U.S. DEPARTMENT OF COMMERCE 

Office of Inspector General 

Office of the Secretary 

Commerce Should Strengthen 

Accountability and Internal Controls 

in Its Motor Pool Operations 

Final Report No. OIG-11-004-A 

October 27, 2010 

FOR PUBLIC RELEASE 

Office of Audit and Evaluation 
UNITED STATES DEPARTMENT OF C

Office of Inspector General 

Washington. D.C. 20230 

OMMERCE 

October 27, 20 I0 

MEMORANDUM FOR: Scott B. Quehl, Chief Financial Officer and Assistant Secretary 

for Administration 

FROM: A~.'t;;". p~,;p" ~,p~,m0,",,,, fm A"d1' 

and Evaluation 

SUBJECT: Final Audit Report o. OIG-II-004-A, Commerce Should 

Strengthen Accountability and Interned Controls in Its Motor 

Pool Operations 

This memorandum transmits our final audit report detailing the results of our audit of the 

Department of Commerce's motor pool operations. The audit included a review of the 

Department's policies, fleet card transactions, logs for scheduling and tracking vehicle usage, 

monitoring of vehicle expenses, and motor pool program oversight. We focused on motor 

vehicles used by the Department during fiscal year 2009. In brief, due to the lack of adequate 

policies and procedures and a fleet management information system, we were unable to 

determine whether government motor vehicles and fleet credit cards were used only for 

allowable purposes. 

The Office of Administrative Services (OAS) response to our report, included as Appendix B, 

concurs with our findings and recommendations. OAS indicated in its response the steps already 

taken, as well as the actions planned, to correct internal control deficiencies and implement 

accountability over motor pool operations. We will evaluate the corrective action plan and assess 

whether the actions taken or planned, if properly implemented, address the findings and 

recommendations reported. 

We thank the Department and bureau staff for their assistance during this audit. If you have any 

questions, please contact me at (202) 482-2754 or Patty McBarnette, Director, Financial 

Statement Audits, at (202) 482-3391. 

cc:	 Mary C. Pleffner, Director, Office of Administrative Services 

Douglas F. Elmic, Deputy Director, Office of Administrative Services 

Greg Falzetta, Chief, Energy, Environmental & Transportation Division 

Terry Jackson, Chief, Transportation Division 

Trudy Gallic, Audit Liaison, Office of Management & Organization 
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Report In Brief

U.S. Department of Commerce, Office of Inspector General 

October 27, 2010

Why We Did This Review 

The Department of Commerce acquires and operates 

motor vehicles to carry out 

official government business; 

such vehicles may also be 

used by officers or employees 

as authorized. The Department’s primary source of vehicles is the General Services 

Administration (GSA); the 

Department also purchases 

and leases motor vehicles 

from commercial sources. 

The objective of this audit 

was to determine whether the

Department and bureaus wer

operating motor pool vehicle

in compliance with regulations. 

Background 

During FY 2009, the Department owned about 700 vehicles, leased about 100 commercial vehicles, and leased 

over 1,400 GSA vehicles at 

a total cost of approximately 

$9.6 million. The Department 

pays GSA a monthly lease 

fee plus mileage costs. Motor vehicles that are owned 

or commercially leased are 

assigned a JPMorgan Chase 

fleet credit card that is used to 

purchase fuel and pay vehicle 

maintenance and repair costs. 

The Department is responsible for monitoring transactions posted to the card, and 

pays these costs directly to 

JPMorgan Chase. GSA monitors transactions and pays 

the costs associated with its 

leased vehicles. 

Office of the Secretary 

Commerce Should Strengthen Accountability and

Internal Controls in Its Motor Pool Operations 

(OIG-11-oo4-A)

What We Found 

Because documentation supporting vehicle use and fleet credit card transactions is

r inconsistent or nonexistent, we were unable to assess the Department’s compliwith applicable regulations; we could not determine whether government motor

cles and fleet credit cards were used only for allowable purposes. This resulted

 inadequate policies and procedures and the lack of a centralized fl eet manage-

 system. 

