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Audit Report - Oig 26 031 Coronavirus Disease 2019 Pandemic Relief Programs Audit Of Airline Wor

Summary

Audit Report OIG-26-031 of the Office of Inspector General, Department of the Treasury, dated May 11, 2026, titled Audit of Airline Worker Support Extension Certification – Air Center Helicopter, Inc. The transmittal memorandum is signed /s/ by Pauletta Battle, Assistant Inspector General for Audit, and states that Saggar & Rosenberg, P.C. (S&R) performed the audit under a contract monitored by the office. It states that S&R found that Air Center Helicopter, a passenger air carrier, included employer-side payroll taxes, per diem expenses and corporate officer compensation among items in its PSP2 Application, totaling $1,141,917, and that the unallowable expenses were entirely offset by the company voluntarily withholding eligible PSP2 compensation. It states that S&R is not making a recommendation.

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Inspector general and oversight reports
Document type
Audit Report
Case
Oig 26 031 Coronavirus Disease 2019 Pandemic Relief Programs Audit Of Airline Wor

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“Audit Report - Oig 26 031 Coronavirus Disease 2019 Pandemic Relief Programs Audit Of Airline Wor.” Original at oig.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/oig-26-031-coronavirus-disease-2019-pandemic-relief-programs-audit-of-airline-wor/, SHA-256 b577db9ff83d1ea44edcde32d1a28275e048217ce7b295c6fb92f7693f5119a8.

Full text

  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-26-031


CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF
PROGRAMS


Audit of Airline Worker Support Extension
Certification – Air Center Helicopter, Inc.


May 11, 2026




Office of Inspector General
Department of the Treasury
This Page Intentionally Left Blank
                                        May 11, 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 — Air
                         Center Helicopter, Inc.

Attached is our audit report for the Audit of Airline Worker Support Extension
Certification – Air Center Helicopter, Inc. (Air Center Helicopter) (OIG-26-031;
May 11, 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
Air Center Helicopter’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 Payroll Support Program
Extension (PSP2). This audit was mandated by Title IV, Subtitle A, Airline Worker
Support Extension, of the Consolidated Appropriations Act, 2021. 1 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 Air Center Helicopter, a passenger air carrier, included
(1) employer-side payroll taxes, (2) per diem expenses, (3) corporate officer
compensation, (4) the difference between the actual benefits paid and the PSP2
Application amount, and (5) an ineligible-employee expense, totaling $1,141,917. The
unallowable expenses were entirely offset by the company voluntarily withholding
$              in eligible PSP2 compensation. Overall, Air Center Helicopter understated
its requested amount by $          . Therefore, S&R is not making a recommendation.

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.


1
    P.L. 116–260 (December 27, 2020)


                                                                                           i
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 Air Center Helicopter’s 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.


Attachment

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 ....................................................6
                   Air Center Helicopter, Inc. ...............................................................6

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

    Finding        Air Center Helicopter Did Not Over-Request PSP2 Financial Assistance
                   Despite Partial Non-Compliance With Application Requirements ...........8


Appendices
Appendix 1: Objective, Scope, and Methodology .................................................. 12
Appendix 2: Air Center Helicopter Inc.’s Management Response ............................ 15
Appendix 3: Treasury Management Response ...................................................... 16
Appendix 4: Report Distribution .......................................................................... 18



Abbreviations
Air Center Helicopter         Air Center Helicopter, Inc.
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
Treasury                      Department of the Treasury
This Page Intentionally Left Blank
                        May 11, 2026

                        Jeffrey Stout
                        Acting Chief Program Officer
                        Department of the Treasury

                        This report presents the results of our audit of Air Center
                        Helicopter Inc.’s (Air Center Helicopter) 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. 2 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) 3 and contractors.

                        Our audit objective was to assess the accuracy, completeness, and
                        sufficiency of Air Center Helicopter’s 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 13, 2021.

                        To accomplish the objective, we reviewed applicable federal laws
                        and regulations; and Treasury’s policies, procedures and guidance,
                        including but not limited to, Title IV, Subtitle A, Airline Worker
                        Support Extension of the CAA; Guidelines and Application

2
    The financial assistance provided under the CAA was split between passenger air carriers
    ($15 billion) and contractors ($1 billion).
3
    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 –
                        Air Center Helicopter Inc. (OIG-26-031)                                     1
                       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 Air
                       Center Helicopter and Treasury. We conducted our fieldwork from
                       January 2025 through July 2025. Appendix 1 contains a more
                       detailed description of our objective, scope, and methodology.


