications - Flight Group Corporation
September 26, 2024
Office of Inspector General
Department of the Treasury
This Page Intentionally Left Blank
September 26, 2024
MEMORANDUM FOR JESSICA MILANO
CHIEF PROGRAM OFFICER
FROM: Deborah L. Harker /s/
Assistant Inspector General for Audit
SUBJECT: Audit of Air Carrier Worker Support Certifications – Flight Group
Corporation
Attached is our audit report for the Audit of Air Carrier Worker Support Certifications –
Flight Group Corporation (OIG-24-038; dated September 26, 2024). 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 Flight Group Corporation’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). This audit was
mandated by Title IV, Subtitle B, Air Carrier Worker Support, of the Coronavirus Aid,
Relief, and Economic Security Act (CARES Act). 1 The scope of this audit covered the
period from April 1, 2019 through September 30, 2019, and included the certified
PSP1 Application, sworn financial statement, tax returns, and other documentation
submitted to Treasury.
In its audit report, S&R found that Flight Group Corporation, a passenger air carrier,
complied with PSP1 Application requirements. Specifically, Flight Group Corporation
incurred in eligible compensation from April 2019 through
September 2019. This amount exceeded the requested amount of ,
resulting in a $130,388 understatement.
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
1
P.L. 116–136 (March 27, 2020).
accepted government auditing standards, was not intended to enable us to express an
opinion on Flight Group Corporation’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: Gregory Till, Chief Operating Officer, Office of Capital Access, Department of
the Treasury
Danielle Christensen, Deputy Chief Program Officer, Office of Capital Access,
Department of the Treasury
Jason Morrow, Senior Counsel, Department of the Treasury
Jeff Davis, Partner, Saggar & Rosenberg, P.C.
Contents
Audit Report
Results in Brief ...................................................................................................2
Background ........................................................................................................3
Treasury Disbursement Processes ....................................................5
PSP1 Interim Audit Report ...............................................................6
Flight Group Corporation .................................................................7
Audit Results......................................................................................................7
Flight Group Corporation Complied with PSP1 Application Requirements...............8
Appendices
Appendix 1: Objective, Scope, and Methodology ..................................................10
Appendix 2: Flight Group Corporation Management Response ................................14
Appendix 3: Treasury Management Response ......................................................15
Appendix 4: Report Distribution ..........................................................................17
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
IRS Internal Revenue Service
OIG Treasury Office of Inspector General
PSP1 Payroll Support Program, CARES Act
SOC1 System of Organizational Controls
S&R Saggar & Rosenberg, P.C.
Treasury Department of the Treasury
i
This Page Intentionally Left Blank
& ROSENBERG, P.C.
Assurance • Tax • Consulting
September 26, 2024
Jessica Milano
Chief Program Officer
Department of the Treasury
This report presents the results of our audit of Flight Group
Corporation’s 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). 1 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). 2
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) 3 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 Flight Group
Corporation’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,
1
P.L. 116–136 (March 27, 2020).
2
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).
3
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 - Flight Group
Corporation (OIG-24-038) 1
sworn financial statement, tax returns, and other documentation
submitted to Treasury on April 23, 2020. 4
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 Flight Group Corporation, Treasury,
and contracted consultants engaged by Treasury to evaluate
certified company applications. We conducted our fieldwork from
July 2023 through November 2023. Appendix 1 contains a more
detailed description of our objective, scope, and methodology.
Results in Brief
In brief, S&R found that Flight Group Corporation, a passenger air
carrier, reported correct information for each of the four sections
reviewed on its PSP1 Application. 5 These sections are:
(1) Applicant Information, (2) Applicant Type, (3) Awardable
Amounts, and (4) Certification. For the Awardable Amounts
section, we found that Flight Group Corporation incurred
of eligible PSP1 compensation between April 1, 2019,
and September 30, 2019, which exceeded the amount certified to
Treasury on the PSP1 Application by $130,388. As a result, Flight
Group Corporation did not over-request PSP1 financial assistance.
We compared information provided in each section of the PSP1
Application to supporting documentation including air carrier
certificate, general ledger data, sworn financial statement, tax
returns, executive-level business charts, payroll registers, and
third-party benefit invoices.
As part of our reporting process, we provided Flight Group
Corporation management with an opportunity to comment on a
draft of this report. In a written response, Flight Group Corporation
4
Flight Group Corporation submitted the PSP1 Application and related supporting documentation on
April 23, 2020.
5
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 - Flight Group
Corporation (OIG-24-038) 2
management stated they have reviewed the report and agreed with
the results. Flight Group Corporation management’s response, in its
entirety, is included as appendix 2 of this report.