Department does not provide adequate oversight of motor pool vehicle inventory,

ity, or cost. Further, the Department has not developed or implemented internal 

ols over motor pool operations. As a result, significant unreconcilable difference 

 found between Commerce records and those of JPMorgan Chase and the GSA

or. Specifi cally, 

• 733 JPMorgan Chase fleet credit cards could not be matched with a vehicle. 

Transactions on these cards totaled over $1 million. 

• 339 bureau vehicles could not be matched with a JPMorgan Chase fl eet credit 

card. 

• 381 credit cards from the GSA vendor could not be matched with a vehicle. 

• 89 vehicles reported by GSA could not be matched with bureau inventory listings. 

• 52 vehicles had multiple JPMorgan Chase fleet credit cards. 

What We Recommend 

We recommend that the Department (1) develop a centralized fleet management information system to oversee the use of motor pool vehicles and costs associated with each; 

(2) implement available JPMorgan Chase fraud training and monitoring tools, (3) update 

policies and procedures to ensure that credit cards are used appropriately, bureaus maintain adequate documentation, home-to-work transportation is supported, premium-grade 

fuel is used only when required in the particular vehicle, accurate odometer readings 

are recorded when fuel is purchased, and fleet managers and employees receive formal 

training on the use of government vehicles; and (4) revise its charge card management 

plan to comply with OMB regulations. 
U.S. Department of Commerce Final Report No. OIG-11-004-A
 

Office of Inspector General October 27, 2010 

Contents 

Introduction..................................................................................................................................... 1 

Findings and Recommendations ..................................................................................................... 2 

I. The Department Does Not Provide Adequate Oversight of Motor Pool Vehicle Inventory, 

Activity, or Cost .......................................................................................................................... 2 

A. Vehicle Inventory and Fleet Credit Card Records are Incomplete .................................. 2 

B. Fraud Monitoring Tools to Prevent or Detect Credit Card Abuse are Not Used ............. 3 

II. The Department Has Not Developed or Implemented Internal Controls Over Motor Pool 

Operations ................................................................................................................................... 4 

A. Documentation and Records-Retention Policies are Inadequate ..................................... 4 

B. Government Vehicles Could be Used for Unauthorized Home-to-Work Transportation

 4 

C. Premium-Grade Fuel Purchases May Have Been Unauthorized ..................................... 5 

D. Erroneous Odometer Readings Recorded during Fuel Purchases .................................... 5 

E. Neither Fleet Managers nor New Employees Receive Formal Training ......................... 5 

Summary of Office of Administrative Services Comments and OIG Response ............................ 7 

Appendix A: Objectives, Scope, and Methodology ....................................................................... 8 

Appendix B: Agency Response ...................................................................................................... 9 
                                                           

 

 

 

U.S. Department of Commerce Final Report No. OIG-11-004-A
 

Office of Inspector General October 27, 2010 

Introduction 

The Department of Commerce acquires and operates motor vehicles to carry out official 

government business, including carrying out authorized programs and rendering assistance in 

major disasters or emergency situations; such vehicles may also be used by officers or employees 

as authorized. The Department’s primary source of vehicles is the General Services 

Administration’s (GSA) Interagency Fleet Management System Services; the Department also 

purchases and leases motor vehicles from commercial sources. 

During FY 2009, the Department owned 709 vehicles, leased 111 commercial vehicles, and 

leased 1,478 GSA vehicles at a total cost of approximately $9.6 million. The Department pays 

GSA a monthly lease fee plus mileage costs. Motor vehicles that are owned or commercially 

leased are assigned a JPMorgan Chase fleet credit card that is used to purchase fuel and pay 

vehicle maintenance and repair costs. The Department’s Energy, Environmental & 

Transportation Division (EETD) and bureau fleet managers are responsible for monitoring 

transactions posted to the JPMorgan Chase fleet credit card; the Department pays these costs 

directly to JPMorgan Chase. Vehicles leased from GSA are assigned a Wright Express fleet 

credit card; GSA is responsible for monitoring these transactions, which are centrally billed to 

GSA. 

