Audit Report - Oig 26 030 Coronavirus Disease 2019 Pandemic Relief Programs Audit Of Airline Wor
Summary
Treasury Office of Inspector General Audit Report OIG-26-030, Audit of Airline Worker Support Extension Certification – STS Aviation Services – Tank Tigers, Inc., dated May 8, 2026, with a memorandum to Jeffrey Stout, Acting Chief Program Officer, from Pauletta Battle. The memo states that Saggar & Rosenberg, P.C. performed the audit under a contract monitored by OIG to assess the accuracy of STS' sworn financial statement used to certify amounts for the Payroll Support Program Extension (PSP2), covering the period from October 1, 2019, through March 31, 2020. It states that S&R found STS, a contractor, incorrectly reported information in the Determining Awardable Amount section of the PSP2 Application and understated its requested awardable amount by $458,580. It states that OIG is not making a recommendation.
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- Oig 26 030 Coronavirus Disease 2019 Pandemic Relief Programs Audit Of Airline Wor
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“Audit Report - Oig 26 030 Coronavirus Disease 2019 Pandemic Relief Programs Audit Of Airline Wor.”
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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-26-030
CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF
PROGRAMS
Audit of Airline Worker Support Extension
Certification – STS Aviation Services –
Tank Tigers, Inc.
May 8, 2026
Office of Inspector General
Department of the Treasury
This Page Intentionally Left Blank
May 8, 2026
MEMORANDUM FOR JEFFREY STOUT
ACTING CHIEF PROGRAM OFFICER
FROM: Pauletta Battle /s/
Assistant Inspector General for Audit
SUBJECT: Audit of Airline Worker Support Extension Certification —
STS Aviation Services – Tank Tigers, Inc.
Attached is our audit report for the Audit of Airline Worker Support Extension
Certification — STS Aviation Services – Tank Tigers, Inc. (STS) 1 (OIG-26-030;
May 8, 2026). 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
STS’ 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 Payroll Support Program Extension (PSP2). This
audit was mandated by Title IV, Subtitle A, Airline Worker Support Extension, of the
Consolidated Appropriations Act, 2021. 2 The scope of our audit covered the period
from October 1, 2019, through March 31, 2020, and included the certified PSP2
Application, sworn financial statement, tax returns, and other documentation
submitted to Treasury.
In its audit report, S&R found that STS, a contractor, incorrectly reported information
in the Determining Awardable Amount section of the PSP2 Application. Specifically,
the company included $ in unsupported health insurance for its benefit
amount; however, the unsupported benefit was entirely offset by differences between
the actual salaries and wages and the requested amount, resulting in a variance of
$ . Overall, STS understated its requested awardable amount by $458,580.
Therefore, we are not making a recommendation.
1
Hereafter, STS refers to all four affiliates, which includes: (1) Airline Tech Reps, LLC; (2) Cannon
Aviation Modification and Repair, LLC; (3) STS Repair and Modification, LLC; and (4) STS Aviation
Services — Tank Tigers, Inc. Each applied individually but Treasury merged the Determining
Awardable Amount sections during the review process.
2
P.L. 116–260 (December 27, 2020)
i
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
accepted government auditing standards, was not intended to enable us to express an
opinion on STS’ compliance with Treasury’s PSP2 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) 927-5400, or a member of your staff may contact Julie Wong, Acting Deputy
Assistant Inspector General for Audit, at (202) 439-6354.
Sincerely,
/s/
Pauletta Battle
Assistant Inspector General for Audit
cc: Thao P. Tran, Acting Chief Operating Officer, Department of the Treasury
Danielle Christensen, Deputy Chief Program Officer for State and Local
Programs, Office of Capital Access, Department of the Treasury
Jason Morrow, Senior Counsel, Department of the Treasury
Jeff Davis, Partner, Saggar & Rosenberg, P.C.
