a

GAO

United States General Accounting Office

Report to the Chairman, Subcommittee 

on Government Efficiency, Financial 

Management and Intergovernmental 

Relations, Committee on Government 

Reform, House of Representatives

June 2002 SINGLE AUDIT

Actions Needed to 

Ensure That Findings 

Are Corrected

GAO-02-705

Page i GAO-02-705 Single Audit

Contents

Letter 1

Results in Brief 2

Background 4

Objectives, Scope, and Methodology 5

Agencies’ Efforts to Ensure That Single Audit Findings are 

Corrected 8

Single Audit Results are Not Communicated to Agency 

Management 19

Conclusions 21

Recommendations for Executive Action 22

Agency Comments and Our Evaluation 23

Appendixes

Appendix I: Comments From the Department of Education 27

Appendix II: Comments From the Department of Housing and Urban 

Development 29

Appendix III: Comments From the Department of Transportation 32

Table Table 1: Number of Audit Findings with Documented Management 

Decisions 12

Abbreviations

CIFG Capital Investment and Formula Grants 

CMS Centers for Medicare and Medicaid Services

CDBG Community Development Block Grant

CPD Office of Community Planning and Development

FAC Federal Audit Clearinghouse

HPCG Highway Planning and Construction Grants

HUD Department of Housing and Urban Development

OCFO Office of the Chief Financial Officer

OESE Office of Elementary and Secondary Education

OIG Office of the Inspector General

OMB Office of Management and Budget

OSFA Office of Student Financial Assistance

PIH Office of Public and Indian Housing

REAC Real Estate Assessment Center
Page ii GAO-02-705 Single Audit
Page 1 GAO-02-705 Single Audit

United States General Accounting Office

Washington, D.C. 20548

A

June 26, 2002 Letr

The Honorable Stephen Horn

Chairman

Subcommittee on Government 

Efficiency, Financial Management

and Intergovernmental Relations

Committee on Government Reform

House of Representatives

Dear Mr. Chairman:

The Single Audit Act, as amended (Single Audit Act), is intended to 

promote sound financial management, including effective internal control 

over federal awards administered by state and local governments and 

nonprofit organizations. According to Office of Management and Budget 

(OMB) figures, these awards amounted to about $325 billion in fiscal year 

2001. The audits required by the Single Audit Act are a critical element in 

the federal government’s ability to ensure that federal funds are properly 

used. Each year, about 30,000 single audits are conducted with several 

thousand identifying weaknesses in award recipients’ financial 

management and internal control systems. The federal government must 

take timely and effective action to ensure that these weaknesses are 

corrected, not only to help ensure effective program operations but also to 

help minimize improper payments -- payments of federal funds that should 

not have been made or that were made for incorrect amounts. 

Given the important role of single audits as an oversight and monitoring 

tool and the critical need to address audit findings, you requested 

information on how federal agencies use single audits and what agencies 

are doing to ensure that recipients of federal awards have corrected 

problems identified by these audits. On February 19, 2002, we briefed you 

on the results of our survey on how the 24 agencies subject to the Chief 

Financial Officers Act indicate that they use single audit results and 

subsequently summarized those results in a report.1

 This follow-up report 

focuses on what program managers for six large programs, two each at the 

departments of Education (Education), Housing and Urban Development 

(HUD), and Transportation (Transportation), do to (1) ensure that federal 

1

U.S. General Accounting Office, Single Audit: Survey of CFO Act Agencies, GAO-02-376

(Washington, D.C.: Mar. 15, 2002).
Page 2 GAO-02-705 Single Audit

award recipients correct the current year and recurring findings identified 

in single audit reports and (2) summarize and communicate single audit 

results and recipient actions to correct audit findings to agency 

management for its use in evaluating agency oversight and monitoring of 

recipient performance and in identifying programwide and recipientspecific problem areas needing management attention. 

Results in Brief In examining the efforts of the departments of Education, HUD, and 

Transportation to ensure that recipients corrected single audit report 

findings, we found that each agency had procedures for obtaining and 

distributing the audit reports to appropriate officials for action. However, 

they often did not issue the required written management decisions or have 

documentary evidence of their evaluations of and conclusions on 

recipients’ actions to correct the audit findings. In addition, program 

managers did not summarize and communicate information on single audit 

results and recipient actions to correct audit findings to agency 

management. 

The three agencies have implemented procedures for obtaining single audit 

reports and distributing audit finding information to appropriate agency 

officials. These procedures varied from having (1) a designated unit review 

and evaluate audit findings and forward them to the appropriate 

organizational units for action to (2) diffused responsibility calling for 

program units to identify and obtain single audit reports with findings 

involving their programs and to take action on those findings. 

Program managers did not consistently issue written management 

decisions to notify the recipients of the corrective actions the federal 

agency deemed necessary to correct the audit findings contained in the 

single audit reports. Our review of the audit files at the three agencies 

revealed that, as of March 2002, the agencies had issued management 

decisions for only 75 (about 30 percent) of the 246 audit findings contained 

in our sample of calendar year 1999 single audit reports. 

The agencies noted several reasons for not preparing management 

decisions for all findings. These include 

• the findings were insignificant and did not require further action,

• follow up with recipients was performed but not documented,
Page 3 GAO-02-705 Single Audit

• the audit report that identified the finding also indicated that the 

recipient had corrected the audit finding as of the report issuance date, 

and

• review of subsequent single audit reports showed that the recipient 

corrected the finding.

The audit files generally did not contain documentation that agency 

officials considered any of these factors or used them as a justification for 

not preparing the required management decisions. 

Regarding agency efforts to ensure that federal award recipients correct 

audit findings, we found that, while the audit files contained copies of 

recipient documents and other records, they did not contain agency 

evaluations of or conclusions on the adequacy of the actions cited in those 

records. Without such information, we could not determine the agency’s 

position on the adequacy of the actions taken or on the need for additional 

actions. 

Program managers also did not summarize and communicate information 

on single audit results and recurring and commonly occurring findings to 

agency management. Compiling and reporting single audit results centrally 

could reveal or confirm the existence of internal control and other 

problems. It can help strengthen accountability and oversight by providing 

management with information useful in the analyses of both programwide 

problems and recurring problems at specific recipients. Further, it can 

provide management officials with information relevant to agency efforts 

to reduce improper payments – a key element of The President’s 

Management Agenda, Fiscal Year 2002, initiative to improve financial 

performance. Our analysis of the Federal Audit Clearinghouse (FAC) 

single audit database information2

 showed common types of findings at 

award recipients for several years and that individual recipients continued 

to have similar and recurring audit findings. For example, program 

eligibility and allowable costs findings were both repeat problems over a 3-

year period for some recipients and were problems for several recipients in 

our sample. 

