Account Structure Assessment and Recommendations in 

Accordance with Section 11201 of the FAST Act of 2015

June 2018

Prepared for:

Committee on Commerce, Science, and Transportation of the Senate, 

and the Committee on Transportation and Infrastructure of the 

House of Representatives
Table of Contents

1 Executive Summary ..........................................................................................................................................3

2 Introduction ......................................................................................................................................................4

2.1 Account Structure Goals and Principles .................................................................................................4

2.2 Account Structure Implementation .........................................................................................................5

3 Adherence to Account Structure Principles ......................................................................................................7

3.1 Account for all of Amtrak’s Activities and Assets with Clarity and Consistency..................................7

3.2 Maximize Efficiency of Implementation by Leveraging Existing Resources ........................................8

3.3 Provide Understandable Information to Investors, Customers, and Amtrak to Make Fully Informed 

Business Decisions ...........................................................................................................................................8

3.4 Request the Right Amount of Information, but No More ......................................................................9

3.5 Fully Integrate the Objectives of Title XI of the FAST Act, Support Planning and Internal Controls 10

4 Advancing the Statutory Principles of the FAST Act .....................................................................................11

4.1 Promote the Effective Use of Amtrak’s Revenues and Other Sources of Funds..................................11

4.2 Enhance the Transparency of Financial Accounting ............................................................................11

5 Assessment and Recommendations ................................................................................................................12

5.1 Assessment ...........................................................................................................................................12

5.2 Data and Process Recommendations ....................................................................................................12

5.3 Other Recommendations ......................................................................................................................13

5.4 Next Steps .............................................................................................................................................14

Appendix A 

Amtrak Report to the Secretary of Transportation, December 4, 2017 ..........................................................15

Appendix B 

Amtrak Letter to FRA, Delivered December 5, 2016 ....................................................................................22 

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1 EXECUTIVE SUMMARY

The Federal Railroad Administration (FRA), on behalf of the Secretary of Transportation (Secretary) and 

in collaboration with Amtrak, established an account and reporting structure (Account Structure) in May 

2016, in accordance with Section 11201 of the Fixing America’s Surface Transportation (FAST) Act. This 

report provides FRA’s assessment of the Account Structure, which supplements Amtrak’s assessment 

delivered to the Secretary on December 4, 2017. 

FRA and Amtrak have adhered to the original principles developed to guide this process, and have 

advanced statutory goals for the Account Structure. The Account Structure has improved FRA’s capacity 

for oversight and enhanced the transparency of Amtrak’s financial accounting. Additional work is needed 

to improve the quality of financial information in the Account Structure reports and make the reports more 

accessible and useful to all stakeholders. 

Evaluation Framework

Joint FRA-Amtrak 

Principles for Implementation Status Section

Account for all of Amtrak’s activities with clarity and 

consistency

In Progress

Address areas of inconsistent reporting; 

update capital allocation methodology 

3.1 

Maximize efficiency of implementation by leveraging 

existing resources

Achieved

Ongoing improvements identified 3.2 

Provide understandable information to investors, 

customers, and Amtrak to make fully informed business 

decisions

In Progress

Standardize reporting; engage with and 

collect feedback from stakeholders 

3.3 

Request the right amount of information, but no more Achieved

Ongoing improvements identified 3.4 

Fully integrate the objectives of Title XI of the FAST Act, 

support planning and internal controls 

Achieved

Ongoing improvements identified 3.5 

Statutory Goals Status Section

Promote the Effective Use of Amtrak’s Revenues Achieved

Ongoing improvements identified 4.1 

Enhance the Transparency of Financial Accounting Achieved

Ongoing improvements identified 4.2 

Recommendations and Next Steps

The report recommendations are organized into near-term and long-term improvements. Near-term 

improvements focus on fully integrating the Account Structure with Amtrak’s corporate structure, 

including further alignment with Amtrak’s organization, reporting, and internal controls processes. A 

priority for Amtrak and FRA is refining the current capital allocation methodology. Long-term 

improvements include updating Amtrak’s financial systems to better support the Account Structure. 