In a written response, Treasury management stated the draft report
describes work performed by OIG’s contractor to determine
whether the recipient’s requested awardable amounts complied
with Treasury’s program requirements. The draft report notes the
extensive fieldwork conducted for this review between July 2023
and November 2023, including interviewing Flight Group
Corporation’s management and reviewing a wide range of the
company’s financial records and corporate documents. In relation
to Flight Group Corporation, Treasury management noted that
OIG’s contractor found no amounts were overpaid. Treasury
management appreciates the OIG’s work on this engagement and
looks forward to working with the OIG to protect the integrity of
the PSP and other recovery programs. 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
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
Audit of Air Carrier Worker Support Certifications - Flight Group
Corporation (OIG-24-038) 3
to the DOT (referred to as 241 air carriers), 6 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 had to 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.
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.
6
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. Flight Group Corporation is not a Large Certificated Air Carrier.
Audit of Air Carrier Worker Support Certifications - Flight Group
Corporation (OIG-24-038) 4
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 Return, 7 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
officials 8 and the applicant’s 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.
Treasury Disbursement Processes
To disburse PSP1 payments to passenger air carrier applicants as
quickly as possible and prior to the application deadline of
April 27, 2020, Treasury applied an initial estimated pro-rata rate
of 76 percent to the awardable amount because not all applications
had been submitted at the time. After the application deadline,
Treasury determined the total amount requested by all passenger
air carrier applicants was approximately $31.8 billion, which
exceeded the $25 billion available financial assistance. Because its
initial estimated pro-rata rate was low, Treasury calculated an
7
IRS Form 941 is a tax form that businesses file quarterly to report income taxes, Social Security
taxes and Medicare taxes they withheld from employees’ paychecks.
8
The certifying officials attested under penalty of perjury that the information and certifications provided
in the application and its attachments are true and correct.
Audit of Air Carrier Worker Support Certifications - Flight Group
Corporation (OIG-24-038) 5
additional 2.2 percent, the top-off amount, for passenger air
carriers making the final awarded pro-rata rate 78.2 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
passenger air carriers 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 passenger air carriers in September 2020.
PSP1 Interim Audit Report
In a prior audit report, 9 OIG identified two systemic issues affecting
the payment amounts administered to all PSP1 recipients for
non-241 air carriers and contractors. Specifically, some of the
recipients audited included unallowable employer-side payroll taxes
or corporate officer compensation in their calculation of the
awardable amounts on their PSP1 applications. Treasury
management acknowledged these issues 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. Based on
our recommendations, in March 2022 Treasury implemented a
PSP1 recertification process whereby recipients had to certify
whether they excluded employer-side payroll taxes and corporate
officer compensation in their calculation of the awardable amounts
on their PSP1 applications. Treasury’s goal was to determine if
overpayments were made to recipients based on inaccurate
information included in PSP1 applications.
Treasury officials told us that if recoupment was necessary for an
applicant’s inclusion of unallowable expenses, such as corporate
officer compensation and/or employer-side payroll taxes in the
application, the recoupment method was dependent on timing. Any
overpayment was first offset against the approved top-off
payment. If an overpayment remained, or the overpayment was
identified after all PSP1 disbursements were made, and the
9
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 - Flight Group
Corporation (OIG-24-038) 6
recipient was entitled to PSP2 or PSP3 funding, the overpayment
was offset against the PSP2 and/or PSP3 awards prior to issuance.
All remaining PSP1 overpayments not previously collected where
the recipient did not qualify for, or apply for, PSP2 and PSP3
funding, were required to be repaid to Treasury.
Flight Group Corporation
Headquartered in Morrisville, North Carolina, Flight Group
Corporation is a passenger air carrier that provides private jet
charters along with private or corporate aircraft management
services.
Flight Group Corporation submitted its PSP1 Application
totaling on April 23, 2020. Flight Group Corporation
received the passenger air carrier top-off for a total award of
$1,201,879, or 78.2 percent of the company’s requested amount.
Treasury’s disbursements to Flight Group Corporation were as
follows:
• June 11, 2020: $584,033
• July 1, 2020: $194,678
• August 3, 2020: $194,678
• September 1, 2020: $194,678
• October 1, 2020: $33,812
Audit Results
We found that Flight Group Corporation reported correct
information for all four sections reviewed on its PSP1 Application.
These sections are: (1) Applicant Information, (2) Applicant Type,
(3) Awardable Amounts, and (4) Certification. We compared
information provided in each section of the PSP1 Application to
supporting documentation including general ledger data, company
Audit of Air Carrier Worker Support Certifications - Flight Group
Corporation (OIG-24-038) 7
sworn financial statement, IRS Form 941, executive-level business
charts, payroll registers, and third-party benefit invoices.