2

The FAC single audit database was established as a result of the Single Audit Act 

Amendments of 1996 and contains summary information on the auditor, the recipient and its 

federal programs, and the audit results. 
Page 4 GAO-02-705 Single Audit

To help ensure the effective implementation of the Single Audit Act and 

that recipients correct the weaknesses identified in single audit reports, we 

recommend that the Secretary at each of the three agencies develop and 

ensure the implementation of single audit guidance that meets all OMB 

Circular A-133 requirements. We also recommend that the Secretary at 

each of the agencies implement policies and procedures for reporting 

information to agency management on (1) the types and causes of findings 

identified in single audit reports and (2) the status of corrective actions. 

This information could be useful in evaluating agency efforts to ensure that 

recipients correct audit findings and identifying programwide and 

recipient-specific problem areas needing management attention.

In commenting on this report, Education and HUD agreed with the findings 

and recommendations. They provided several editorial and/or clarification 

changes and supplemental information that we considered and included in 

the report, as appropriate. Transportation’s comments raised several 

issues concerning both the scope of our audit work and the 

appropriateness of our conclusions and recommendations. Despite the 

comments and the issues they raised, we continue to believe that our 

conclusions are sound and that the recommendations for agency actions 

are needed to help ensure the overall effectiveness of agencies’

implementation of the Single Audit Act and of their consideration and use 

of single audit findings. The “Agency Comments and Our Evaluation”

section of this report provides more detailed information on each agency’s 

comments on a draft of this report, which are reprinted in appendixes I 

through III. 

Background The Single Audit Act is intended to, among other things, 

• promote sound financial management, including effective internal 

controls, with respect to federal awards administered by nonfederal 

entities; 

• promote the efficient and effective use of audit resources; and 

• ensure that federal departments and agencies, to the maximum extent 

practicable, rely upon and use single audit work.

The Single Audit Act requires state and local governments and nonprofit 

organizations that expend $300,000 or more in federal awards in a fiscal 

year to have either a single audit or program-specific audit conducted. 
Page 5 GAO-02-705 Single Audit

Federal awards include grants, loans, loan guarantees, property, 

cooperative agreements, interest subsidies, insurance, food commodities, 

and direct appropriations and federal cost reimbursement contracts. 

The Single Audit Act also requires recipients to forward an audit reporting 

package to the FAC for archival purposes and for distribution to each 

federal agency responsible for programs for which the audit report 

identifies a finding. The reporting package includes (1) the recipient’s 

financial statements and schedule of expenditures of federal awards, (2) a 

summary schedule of prior audit findings, including the status of all audit 

findings included in the prior audit’s schedule of findings and questioned 

costs for federal awards, (3) the auditor’s opinion on the recipient’s 

financial statements and schedule of expenditures of federal awards, 

reports on internal control and compliance with laws, regulations, and 

provisions of contracts or grant agreements, and (4) a schedule of findings 

and questioned costs. 

Single audits are a key control for the oversight and monitoring of recipient 

use of federal awards. Federal agency actions to ensure that award 

recipients address audit findings contained in single audit reports are a 

critical element in the federal government’s ability to efficiently and 

effectively administer federal awards. These findings can include internal 

control weaknesses; material noncompliance with the provisions of laws, 

regulations, or grant agreements; and fraud affecting a federal award. 

The President’s Management Agenda, Fiscal Year 2002, identifies the 

need to reduce improper payments as a significant element of the 

Administration’s initiative to improve financial performance throughout the 

government. Single audits can have an impact on the government’s efforts 

to address improper payments since many of the programs experiencing 

improper payments are audited as part of the over 30,000 single audits 

conducted annually. For example, recent estimates by the departments of 

Agriculture and HUD identified about $976 million and $2 billion in 

improper payments in food stamps and housing subsidy programs, 

respectively. These programs are often audited as part of a single audit. 

Objectives, Scope, and 

Methodology

Our objectives were to determine what program managers for six large 

programs, two each at Education, HUD, and Transportation, do to (1) 

ensure that federal award recipients correct the current year and recurring 

findings identified in single audit reports and (2) summarize and 

communicate single audit results and actions taken to correct audit 
Page 6 GAO-02-705 Single Audit

findings to agency management for its use in evaluating agency oversight 

and monitoring of recipient performance and in identifying programwide 

and recipient-specific problem areas needing management attention. We 

selected these agencies because they are three of the four federal agencies 

that provide the largest amount of federal awards to state and local 

governments and nonprofit organizations. OMB documents show that, in 

fiscal year 2001, these agencies made grants totaling $84 billion to state and 

local governments. We did not include the Department of Health and 

Human Services, the agency with the largest amount of federal awards, in 

this review because of our current work3

 to evaluate the Centers for 

Medicare and Medicaid Services’ (CMS) efforts to monitor its financial 

oversight to help ensure the propriety of Medicaid expenditures. That 

work included the review of single audit reports for fiscal year 1999 and 

found that the correction of audit findings and monitoring of CMS and its 

regional offices were limited and audit resolution activities were 

inconsistently performed across regions.

To assess how program managers ensure that federal award recipients 

corrected problems discussed in single audit reports, we reviewed the 

Single Audit Act, OMB Circular A-133, Audits of States, Local 

Governments, and Non-Profit Organizations, and the Comptroller 

General’s Standards for Internal Control in the Federal Government to 

identify agency responsibilities for correcting single audit findings. This 

review identified the following three areas of responsibility, which 

represent the criteria we used in making our assessment. 

• Obtain single audit reports and distribute them to agency officials 

responsible for reviewing the report findings and taking actions on 

those findings.

• Issue written management decisions on audit findings within 6 months 

of the receipt of the audit report to notify recipients of actions the 

federal agency considers necessary to correct the audit findings.

• Follow up with award recipients to ensure that corrective actions 

occurred.