Results in Brief

                       We found that Air Center Helicopter, a passenger air carrier,
                       reported correct information for five of six sections reviewed on its
                       PSP2 Application. 4 These sections are: (1) Recipient Information,
                       (2) Eligibility Questions, (3) Company Information, (4) Affiliates,
                       and (5) Certification. We also found that Air Center Helicopter
                       reported incorrect information in the Determining Awardable
                       Amount section of the PSP2 Application.

                       We found that Air Center Helicopter included (1) $             in
                       employer-side payroll taxes, (2) $           in per diem expenses,
                       (3) $         in corporate officer compensation, (4) $26,954 from
                       the difference between the actual benefits paid and the PSP2
                       Application amount, and (5) $        from an ineligible-employee
                       expense, totaling $1,141,917. The unallowable expenses were
                       entirely offset by the company voluntarily withholding $
                       in eligible PSP2 compensation. Overall, Air Center Helicopter
                       understated their requested amount by $            . Therefore, we are
                       not making a recommendation.

                       As part of our reporting process, we provided Air Center
                       Helicopter’s management with an opportunity to comment on a
                       draft of this report. In a written response, Air Center Helicopter’s
                       management stated they are not contesting the conclusions or
                       recommendations in the report. Air Center Helicopter’s
                       management’s response, in its entirety, is included as appendix 2
                       of this report.


4
    The PSP2 Application is comprised of ten 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 amounts; and the Validation of Payroll Support
    Program (PSP1) Award Amount section had no impact on Air Center Helicopter’s PSP2 awarded
    amount because the company did not receive PSP1 financial assistance.



                       Audit of Airline Worker Support Extension Certification –
                       Air Center Helicopter Inc. (OIG-26-031)                                   2
                        In a written response, Treasury management noted that Air Center
                        Helicopter 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 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 passenger air carriers that file financial reports to
                        DOT (referred to as 241 air carriers), 5 in an amount equal to:
                        (1) the amount such air carrier was approved to receive (without
                        taking into account any pro-rata reduction) under the Payroll
                        Support Program (PSP1); 6 or (2) at the request of such air carrier,
                        or in the event such air carrier did not receive financial assistance
                        under PSP1, the amount of the salaries and benefits reported by
                        the air carrier to DOT, for the period from October 1, 2019,
                        through March 31, 2020.


5
    14 CFR Part 241, Uniform System of Accounts and Reports for Large Certificated Air Carriers
    defines large certificated air carrier 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. Air Center Helicopter is not a large certificated air carrier.
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 –
                        Air Center Helicopter Inc. (OIG-26-031)                                        3
Passenger air carriers that do not file financial reports to DOT
(referred to as non-241 passenger air carriers) were provided with
the alternative methods for calculating the awardable amount under
PSP2. Financial assistance was required in an amount equal to:

   (1) The amount such air carrier was approved to receive
   (without taking into account any pro-rata reduction) under
   PSP1, plus an additional 15 percent of such amount;

   (2) The sum of (a) the amount that such air carrier certifies,
   using sworn financial statements or other appropriate data, as
   the amount of total salaries and related fringe benefits that such
   air carrier incurred and would be required to be reported to DOT
   pursuant to such part 241, if such air carrier was required to
   transmit such information during the period from April 1, 2019,
   through September 30, 2019; and (b) an additional amount
   equal to the difference between the amount certified under part
   (a) and the amount the air carrier received under PSP1; or

   (3) In the event such air carrier did not receive financial
   assistance under PSP1, an amount such an air carrier certifies,
   using sworn financial statements or other appropriate data, as
   the amount of total salaries and related fringe benefits that such
   air carrier incurred and would be required to be reported to DOT
   pursuant to such part 241, if such air carrier was required to
   transmit such information during the period from
   October 1, 2019, through March 31, 2020.

The amounts submitted with the application to Treasury were
considered sworn financial statements. To be eligible for payments,
passenger air carriers 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:

   1. Recipient Information — (1) indication of whether the
      applicant is an eligible passenger air carrier or an eligible




Audit of Airline Worker Support Extension Certification –
Air Center Helicopter Inc. (OIG-26-031)                               4
                                 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
                               for PSP1, number of involuntary reductions after


7
   A Form-41 filer is a large certificated air 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 –
                        Air Center Helicopter Inc. (OIG-26-031)                                        5
                                   March 27, 2020; and (4) if applicant applied for PSP1,
                                   number of involuntary reductions after October 1, 2020.

                              7. Determining Awardable Amount — applicant’s decision on
                                 which method will be used to calculate the PSP2 awardable
                                 amount.