ii
Contents
Audit Report
Results in Brief ...................................................................................................2
Background ........................................................................................................3
Treasury Disbursement Processes ....................................................5
STS Aviation Services – Tank Tigers, Inc. .........................................5
Audit Results......................................................................................................6
Finding STS Did Not Over-Request PSP2 Financial Assistance Despite Partial
Non-Compliance With Application Requirements.................................7
Appendices
Appendix 1: Objective, Scope, and Methodology ..................................................10
Appendix 2: STS Aviation Services – Tank Tigers, Inc. Management Response ........13
Appendix 3: Treasury Management Response ......................................................14
Appendix 4: Report Distribution ..........................................................................16
Abbreviations
CAA Consolidated Appropriations Act
DOT Department of Transportation
DUNS Data Universal Numbering System
IRS Internal Revenue Service
OIG Treasury Office of Inspector General
PSP1 Payroll Support Program, Coronavirus Aid, Relief, and
Economic Security Act
PSP2 Payroll Support Program Extension, Consolidated
Appropriations Act, 2021
PSP2 Guidelines Guidelines and Application Procedures for Payroll Support to
Passenger Air Carriers and Contractors
S&R Saggar & Rosenberg, P.C.
SOC 1 System and Organizational Controls
STS STS Aviation Services — Tank Tigers, Inc.
Treasury Department of the Treasury
This Page Intentionally Left Blank
May 8, 2026
Jeffrey Stout
Acting Chief Program Officer
Department of the Treasury
This report presents the results of our audit of STS Aviation
Services — Tank Tigers, Inc.’s (STS) certifications made to the
Department of the Treasury (Treasury) as part of its participation in
the Payroll Support Program Extension (PSP2). This audit was
mandated by Title IV, Subtitle A, Airline Worker Support Extension,
of the Consolidated Appropriations Act, 2021 (CAA). Under the
CAA, Treasury was to provide $16 billion in financial assistance to
passenger 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. 3 Furthermore, the Treasury Office of
Inspector General (OIG) is required to audit certifications made by
passenger air carriers that do not report salaries and benefits to the
Department of Transportation (DOT) (hereinafter referred to as
non-241 air carriers) 4 and contractors.
Our audit objective was to assess the accuracy, completeness, and
sufficiency of STS’ sworn financial statement or other data used to
certify the wages, salaries, benefits, and other compensation
amounts submitted and approved by Treasury for PSP2. The scope
of our audit covered the period from October 1, 2019, through
March 31, 2020, and included the certified PSP2 Application,
sworn financial statement, tax returns, and other documentation
submitted to Treasury on January 14, 2021.
To accomplish the objective, we reviewed applicable federal laws
and regulations; and Treasury’s policies, procedures and guidance,
3
The financial assistance provided under the CAA was split between passenger air carriers
($15 billion) and contractors ($1 billion).
4
Passenger 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 Airline Worker Support Extension Certification –
STS Aviation Services – Tank Tigers, Inc. (OIG-26-030) 1
including but not limited to, Title IV, Subtitle A, Airline Worker
Support Extension of the CAA; Guidelines and Application
Procedures for Payroll Support to Passenger Air Carriers and
Contractors (PSP2 Guidelines); PSP2 Agreement; and Question and
Answer: Payroll Support Program Extension for Passenger Air
Carriers and Contractors. We interviewed key personnel from STS
and Treasury. We conducted our fieldwork from February 2025
through July 2025. Appendix 1 contains a more detailed
description of our objective, scope, and methodology.
Results in Brief
We found that STS, a contractor, reported correct information for
five of six sections reviewed on its PSP2 Application. 5 These
sections are: (1) Recipient Information, (2) Eligibility Questions,
(3) Company Information, (4) Affiliates, and (5) Certification. We
also found that STS reported incorrect information in the
Determining Awardable Amount section. Specifically, the company
included $ in unsupported health insurance for its benefit
amount; however, the unsupported benefit was entirely offset by
differences between the actual salaries and wages and the
requested amount, resulting in a variance of $ . Overall,
STS understated its requested amount by $458,580. Therefore,
we are not making a recommendation.
As part of our reporting process, we provided STS management
with an opportunity to comment on a draft of this report. In a
written response, STS management stated they have reviewed the
report and agreed with the results. STS management’s response, in
its entirety, is included as appendix 2 of this report.
In a written response, Treasury management noted that STS
understated its awardable amount; therefore no amounts are owed
back to Treasury. Additionally, Treasury management appreciates
the work on this engagement and looks forward to working with
the OIG to protect the integrity of the PSP and other recovery
5
The PSP2 Application is comprised of ten sections. We did not review four sections because the
Financial Information, Bankruptcy Information, and Employment Levels sections had no impact on
Treasury’s determination of recipients’ award amounts; and the Validation of Payroll Support
Program (PSP1) Award Amount section had no impact on STS’ PSP2 awarded amount because the
company did not receive PSP1 financial assistance.