The objective of our audit was to determine whether the Department and bureaus were operating 

motor pool vehicles in compliance with regulations, including those related to home-to-work 

transportation. However, because the documentation supporting vehicle use and fleet credit card 

transactions is inconsistent or nonexistent, we were unable to assess the Department’s 

compliance with applicable regulations. Specifically, we could not determine whether 

government motor vehicles and fleet credit cards were used only for allowable purposes. This 

resulted from inadequate policies and procedures and the lack of a centralized fleet management 

system. Although EETD is responsible for oversight,1

 EETD management was unable to assist 

us because the division actually provides only minimal oversight of motor pool operations and is 

not utilizing monitoring tools currently available. Not utilizing such oversight tools leaves 

Commerce at risk for fraud and/or misuse of government vehicles and fleet credit cards. 

Appendix A describes the scope and methodology of our audit. 

1

 Department Organization Order 20-1 section 4 states, “The Office of Administrative Operations (OAO) 

 shall ...oversee the motor vehicle fleet management program for the Department and serve as liaison with GSA

 on operational programs relating to federal motor vehicle fleet management.” Pursuant to Section 3 of DOO 20-1,

 EETD is a division within OAO that has been delegated responsibility for motor vehicle fleet management. 
 

 

                                                           

 

U.S. Department of Commerce Final Report No. OIG-11-004-A
 

Office of Inspector General October 27, 2010 

Findings and Recommendations 

I.	 The Department Does Not Provide Adequate Oversight of Motor Pool Vehicle 

Inventory, Activity, or Cost 

Commerce management—through its Energy, Environmental, &Transportation Division 

(EETD)—was unable to resolve discrepancies identified because it does not have in place a 

centralized fleet management information system, as required by federal law.2 Instead, EETD 

relies on the Department’s individual bureaus to correctly track and monitor motor pool vehicle 

inventory and usage. As a result of not utilizing a fleet management information system, we 

noted the following issues: 

A. Vehicle Inventory and Fleet Credit Card Records 

are Incomplete 

Lacking a fleet management information system, EETD 

had to collect inventory data from each Commerce bureau, 

in response to our audit request for an inventory of all 

motor pool fleet vehicles held during Fiscal Year (FY) 

2009. The bureaus provided inventory information from 

different sources, in varying formats, and with inconsistent 

information. Complete vehicle information, including 

vehicle identification number (VIN) and tag number, are 

required to match a motor pool vehicle with a fleet credit 

card. However, some bureaus provided VINs while others 

provided only vehicle license numbers. 

To verify the accuracy of information provided by 

bureaus, we attempted to reconcile the vehicle inventory 

records provided with the FY 2009 GSA Federal 

Automotive Statistical Tool (FAST) report. This report is 

produced by GSA based on fleet-related data collected 

from federal agencies. The FAST report contained a motor 

pool vehicle inventory at September 30, 2009, of 2,298, 

whereas the inventory provided by bureaus totaled 2,209 

vehicles. EETD was unable to resolve the difference 

because it lacks a centralized fleet management 

information system. 

Unreconciled differences between 

Commerce, JPMorgan Chase, 

and Wright Express records: 

► 733 JPMorgan Chase fleet 

credit cards (with transactions 

totaling over $1 million) could not 

be matched with a vehicle. 

► 339 bureau vehicles could not 

be matched with a JPMorgan fleet 

credit card. 

► 381 Wright Express credit 

cards could not be matched with 

a vehicle. 

► 40 GSA-leased vehicles could 

not be matched with a Wright 

Express credit card. 

► 89 vehicles reported on the 

FAST report were not included on 

bureau inventory listings 

► 52 vehicles were found to 

have multiple JPMorgan fleet 

credit cards 

2

 Executive agency motor pool fleets are required to have a centralized system to identify, collect, and analyze motor 

 vehicle data with respect to all costs incurred for the operation, maintenance, acquisition, and disposition of motor 

 vehicles. See 40 U.S.C. § 17502, 41 C.F.R. § 102-34.340, and 41 CFR § 102-34.347. 

2
 
U.S. Department of Commerce Final Report No. OIG-11-004-A
 

Office of Inspector General October 27, 2010 

We then attempted to match vehicles reported by bureaus to a listing of JPMorgan Chase fleet 

credit card transactions covering October 1, 2008 through December 31, 2009 (obtained directly 

from JPMorgan). We identified 339 vehicles that could not be matched to a JPMorgan credit 

card, and 733 JPMorgan credit cards—with 14,310 transactions ranging from $0.04 to $7,616 

and totaling $1,052,843—that could not be matched to a departmental vehicle. Neither EETD 

nor JPMorgan could resolve the discrepancy. 