FRA will continue to work with Amtrak to improve the Account Structure and reports, as needed. The 

initial implementation has been successful, despite significant challenges for Amtrak. The next phases 

will allow FRA and Amtrak to build on an already strong foundation. 

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2 INTRODUCTION

Section 11201 of the Fixing America’s Surface Transportation (FAST) Act (P.L. 114-94, enacted 

December 4, 2015) directs the Secretary of Transportation (Secretary), in consultation with Amtrak, to 

“define an account structure and improvements to accounting methodologies, as necessary, to support, at 

a minimum, the Northeast Corridor and the National Network.” The provisions of Section 11201 are 

codified at 49 U.S.C. § 24317. 

The Federal Railroad Administration (FRA), on behalf of the Secretary, and in collaboration with Amtrak, 

established an account and reporting structure (Account Structure) in May 2016.1 Section 11201(h) 

requires Amtrak to assess the Account Structure and provide recommendations for further action two years 

after its establishment, and mandates that the Secretary submit a supplement to Amtrak’s report within 

180 days thereafter. This report provides FRA’s assessment of the Account Structure, which supplements 

Amtrak’s assessment, delivered to the Secretary on December 4, 2017.

2

 

2.1 Account Structure Goals and Principles

Section 11201 establishes separate accounts for the Northeast Corridor (NEC)3 and the National Network 

(NN) and directs development of an Account Structure to support this framework.4 Per Section 11201, the 

purpose of the Account Structure is to “promote the effective use and stewardship by Amtrak of Amtrak 

revenues, Federal, State, and third party investments, appropriations, grants and other forms of financial 

assistance, and other sources of funds; and...enhance the transparency of the assignment of revenues and 

costs among Amtrak’s business lines while ensuring the health of the Northeast Corridor and National 

1 Federal Railroad Administration, “Account Structure Definition and Accounting Methodology Improvements to Address 

Section 11201 of the FAST Act of 2015,” May 2016, Congressional submission. 2 See Amtrak Report to the Secretary of Transportation, December 4, 2017, in Appendix A.

3 Section 11201(i) defines the NEC as “the Northeast Corridor mainline between Boston, Massachusetts and the District of 

Columbia, and facilities and services used to operate and maintain that line.” 4 See Section 11201(b)-(c). In addition to the creation of separate NEC and NN accounts, Section 11101 of the FAST Act 

authorizes separate appropriations to Amtrak for activities associated with the NEC and the NN. Before enactment of the FAST 

Act, Congress provided Amtrak’s annual funding through an operating grant and a capital/debt grant that did not distinguish 

between the NEC or NN. Following enactment of the FAST Act, Congress has appropriated separate amounts for Amtrak 

activities associated with the NEC and the NN. 

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Network.” During the initial stages of defining the Account Structure, FRA and Amtrak jointly agreed on 

goals for the Account Structure and defined principles to be followed in pursuit of these goals.5

To assess the current status of the Account Structure, FRA evaluates in this report whether the process has 

adhered to these principles and, whether implementation to date has advanced or met these goals. FRA 

also responds to the recommendations Amtrak submitted in its December 2017 assessment and provides 

additional recommendations for improvement. 

2.2 Account Structure Implementation

Section 11201 includes deadlines to establish the Account Structure (June 1, 2016), implement the 

Account Structure (December 4, 2016), and produce deliverables for reporting financial information under 

the Account Structure (January 4, 2017 and monthly thereafter). 

FRA, working in coordination with Amtrak, established the Account Structure in May 2016. FRA sent to 

Congress a letter that provides additional detail, including definitions and a discussion of mapping the 

Service Lines6 to the NEC and NN accounts.7 The conceptual design of the Account Structure is shown 

in Figure 1. 

 

5 The principles listed in the table are the same as in the “Account Structure Definition and Accounting Methodology 

Improvements to Address Section 11201 of the FAST Act of 2015,” but arranged in a different order for the purposes of this 

evaluation. 