Audit of Airline Worker Support Extension Certification –
STS Aviation Services – Tank Tigers, Inc. (OIG-26-030) 2
programs. Treasury management’s response, in its entirety, is
included as appendix 3 of this report.
Background
Title IV, Subtitle A, of the CAA, Airline Worker Support Extension,
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
$15 billion; and
(2) contractors, in an aggregate amount up to $1 billion.
According to the CAA, Treasury is required to provide financial
assistance to contractors, in an amount equal to: (1) the amount
such contractor was approved to receive (without taking into
account any pro-rata reduction) under Payroll Support Program
(PSP1); 6 or (2) in the event such contractor did not receive
financial assistance under PSP1, an amount that the contractor
certifies, using sworn financial statements or other appropriate
data, as the amount of wages, salaries, benefits, and other
compensation that such contractor paid the employees of such
contractor during the period from October 1, 2019, through
March 31, 2020. The amounts submitted on the application to
Treasury were considered sworn financial statements. To be
eligible for payments, contractors must enter into agreements with
Treasury certifying that they meet certain required assurances,
terms, and conditions.
On December 29, 2020, Treasury posted on its website the PSP2
Guidelines. Afterwards, Treasury posted a web-based PSP2
Application for applicants to complete and submit. The PSP2
Application was comprised of ten sections:
6
The Coronavirus Aid, Relief, and Economic Security Act (P.L. 116-136), enacted on March 27, 2020,
created the Air Carrier Worker Support. The program provided payroll support to passenger air
carriers, cargo air carriers, and certain contractors for the continuation of payment of employee
wages, salaries, and benefits in response to the economic impact of Coronavirus Disease 2019.
Treasury referred to this as Payroll Support Program (PSP1).
Audit of Airline Worker Support Extension Certification –
STS Aviation Services – Tank Tigers, Inc. (OIG-26-030) 3
1. Recipient Information — (1) indication of whether the
applicant is an eligible passenger air carrier or an eligible
contractor; (2) Form-41 filer indication; 7 (3) applicant’s
name; (4) applicant’s taxpayer identification number; and
(5) PSP1 Applicant indication, if applicable, by listing the
PSP1 Application number, whether PSP1 Application was
approved, and financial assistance received.
2. Eligibility Questions — selection of whether the applicant is
a direct passenger air carrier, an indirect passenger air
carrier, a direct contractor, or a subcontractor. 8
3. Company Information — (1) applicant’s Data Universal
Numbering System (DUNS) number; 9 (2) indication of
whether the applicant is registered with the System for
Award Management; 10 (3) applicant’s entity type;
(4) applicant’s address; and (5) contact person name, title,
phone number, and email address.
4. Financial Information — (1) the applicant’s account type,
number, and routing number; and (2) the financial
institution’s name, address, and telephone number.
5. Bankruptcy Information — applicant’s indication as to
whether they have taken or is contemplating taking action
to commence bankruptcy, to include explanation, debtor
name, bankruptcy court, case number, type of bankruptcy
filing, and date of bankruptcy filing.
6. Employee Levels — (1) applicant’s average number of
employees for 2019 and 2020; (2) employee count as of the
date of the PSP2 Application; (3) if applicant did not apply
7
A Form-41 filer is a large certificated carrier, who is required to report financial information to DOT.
8
Direct air carrier means a certificated commuter, foreign air carrier, an air taxi operator, or a Canadian
charter air taxi operator; that directly engages in the operation of aircraft under a certificate,
authorization, permit or exemption issued by DOT. Indirect air carriers are organizers and service
providers who use services of a direct air carrier but do not operate or own the aircraft. A direct
contractor is hired directly by the client to complete a project, whereas a subcontractor is hired by
the contractor to complete tasks within the contract.
9
A DUNS number is a unique nine-digit identifier associated with a company’s credit profile.
10
Entities registered on the System for Award Management, which is administered by the General
Services Administration, are allowed to bid on government contracts and apply for federal
assistance.
Audit of Airline Worker Support Extension Certification –
STS Aviation Services – Tank Tigers, Inc. (OIG-26-030) 4
for PSP1, number of involuntary reductions after
March 27, 2020; and (4) if applicant applied for PSP1,
number of involuntary reductions after October 1, 2020.