Similarly, in comparing bureau inventory listings of GSA-leased vehicles against the Wright 

Express fleet credit card database of transactions, our analysis identified 40 GSA vehicles on the 

bureau inventory vehicle listing that could not be matched with the Wright Express database of 

transactions. We also identified 381 vehicles in the Wright Express database that were not 

included in the bureau inventory listings of GSA vehicles. An EETD official was unable to 

resolve the discrepancy. 

Finally, our analysis also identified 52 vehicles with multiple fleet credit cards. Of these, 47 

vehicles were issued two credit cards, and five vehicles were issued three cards. EETD 

management was unaware of this and could not explain it. According to EETD officials, while 

they do not dispute our findings, they attributed the lack of a centralized fleet information system 

to budget constraints. 

Based on the results of our data analysis, we have requested follow-up by our Office of 

Investigations for several questionable trends we noted regarding vehicle and/or credit card use. 

B. Fraud Monitoring Tools to Prevent or Detect Credit Card Abuse are Not Used 

Neither EETD nor the bureaus utilize fraud monitoring tools to prevent or detect credit card 

abuse. Tools such as the PaymentNetG Electronic Access System and Expert Monitoring System 

are available to the Department. These tools permit queries of fleet credit card databases to 

identify unusual transactions that may indicate fraud; once identified, suspicious transactions can 

then be researched to determine if the purchase is allowable. According to both EETD 

management and bureau fleet managers, available fraud detection tools are not currently used 

because fleet managers have not been sufficiently trained to implement the tools and develop 

monitoring queries. 

We analyzed the JPMorgan credit card transactions database to identify unusual transactions— 

such as credit card charges on federal holidays or weekends, multiple daily transactions, and 

transactions with unusual vendors—to determine if vehicles or fleet credit cards are being used 

for unallowable purposes. EETD, bureaus, and line offices could similarly utilize these fraud 

monitoring tools to identify these types of questionable activities in its monitoring of motor pool 

operations. However, according to EETD officials, fleet managers have limited resources, and 

motor pool responsibilities at the regional offices and centers are usually auxiliary duties. As a 

result, fleet managers do not focus full-time on motor pool operations. 

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U.S. Department of Commerce Final Report No. OIG-11-004-A
 

Office of Inspector General October 27, 2010 

II.	 The Department Has Not Developed or Implemented Internal Controls Over Motor 

Pool Operations 

Although EETD is required to develop motor pool policies and procedures, our review of its 

personal property management manual indicates that the manual does not identify documentation 

requirements or standardized forms to be used in motor pool operations. Further, it does not 

identify records-retention requirements or internal controls that should be implemented to 

prevent or detect misuse of government vehicles or fleet credit cards. The manual was issued in 

October 2007, prior to the Department’s contracting with JPMorgan Chase for fleet credit card 

services. According to EETD officials, the fleet manager has not updated the policies and 

procedures due to time constraints. In addition, EETD officials say, it is difficult for them to get 

bureau and line office fleet managers—who perform fleet management tasks as an auxiliary 

duty—to comply with policies and procedures. As a result, we noted the following internal 

control problems: 

A. Documentation and Records-Retention Policies are Inadequate 

Documents supporting use of motor pool vehicles and fleet credit card transactions are not 

prepared and retained by the Department and bureaus; fleet managers were unable to 

demonstrate that all transactions selected for testing were allowable government costs. We 

selected 200 transactions out of 73,054 that occurred during the period under audit. Of the 

transactions selected, we received documentation supporting only 11. However, the information 

provided was inadequate. Interviews with bureau and operating unit fleet managers revealed that 

no standard forms are required to request use of a motor pool vehicle or to record costs 

associated with motor pool vehicles. Receipts supporting vehicle usage and fleet credit card 

transactions were not consistently provided to fleet managers by motor pool vehicle drivers. In 

addition, a fleet manager within the National Oceanic and Atmospheric Administration informed 

auditors that motor vehicle records that are prepared need only be kept for 3 months, according 

to National Archives and Records Administration General Records Schedule 10, Section 2(a). 

