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Audit Report - Oig 26 025 Audit Of Air Carrier Worker Support Certifications Ibc Airways Inc

Summary

Audit Report OIG-26-025 of the Office of Inspector General, Department of the Treasury, dated March 13, 2026, titled Audit of Air Carrier Worker Support Certifications – IBC Airways, Inc. It is addressed to Jeffrey Stout, Acting Chief Program Officer. The Results in Brief states that IBC Airways, a cargo air carrier, reported correct information for five of the six sections reviewed on its PSP1 Application, but incorrectly reported information in the Awardable Amounts section by including unallowable employer-contribution portion of benefits to its corporate officers. The report recommends that Treasury seek reimbursement of the overpayment, and states that Treasury management concurred with the recommendation.

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Audit Report
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Oig 26 025 Audit Of Air Carrier Worker Support Certifications Ibc Airways Inc

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  SENSITIVE BUT
  UNCLASSIFIED
                         (SBU)
                                                 asu   ry
                                            T r e
                                       U.S.




                     SBU Cover Sheet




For further information, refer to the
Treasury Security Manual (TD P 15-71) at
http://intranet.treas.gov/security/

  TD F 15-05.11 (3/07)
Audit Report




OIG-26-025


CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF
PROGRAMS


Audit of Air Carrier Worker Support
Certifications – IBC Airways, Inc.

March 13, 2026




Office of Inspector General
Department of the Treasury
This Page Intentionally Left Blank
Contents
Audit Report
Results in Brief ...................................................................................................2

Background ........................................................................................................3

                   PSP1 Interim Audit Report ...............................................................5
                   IBC Airways, Inc. ...........................................................................6

Audit Results......................................................................................................7

    Finding        Inaccurate Compilation of the PSP1 Application Awardable Amount .....7
                   Recommendation............................................................................8

Appendices
Appendix 1: Objective, Scope, and Methodology .................................................. 10
Appendix 2: Schedule of Monetary Benefits ......................................................... 14
Appendix 3: IBC Airways Management Response ................................................. 15
Appendix 4: Treasury Management Response ...................................................... 16
Appendix 5: Major Contributors to This Report ..................................................... 19
Appendix 6: Report Distribution .......................................................................... 20



Abbreviations
CARES Act                     Coronavirus Aid, Relief, and Economic Security Act
DOT                           Department of Transportation
Guidelines                    Guidelines and Application Procedures for Payroll Support to Air
                                Carriers and Contractors under Division A, Title IV, Subtitle B
                                of the Coronavirus Aid, Relief, and Economic Security Act
IRS                           Internal Revenue Service
IBC Airways                   IBC Airways Inc.
OIG                           Treasury Office of Inspector General
PSP1                          Payroll Support Program, CARES Act
PSP2                          Payroll Support Program Extension, Consolidated Appropriations
                                Act, 2021
PSP3                          Payroll Support Program 3, American Rescue Plan Act of 2021
SOC 1                         System and Organizational Controls
Treasury                      Department of the Treasury



                                                                                                               i
This Page Intentionally Left Blank
                        March 13, 2026

                        Jeffrey Stout
                        Acting Chief Program Officer
                        Department of the Treasury

                        This report presents the results of our audit of IBC Airways, Inc.’s
                        (IBC Airways) certification 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. 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.

                        Our audit objective was to assess the accuracy, completeness, and
                        sufficiency of IBC Airways’ 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 period from
                        April 1, 2019, through September 30, 2019, and included the



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 Carriers Worker Support Certifications –
                        IBC Airways, Inc. (OIG-26-025)                                            1
                       certified PSP1 Application, sworn financial statement, tax returns,
                       and other documentation submitted to Treasury on April 3, 2020. 4

                       To accomplish the objective, we reviewed applicable laws,
                       regulations, and Treasury’s policies and procedures, including but
                       not limited to, Title IV, Subtitle B, Air Carrier Worker Support of the
                       CARES Act; Guidelines and Application Procedures for Payroll
                       Support to Air Carriers and Contractors under Division A, Title IV,
                       Subtitle B of the Coronavirus Aid, Relief, and Economic Security
                       Act (Guidelines); PSP1 Agreement; and Frequently Asked
                       Questions: Application Procedures for Payroll Support to Air
                       Carriers and Contractors. We interviewed key personnel from IBC
                       Airways, Treasury, and contracted consultants engaged by
                       Treasury to evaluate certified company applications. We conducted
                       our fieldwork from October 2020 through August 2022.
                       Appendix 1 contains a more detailed description of our audit
                       objective, scope, and methodology.