6 Section 11203 identifies four Business Lines (Northeast Corridor train services; State Supported routes operated by Amtrak; 

Long-distance routes operated by Amtrak and Ancillary services operated by Amtrak) and four Asset Categories (Infrastructure, 

Passenger Rail Equipment, Stations, National Assets) that are also cross-referenced in Section 11201(e). FRA and Amtrak later 

determined that the term Service Lines better reflects the purpose and activities performed by the components of the corporation 

that Congress identified as Business Lines. Similarly, Amtrak determined that the term Asset Lines is a better representation

of what Congress identified as Asset Categories. FRA uses the terms Service Lines and Asset Lines in place of statutory 

language throughout this document.

7 Federal Railroad Administration, “Account Structure Definition and Accounting Methodology Improvements to Address 

Section 11201 of the FAST Act of 2015,” May 2016, Congressional submission.

Goals

• Promote the effective use and 

stewardship by Amtrak of Amtrak 

revenues, Federal, State, and third party 

investments, appropriations, grants and 

other forms of financial assistance, and 

other sources of funds 

• Enhance the transparency of the 

assignment of revenues and costs among 

Amtrak business lines while ensuring the 

health of the Northeast Corridor and 

National Network 

Principles

• Account for all of Amtrak’s activities and 

assets with clarity and consistency

• Maximize efficiency of implementation by 

leveraging existing resources

• Provide understandable information to 

investors, customers and Amtrak to make fully 

informed business decisions

• Request the right amount of information, but 

no more 

• Fully integrate the objectives of Title XI of the 

FAST Act and support the planning and 

internal control requirements for Sections 

11201, 11202 and 11203 of the FAST Act 

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Figure 1. Amtrak Conceptual Account Structure 

Amtrak and FRA finalized Account Structure reporting protocols in December 2016, which consists of a 

series of reporting tables that display Amtrak’s revenues and expenditures in varying levels of detail 

(Account Structure reports). The most detailed table of the Account Structure reports is the Consolidated 

Sources and Uses Statement;

8 the two other tables present summarized information. After the reporting 

protocols were finalized, Amtrak began submitting preliminary Account Structure reports to FRA in 

January 2017.9 

Later that month, Amtrak underwent a staff reorganization, hired a new CEO, and altered management’s 

roles and responsibilities. In light of this corporate reorganization, Amtrak requested that the preliminary 

Account Structure reports be reviewed only by FRA so that they could be further revised pending 

additional changes or adjustments from Amtrak’s new management team. Amtrak submitted these 

preliminary reports to FRA until Amtrak’s organizational structure was finalized on June 2, 2017, at which 

point the Account Structure reports were considered final. Currently, Amtrak provides FRA with monthly 

Account Structure reports and also posts summary information on their public website.10 

Implementation of the Account Structure is tied to additional planning requirements as prescribed in the 

FAST Act. Amtrak’s 5-Year Service and Asset Line Plans11 (described in Section 11203 of the FAST 

Act, codified at 49 U.S.C. § 24320) are organized consistent with the Account Structure framework and 

use the Account Structure to report 5-year financial projections. The plans are fiscally-constrained 

statements of Amtrak’s objectives, goals, and service plan for each of the five Service Lines. Amtrak 

submitted the most recent Service Line Plans for FY19-23 on February 16, 2018. 

 

8 Section 11201(e) requires Amtrak, in consultation with the Secretary, to produce profit and loss statements for each of the 

Service Lines and as appropriate, each of the Asset Lines. However, as the legislation directs Amtrak to include appropriations 

in the profit and loss statements and this does not align with what is commonly included in a profit and loss statement, Amtrak 

recommended renaming these statements Sources and Uses Statements. FRA agreed to this recommendation.

9 See Amtrak Letter to FRA, December 5, 2016, in Appendix B. 

10 Access Amtrak’s Monthly Performance Reports at: https://www.amtrak.com/reports-documents 11 Per Section 11203, Service Line Plans were initially due February 15, 2017, and required to be updated annually thereafter. 

Asset Line Plans are first due by February 15, 2019. 

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By implementing the Account Structure, producing monthly Sources and Uses Statements, and developing 

5-Year Plans using the financial information from the Account Structure reports, Amtrak has complied 

with the requirements set out in Section 11201. 