                              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 passenger air carrier applicants exceeded the
                          $15 billion available financial assistance. As a result, Treasury
                          applied a preliminary pro-rata rate of 40 percent to the requested
                          amount. Because its preliminary estimated pro-rata rate was low,
                          Treasury calculated an additional 6 percent, a top-off amount,
                          making the final pro-rata rate 46 percent. Generally, Treasury
                          disbursed two payments—each half of the awarded amount.

                          Air Center Helicopter, Inc.
                          Headquartered in Burleson, Texas, Air Center Helicopter is a
                          passenger air carrier that provides a variety of airlift support
                          services to U.S. Government and commercial clients.

                          Air Center Helicopter submitted its PSP2 Application totaling
                          $             on January 13, 2021. The company received


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 –
                          Air Center Helicopter Inc. (OIG-26-031)                                         6
                       $6,432,457, or 46 percent of the requested amount. Treasury’s
                       disbursements to Air Center Helicopter were as follows:

                           •   March 25, 2021: $2,796,720

                           •   April 5, 2021: $2,796,720

                           •   April 22, 2021: $839,017

                       In addition to PSP2, Treasury awarded Air Center Helicopter
                       $5,999,552 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 Air Center Helicopter reported correct information
                       for five of six sections reviewed on its PSP2 Application. These
                       sections are: (1) Recipient Information, (2) Eligibility Questions,
                       (3) Company 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, payroll registers,
                       and third-party benefit claim and invoice data, among other items.

                       We also found that Air Center Helicopter incorrectly reported
                       information in the Determining Awardable Amount section.
                       Specifically, the company included: (1) unallowable employer-side
                       payroll taxes, (2) per diem expenses, (3) corporate officer
                       compensation, (4) the difference between the actual benefits paid
                       and the PSP2 Application amount, and (5) an ineligible-employee
                       expense, totaling $1,141,917; however, the unallowable expenses
                       were entirely offset by the company voluntarily withholding
                       $             in eligible PSP2 compensation. Overall, Air Center
                       Helicopter understated its requested amount by $           .

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.
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 –
                       Air Center Helicopter Inc. (OIG-26-031)                                      7
Finding                  Air Center Helicopter Did Not Over-Request PSP2
                         Financial Assistance Despite Partial Non-Compliance With
                         Application Requirements
                         Treasury’s PSP2 Application instructs non-241 passenger air
                         carriers, who did not receive financial assistance under PSP1 to
                         complete a Form 41 Worksheet. The Form 41 Worksheet requested
                         the following information: (1) salaries for general management
                         personnel, flight personnel, maintenance labor, aircraft and traffic
                         handling personnel, and other personnel; (2) personnel expenses;
                         (3) employee benefits and pensions; and (4) payroll taxes. The
                         amounts reported in the worksheet were for October - December of
                         tax year 2019 and January - March of tax year 2020.

                         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
                            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;

                            employee as an individual who is employed by an air carrier or a
                            contractor and whose principal place of employment is in the
                            United States (including its territories and possessions),
                            including salaried, hourly, full-time, part-time, temporary, and
                            leased employees, but excluding any individual who is a
                            corporate officer or independent contractor;

                            corporate officer as with respect to a passenger air carrier, a
                            president; any vice president in charge of a principal business
                            unit, division, or function (such as sales, administration or
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 –
                         Air Center Helicopter Inc. (OIG-26-031)                                   8
   finance); any other officer who performs a policy-making
   function; or any other person who performs similar
   policy-making functions for the passenger air carrier or
   contractor. Executive officers of subsidiaries or parents of a
   passenger air carrier or contractor may be deemed corporate
   officers of the passenger air carrier or contractor if they perform
   such policy-making functions for the 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;

   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.

According to the Question and Answer: Payroll Support Program
Extension for Passenger Air Carriers and Contractors dated
January 19, 2021, PSP2 applicant’s requested awardable amount
must not include per diem expenses.

Air Center Helicopter incorrectly certified its PSP2 awardable
amount, resulting in an overstatement of $1,141,917. Specifically,
Air Center Helicopter included:

   •   Employer-side payroll taxes, resulting in an overstatement of
       $        ;

   •   Per diem expenses, resulting in an overstatement of
       $         ;

   •   Corporate officer compensation, resulting in an
       overstatement of $       ;




Audit of Airline Worker Support Extension Certification –
Air Center Helicopter Inc. (OIG-26-031)                          9
   •   Differences between the actual benefits paid and the
       application figures compiled using accrual-based financial
       information, resulting in an overstatement of $26,954, as
       detailed below:

           o Overstatement of $         in benefits requested for
             April 2020, which is outside of the October 1, 2019,
             through March 31, 2020 timeframe; and
           o Understatement of $          in unknown
             discrepancies; and

   •   Ineligible-employee (a member of the Board of Directors)
       transportation expense, resulting in an overstatement of
       $     .