Results in Brief

                       We found that IBC Airways, a cargo air carrier, reported correct
                       information for five of the six sections reviewed on its PSP1
                       Application. 5 These sections are: (1) Applicant Information,
                       (2) Applicant Type, (3) Financial Institution Information,
                       (4) Additional Information, and (5) Certification; however, IBC
                       Airways incorrectly reported information in the Awardable Amounts
                       section of the PSP1 Application.

                       IBC Airways included unallowable employer-contribution portion of
                       benefits to its corporate officers, resulting in $
                       overpayment. Treasury disbursed PSP1 funds to cargo air carriers
                       at 100 percent of the requested amount. As a result, we
                       questioned the costs totaling $           and recommend that
                       Treasury seek reimbursement of the overpayment. Appendix 2
                       contains the schedule of monetary benefits.



4
    IBC Airways submitted its PSP1 Application and related supporting documentation on April 3, 2020.
5
    The PSP1 Application is comprised of eight sections. We did not review two sections because the
    Taxpayer Protection section generally does not apply to non-241 air carriers; and the Employment
    Levels section had no impact on Treasury’s determination of recipients’ award amounts.



                       Audit of Air Carriers Worker Support Certifications –
                       IBC Airways, Inc. (OIG-26-025)                                           2
                         As part of our reporting process, we provided IBC management
                         with an opportunity to comment on a draft of this report. In a
                         written response, IBC management stated they have reviewed the
                         report and accepted the results. IBC management’s response, in its
                         entirety, is included as appendix 3 of this report.

                         In a written response, Treasury management concurred with the
                         recommendation and agreed that any overpayments of PSP funds
                         should be recouped. Treasury stated that it will conduct a review
                         of the findings, consider any response from the recipient, and seek
                         recoupment of any amounts that Treasury determines have been
                         overpaid. Treasury management will need to record an estimated
                         completion date for these actions in the Joint Audit Management
                         Enterprise System (JAMES). Management’s planned corrective
                         actions meet the intent of our recommendations. Treasury
                         management response, in its entirety, is included as appendix 4 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
                         to DOT (referred to as 241 air carriers), 6 in an amount equal to the

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




                         Audit of Air Carriers Worker Support Certifications –
                         IBC Airways, Inc. (OIG-26-025)                                                 3
                     salaries and benefits reported to DOT for the period April 1, 2019,
                     through September 30, 2019. For air carriers that do not report
                     such data to DOT (referred to as non-241 air carriers), and
                     contractors, financial assistance is required to be in an amount that
                     the air carrier or contractor certifies using sworn financial
                     statements or other appropriate data as the amount of wages,
                     salaries, benefits, and other compensation paid to employees
                     during the period of April 1, 2019, through September 30, 2019.
                     The amounts submitted on the application to Treasury were
                     considered sworn financial statements. To be eligible for payments,
                     air carriers and contractors must enter into agreements with
                     Treasury certifying that they meet certain required assurances,
                     terms, and conditions.

                     On March 30, 2020, Treasury posted on its website the
                     Guidelines, which included the PSP1 Application. The PSP1
                     Application is comprised of eight sections:

                         1. Applicant Information – (1) applicant name; (2) taxpayer
                            identification number and address; and (3) contact person’s
                            name, title, phone number, and email address.

                         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 number of involuntary reductions
                            after March 1, 2020.




Puerto Rico, and the U.S. Virgin Islands. These air carriers are required to report financial information
to DOT. IBC Airways is not a large, certificated air carrier.



                     Audit of Air Carriers Worker Support Certifications –
                     IBC Airways, Inc. (OIG-26-025)                                                 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 the 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.

                        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
                        and/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

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.
9
    Treasury OIG, Interim Audit Update: Air Carrier and Contractor Certifications for Payroll Support
    Program (Interim Audit), OIG-21-025 (March 31, 2021).



                        Audit of Air Carriers Worker Support Certifications –
                        IBC Airways, Inc. (OIG-26-025)                                                   5
                       (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 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
                       recipient was entitled to Payroll Support Program Extension
                       (PSP2) 10 or Payroll Support Program 3 (PSP3) 11 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.