However, sections 3 and 4 of the same schedule state that motor vehicle cost and report files may 

only be destroyed 3 years after the discontinuance of the ledger, date of the worksheet, or date of 

the report. As a result, the risk exists that Department or bureau fleet managers would not be able 

to ascertain whether suspected fraud or misuse occurred due to lack of documentary evidence 

after just 3 months. 

We further found that the Department’s charge card management plan, section 3.5, Record 

Keeping, is not in compliance with Office of Management and Budget (OMB) Circular A-123, 

Appendix B Revised, Improving the Management of Government Charge Card Programs, 

section 2.3, which requires the agency plan to include documentation and records-retention 

requirements. While retention requirements are listed in the plan for purchase cards, they are not 

listed for fleet credit card records. 

B. Government Vehicles Could be Used for Unauthorized Home-to-Work Transportation 

Some bureau officials appear to have used government vehicles for transportation between their 

homes and work locations, as well as for other unofficial purposes. However, we were unable to 

confirm that any violations of departmental policies occurred because bureaus did not prepare 

mileage logs or other vehicle records that auditors could review. Bureau officials interviewed 

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U.S. Department of Commerce Final Report No. OIG-11-004-A
 

Office of Inspector General October 27, 2010 

indicated that they do not use government motor pool vehicles for transportation between an 

employee’s home and work location. Without the use of mileage logs or records, government 

vehicles could have been used for home-to-work or for personal transportation without being 

detected. 

C. Premium-Grade Fuel Purchases May Have Been Unauthorized 

We also found that 1,776 JPMorgan Chase credit card transactions—valued at $97,514— 

engaged in potentially unauthorized premium-grade fuel purchases, at a greater cost to the 

government. Such use is prohibited unless specifically required by the vehicle. EETD officials 

were unable to provide us with a listing of vehicles that must use premium-grade fuel. As a 

result, such purchases may have been unauthorized. 

D. Erroneous Odometer Readings Recorded during Fuel Purchases 

Both Wright Express and JPMorgan fleet credit cards require that odometer readings be recorded 

at the time fuel is purchased. The odometer reading provides a record of vehicle mileage and, 

because EETD has not developed a policy requiring mileage logs, the odometer reading may be 

the only method of tracking vehicle use. We found that 846 out of 12,567 JPMorgan fleet credit 

card transactions—having a total dollar amount of $45,435—had erroneous “0” or “999999” 

odometer readings recorded during fuel transactions. As a result of erroneous odometer readings 

and lack of mileage logs, motor vehicle usage cannot be effectively monitored by management 

for impropriety. 

E. Neither Fleet Managers nor New Employees Receive Formal Training 

While no formal training on motor pool operating policies and procedures exists for fleet 

managers or new employees, according to EETD officials, fleet managers are trained annually at 

the Federal Fleet Training Conference. At one regional office, we were told that the 

administrative staff instructs new employees that “GSA vehicles are available for official use 

only and have to be approved for use and show a valid driver’s license.” However, staff could 

not provide us with formal training material used for new employees during orientation. The 

current departmental personal property management manual, dated October 2007, also lacks a 

formal training policy for fleet managers and new employees. 

Recommendations 

To strengthen the Department’s motor pool operations, we recommend that the Secretary direct 

the Assistant Secretary for Administration to take the following actions: 

1.	 Develop a centralized fleet management information system as required by 40 U.S.C. § 

17503 for all fleet vehicle inventory that enables EETD management to monitor and 

provide adequate oversight over the usage of motor pool vehicles and costs associated 

with each vehicle, whether agency-owned or GSA- or commercially-leased. 

2.	 Implement available JPMorgan Chase fraud training and monitoring tools for preventing 

or detecting fraud in fleet card transactions. 