3 ADHERENCE TO ACCOUNT STRUCTURE PRINCIPLES

To assess the effectiveness of the Account Structure, FRA has reviewed whether the implementation of 

the Account Structure, the production of monthly Sources and Uses Statements, and the development of 

the 5-Year Plans adhere to the original principles outlined in Section 2.1, developed by FRA and Amtrak. 

3.1 Account for all of Amtrak’s Activities and Assets with Clarity and Consistency

The Account Structure accounts for all of Amtrak’s activities and assets clearly. The Account Structure 

reporting format established by FRA and Amtrak contains financial data for all of Amtrak’s activities, 

including the NEC, State-Supported and Long Distance train services and Amtrak’s Ancillary (non-core) 

businesses that were identified in the FAST Act. During the initial Account Structure definition process, 

FRA and Amtrak determined it was necessary to add two additional lines of reporting: the Infrastructure 

Access Service Line and the Train Operations Asset Line to fully reflect the whole of Amtrak’s business.

Infrastructure Access captures revenues and expenses related to Amtrak’s provision of access to its rightof-way.

12 The Train Operations Asset Line captures costs associated with operating and moving trains, in 

addition to the statutorily identified Asset Lines of Equipment, Infrastructure, Stations, and National 

Assets. The Train Operations Asset Line was subsequently changed at Amtrak’s request to Transportation 

in March 2018 to be consistent with the differing roles of Amtrak’s Operations and Commercial groups. 

The reporting format includes all financial sources and uses, for operating, capital, and debt service

activities. From Amtrak’s perspective, “the account structure is intended to provide a comprehensive view 

of Amtrak’s financial information”13 and FRA’s analysis of the Account Structure reports confirms this 

approach. 

However, the Account Structure lacks consistency in reporting financial information. FRA has 

documented where some amounts are recorded as accruals while others are recorded on a cash basis within 

the same report.

14 FRA has also documented instances of capital projects being allocated inconsistently 

to Service Lines. FRA recommends Amtrak establish a clearer methodology and an automated process 

for allocating capital costs. Amtrak concurs with this recommendation (see Section 5.2). 

Though Amtrak had developed extensive procedures and processes for allocating operating costs across 

its business activities prior to enactment of the FAST Act,

15 for the first time the Account Structure 

required allocation of capital sources and uses across business activities. Amtrak created a standalone 

methodology using a spreadsheet-based tool to sort and allocate capital project-level data. This new capital 

methodology provides an adequate approach to allocating capital sources and uses, but this primarily

 

12 The Infrastructure Access Service Line seeks to safely and efficiently plan for, develop, manage, and provide access to 

Amtrak-owned or controlled infrastructure and facilities, consistent with Amtrak’s statutory obligations. Its primary customers 

include rail operators, such as commuter and freight rail, that currently use, or plan to use, Amtrak-owned assets.

13 See Amtrak Report to the Secretary of Transportation, December 4, 2017, in Appendix A. 14 For example, operating payments are recorded as accrued amounts while financing proceeds received are reported as cash 

payments.

15 See Update on the Methodology for Amtrak Cost Accounting Amtrak Performance Tracking (APT), April 22, 2016. Available 

online at: https://www.fra.dot.gov/Elib/Document/15780. 

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manual process is resource-intensive and requires significant post-processing of financial information. 

Amtrak, in coordination with FRA and staff at the Volpe National Transportation Systems Center, is 

currently integrating the methodology into the Amtrak Performance Tracking (APT) system to automate 

and further refine the capital allocation process. 

3.2 Maximize Efficiency of Implementation by Leveraging Existing Resources

Amtrak leveraged existing resources to implement the Account Structure, but doing so was not time

efficient because existing resources were not well aligned with the Account Structure. Amtrak 

implemented Account Structure reporting using existing financial systems and resources. Financial 

information from Amtrak’s general ledger accounting system, SAP Enterprise Resource Planning System 

(SAP ERP), populates the reporting tables for operating sources and uses. Amtrak uses the allocation 

methodology from the existing APT system to report operating financial performance. As described 

above, Amtrak developed a new process for allocating capital sources and uses, though the financial 

information is derived from existing databases and did not require procurement of additional systems or 

software.