3

U.S. General Accounting Office, Medicaid Financial Management: Better Oversight of 

State Claims for Federal Reimbursement Needed, GAO-02-300 (Washington, D.C.: Feb. 28, 

2002). 
Page 7 GAO-02-705 Single Audit

The FAC single audit database was established as a result of the Single 

Audit Act Amendments of 1996 and contains summary information on the 

auditor, the recipient and its federal programs, and the audit results. We 

did not independently test the reliability of the database. However, at 

OMB’s request, the Office of the Inspector General (OIG) at the Department 

of Commerce reviewed the database to assist OMB, the Census Bureau, 

and other users in assessing the accuracy of the fiscal year 1998 audit 

report information in the database. We reviewed the OIG’s sampling 

methodology, monitored the audit scope and the progress of the review, 

and discussed the results with OMB and OIG officials. We concluded that 

the database for calendar year 1999 was reliable and adequate for our 

sampling purposes. 

At each agency, we identified two large award programs and queried the 

FAC single audit database for calendar year 1999 single audit reports4

 to 

determine the 10 grantees receiving the largest amount of funding for each 

program. The programs identified for review were Title I5

 and Pell Grants6

at Education, the Community Development Block Grant7

 (CDBG) 

entitlement and Section 8 Tenant-Based8

 (Section 8) programs at HUD, and 

Capital Investment and Formula Grants9

 (CIFG) and Highway Planning and

4

We used calendar year 1999 single audit reports because that was the most recent year for 

which all audit reports and agency responses were available and it provided the most 

complete universe from which our selection of audit findings could be made. 

5

The objective of Title I is to improve the teaching and learning of children who are at risk of 

not meeting challenging academic standards and who reside in areas with high 

concentrations of children from low-income families. 

6

The objective of the Pell Grant program is to provide eligible undergraduate postsecondary 

students who have demonstrated financial need with grant assistance to help with 

expenses. 

7

The primary objective of the CDBG program is to develop viable urban communities by 

providing decent housing, a suitable living environment, and expanding economic 

opportunities, principally for persons of low or moderate income. 

8

The primary objective of the Section 8 Tenant-Based program is to assist very low income 

families in affording decent, safe, and sanitary housing. 

9

The objective of the Capital Investment and Formula Grants is to assist in financing the 

planning, acquisition, construction, preventative maintenance, and improvement of facilities 

and equipment in mass transportation services. 
Page 8 GAO-02-705 Single Audit

Construction Grants10 (HPCG) at Transportation. For each grantee 

identified above, we queried the FAC single audit database to identify audit 

findings in the programs selected. The query identified 246 audit findings. 

We interviewed agency officials and reviewed agency guidance to 

determine their procedures for ensuring that audit findings are 

communicated to appropriate officials and/or offices for action and 

assessment of recipients’ corrective actions. We also provided each agency 

with a list of the audit reports and findings selected for review. For each 

finding, we requested documentation including written management 

decisions and evidence of agency follow up with recipients on the 

corrective actions taken and the appropriateness of those actions. We 

interviewed agency officials and reviewed the management decisions and 

documentation provided on agency follow up on recipient corrective 

actions. 

Reporting single audit results and recipient actions to correct audit findings 

to agency management provides management with valuable information 

for use in assessing program risks and identifying areas needing action. To 

determine whether and how the three selected agencies summarized and 

communicated the single audit results and actions to correct audit findings 

to agency management, we interviewed officials at the three agencies to 

determine the reports generated to inform agency officials of the single 

audit results.

We conducted our review from October 2001 through March 2002 in 

accordance with generally accepted government auditing standards.

Agencies’ Efforts to 

Ensure That Single 

Audit Findings are 

Corrected

Education, HUD, and Transportation had procedures in place that 

established responsibility for obtaining, distributing, and reviewing single 

audit findings and for communicating that information to appropriate 

officials for action. However, although required by OMB Circular A-133, 

agencies often did not issue written management decisions or have 

documentary evidence of their evaluations of and conclusions on recipient 

actions to correct the audit findings. 

10The objectives of the Highway Planning and Construction Program are to assist states in 

constructing and rehabilitating the National Highway System, foster safe highway design, 

and replace or rehabilitate unsafe bridges. 
Page 9 GAO-02-705 Single Audit

Guidance Existed for 

Obtaining Single Audit 

Reports and Distributing 

Reports to Appropriate 

Officials 

If federal agencies are going to take action on single audit findings, they 

must first obtain the single audit reports or other documentation 

containing single audit findings relating to their programs and distribute 

this information to appropriate offices for action. The three agencies in our 

review had procedures for obtaining single audit reports and for 

distributing audit finding information to appropriate agency offices. 

Receipt and Distribution of 

Single Audit Findings - 

Education

At Education, different offices receive and distribute single audit reports or 

audit findings. For example, the Office of the Chief Financial Officer’s 

(OCFO) audit resolution coordinator receives copies of single audit reports 

with Title I program findings from the FAC and distributes audit finding 

information to the Office of Elementary and Secondary Education (OESE). 

OESE is responsible for the overall administration of the Title I program 

and resolving the audit findings and following up on corrective actions. 

The Office of Student Financial Assistance (OSFA) administers the Pell 

Grant program. OSFA receives copies of the single audit reports with Pell 

Grant findings directly from the FAC and distributes copies of the reports 

to the appropriate Pell Grant program offices for action. 

Receipt and Distribution of 

Single Audit Findings - HUD

Although the FAC provides copies of single audit reports containing HUD 

program audit findings to the OCFO, officials responsible for the CDBG 

and Section 8 programs stated that their offices did not use those reports to 

identify single audit reports with findings. Rather, they obtained copies of 

single audit reports and/or audit finding information relating to their 

programs from other sources, including the award recipients and a HUD 

database developed by its Real Estate Assessment Center (REAC). OCFO 

officials noted that the office considers these procedures more efficient 

than having OCFO personnel review each single audit report, identify audit 

findings, and distribute those findings to the appropriate HUD offices. 

To identify CDBG findings, the Office of Community Planning and 

Development (CPD) tasks its 42 field offices with identifying award 

recipients whose single audit reports contained CDBG-related audit 

findings. An August 2000 CPD memorandum instructed field offices to 

query the FAC single audit database to identify single audit reports 

containing audit findings related to the CDBG program and to obtain copies 

of these single audit reports directly from the federal award recipients. To 

perform this task, the field offices use award documents and other agency 

reports to identify award recipients for which they have oversight 

responsibility. They then query the FAC single audit database to identify 
Page 10 GAO-02-705 Single Audit

those recipients whose single audit reports contain findings and obtain 

copies of those reports directly from the recipients. 