Flight Group Corporation Complied with PSP1 Application
Requirements
Flight Group Corporation complied with PSP1 Application
requirements since the amount requested did not include
unallowable expenses. For salaries and wages, we found that Flight
Group Corporation incurred in eligible compensation
from April 2019 through September 2019. This amount exceeded
-
the requested amount of
resulting in a
on the PSP1 Application,
understatement. Flight Group Corporation
excluded eligible voluntary deductions from its employees’
paychecks for (1) 401k retirement contributions, and (2) fringe
benefit insurance premiums in its calculation for salaries and
wages. 10
- -
For benefits, we found that Flight Group Corporation incurred
in eligible employer contributed expenses from April 2019
through September 2019. This amount exceeded the requested
amount of on the PSP1 Application, resulting in a
understatement. Flight Group Corporation applied a 50-percent -
reduction to the total invoice amount for medical, vision, and
dental benefits as opposed to using the actual expense amounts.
In aggregate, Flight Group Corporation incurred of
eligible PSP1 compensation which exceeded its PSP1 Application
10
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 or
post-tax basis.
Audit of Air Carrier Worker Support Certifications - Flight Group
Corporation (OIG-24-038) 8
by $130,388, as illustrated in Table 1 below. As such, Flight
Group Corporation did not over-request PSP1 financial assistance.
Table 1: Awardable Amount Comparison
Requested Re-Calculated
Amount Amount Variance
-- -- --
Month
April 2019
May 2019
June 2019
July 2019 -- -- --
August 2019
-- -- --
- -
September 2019
TOTAL $130,388
Source: S&R Calculation of Awardable Amount
******
We appreciate the courtesies and cooperation provided to our staff
during the audit. A distribution list for this report is provided as
appendix 4.
Saggar & Rosenberg, P.C. /s/
Audit of Air Carrier Worker Support Certifications - Flight Group
Corporation (OIG-24-038) 9
Appendix 1: Objective, Scope, and Methodology
Our objective was to assess the accuracy, completeness, and
sufficiency of Flight Group Corporation’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).
The scope of our audit covered the period from April 1, 2019
through September 30, 2019, and included the certified Payroll
Support Program (PSP1) Application, sworn financial statement,
tax returns, and other documentation submitted to Treasury on
April 23, 2020. 11
To accomplish this objective, Saggar & Rosenberg, P.C. (S&R)
performed the following activities during audit fieldwork conducted
remotely from July 2023 through November 2023:
• Reviewed applicable Federal laws and regulations, including:
o Title IV, Subtitle B, Air Carrier Worker Support, of the
Coronavirus Aid, Relief, and Economic Security Act
(CARES Act); 12 and
o 14 CFR, Part 241, 13 Uniform System of Accounts and
Reports for Large Certificated Air Carriers, amended
August 12, 2022.
• Reviewed Treasury’s policies, procedures, and guidance related
to PSP1:
o Guidelines and Application Procedures for Payroll Support
to Air Carriers and Contractors, which included the
PSP1 Application, March 30, 2020;
o PSP1 Agreement;
11
Flight Group Corporation submitted the PSP1 Application and related support documentation on
April 23, 2020.
12
P.L. 116–136 (March 27, 2020).
13
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. Flight Group Corporation is not a Large Certificated Air Carrier.
Audit of Air Carrier Worker Support Certifications - Flight Group
Corporation (OIG-24-038) 10
Appendix 1: Objective, Scope, and Methodology
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 Flight Group Corporation representatives
responsible for the completion and submission of the sworn
financial statement.
• Reviewed sworn financial statement and documents to support
the requested payroll support amount. The documentation
included general ledger data; company pay registers; benefit
invoices; Internal Revenue Service (IRS) Form 941, Employer’s
Quarterly Federal Tax Return; 14 and organizational hierarchy
information.
• Reviewed Government Accountability Office’s (GAO) Standards
for Internal Control in the Federal Government 15 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 the Flight Group Corporation
14
IRS Form 941 is a tax form that businesses file quarterly to report income taxes, Social Security
taxes, and Medicare taxes they withheld from employees’ paychecks.
15
GAO-14-704G (September 2014).
Audit of Air Carrier Worker Support Certifications - Flight Group
Corporation (OIG-24-038) 11
Appendix 1: Objective, Scope, and Methodology
payroll system, was significant to the audit objective. 16 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 Flight Group Corporation’s payroll
system, we reviewed a System and Organizational Controls 1
(SOC 1) report, 17 Data Supplier Questionnaire, 18 and interviewed
Flight Group Corporation’s management responsible for
generating and using the data. Additional details regarding our
assessment of the reliability of the data is reported in the
section below.