While leveraging existing systems avoided additional information technology costs, implementing the 

Account Structure was a resource-intensive process for Amtrak. The implementation process took longer 

than expected, in part because “the complex allocation rules for operating and capital [sources and uses] 

take resources, time, and understanding.”16 Additional steps to format the Sources and Uses Statements

required a post-processing effort, though this has been streamlined over time. Amtrak also noted that 

implementing the Account Structure led to “a clean-up effort” associated with their operating data and 

resulted in necessary corrections and adjustments in accounting. 

Full implementation (e.g., producing final/non-preliminary reports) also took longer than expected due to 

key personnel changes during the process, including executive and senior management leadership. 

Aligning the Account Structure to organizational changes in a dynamic business enterprise has proven to 

be challenging. Amtrak’s current leadership has signaled their support of the Account Structure; FRA and 

Amtrak will continue to improve the processes for reporting financial information to reflect how Amtrak 

manages its business. 

3.3 Provide Understandable Information to Investors, Customers, and Amtrak to Make 

Fully Informed Business Decisions

The Account Structure reports are used by various stakeholders, both within and outside Amtrak’s 

organization. For Amtrak’s internal use, the reports provide a useful understanding of the financial 

performance of each Service Line. The reports have “resulted in improved decision-making” and have 

“enabled internal management to easily identify...the profitability of each Service Line.”17 However, as 

noted above, this reporting structure did not initially align with Amtrak’s organizational structure and 

business, which potentially limited how Service Line managers used the Account Structure reports. It has 

also taken longer than anticipated for the Account Structure to become an accepted concept within the 

organization, as the reported information is used to different extents and for different purposes by the 

Service Line managers. Amtrak managers continue to use other internal reports, like the Route 

Performance Report and Monthly Performance Report, to report financial information, requiring Amtrak 

Finance to develop “crosswalks” to explain variances between reports. 

 

16 See Amtrak Report to the Secretary of Transportation, December 4, 2017, in Appendix A.

17 See Amtrak Report to the Secretary of Transportation, December 4, 2017, in Appendix A.

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Amtrak’s reorganization of staff responsibilities integrated the Service and Asset Lines as fundamental

principles, making the Account Structure reports more useful for supporting business decisions. FRA 

recommends modifying Account Structure reports as needed to enhance Amtrak’s business management; 

line items within the established Service and Asset Lines should be adapted to reflect Amtrak’s 

organization, pending consultation and agreement with FRA. 

It is too early to tell whether the Account Structure reports to date have provided external stakeholders 

with valuable financial information. The reports, viewed as preliminary versions until June 2017, have not 

been widely distributed or publicly shared, in part, to limit confusion until they were finalized. Amtrak 

has recently committed to including Account Structure summary information with their Monthly 

Performance Reports on Amtrak’s website. It is not clear whether any investors have reviewed the 

Account Structure reports, or their impact on external parties. 

Even if they are shared, the reports may not yet be a useful tool for key financial partners, particularly 

states with cost-sharing arrangements subject to Sections 209 and 212 of the Passenger Rail Investment 

and Improvement Act (PRIIA) of 2008. As Amtrak recognizes, Section 209 and 212 cost allocation 

methodologies differ from the Account Structure, due to various policy decisions or contract terms that 

were agreed upon prior to the enactment of the FAST Act and implementation of the Account Structure.

18

Amtrak and FRA will continue to understand and explain structural differences to these stakeholders and 

make the reports more useful to these customers. 

The FAST Act required Amtrak to produce profit and loss statements for each of the Service Lines. The 

Sources and Uses Statements is a hybrid report agreed upon by the FRA and Amtrak that does not include 

non-cash expenses generally found in profit and loss statements, such as depreciation, amortization, and 

interest. To reconcile the differences, Amtrak produces a monthly “crosswalk” document for FRA to show 

the adjustments made by Amtrak on its profit and loss statement to arrive at the operating portion of the 

Source and Uses Statement. There may be other ways to adapt Account Structure reports to align to other 

financial statements, such as a cash flow statement, that could provide another assessment of Service Line 

financial performance and provide better information to internal and external stakeholders. FRA will 

continue to work with Amtrak to analyze or adopt these types of improvements. 