                       IBC Airways, Inc.
                       Headquartered in Fort Lauderdale, Florida, IBC Airways is a cargo
                       air carrier that specializes in transportation of hazardous materials
                       to and from the Caribbean, Latin American, and the United States.

                       IBC Airways submitted its PSP1 Application requesting
                       $            on April 3, 2020. The requested amount included two
                       components of IBC Airways – IBC Airways and IBC Travel. On
                       June 11, 2020, based on guidance from Treasury, IBC Airways
                       submitted a revised PSP1 Application, removing the IBC Travel
                       component. This resulted in a revised requested amount of

10
   The Consolidated Appropriations Act, 2021 (P.L. 116–260), enacted on December 27, 2020,
   created the Airline Worker Support Extension for passenger air carriers and certain contractors.
   Treasury referred to this as Payroll Support Program Extension (PSP2).
11
   The American Rescue Plan of 2021 (P.L. 117–2), enacted on March 11, 2021, created the Air
   Transportation Payroll Support Program Extension authorizing Treasury to provide additional
   assistance to passenger air carriers and contractors that received financial assistance under PSP2.
   Treasury referred to this as Payroll Support Program 3 (PSP3).



                       Audit of Air Carriers Worker Support Certifications –
                       IBC Airways, Inc. (OIG-26-025)                                               6
                $3,222,391, all of which was awarded by Treasury. Treasury’s
                disbursements to IBC Airways were as follows:

                   •   June 17, 2020: $1,611,195.50

                   •   July 7, 2020: $537,065.17

                   •   August 6, 2020: $537,065.17

                   •   September 4, 2020: $537,065.16


Audit Results

                IBC Airways reported correct information for five of the six
                sections reviewed on the PSP1 Application. These sections are:
                (1) Applicant Information, (2) Applicant Type, (3) Financial
                Institution Information, (4) Additional Information, and
                (5) Certification. We compared information provided in each section
                of the PSP1 Application to supporting documentation including
                payroll reports, benefit statements, bank statements, IRS Form
                941, among other things. We found the company incorrectly
                reported information in the Awardable Amounts section, resulting
                in a $          overpayment related to corporate officers’ benefits.


Finding         Inaccurate Compilation of the PSP1 Application
                Awardable Amount

                Both the CARES Act and Treasury’s Guidelines define “employee”
                as “an individual, other than a corporate officer, who is employed
                by an air carrier or contractor in the United States (including its
                territories and possessions).”

                The PSP1 Agreement defines corporate officer as:

                   with respect to the recipient, its president; any vice president in
                   charge of a principal business unit, division, or function (such as
                   sales, administration or finance); any other officer who performs
                   a policy-making function; or any other person who performs
                   similar policy making functions for the recipient. Executive
                   officers of subsidiaries or parents of the recipient may be



                Audit of Air Carriers Worker Support Certifications –
                IBC Airways, Inc. (OIG-26-025)                                   7
   deemed corporate officers of the recipient if they perform such
   policy-making functions for the recipient.

We found that IBC Airways has three executives: (1) President,
(2) Vice President of Finance, and (3) Vice President of Corporate
Development. All three executives met the definition of a corporate
officer per Treasury’s PSP1 Agreement, through discussions with
management, and review of the IBC Airways 2019 organizational
chart. IBC Airways properly excluded all three corporate officers’
salaries; but included the employer-contribution portion of benefits
(healthcare, dental, vision, and life insurance costs) for its
corporate officers, resulting in a $         overpayment. IBC
Airways management stated that the inclusion of unallowable
benefits was an oversight.

To remedy the findings noted in the prior OIG audit report (see
footnote 9), Treasury required cargo recipients to recertify their
PSP1 awardable amounts. IBC Airways erroneously recertified to
Treasury that it did not include corporate officer compensation in
its PSP1 Application. Treasury stated it relies on applicants’
certifications that they did not include unallowable expenses (i.e.
corporate officer compensation and employer-side payroll taxes),
and no further validation checks were performed.

Recommendation
We recommend that Treasury’s Acting Chief Program Officer:

   1. Seek reimbursement of $              overpayment of PSP1
      financial assistance.

       Management Response

       Treasury will conduct a review of the finding, consider any
       response from the recipient, and seek recoupment of any
       amounts that Treasury determines have been overpaid.