• Reviewed GAO’s Assessing Data Reliability 19 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,
conclusions, or recommendations in the context of the audit
objective. Flight Group Corporation prepared the PSP1
Application using gross pay, less non-taxable employee-paid
medical contributions, from April 2019 through
September 2019, which included information developed from
Flight Group Corporation’s payroll system. We compared details
generated from payroll registers at the individual employee level,
as well as third-party vendor benefit invoices from April 2019
through September 2019, to the amounts presented in the
Awardable Amounts section of the PSP1 Application.
To assess data reliability of these sources, we reviewed the
SOC 1 report and Data Supplier Questionnaire for the payroll
system, and interviewed Flight Group Corporation management
responsible for generating and using the data. Based on our
assessment, we determined that the data was sufficiently
16
The five components in GAO’s Standards for Internal Control in the Federal Government are Control
Environment, Risk Assessment, Control Activities, Information and Communication, and Monitoring.
17
SOC 1 report addresses 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.
18
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.
19
GAO-20-283G (December 2019).
Audit of Air Carrier Worker Support Certifications - Flight Group
Corporation (OIG-24-038) 12
Appendix 1: Objective, Scope, and Methodology
reliable to support the findings and conclusions to answer the
objective of this audit.
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 - Flight Group
Corporation (OIG-24-038) 13
Appendix 2: Flight Group Corporation Management Response
F LIGH T GROU P
August 26, 2024
Tyler Robe11son, CPA
Saggar & Rosen~, P.C.
One Church Street, Suite 700
Rockville, MD 20850
Mr. Robertson:
We are responding to your i-equest fo:r comments n!g.rrdmg the Fonnal Draft Repoli on yom audit ofthe
Treasury PSP Program for Flight Group Corporation.
We've re.;ewed lhe report and agree with your final assessment that Fli,ght Group Coi-por.a.tion was in
full compliance with the program rules and guidelines.
We have no further comments to add for the completion ofthe report, and its delive1y to the Traasury
Department.
Please let us .know if you have any questioil!I or further needs from us in this regard.
Sincerely,
flight Group Col]>oration
P.O. BOX ~ O:JJ&
f LIG: 11T G ftO U PC.01-lf't. COM
RA LEIGH , NC t 76 '1'S
Audit of Air Carrier W orker Support Certif ications - Flight Group
Corporation (OIG-24-038) 14
Appendix 3: Treasury Management Response
OF THE TREASURY
WASHINGTON,, D.C. 20220
September 20, 2024
Deborah L Harl:-e,r
As<.:ista.nt Inspector Genera] for Al!ldit
U.S. Department of the Tre.asurry - Offioe of Inspector Genera]
1500 Peruis.ylvania Avenue N.W.
Vi ashiington, D . • . 20220
Dear :Ms. Hark,e r:
I write regarding fue Offioe oflmpeoto:rGene:rn.l' s ~OIG} d'.raftA.udit ofAir C01rfr-r Worker
Support Cei1ifica-tions (Draft Report), regarding Flight Group COl]loration (t!b.e Recipient), a
1,ecipient of funds WJ.de:rTre;mny's PayToll Support Prngrmn (FSP). The U. . Depmtment ofthe
Treasmy (TFeas.my) appreci.1Jtes OIG':s effort<.:.
PSP ,va. part of m effort to provide emergency a:ssistance in res-p001Se· to the W1precedented
challenUi, presented by the OOVJD- ] 9 public health emergency md had lhFee i erations:
• The Coronarvims Aid, Relief, arnd Economic Security Ac (C-IB.ES A t) ,,"ll!s ,ena ted on
March 2" , 2 010 and ,e..st.ibliished the Pay:roU Surpport Program (PSP]) to provide financiaP
assis.1anoe· to i\meric--11' s passengeT air c-.mriers, ,cargorur
cm:i.en, and ertain aviaition
c011Jtmotorn. Treasmy disburned mOFe than :,28 billion to mr-er 600 bmine.sses inPSPl ,,
diirectly supportiing moFe than 600,000 American j.obs.
• fu December 2020 the Consolidated Appro_priaitiom; Act, 021 cre:-111:ed the Payroll
Support Program Ex eosiio11 (PSP2) for eligible passenger air c-.an:i.e:rs. and certain aviation
contrac,to:rs_Treasury- disbursed o,ra- 15 billiion to over 80 passenger aiir carri,ers and
ccm1tracetors l!IDder PSP2.