For the Office of Public and Indian Housing (PIH), program managers 

located in 43 PIH field offices generally obtain audit finding information for 

the Section 8 program from HUD’s REAC database. Recipients 

electronically submit financial and compliance information, which is 

excerpted from single audit reports, directly into the REAC system for 

REAC analysis. According to HUD officials, this database contains 

information including the financial statements, notes to the financial 

statements, the schedule of expenditures of federal awards, the type of 

audit opinion, an identification of audit findings, and recipient corrective 

action plans. Findings that are in noncompliance with HUD regulations 

and agreements are referred to the HUD Departmental Enforcement Center 

for processing and follow up. PIH officials stated that the REAC database 

covers about 75 percent of the Section 8 program recipients and that 

program managers responsible for overseeing federal award recipients not 

covered by REAC could query the FAC single audit database to identify 

other single audit reports with findings. Once program managers identify 

reports with findings, they obtain copies of the single audit reports directly 

from the recipients. PIH is in the process of developing single audit 

guidance that it plans to issue during the summer of 2002. 

Receipt and Distribution of 

Single Audit Findings - 

Transportation

The OIG receives single audit reports from the FAC and decides which 

single audit findings should be formally addressed by the Operating 

Administrations based on a number of factors. These factors include the 

dollar amount of expenditures, the number of federal award findings 

identified by the auditor, and the type of finding identified. Based on its 

decisions, the OIG sends “action” memoranda to the program field offices 

informing them of the single audit findings that require action and a 

response to the OIG. The OIG uses “informational” memoranda to inform 

the program field offices of single audit findings for which the OIG does not 

require a formal response. Although the OIG does not require a formal 

response on the “informational” memoranda, agency officials stated that 

they expect the field offices to ensure that recipients correct all findings, 

irrespective of the type of memorandum used to communicate the findings. 

An agency official noted that they developed this method of addressing 

audit report findings because they consider many findings insignificant and 

follow up by OIG officials is not an effective use of resources. 
Page 11 GAO-02-705 Single Audit

Written Management 

Decisions Generally Not 

Prepared

Our review found that the audit files at the three agencies contained 

written management decisions for 75 (about 30 percent) of the 246 

findings. OMB Circular A-133 requires federal agencies to issue written 

management decisions on the audit findings contained in single audit 

reports within 6 months of receiving the recipient’s single audit report. The 

management decisions should describe the corrective actions agencies 

consider necessary based on their evaluation of the audit findings and 

corrective action plans contained in the single audit reporting package. 

Since federal agencies are responsible for ensuring that the recipients 

implement adequate corrective action, it is important for management to 

clearly communicate the agency’s expectations and time frames for action 

through management decisions. 

The issuance of a management decision is also critical because, based on 

OMB Circular A-133, award recipients may consider an audit finding invalid 

and not warranting further action if all the following have occurred: 

• a management decision was not issued,

• 2 years have passed since the audit report in which the finding occurred 

was submitted to the FAC, and

• the federal agency or pass-through entity11 is not currently following up 

with the recipient on the audit finding.

As shown in table 1, the audit files reviewed contained documentation 

evidencing management decisions for 75 of the 246 audit findings 

contained in our sample audit reports. 

11OMB Circular A-133 defines a pass-through entity as a nonfederal entity that provides a 

federal award to a subrecipient to carry out a federal program. 
Page 12 GAO-02-705 Single Audit

Table 1: Number of Audit Findings with Documented Management Decisions

Agency officials noted several possible reasons that management decisions 

were not prepared and available for our review including 

• the findings were insignificant and did not require further action, 

• follow up with recipients was performed but not documented, 

• the audit report that identified the finding also indicated that the 

recipient had corrected the audit finding as of the report issuance date, 

and 

• subsequent audit reports were reviewed to determine if the finding had 

been corrected. 

The audit files generally did not contain an indication that agency officials 

considered any of these four factors or used them as a justification for not 

preparing the required management decisions. Since it is the federal 

agency’s responsibility to ensure that corrective action implemented by the 

recipient will correct a finding, the agency should be on record as agreeing 

with the recipient’s planned or completed corrective actions or pointing out 

other actions needed to correct the findings. In our view, none of the 

reasons cited justify the nonissuance of a management decision. For 

example, by including a finding in a single audit report, auditors are 

indicating that the finding is significant since government auditing 

 Agency/program

Audit

findings

Management decisions

Documented Not documented

Education/Pell Grant 66 53 13

Education/Title I 47 13 34

HUD/Community Development 

Block Grants (CDBG)

37 3 34

HUD/Section 8 48 2 46

Transportation/Capital 

Investment and Formula Grants 

(CIFG)

17 4 13

Transportation/Highway 

Planning and Construction 

Grants (HPCG)

31 0 31

Total 246 75 171
Page 13 GAO-02-705 Single Audit

standards require auditors to report all significant findings in the report. 

The standards identify other means of communicating insignificant 

findings. Regarding the use of subsequent-year single audit reports to 

justify the nonissuance of a management decision, it should be noted that 

single audit reports must be issued no later than 9 months after the 

recipient’s year-end. By waiting for the subsequent year’s audit report, as 

many as 21 months could have expired from the end of the audit period for 

which the finding was initially reported to the receipt of the subsequent 

year’s audit report. In our opinion, waiting for the subsequent audit report 

would not result in a timely notification to the recipient of the agency’s 

position on an audit finding and the recipient’s planned, in progress, or 

completed corrective actions. 

The following section provides more detailed information on the results of 

our review of management decisions. 

Management Decisions - 

Education 

Our review of the audit files for the 113 Title I and Pell Grant audit findings 

at Education revealed that 66 of the findings had documented management 

decisions. Of the 47 with no written management decisions, 25 were in the 

Cooperative Audit Resolution and Oversight Initiative (CAROI) process, 

which is discussed in more detail below. 