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U.S. Department of Commerce Final Report No. OIG-11-004-A
 

Office of Inspector General October 27, 2010 

3.	 Update policies and procedures to ensure that 

a.	 motor pool vehicles and fleet credit cards are only used for official government 

purposes; 

b.	 bureaus and operating units maintain adequate documentation—such as standard 

forms required to request a motor vehicle, mileage logs, and records to support 

official government use—for a consistent period of time; 

c.	 all home-to-work transportation via government vehicle is adequately supported; 

d.	 operators of government vehicles do not use premium-grade gasoline fuel unless 

the motor vehicle specifically requires it; 

e.	 all government vehicle operators and employees enter accurate odometer readings 

at the time of fuel purchases; and that 

f.	 fleet managers and new employees receive formal training on the proper use of 

government vehicles. 

4.	 Revise the Department’s charge card management plan, section 3.5, Record Keeping, to 

comply with OMB Circular A-123, Appendix B Revised, Improving the Management of 

Government Charge Card Programs, section 2.3, and include records-retention 

requirements for fleet credit card transactions. 

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U.S. Department of Commerce Final Report No. OIG-11-004-A
 

Office of Inspector General October 27, 2010 

Summary of Office of Administrative Services Comments and OIG Response 

In response to our draft report, the Office of Administrative Services (OAS) concurred with our 

findings and recommendations. As described in Appendix B, OAS has developed a corrective 

action plan and has started taking steps to implement accountability and internal controls over 

motor pool operations. OAS anticipates that initial corrective measures will be completed in 

January 2011, and that longer range steps, such as implementing a fleet management information 

system and internal control review program, will be completed in July 2011. 

We appreciate OAS’ efforts to quickly identify steps needed to correct the significant 

deficiencies noted during our audit of motor pool operations. We will review the corrective 

action plan and assess whether the actions, taken or planned, if properly implemented, will 

address the findings and recommendations reported. 

7 
 

U.S. Department of Commerce Final Report No. OIG-11-004-A
 

Office of Inspector General October 27, 2010 

Appendix A: Objectives, Scope, and Methodology 

Our audit included a review of the General Services Administration’s (GSA) and Department’s 

regulations and policies, fleet card transactions, logs for scheduling and tracking vehicle usage, 

monitoring of vehicle expenses, and Department motor pool program oversight. We focused on 

motor vehicles used by the Department during fiscal year 2009. 

We obtained an understanding of internal controls by interviewing Department and bureau fleet 

managers with motor pool program and JPMorgan Chase credit card oversight responsibilities, 

as well as GSA representatives about the leased vehicles program and Wright Express system. 

We reviewed Department Organizational Order 20-1, GSA Guide to Federal Fleet Management, 

OMB Circular A-123, Appendix B Revised, Department Personal Property Management 

Manual, U.S. Department of Commerce Charge Card Management Plan, and Commerce 

Acquisition Manual. We collected credit card transaction data occurring between October 1, 

2008 and December 31, 2009, from JPMorgan and between October 1, 2008 and September 30, 

2009, from Wright Express. We selected a nonstatistical, judgmental sample of fleet credit card 

transactions using unique fraud indicators. Specifically, we identified unusual and/or 

questionable credit card transactions, such as charges made on federal holidays, weekends, and 

multiple transactions on the same day. 

We reviewed the Department’s compliance with provisions of the following regulations: Code of 

Federal Regulations (CFR) Section 41 CFR 102-34.347 and 102-34.335(b); and 31 United States 

Code§ 1344. Because of the lack of available data, we were unable to determine whether 

government vehicles were used to provide unauthorized home-to-work transportation and 

whether government vehicles and credit cards were used only for official purposes. 

To assess the reliability of computer-generated data, we attempted to reconcile the JPMorgan and 

Wright Express vehicle transactions with the vehicle inventory database provided by the 

Department and its bureaus. However, as we were unable to reconcile the data and determine its 

completeness, we did not rely on the computer-generated information. 

We conducted this audit from October 2009 through July 2010 at the Department’s headquarters 

in Washington, D.C., under the authority of the Inspector General Act of 1978, as amended, and 

Department Organization Order 10-13, dated August 31, 2006. In addition, we conducted this 

audit in accordance with generally accepted government auditing standards, which 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 the evidence 

obtained does provide a reasonable basis for our findings and conclusions. 

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U.S. Department of Commerce Final Report No. OIG-11-004-A
 

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Appendix B: Agency Response 

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(OAE-19880) 

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