• In M:m:-ch 202 1, fue American Rescue P]a.n Act of2021 provide.cl. a:n ad!d'iitiona] $]5 b:ill!ion
for Tre.ismy to mal:!e further payroll support payments ••o entii •es ilia panicipated .in
PSP2 (PSP3). Treasury disbm:.ed over • 4.5 b:il.liou to ove.r 480 pas:senge,r air carriers
and. contraotorn under PSP3,.
The ARES Act set forth two different medi.odologies fo r calrnla:ting awardable amot111ts for t!b.e
largest carriers and for smaller rur c,ame.i:s and avianoncontra.ctors. For fue largest air carrier:s
which Feceived approximately 89% o,f the to l PS? assistance PSP ] amounts ,vere based on
reports tile carriers had filed with the -. . Department of Tr::msportation under ]4 C.F.R. part
4l In contrast., fue starlute raqllired Trea:smy to prov:ide fin.an·cial as,sist:.m: e to smaller air
carrier:s lllDd aviation contra.ctors .in 3111 amot111f fuar tl1e applicants cemfie:4 usiing S'l'iOrn financial
statements or olheT appropriate dlata, as the, am.0W1t of wages, salaries, and benefiits fu-at they paid
to their ,empl.o,ye-es during fue t:ime period iomApri] 1 2019, furn ugh September 30 2019.
Audit of Air Carrier Worker Support Certifications - Flight Group
Corporation (OIG-24-038) 15
or awards to the smaller companies, the PSPl application and Treastll)•'s gtridelines made clear
that the awardable amounts should not include, inter alia, (I) any employer-side payroll taxes,
which are not paid to employees, and (2) compensation paid to COIJ>Orale officers and non
employee contractors. Before accepting PSP2 applications, Treasury published additional
guidance further emphasizing that such amounts sho,tld not be included in the comparries'
awardable amount calcttlations. 1 In both PSPl and PSP2, Treasury required two officials of each
applicant, including at least one COIJ>Orale officer, to certify that the information provided in the
application was correct and did not contain any materially false or fraudulent statements.
In April 2020, OIG began a series of audits of PSPI recipients lo determine whether they had
properly calculated their requested awardable arno,mts. In March 202 1, OIG issued an Interim
Audit Update, notifying Treasury that a munber of recipients being audited had impermissibly
included, in their PSPI applications, employer-side payroll taxes or COIJ>Orate officer
compensation in the calculation of the awardable amo\ml, which may have resulted in an
overstatement of the amount of PSPI ftmds requested. In response, Treasury promptly took a
series of remedial actions, including requiring that all PSPI applicants receiving awards on the
basis of self-certification re-certify whether their awardable amounts included employer-side
payroll taxes or corporate officer compensation. Where a company informed Treasury that it had
improperly included those amounts in its application, Treasury either withheld foture PSPI
disbursements or began pursuing debt recoupment. Through this process, Treasury has
successfolly recouped more than Sl47 million of PSP ovel]lay,nents.
The Draft Report
The Draft Report describes the work performed by OIG' s contractor to determine whether the
Recipient's requested awardable amount complied with the guidelines provided by Treasury. Tue
Draft Report notes the eJ<tensive fieldwork conducted for this re>iew between July 2023 and
November 2023 to determine the aCctiracy of the information in the Recipient' s PSPI application
submitted to Treasury, including interviewing the Recipient's management and collecting and
reviev.ing a v.ide range of the company's financial records and coiporate documents. OIG found
that the Recipient reported correct information in its PSPI application and did not overstate its
requested awardable amotmt.
Again, Treasury appreciates OIG's work on these engagements. We look fonvard to working
with you to protect the integrity of the PSP and other recovery programs.
Sincerely,
Q~u-01~
Jessica Milano
Chief Program Officer
1 Bec.suse awardable amounts iD PSP3 v.-ere calcula:ed as a percentage of eac.b compmy•s PSP'2 award, companies
were not required to calculate awardab!e amounts for PSP3.
2
Audit of Air Carrier Worker Support Certifications - Flight Group
Corporation (OIG-24-038) 16
Appendix 4: Report Distribution
Department of the Treasury
Deputy Secretary
Treasury Audit Liaison
Office of Strategic Planning and Performance Improvement
Office of the Deputy Chief Financial Officer, Risk and Control
Group
Flight Group Corporation
President
Secretary/Controller
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 Accountability
Committee on Financial Services
Committee on the Budget
Committee on Transportation and Infrastructure
Audit of Air Carrier Worker Support Certifications - Flight Group
Corporation (OIG-24-038) 17
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