Use of Federal Funds - Improper Payment Audit

The Department of Transportation (DOT) has initiated its FY 2017 Improper Payment Audit testing under the Improper Payment Elimination and Recovery Act of 2010 (IPERA) and the Improper Payment Elimination and Recovery Improvement Act of 2012 (IPERIA).

FRA’s IPERIA Program Training is available HERE

FRA Improper Payments Program Test Procedures Checklist

The following checklist supports all FRA grant recipients’ responsibilities for:

  • Grant execution to ensure proper use of federal funds; and
  • Retention of supporting payment documentation during grant execution and for three years following grant closeout.

1. Grant Agreement Approval

  Was the Grant Agreement approved by an authorized signor?

2. Valid Vendor

  Does the vendor meet any one of the three conditions?

  • The vendor is registered on the System for Award Management (SAM.gov) prior to entering into an agreement;
  • The vendor self-certified for eligibility of receiving federal funds; or 
  • The vendor agreement includes a clause or condition that the vendor is not suspended or disbarred.

3. Vendor Agreement Approval

  Was the vendor agreement approved by an authorized signor?

4. Date of Funding 

 Was the cost incurred after the vendor agreement was executed?

 Was the cost incurred within the agreed upon period of performance of the vendor agreement?

5. Allowable Costs

  Was the purpose of the payment allowable under OMB Circular A-87, Attachment B as well as the grant agreement and FRA grant provisions?

6. Invoice Discounts

  Were any applicable discounts taken advantage of at the time of payment?

7. Price

  Does the price on the invoice agree with the price in the vendor agreement?

8. Goods/Services Received

  Is there documentation that the contracted goods and/or services were received in exchange for payment?

  Was the cost approved by an appropriate authority?

9. Federal Share

  Is the federal share requested for reimbursement in accordance with the grant agreement?

10. Payment

  Is the price on the vendor’s invoice in accordance with the contract?

  Is the employee’s salary, hourly, or overtime rate approved and agree with the rate charged to the project?

11. Project Charged

  Was the cost charged to the project allowable under the grant agreement?

12. Buy America Certification

  Were items purchased subject to Buy America requirements or Amtrak’s Domestic Buying Preference?