       OIG Comment

       Managements planned corrective actions meet the intent of
       our recommendation. Treasury management will need to




Audit of Air Carriers Worker Support Certifications –
IBC Airways, Inc. (OIG-26-025)                                   8
       record an estimated completion date for these actions in
       JAMES.

                              ******

We appreciate the courtesies and cooperation provided to our staff
during the audit. If you wish to discuss the report, you may
contact me at (202) 439-6354, or Christopher Culbreath, Acting
Audit Manager, at (202) 486-1983. Major contributors to this
report are listed in appendix 5. A distribution list for this report is
provided as appendix 6.

/s/

Julie Wong
Acting Deputy Assistant Inspector General for Audit




Audit of Air Carriers Worker Support Certifications –
IBC Airways, Inc. (OIG-26-025)                                     9
Appendices

Appendix 1: Objective, Scope, and Methodology

             Our objective was to assess the accuracy, completeness, and
             sufficiency of IBC Airways, Inc.’s (IBC Airways) 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 Payroll Support
             Program (PSP1).

             The scope of our 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 on April 3, 2020.

             To accomplish this objective, we performed the following activities
             during audit fieldwork conducted remotely from October 2020
             through August 2022:

             •   Reviewed applicable laws and regulations, including:
                    o Title IV, Subtitle B, Air Carrier Worker Support, of the
                      Coronavirus Aid, Relief, and Economic Security Act
                      (CARES Act), and
                    o 14 CFR Part 241, Uniform System of Accounts and
                      Reports for Large Certificated Air Carriers, amended
                      May 31, 2024.
             •   Reviewed Treasury’s policies, procedures, and guidelines related
                 to PSP1:
                    o Guidelines and Application Procedures for Payroll Support
                      to Air Carriers and Contractors under Division A, Title IV,
                      Subtitle B of the Coronavirus Aid, Relief, and Economic
                      Security Act, which included the PSP1 Application,
                      March 30, 2020;
                    o PSP1 Agreement;
                    o Question and Answer: Payroll Support to Air Carriers and
                      Contractors (April 2, 2020, April 3, 2020, and
                      April 20, 2020 versions);




             Audit of Air Carriers Worker Support Certifications –
             IBC Airways, Inc. (OIG-26-025)                                  10
Appendix 1: Objective, Scope, and Methodology

                                o Frequently Asked Questions: Application Procedures for
                                  Payroll Support to Air Carriers and Contractors,
                                  April 3, 2020; and
                                o Treasury’s Payroll Support Program to Air Carriers and
                                  Contractors Draft Internal Program Review Guide, July
                                  2020.
                        •   Performed 100 percent testing for six of the eight sections in
                            the PSP1 Application—specifically, the Applicant Information,
                            Applicant Type, Financial Institution Information, Awardable
                            Amounts, Additional Information, and Certification sections. The
                            other two sections were not reviewed because the Taxpayer
                            Protection section generally does not apply to non-241 air
                            carriers; the Employment Levels section had no impact on
                            Treasury’s determination of recipients’ award amount.
                        •   Interviewed key Treasury personnel and contracted consultants
                            engaged by Treasury to aid in its evaluation of air carriers’ and
                            contractors’ certified applications and other data.
                        •   Interviewed IBC Airways’ representatives responsible for the
                            completion and submission of the sworn financial statement.
                            The amounts submitted in the Awardable Amounts section of
                            the PSP1 Application were considered the sworn financial
                            statement.
                        •   Reviewed sworn financial statement and documents to support
                            the requested payroll support amount. The documentation
                            included, but was not limited to (1) PSP1 Application; (2) 2019
                            Internal Revenue Service Form 941, Employer’s Quarterly
                            Federal Tax Return; (3) April through September 2019 payroll
                            reports; (4) PSP1 Agreement; and (5) third-party benefit
                            invoices.
                        •   Reviewed Government Accountability Office’s Standards for
                            Internal Control in the Federal Government 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 IBC Airways’ payroll systems,
                            was significant to the audit objective.12 This component states
12
     The five components of internal control are Control Environment, Risk Assessment, Control
     Activities, Information and Communication, and Monitoring.