3.4 Request the Right Amount of Information, but No More

The Account Structure provides a sufficient level of information to analyze Amtrak’s profitability and 

track financial performance of the NEC and NN accounts. Through implementing the Account Structure, 

Amtrak and FRA staff have worked closely to develop and analyze the reports. It has been an iterative 

process aimed at being as efficient as possible and complying with the mandates of Section 11215 of the 

FAST Act (codified at 49 USC § 24320 note) to eliminate duplicative reporting.19 FRA and Amtrak are 

working to assure the process continues to result in improved coordination at the staff and executive 

leadership levels through quarterly meetings on the Account Structure and Service/Asset Line planning. 

 

18 See Amtrak Report to the Secretary of Transportation, December 4, 2017, in Appendix A.

19 FRA and Amtrak have agreed to eliminate one reporting requirement (Operating Summary Performance report, VaVh) as 

the Account Structure reports provide sufficiently similar information. 

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Within FRA, implementing the Account Structure has improved internal coordination among FRA staff

and enhanced oversight of Amtrak-related activities. Within Amtrak, developing the Account Structure 

has “led to more communication among accounting, finance, and the field groups.”20 From FRA’s 

perspective, implementing the Account Structure has been largely a finance-driven effort. FRA 

recommends further coordination between Amtrak Finance and other Amtrak divisions (such as

Engineering, Planning, and Service Line Management) to break down institutional silos, and foster 

knowledge sharing across the organization. 

3.5 Fully Integrate the Objectives of Title XI of the FAST Act, Support Planning and 

Internal Controls

The Account Structure fully integrates the objectives of Title XI of the FAST Act. The Account Structure 

reports provide financial information for Amtrak’s 5-Year Service Line Plans. The first version of these 

annual plans for FY17-21 were published in June 2017 and presented financial data and forecasts for each 

of the Service Lines using the Account Structure reporting formats. The current version of the 5-year 

Service Line Plans (FY19-23, published February 16, 2018) also uses the Account Structure format. 

Amtrak and FRA meet quarterly to review plan content and development, which are developed from 

Account Structure reports. Five-year plans for Asset Lines are due on February 15, 2019, and it is 

understood that financial data in these plans will also follow the Account Structure reporting format. The 

relationship with other FAST Act reporting and planning requirements is shown in Figure 2. 

Figure 2. Account Structure Relationship with Other FAST Act Requirements 

 

20 See Amtrak Report to the Secretary of Transportation, December 4, 2017, in Appendix A.

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Amtrak has updated existing internal controls to reflect the Account Structure, primarily to “ensure 

Amtrak’s costs, revenues, and other compensation are appropriately allocated to the Northeast Corridor, 

including train services or infrastructure, or the National Network, including the proportional shares of 

common and fixed costs,” per Section 11202 of the FAST Act, codified at 49 U.S.C.§ 24318. FRA 

reviewed the internal controls process for the Account Structure and recommends Amtrak continue to

further refine and expand the testing to include both financial allocations and the reporting process. 

4 ADVANCING THE STATUTORY PRINCIPLES OF THE FAST ACT

As discussed above, the FAST Act directs FRA and Amtrak to develop the Account Structure to promote 

the effective use of Amtrak’s revenues and other sources of funds, and to enhance the transparency of 

financial accounting. FRA has evaluated whether those goals have been met or advanced. 