7. Determining Awardable Amount — applicant’s sworn
financial statement consisting of salaries, wages, benefits,
and other compensation for October 1, 2019, to
March 31, 2020.
8. Validation of PSP1 Award Amount — applicant’s
recertification to whether unallowable expenses were
included in its PSP1 Application, to include corporate officer
compensation, independent contractors, employer-side
payroll taxes, and amounts other than wages, salaries,
benefits, and other compensation.
9. Affiliates — (1) affiliate name; (2) affiliate applicant type;
(3) affiliate taxpayer ID; and (4) affiliate DUNS number.
10. Certification — names, titles, and signatures of two
certifying officials 11 and application submission date.
Treasury Disbursement Processes
The total PSP2 requested amount (also referred to as awardable
amount) by all contractor applicants exceeded the $1 billion
available financial assistance. As a result, Treasury applied a
pro-rata rate of 30.4 percent to the requested amount. Generally,
Treasury disbursed two payments—each half of the awarded
amount.
STS Aviation Services – Tank Tigers, Inc.
Headquartered in Jensen Beach, Florida, STS is a contractor that
provides a variety of services to commercial airlines including, but
not limited to, ground handling and aircraft maintenance services.
STS’ PSP2 Application was comprised of four United States based
affiliate companies (1) Airline Tech Reps, LLC, (2) Cannon Aviation
Modification and Repair, LLC, (3) STS Repair and Modification,
11
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 Airline Worker Support Extension Certification –
STS Aviation Services – Tank Tigers, Inc. (OIG-26-030) 5
LLC, and (4) STS Aviation Services – Tank Tigers, Inc. Initially, the
affiliates submitted individual PSP2 applications to Treasury;
however, Treasury merged the Determining Awardable Amount
section for the four applications during the review process, and the
total requested amount is $26,376,155, as shown in Table 1.
Table 1. PSP2 Initial Application Requests
Company Requested Amount
STS Aviation Services – Tank Tigers, Inc. $
Airline Tech Reps, LLC $
Cannon Aviation Modification & Repair, LLC $
STS Repair & Modification, LLC $
TOTAL – Merged Application $26,376,155
Source: Initial PSP2 Applications.
STS received a total award amount of $8,018,351, or
30.4 percent of the company’s requested amount. Treasury’s
disbursements to STS were as follows:
• April 8, 2021: $4,009,175
• May 17, 2021: $4,009,176
In addition to PSP2, Treasury awarded STS $8,018,351 under
Payroll Support Program 3 authorized by the American Rescue Plan
Act of 2021. 12 Payroll Support Program 3 was not the subject of
this audit.
Audit Results
We found that STS reported correct information for five of six
sections reviewed on its PSP2 Application. These sections are:
(1) Recipient Information, (2) Eligibility Questions, (3) Company
12
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.
Audit of Airline Worker Support Extension Certification –
STS Aviation Services – Tank Tigers, Inc. (OIG-26-030) 6
Information, (4) Affiliates, and (5) Certification. We compared
information provided in each section of the PSP2 Application to
supporting documentation, including general ledger data, company
sworn financial statement, Internal Revenue Service (IRS) Form
941, 13 executive-level business charts, and payroll registers, among
other items.
We also found that STS incorrectly reported information in the
Determining Awardable Amount section. Specifically, the company
included $ in unsupported health insurance for its benefit
amount; however, the unsupported benefit was entirely offset by
differences between the actual salaries and wages and the
requested amount, resulting in a variance of $ . Overall,
STS understated its requested awardable amount by $458,580.
Finding STS Did Not Over-Request PSP2 Financial Assistance
Despite Partial Non-Compliance With Application
Requirements
Treasury’s PSP2 Application instructs applicants to enter:
(1) salaries and wages as an amount equal to Line 2 on its IRS
Form 941 for October - December of tax year 2019 and
January - March of tax year 2020, less amounts paid to corporate
officers of the company; and (2) benefits in an amount equal to
benefits paid to all individuals on payroll from October 1, 2019
through March 31, 2020, less benefits paid to corporate officers of
the company.