When either the OESE or Pell Grant program offices receive single audit 

findings, special teams assess the seriousness of the audit findings to 

determine the amount of attention needed for resolution. According to 

draft Education guidance, Post Audit User Guide, which has been in effect 

since 1987 and has been periodically updated, the purpose of this 

assessment process is to promote the most efficient use of external audits 

to assist management in achieving program goals and discharging its 

fiduciary responsibilities. The teams evaluate the audit findings based on 

criteria established in the draft guidance, which states that audit findings 

may be addressed using three approaches -- full resolution, abbreviated 

resolution, or technical assistance. The principle criteria used in evaluating 

each finding and determining the resolution approach is the seriousness of 

the finding, that is, the monetary or program compliance issues identified 

or the recurring nature of the finding. Full and abbreviated resolution 

approaches require written notification to the recipient. The guidance 

states that resolution by technical assistance does not require a written 

management decision. However, it does require that all communication 

with the auditee in the resolution of an audit finding using the technical 

assistance approach be documented and available in the audit file. 
Page 14 GAO-02-705 Single Audit

Education has also developed a process to facilitate management decisions 

on complex audit issues affecting multiple programs. This process, CAROI, 

uses a collaborative approach to resolve audit findings and their underlying 

causes. During the CAROI process, representatives from Education’s 

program and OIG offices work collaboratively with state and local program 

managers to address complex audit findings affecting multiple programs. 

An agency official noted that the process may not be completed in the 6-

month management decision time frame set forth in OMB Circular A-133. 

For those findings in our sample being addressed using the CAROI process, 

the 6-month requirement was not met. It should be noted, however, that an 

Education report12 stated that CAROI projects have had a positive impact in 

reducing recurring findings identified in statewide audits.

Of the 25 single audit findings with no management decisions that are in the 

CAROI process, 22 relate to one recipient. Education officials told us that 

they are working with other federal agencies, including the Department of 

Justice, on fraud and other program-related issues involving this recipient. 

Regarding the remaining 22 findings with no written management 

decisions, officials stated that, depending upon the approach the review 

team determined appropriate for the audit finding, program staff may have 

followed up with recipients but not prepared a management decision. They 

noted that, although no record of these discussions was in the audit files, 

this could have been the case for at least some of the 22 audit findings. 

OMB Circular A-133 requires that management decisions clearly state 

whether or not the federal agency sustains the audit finding, the reasons for 

the decision, the expected corrective action, and that they describe any 

appeal process available to the recipient. Further, the Circular requires 

that, if the recipient has not completed corrective action as of the 

management decision date, the decision should give a timetable for this 

action. For the 66 findings with written management decisions, our review 

showed that the management decisions often did not contain all of the 

elements required by OMB Circular A-133. For example, 5 of the Title I 

management decisions and 25 Pell Grant management decisions did not 

include a timetable for follow up on the implementation of corrective 

12Department of Education, Management Challenges: Successes and On-Going Efforts, 

(Washington, D.C.: June 2001 (http:///www.Ed. Gov/Pubs/Planrpts (downloaded May 24, 

2002). 
Page 15 GAO-02-705 Single Audit

action. Further, 3 of the Pell Grant findings did not include expected action 

to correct the findings. 

Management Decisions - HUD HUD files contained only five written management decisions for the 85 

CDBG and Section 8 program audit findings we reviewed. The audit files 

contained three written management decisions for the 37 CDBG audit 

findings. Fifteen of these findings were first-time findings and 22 were 

recurring findings. Of the recurring findings, 16 related to one recipient. 

Further, only two of the 48 Section 8 findings had written management 

decisions. Of these findings, 16 were first-time findings and 32 were 

recurring findings. Eighteen of the recurring findings were for one 

recipient. This recipient has been identified as having multiple internal 

control issues related to HUD and other federal agencies that require 

coordination with the OIG and other federal agencies. HUD officials 

stated that they were continuing to work with the recipient to resolve these 

issues. 

Officials from both the Offices of Community Planning and Development 

and Public and Indian Housing noted that one possible reason for the lack 

of a written management decision was that program personnel reviewed 

the subsequent year’s single audit reports and determined that no further 

action was necessary based on the status of corrective actions as cited in 

the report. Our review of the calendar year 2000 audit reports indicated 

that 27 (13 CDBG and 14 Section 8) of the 85 findings in our sample had 

been corrected. Therefore, this possibility did not account for most of the 

instances of missing management decisions. Further, as noted earlier, 

agencies generally receive subsequent single audit reports well after the 6-

month time frame within which management decisions are required. So, at 

a minimum, the agency did not comply with OMB Circular A-133 timing 

requirements for the issuance of management decisions. 

Like Education, HUD’s management decisions did not include all OMB 

Circular A-133-required information. For example, two of the three CDBG 

program management decisions did not include a timetable for follow up.

In response to our work, HUD’s Office of Community Planning and 

Development issued Field Guidance on Single Audit Act Requirements

(CPD Field Guidance) on March 13, 2002. This guidance contains 

requirements outlined in OMB Circular A-133, including the requirements 

that management decisions clearly state whether or not the audit finding is 

sustained, the reasons for the decision, and the expected grantee action. If 

the recipient has not completed corrective action, the guidance requires 
Page 16 GAO-02-705 Single Audit

that the field offices establish a timetable for follow up. Finally, the 

guidance requires that management decisions describe the appeal process 

available to the recipient. In issuing this guidance, CPD referred to our 

review as showing that more detailed guidance was needed to help ensure 

that CPD properly carries out its oversight responsibilities. This guidance 

is a positive step toward ensuring that management decisions are issued for 

all audit findings related to the CDBG program. According to PIH officials, 

they plan to issue guidance covering the process for correcting audit 

findings contained in single audit reports in the summer of 2002. 

Management Decisions - 

Transportation

Transportation files contained only four written management decisions for 

the 48 CIFG and HPCG audit findings we reviewed, all of which related to 

the 17 CIFG findings. Transportation guidance requires each Operating 

Administration to establish a system to ensure prompt responses to audit 

reports and implementation of audit recommendations. The guidance 

requires that the system provide for a complete record of actions taken on 

audit recommendations. Transportation assigns program managers in field 

offices the responsibility for preparing management decisions and 

following up on corrective action for those findings addressed in OIG 

“action” memoranda. Despite this guidance, we found few written 

management decisions in the audit files reviewed. 

The OIG issued “action” memoranda for 4 of the 17 CIFG findings. 

Management decisions existed for 2 of these findings, 1 of which involved 

questioned costs of over $300,000 and for which the single audit report 

noted that corrective actions had been completed. The other 2 

management decisions involved audit findings for which the OIG had 

issued “informational” memoranda. Further, of the 31 HPCG findings, the 

OIG issued two “action” memoranda that addressed 10 findings. The audit 

files did not contain written management decisions for these findings. 

Our review of the management decisions to determine if they contained all 

OMB Circular A-133-required elements revealed that none of the four 

Transportation management decisions did so. For example, they did not 

contain information on the reason for the decision to sustain or not sustain 

the audit finding or a description of the appeals process. 