The $1,141,917 overstatement was entirely offset due to
$            of eligible compensation paid to company employees
that Air Center Helicopter voluntarily withheld from the PSP2
Application. Overall, Air Center Helicopter understated its
awardable amount by $            as illustrated in Table 1.

Table 1: Aggregate Understatement

 Description                                                        Amount
 PSP2 Application Requested                             $
 Amount
    Less Employee Payroll Tax                               $
    Less Per Diem Expenses                                  $
    Less Corporate Officer
                                                                $
    Compensation
    Less Differences between
    Application and Actual                                      $(26,954)
    Benefits Paid
    Less Ineligible-Employee
                                                                        $
    Expense
    Plus Eligible Compensation                              $
    Excluded
  PSP2 Calculated Amount                                $14,011,784
 Understatement                                                     $
Source: S&R Calculation of Awardable Amount.




Audit of Airline Worker Support Extension Certification –
Air Center Helicopter Inc. (OIG-26-031)                                     10
Treasury’s Form 41 Worksheet instructed applicants to provide
employer-side payroll taxes; however, employer-side payroll taxes
were an unallowable expense per PSP2 Guidelines. Additionally, Air
Center Helicopter’s management stated that the inclusion of per
diem expenses, corporate officer compensation, an
ineligible-employee expense, and the differences between the
actual benefits paid and the PSP2 Application amount was due to
unintentional oversight. Air Center Helicopter’s management also
stated that eligible PSP2 employee compensation was excluded
from its PSP2 Application to exercise conservatism. Ultimately, the
company did not over-request PSP2 financial assistance; therefore,
we are not making a recommendation.

                              ******
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 –
Air Center Helicopter Inc. (OIG-26-031)                        11
Appendices

Appendix 1: Objective, Scope, and Methodology

             Our objective was to assess the accuracy, completeness, and
             sufficiency of Air Center Helicopter Inc.’s (Air Center Helicopter)
             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 13, 2021.

             To accomplish this objective, Saggar & Rosenberg, P.C. performed
             the following activities during audit fieldwork from January 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



             Audit of Airline Worker Support Extension Certification –
             Air Center Helicopter Inc. (OIG-26-031)                         12
Appendix 1: Objective, Scope, and Methodology

                           impact on Treasury’s determination of recipients’ award
                           amounts; and the Validation of Payroll Support Program Award
                           Amount section had no impact on Air Center Helicopter’s PSP2
                           awarded amount because the company did not receive Payroll
                           Support Program financial assistance.
                       •   Interviewed key Treasury personnel.
                       •   Interviewed Air Center Helicopter’s 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) benefit claim information,
                           (4) Internal Revenue Service Form 941 – Employer’s Quarterly
                           Federal Tax Return, and (5) 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 Air Center Helicopter’s 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 Air Center Helicopter’s payroll system,
                           we examined Air Center Helicopter’s response to Data Supplier
                           Questionnaires, 16 reviewed a System and Organizational
                           Controls 1 (SOC 1) report, 17 and interviewed Air Center
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 –
                       Air Center Helicopter Inc. (OIG-26-031)                                     13
Appendix 1: Objective, Scope, and Methodology

                   Helicopter’s management responsible for generating and using
                   the 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. Air Center Helicopter prepared the PSP2
                   Application using payroll and benefit information from Air
                   Center Helicopter’s payroll and financial accounting systems.
                   We compared details generated from the payroll registers at the
                   individual employee level, as well as third-party benefit data
                   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 Air Center Helicopter’s
                   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 –
               Air Center Helicopter Inc. (OIG-26-031)                          14
Appendix 2: Air Center Helicopter Inc.’s Management Response




             Audit of Airline Worker Support Extension Certification –
             Air Center Helicopter Inc. (OIG-26-031)                     15
Appendix 3: Treasury Management Response




            Audit of Airline Worker Support Extension Certification –
            Air Center Helicopter Inc. (OIG-26-031)                     16
Appendix 3: Treasury Management Response




              Audit of Airline Worker Support Extension Certification –
              Air Center Helicopter Inc. (OIG-26-031)                     17
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
              Air Center Helicopter, Inc.
                 Chief Executive Officer
                 Chief Operating Officer
              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 –
              Air Center Helicopter Inc. (OIG-26-031)                       18
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