                        Audit of Air Carriers Worker Support Certifications –
                        IBC Airways, Inc. (OIG-26-025)                                           11
Appendix 1: Objective, Scope, and Methodology

                           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 IBC
                           Airways’ payroll systems, we examined IBC Airways’ responses
                           to Data Supplier Questionnaires, 13 reviewed a System and
                           Organizational Controls 1 (SOC 1) 14 report, and interviewed IBC
                           Airways’ 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 Government Accountability Office’s Assessing Data
                           Reliability guidance, which states that 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. IBC Airways used information generated from
                           its payroll and accounting systems to complete the PSP1
                           Application. As such, we compared the payroll information to
                           third-party vendor benefit invoices from April 2019 through
                           September 2019, as well as to the information in the Awardable
                           Amounts section of the PSP1 Application. Similarly, we
                           compared the general ledger information to third-party vendor
                           benefit invoices from April 2019 through September 2019, and
                           the information in the Awardable Amounts section of the PSP1
                           Application.
                           To assess the reliability of IBC Airways’ payroll and accounting
                           systems, we (1) reviewed IBC Airways’ completed Data
                           Supplier Questionnaire; (2) reviewed the payroll system’s SOC 1
                           report; and (3) interviewed IBC Airways’ representatives
                           knowledgeable about the data. Based on our assessment, we
                           determined that the data were sufficiently reliable to support
                           the findings and conclusions to answer the objective of this
                           audit.



13
   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.
14
   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.



                       Audit of Air Carriers Worker Support Certifications –
                       IBC Airways, Inc. (OIG-26-025)                                              12
Appendix 1: Objective, Scope, and Methodology

               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 Carriers Worker Support Certifications –
               IBC Airways, Inc. (OIG-26-025)                                13
Appendix 2: Schedule of Monetary Benefits

                       According to the Code of Federal Regulations, 15 a questioned cost
                       is an amount expended or received from a Federal award, that in
                       the auditors judgment:

                           (a) is noncompliant or suspected noncompliant with Federal
                               statutes, regulations, or the terms and conditions of the
                               Federal award;

                           (b) at the time of the audit lacked adequate documentation to
                               support compliance; or

                           (c) appeared unreasonable and did not reflect the actions a
                               prudent person would take in the circumstances.


                       Questioned costs are to be recorded in the Department of the
                       Treasury’s (Treasury) Joint Audit Management Enterprise System.
                       The amount will also be included in the Treasury Office of
                       Inspector General (OIG) Semiannual Report to Congress. It is
                       Treasury management’s responsibility to report to Congress on the
                       status of the agreed to OIG recommendations with monetary
                       benefits in accordance with Section 405(c) of the Inspector
                       General Act of 1978, as amended.

                       Recommendation                                Questioned Costs
                       Recommendation No. 1                                  $

                       The questioned cost represents amounts provided by Treasury
                       under the Payroll Support Program (PSP1). As discussed in
                       Finding 1, IBC Airways, Inc. overstated its PSP1 Application
                       awardable amount to Treasury by $            due to the inclusion of
                       unallowable employer-contribution portion of benefits to its
                       corporate officers.




15
     2 CFR § 200.1 – Questioned Cost.



                       Audit of Air Carriers Worker Support Certifications –
                       IBC Airways, Inc. (OIG-26-025)                                    14
Appendix 3: IBC Airways Management Response




            Audit of Air Carriers Worker Support Certifications –
            IBC Airways, Inc. (OIG-26-025)                          15
Appendix 4: Treasury Management Response




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Audit of Air Carriers Worker Support Certifications –
IBC Airways, Inc. (OIG-26-025)                          17
Audit of Air Carriers Worker Support Certifications –
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Appendix 5: Major Contributors to This Report

                 Olivia Scott, Acting Audit Director
                 Christopher Culbreath, Acting Audit Manager
                 Adrianne Gilbert, Auditor-in-Charge
                 Emilie Kane, Auditor
                 Eduardo Coney, Referencer




              Audit of Air Carriers Worker Support Certifications –
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Appendix 6: Report Distribution

              Department of the Treasury
                 Treasury Secretary
                 Deputy Secretary
                 Treasury Audit Liaison
                 Office of Strategy, Planning and Performance Improvement
                 Office of the Deputy Chief Financial Officer, Risk and Control
                   Group
              IBC Airways, Inc.
                 Chief Financial Officer
              Office of Management and Budget
                 OIG Budget Examiner
              U.S. 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

              U.S. House of Representatives
                Committee on Oversight and Government Reform
                Committee on Financial Services
                Committee on the Budget
                Committee on Transportation and Infrastructure




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