Follow Up Needed to 

Ensure Completion of 

Corrective Actions

Program officials at the three agencies told us that they follow up on the 

implementation of corrective actions through site visits, telephone 

conversations, and review of subsequent single audit reports. Although the 

audit files contained some information relating to corrective actions, we 
Page 17 GAO-02-705 Single Audit

found very little documentation identifying program or field office 

evaluations of and conclusions on the adequacy of the corrective actions 

taken by recipients. OMB Circular A-133 requires agencies to provide the 

recipient with a timetable for implementing corrective action and to ensure 

that the award recipient takes appropriate and timely corrective actions. 

The Comptroller General’s Standards for Internal Control in the Federal 

Government states that agency efforts to monitor internal controls should 

include policies and procedures for ensuring that the findings of audits and 

other reviews are promptly resolved. The lack of documentation makes it 

difficult for management to ensure that program offices and award 

recipients are meeting their audit finding-related responsibilities in an 

appropriate and timely manner. 

Corrective Action Follow Up - 

Education

Our review of the audit files for the 47 Title I and 66 Pell Grant audit 

findings showed that 5 Title I and 25 Pell Grant files did not contain 

documentation of follow-up actions. Education’s program managers 

responsible for the Title I and Pell Grant programs stated that they verify 

that corrective action was implemented using site visits and subsequent 

single audit reports. Education’s draft guidance requires program officials 

to maintain accurate records of all audit follow-up activities, including all 

correspondence, documentation, and analysis of the documentation. 

Based on our audit file review, we were unable to verify that the agency had 

evaluated and concluded on the adequacy of the recipient’s corrective 

actions. 

Corrective Action Follow Up - 

HUD

Our review of 85 single audit findings for the CDBG and Section 8 programs 

identified documentation of follow up for 28 of the findings. For example, 

the audit files contained evidence of a review of subsequent single audit 

reports for 14 findings and of follow up with the recipient and 

determination that the audit finding was resolved for 4 findings. 

CPD and PIH officials advised us that program managers located in field 

offices are tasked with following up with recipients on audit findings 

contained in single audit reports. They told us that these offices used 

various procedures, including contacting the federal award recipients 

concerning the audit findings and corrective actions and reviewing the 

status of the audit findings in the subsequent single audit reports, to 

determine if the audit findings were corrected. If considered appropriate, 

field offices might also conduct on-site monitoring visits at the award 

recipients. While field office staff may have actively followed up on 

findings, our review of audit files provided by field office locations showed 

evidence of follow up or monitoring for only 28 of the 85 findings. 
Page 18 GAO-02-705 Single Audit

The March 2002 CPD Field Guidance requires each field office to maintain 

files that contain all audit-related communications with the CPD award 

recipients, including any appropriate reports from the FAC, audit reports, 

and, if applicable, the auditor’s management letter.13 As noted above, PIH 

officials stated that they also plan to issue guidance in the summer of 2002 

covering the process for correcting audit findings contained in single 

audits. 

Corrective Action Follow Up - 

Transportation

Our review of documentation provided by Transportation for the 17 CIFG 

and 31 HPCG audit findings revealed little evidence of follow-up activity in 

the audit files. Although these files contained some information relating to 

corrective actions, they generally did not contain documentation 

identifying agency evaluations of and conclusions on the adequacy of the 

corrective actions taken by recipients. Without documentation that 

corrective action is appropriate, timely, and implemented, management 

cannot be sure that program offices and award recipients are meeting their 

audit finding-related responsibilities. 

During discussions with field office program managers, we determined that 

follow-up activities vary widely. For example, personnel in one field office 

told us that the office follows up with the recipient to ensure that 

corrective action has been implemented and that follow up is tracked and 

documented using an automated system. Other field office program 

managers told us that they review the subsequent year’s single audit report 

to determine if the deficiency has been corrected and may verify that 

corrective action has been implemented during site visits to the recipient. 

However, the audit files reviewed did not contain evidence of agency 

evaluations of or conclusions on the adequacy of recipient actions to 

correct audit findings. 

Audit follow-up guidance issued by the Office of the Secretary in 1989 

requires each Operating Administration to establish a system to ensure 

prompt responses to audit reports and the implementation of audit 

recommendations and further states that the system must be capable of 

reporting in a timely and uniform manner in order to meet information and 

reporting requirements. Transportation’s current guidance, which it issued 

in March 2000, makes no mention of several OMB requirements included in 

earlier agency guidance, including the contents of management decisions, 

13The auditor’s management letter contains findings that the auditor did not consider 

significant enough to include in the audit report.
Page 19 GAO-02-705 Single Audit

timely responses to audit reports and follow up procedures, and 

maintaining records of follow-up actions. 

Single Audit Results 

are Not Communicated 

to Agency Management

Based on discussions with officials at the three agencies, none of the 

program offices with management decision preparation and corrective 

action responsibilities reported single audit results or recipient actions to 

correct single audit findings to agency management. Although neither the 

Single Audit Act nor OMB Circular A-133 requires this reporting, the 

Comptroller General’s Standards for Internal Control in the Federal 

Government note that agency officials, program managers, and others 

responsible for managing and controlling program operations need 

relevant, reliable, and timely information to make operating decisions, 

monitor performance, and allocate resources. 

Discussions with officials at each of the three agencies revealed that, even 

when program or other offices have information on single audit results and 

recipient actions to correct single audit findings, this information is not 

communicated to agency management for review, analysis, and possible 

action. 

• Although officials at Education’s OCFO told us that their audit 

resolution tracking system was capable of reporting on the status of 

single audit findings, no reporting to Education management occurred. 

• According to an OCFO official at HUD, the various program offices 

within HUD do not prepare reports on the status of audit findings 

contained in single audit reports.

• At Transportation, the OIG reports unresolved and incompletely 

corrected single audit findings in its semi-annual report to the Congress. 

However, the report does not include information on all single audit 

findings, since the OIG only tracks findings for which it issues “action”

memoranda, and the report contains only general information and no 

specific details on the nature and extent of single audit findings. 

Information for such management reporting can come from many sources 

including agency analyses of single audit findings and agency databases, 

such as HUD’s REAC database. Another valuable source of information is 

the FAC single audit database. This database consists of information 

obtained from a data collection form that recipients send to the FAC as part 

of their single audit reporting package. It contains summary information 
Page 20 GAO-02-705 Single Audit

on the auditor, the recipient and its federal programs, and audit results. 