According to the instructions for IRS Form 941, employers are to
enter amounts on Line 2 that are equal to Box 1 [Wages, tips,
other compensation] of the employees' IRS Forms W-2. The Form
W-2 instructions requires that Box 1 excludes elective deferrals
such as employee contributions to 401(k).
Treasury’s PSP2 Guidelines defines:
benefits as without duplication of any amounts counted as
salary or wages, pension expenses in respect of employees, all
expenses for accident, sickness, hospital, and death benefits to
employees, and the cost of insurance to provide such benefits;
any severance pay or other benefits payable to employees
13
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.
Audit of Airline Worker Support Extension Certification –
STS Aviation Services – Tank Tigers, Inc. (OIG-26-030) 7
pursuant to a bona fide voluntary early retirement program or
voluntary furlough; and any other similar expenses paid by a
passenger air carrier or contractor for the benefit of employees,
including any other fringe benefit expense described in lines 10
and 11 of Financial Reporting Schedule P-6, 14 Form-41, as
published by the Department of Transportation, but excluding
any federal, state, or local payroll taxes paid by a passenger air
carrier or contractor;
salaries as without duplication of any amounts counted as
benefits, a predetermined regular payment, typically paid on a
weekly or less frequent basis but which may be expressed as an
hourly, weekly, annual or other rate, as well as cost-of-living
differentials, vacation time, paid time off, sick leave, and
overtime pay, paid by a passenger air carrier or contractor to its
employees, but excluding any federal, state, or local payroll
taxes paid by the passenger air carrier or contractor; and
wages as without duplication of any amounts counted as
benefits, a payment, typically paid on an hourly, daily, or
piecework basis, including cost-of-living differentials, vacation,
paid time off, sick leave, and overtime pay, paid by a passenger
air carrier or contractor to its employees, but excluding any
federal, state, or local payroll taxes paid by the passenger air
carrier or contractor.
STS did not provide sufficient supporting documentation to
demonstrate that the $ requested for health insurance
benefits were eligible for PSP2. The company did not provide
health insurance invoices, itemized at the employee-level, to
quantify the amounts associated with ineligible corporate officer’s
benefits. The unsupported benefits were entirely offset by
differences between the actual salaries and wages and the
requested amounts. STS incurred $26,834,735 in eligible salaries
and wages from October 1, 2019, through March 31, 2020. This
exceeded the $ requested in the application, resulting
in a variance of $ .
In aggregate, STS understated its requested amount by $458,580.
This aggregate understatement was due to (1) the company
14
The Schedule P-6 is one of the financial reports 241 air carriers must submit to DOT. The schedule
contains data for a company’s quarterly operating expenses and is separated into categories such as
salaries and fringe benefits.
Audit of Airline Worker Support Extension Certification –
STS Aviation Services – Tank Tigers, Inc. (OIG-26-030) 8
electing to forgo providing support for the benefit amount due to
additional efforts required to obtain the supporting documentation;
and (2) Treasury’s PSP2 Application instructing applicants to
exclude elective deferrals, such as employee contributions to
401(k) and health insurance, which are considered eligible
compensation for PSP2 purposes. Ultimately, STS did not
over-request PSP2 financial assistance; therefore, we are not
making a recommendation. Table 2 illustrates the aggregate
understatement.
Table 2: Aggregate Understatement
Description Amount
PSP2 Application Requested Amount $26,376,155
Less Unsupported Health Insurance Benefits $( )
Plus Eligible Employee Salaries and Wages $
PSP2 Calculated Amount $26,834,735
Understatement $458,580
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 Airline Worker Support Extension Certification –
STS Aviation Services – Tank Tigers, Inc. (OIG-26-030) 9
Appendix 1: Objective, Scope, and Methodology
Our objective was to assess the accuracy, completeness, and
sufficiency of STS Aviation Services – Tank Tigers, Inc.’s (STS)
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
Payroll Support Program Extension (PSP2).
The scope of our audit covered the period from October 1, 2019,
through March 31, 2020, and included the certified PSP2
Application, sworn financial statement, tax returns, and other
documentation submitted to Treasury on January 14, 2021.
To accomplish this objective, Saggar & Rosenberg, P.C. performed
the following activities during audit fieldwork from February 2025
through July 2025:
• Reviewed applicable federal laws and regulations, including:
o Title IV, Subtitle A, Airline Worker Support Extension, of
the Consolidated Appropriations Act, 2021; and
o 14 CFR Part 241, Uniform System of Accounts and
Reports for Large Certificated Air Carriers, amended
April 2, 2025.