The database contains about 4 years of information on over 30,000 annual 

single audit reports. The various data query options available provide 

potential users, including program managers, auditors, and other interested 

parties, with significant amounts of readily available information on grant 

recipient financial management and internal control systems and on 

compliance with federal laws and regulations.

To determine the types and frequency of audit findings at the six programs 

in the three agencies included in our review, we queried the FAC single 

audit database and reviewed the sample single audit reports to determine if 

the grantees in our selection had similar types of audit findings. Our query 

showed that similar audit findings were reported for grantees in each of the 

programs. For example, 33 of the 66 audit findings we reviewed for the Pell 

Grant program were attributable to grantees’ noncompliance with special 

tests and provisions applicable to the program. These findings typically 

involved situations where colleges or universities were unable to provide 

documentation to show that students receiving federal aid attended class. 

For Title I programs, 11 of the 47 audit findings reviewed were attributable 

to grantees’ noncompliance with allowable costs provisions specified in the 

grant. Further, our query showed 16 of the 37 audit findings for recipients 

of HUD’s CDBG program were attributable to noncompliance with the 

grants reporting requirements, and 18 of the 48 HUD Section 8 program 

audit findings were attributable to grantees’ noncompliance with the 

special test and provisions requirements of the Section 8 grants.

We also queried the FAC single audit database to determine if any of the 

programs selected for review had recurring types of audit findings. We 

found several instances in which single audit reports contained types of 

audit findings that were repeated in 3 or more consecutive years. For 

example, 4 of the 10 Education Pell Grant recipient reports identified 

eligibility findings that repeated in 3 or more consecutive years. For the 

Title I program, 4 grantees had subrecipient monitoring findings that 

repeated in 3 or more consecutive years. At HUD, a review of the database 

and single audit reports showed that 15 of the 37 CDBG audit findings were 

not corrected over a period of 3 successive years. Twelve of these 15 

recurring audit findings occurred at one recipient. The remaining 3 

recurring audit findings occurred at three other recipients. In addition, 

CDBG and Section 8 grants also had recipients with audit findings 

attributable to reporting, allowable costs, and eligibility that were repeated 

in 3 or more subsequent years. Transportation recipients selected for 

review had cash management, subrecipient monitoring, allowable costs, 
Page 21 GAO-02-705 Single Audit

and equipment and real property management findings that were repeated 

in 3 or more years at individual recipients. 

This type of information could be a valuable tool in improving grants 

management by helping management evaluate agency oversight and 

monitoring activities and identify problem areas. It could also assist in 

setting priorities for actions needed to correct program problems. In 

addition, it can provide agencies with information needed to help them 

accomplish their responsibilities as established by The President’s 

Management Agenda, Fiscal Year 2002, initiative to reduce improper 

payments in federal programs. 

Conclusions The first step in an agency’s efforts to address single audit findings is 

obtaining single audit reports and distributing them to agency officials 

responsible for reviewing the report findings and taking actions on those 

findings. Each of the three agencies in our review had procedures for 

communicating audit reports and/or audit finding information to program 

or field offices for action. 

OMB Circular A-133 requires agencies to prepare written management 

decisions on audit findings contained in single audit reports. Our review of 

the audit files at the three agencies found that they issued written 

management decisions for only 75 of the 246 audit findings contained in the 

single audit reports included in our review. The agencies noted several 

reasons for not preparing written management decisions, including (1) the 

audit findings were considered insignificant or not serious, (2) follow up 

with recipients was performed but not documented, (3) the single audit 

report stated that the recipient had corrected the finding prior to the 

report’s issuance, and (4) the subsequent year’s single audit report 

indicated that the recipient had corrected the finding. In our view, none of 

these reasons justify the nonissuance of a management decision. Further, 

the audit files generally did not contain any evidence that agency officials 

considered these factors or otherwise considered the preparation of 

management decisions. 

Education, HUD, and Transportation do not adequately document their 

evaluations of and conclusions on the corrective actions taken by 

recipients to correct single audit findings. While the audit files contained 

copies of recipient documents and other records, they generally did not 

contain agency evaluations of or conclusions on the adequacy of the 

recipient actions cited in those records. This documentation is critical 
Page 22 GAO-02-705 Single Audit

because each agency relies heavily on program, regional, or field offices to 

ensure that corrective actions occur and none requires reporting on the 

corrective action status on all findings contained in single audit reports. 

Therefore, requiring documentation can help ensure that these offices 

perform their responsibilities in ensuring that recipients take all necessary 

corrective actions. 

Through discussions with agency officials, we determined that none of the 

agencies report single audit results or the status of single audit findings and 

implementation of action to correct deficiencies to agency management. 

This reporting can strengthen accountability and oversight by providing 

management with information useful in the analyses of both programwide 

problems and recurring problems at specific recipients. Further, because 

many federal programs that are subject to single audits also experience 

improper payments, this reporting can be useful to agency management in 

addressing the requirements established in The President’s Management 

Agenda, Fiscal Year 2002, for reducing such payments. 

Recommendations for 

Executive Action

To ensure that recipients correct the weaknesses identified in single audit 

reports, we recommend that the Secretary for the departments of 

Education, HUD, and Transportation ensure that each has established and 

follows guidance that addresses the OMB Circular A-133 requirements for 

all agency programs whose awards are subject to the Single Audit Act. This 

guidance should clearly define the roles and responsibilities of each agency 

unit in ensuring appropriate and timely actions on single audit findings 

including:

• preparing and issuing management decisions that clearly communicate 

the results of agency analyses of single audit findings and the adequacy 

of corrective actions implemented or planned by the recipient,

• performing follow up procedures to ensure that the recipient 

implemented adequate corrective action, and

• documenting results of evaluations of and conclusions on recipients’

actions to correct audit findings.

We also recommend that the Secretary of each of the three agencies 

implement policies and procedures for reporting information to agency 

management on (1) the types and causes of findings identified in single 

audit reports and (2) the status of corrective actions. 
Page 23 GAO-02-705 Single Audit

Agency Comments and 

Our Evaluation

Education agreed with the thrust of the report’s findings and 

recommendations. Its comments (reprinted in appendix I) noted that it is 

important to ensure that recipients correct the weaknesses identified in 

single audit reports and that the department takes the necessary steps to 

ensure the implementation of single audit guidance as required under OMB 

Circular A-133. An attachment to the comments, which is not reprinted, 

provided several clarification points and suggested additions to the report, 

which we considered and included in the report, as appropriate. 

HUD agreed with the report’s findings and recommendations. Its 

comments (reprinted in appendix II) described actions that HUD is taking 

to improve its oversight and use of single audits to strengthen its program 

compliance and performance. They also contained several minor technical 

or editorial revisions that we considered and included in the report, as 

appropriate. 

The Department of Transportation’s comments (reprinted in appendix III) 

raised several issues about the scope of our audit work, the conclusions 

reached, and the recommendations made. 

• Transportation questioned our audit scope and suggested that we 

should have conducted independent field testing to determine the 

extent and effectiveness of recipient actions taken. Our objective was 

to determine what agencies do to ensure that recipients take timely and 

appropriate action; not to independently reperform the steps that 

program and other offices, as applicable, would need to do to evaluate 

recipient corrective actions. To accomplish our objective, we examined 

agency audit files to determine the extent to which those files contained 

evidence of agency actions to ensure that recipients had taken 

appropriate and timely corrective actions on all audit findings. As we 

noted in the report, the audit files generally did not contain evidence of 

these actions either through written management decisions or through 

documentary evidence of agency evaluations of or conclusions on 

recipient corrective actions. 

• Transportation noted that not all single audit findings are useful or 

meaningful and that our report did not recognize this point. Two points 

are relevant here. First, the Comptroller General’s Government 

Auditing Standards, which auditors performing single audits are 

required to follow, requires auditors to “report the significant audit 

findings developed in response to each audit objective.” The standards 
Page 24 GAO-02-705 Single Audit

also note that audit findings not reported, because of their 

insignificance, should be separately communicated to the auditee. The 

auditors included all of the findings discussed in our report in their 

single audit reports. Our objective was not to evaluate the usefulness of 

audit findings or whether auditors made the right determination as to 

significance in including the 48 findings in the reports covered by our 

review. Regarding the second point, the “Management Decisions –

Transportation” section of the report that we provided for comment 

identified management decision information for findings addressed by 

both “action” and “informational” memoranda. In using these different 

memoranda, Transportation distinguished between serious or 

significant and other types of findings. We did not separately judge or 

evaluate the decision to use one or the other type of memoranda. 

However, OMB Circular A-133 does not distinguish between the serious 

or other types of audit findings. It clearly states that actions are 

required on all audit findings. 

• Transportation’s comments also discussed the agency’s process for 

reviewing and tracking audit findings. They noted that the agency 

tracks significant findings in the joint OIG/management tracking system 

until documentation is provided that action has been completed and 

stated that less significant actions are tracked locally. The draft report 

we provided for comment generally contained this same information 

and discussed the types of memoranda the agency used to communicate 

single audit findings to appropriate agency offices. We do not take issue 

with the agency’s process. However, as our report states, our review of 

audit files, irregardless of whether the agency handled the audit findings 

with “action” or “informational” memoranda, found that the files 

generally did not contain documentation identifying agency evaluations 

of and conclusions on the adequacy of the corrective actions taken by 

recipients. 

• Transportation stated that our report recommends that each department 

create a new system or systems for communicating audit findings to top 

management. While our report recommends reporting to top 

management, it also notes that information for such reporting can come 

from such sources as agency analyses of single audit findings, agency 

databases, and the FAC single audit database. We do not recommend or 

suggest that agencies develop new systems. Agencies such as 

Transportation, that uses a joint OIG/management tracking system for 

significant findings, should use information obtained from that or other 

existing systems to summarize single audit results and the status of 
Page 25 GAO-02-705 Single Audit

recipient corrective actions and communicate that information to top 

management. 

The final agency comment notes that documentation concerns alone are 

insufficient to demonstrate that agencies are ineffective at ensuring that 

grantees achieve the changes recommended by single audits to safeguard 

federal funds. Our report does not make the point that agencies are 

ineffective if they do not maintain appropriate documentation. Clearly, 

recipients can take timely and appropriate action to correct audit findings 

without regard to federal agency documentation that such action occurred. 

However, absent documentation that timely and appropriate actions 

occurred, agency management would have no basis for concluding that 

agency follow-up with recipients occurred or that recipient corrective 

actions, if any, were timely and appropriate. 

We are sending copies of this report to the Ranking Minority Member, 

Subcommittee on Government Efficiency, Financial Management and 

Intergovernmental Relations, House Committee on Government Reform; 

the Chairman and Ranking Minority Member, Senate Committee on 

Appropriations; the Chairman and Ranking Minority Member, House 

Committee on Appropriations; the Chairman and Ranking Minority 

Member, Senate Committee on Governmental Affairs; the Chairman and 

Ranking Minority Member, House Committee on Government Reform; the 

Chairman and Ranking Minority Member, Senate Budget Committee; and 

the Chairman and Ranking Minority Member, House Budget Committee. 

We are also sending copies to the Director of the Office of Management and 

Budget and agency CFOs and IGs. Copies of this report will be made 

available to others upon request. This report will also be available on 

GAO’s home page (http://www.gao.gov). 

Please call me at (213) 830-1065 or Tom Broderick, Assistant Director, at 

(202) 512-8705 if you or your staff have any questions about the information 

in this report. Key contributors to this report were Marian Cebula, Cary 
Page 26 GAO-02-705 Single Audit

Chappell, Mary Ellen Chervenic, Perry Datwyler, Taya Tasse, and Jack 

Warner. 

Sincerely yours,

Sally E. Thompson

Director, Financial Management and Assurance 
Page 27 GAO-02-705 Single Audit

Appendix I

Comments From the Department of Apendxies

Education ApendxiI
Appendix I

Comments From the Department of 

Education

Page 28 GAO-02-705 Single Audit
Page 29 GAO-02-705 Single Audit

Appendix II

Comments From the Department of Housing 

and Urban Development ApendxiI
Appendix II

Comments From the Department of Housing 

and Urban Development

Page 30 GAO-02-705 Single Audit
Appendix II

Comments From the Department of Housing 

and Urban Development

Page 31 GAO-02-705 Single Audit
Page 32 GAO-02-705 Single Audit

Appendix III

Comments From the Department of 

Transportation ApendxiI
Appendix III

Comments From the Department of 

Transportation

(193029) Page 33 GAO-02-705 Single Audit
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