• Reviewed Treasury’s policies, procedures, and guidance related
to PSP2:
o Guidelines and Application Procedures for Payroll Support
to Passenger Air Carriers and Contractors,
December 29, 2020;
o PSP2 Agreement;
o Question and Answer: Payroll Support Program Extension
for Passenger Air Carriers and Contractors,
(January 19, 2021, and March 10, 2021, versions).
• Performed 100 percent testing for six of the ten sections of the
PSP2 Application—specifically, the Company Information,
Recipient Information, Eligibility Questions, Affiliates,
Determining Awardable Amount, and Certification sections. We
did not review four sections because the Financial Information,
Bankruptcy Information, and Employee Levels sections had no
impact on Treasury’s determination of recipients’ award
Audit of Airline Worker Support Extension Certification –
STS Aviation Services – Tank Tigers, Inc. (OIG-26-030) 10
Appendix 1: Objective, Scope, and Methodology
amounts; and the Validation of Payroll Support Program Award
Amount section had no impact on STS’ PSP2 awarded amount
because the company did not receive Payroll Support Program
financial assistance.
• Interviewed key Treasury personnel.
• Interviewed STS’ management responsible for the completion
and submission of the sworn financial statement in the
Determine Awardable Amount section of the PSP2 Application.
• Reviewed sworn financial statement and documents to support
the requested payroll support amount. The documentation
included but was not limited to: (1) general ledger data,
(2) company pay registers, (3) Internal Revenue Service Form
941 – Employer’s Quarterly Federal Tax Return, and
(4) organizational hierarchy.
• 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 STS’ payroll system, was
significant to the audit objective. 15 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
STS’ payroll system, we examined STS’ response to Data
Supplier Questionnaires, 16 reviewed a System and
Organizational Controls 1 (SOC 1) report, 17 and interviewed
STS’ management responsible for generating and using the
15
The five components of internal control are Control Environment, Risk Assessment, Control
Activities, Information and Communication, and Monitoring.
16
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 of a third-party vendor’s accounting and
financial controls. The Data Supplier Questionnaire would be one of the tools used during the Data
Reliability Assessment.
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.
Audit of Airline Worker Support Extension Certification –
STS Aviation Services – Tank Tigers, Inc. (OIG-26-030) 11
Appendix 1: Objective, Scope, and Methodology
data. Additional details regarding our assessment of the
reliability of the data are reported in the section below.
• Reviewed Government Accountability Office’s Assessing Data
Reliability 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 needed to support
the findings, conclusions, or recommendations in the context of
the audit objective. STS prepared the PSP2 Application using
payroll and benefit information from STS’ payroll and financial
accounting systems. We compared details generated from the
payroll registers at the individual employee level, from
October 1, 2019, through March 31, 2020, to the amounts
presented in the Determine Awardable Amount section of the
PSP2 Application.
To assess data reliability of these sources, we (1) reviewed the
Data Supplier Questionnaires for the payroll and financial
accounting systems, (2) reviewed the SOC 1 report for the
payroll system, and (3) interviewed STS’ management
responsible for generating and using the data. Based on our
assessment, we determined that the data was sufficiently
reliable to support the findings and conclusions to answer the
objective of this audit.
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 Airline Worker Support Extension Certification –
STS Aviation Services – Tank Tigers, Inc. (OIG-26-030) 12
Appendix 3: Treasury Management Response
Audit of Airline Worker Support Extension Certification –
STS Aviation Services – Tank Tigers, Inc. (OIG-26-030) 14
Appendix 3: Treasury Management Response
Audit of Airline Worker Support Extension Certification –
STS Aviation Services – Tank Tigers, Inc. (OIG-26-030) 15
Appendix 4: Report Distribution
Department of the Treasury
Deputy Secretary
Treasury Audit Liaison
Office of Strategy, Planning, and Performance Improvement
Office of the Deputy Chief Financial Officer, Risk and Control
Group
STS Aviation Services – Tank Tigers, Inc.
Chief Executive Officer
Corporate 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 Government Reform
Committee on Financial Services
Committee on the Budget
Committee on Transportation and Infrastructure
Audit of Airline Worker Support Extension Certification –
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