4.1 Promote the Effective Use of Amtrak’s Revenues and Other Sources of Funds

The Account Structure provides additional information related to Amtrak’s finances, which improves 

FRA’s oversight functions and promotes the effective use of revenue and other funds. The Account 

Structure has improved FRA’s view of Amtrak’s business and has provided more information on Amtrak’s 

sources and uses, of which the annual Federal grant is a major component. Federal grant oversight is 

fundamental to FRA’s mission. Prior to the FAST Act, FRA relied on a number of financial reports that 

showed Amtrak’s monthly and cumulative capital project expenditures and the amount of grant funding 

used to cover operating losses. The Sources and Uses Statements serves as an additional resource to 

provide oversight of Amtrak’s compliance with its grant agreement. In the near term, FRA seeks to 

strengthen the relationship between the Account Structure reports and grant reporting. In addition, the 

Account Structure reports identify other revenue sources (such as contractual contributions, third party 

investments, and other Federal grants) that were not previously reported in that level of detail. 

Amtrak has adopted the Account Structure format in both its FY18 and FY19 General and Legislative 

Report and Grant Request to Congress. Upon the conclusion of FY18 and in future fiscal years, Amtrak, 

FRA, Congress, and other stakeholders will now be able to monitor the full lifecycle of Amtrak financial 

planning and performance in a consistent format. 

Account Structure reporting has also allowed FRA to understand the financial performance of Amtrak’s 

non-core Ancillary Service Line. FRA is using this information and working with Amtrak to determine 

how to leverage opportunities within the Ancillary Service Line to improve the overall financial 

performance of Amtrak and assure accurate reporting. 

4.2 Enhance the Transparency of Financial Accounting

The Account Structure enhances the transparency of Amtrak’s financial allocations, particularly in the 

assigning of revenues and costs, though this remains a work in progress. As stakeholders gain more 

information, they identify new areas for improvement. Amtrak has been receptive to continuing to refine 

and improve the Account Structure reports and process accordingly. 

The Sources and Uses Statements have also allowed FRA to better understand how Federal funding is 

used by the various Service Lines. Identifying both operating and capital needs by Service Line requires 

Amtrak to present detailed financial planning information and prioritize investments in a more transparent 

manner. Through the Account Structure reports, FRA can also begin to measure the impact of cost-sharing 

agreements between states and Amtrak, such as Section 209 and 212 of PRIIA, on the overall levels of 

Federal investment. 

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5 ASSESSMENT AND RECOMMENDATIONS

5.1 Assessment

The Account Structure represents a significant change to Amtrak’s financial reporting and business 

organization. Though full implementation has taken longer than expected, FRA and Amtrak have adhered 

to the original principles developed to guide this process, and have advanced the goals outlined in Section 

11201. Both FRA, as described in Section 5.2.1, and Amtrak, as described in its December 4, 2017 report, 

have identified potential improvements to the Account Structure. FRA and Amtrak are committed to 

improving the quality of financial information in the Account Structure reports and making the reports 

more accessible and useful to all stakeholders. 

5.2 Data and Process Recommendations

5.2.1 FRA Recommendations

As described earlier in the document, FRA recommends Amtrak continue to improve the data quality and 

process of generating the Account Structure reports through the following actions: 

• Ensure financial information is recorded consistently in Account Structure reports, either as 

accruals or on a cash basis. Assess whether additional changes are needed to improve consistency 

with other financial statements.

• Refine the methodology and automate the process for allocating capital costs to the Service Lines.

• Review guidelines for initiating capital projects to ensure there is sufficient detail to support the 

Account Structure allocation process. 

• Identify and adopt changes in the Account Structure to align with Amtrak’s corporate organization.

• Coordinate internally with Amtrak Finance and Service Line managers to ensure financial 

information is accurate and that the Account Structure reports provide useful information for 

management and decision-making. 

• Identify the need for any additional crosswalks to explain how the Account Structure reports relate 

to other financial statements (such as income statements or cash flow statements) or cost-sharing 

agreements (such as customer agreements subject to PRIIA Sections 209 and 212). 

• Engage external stakeholders to collect feedback on the usefulness of Amtrak’s reported financial 

metrics.

• Refine and expand the number of internal controls submitted for testing, to include controls on the 

financial allocations and the reporting process. 

• Improve and streamline annual grant reporting to better align with Account Structure reporting. 

Amtrak is already working to realize some of these recommendations, such as Amtrak’s work to integrate 

the current capital allocation methodology into APT. Amtrak and FRA are coordinating on this effort and 

are working toward implementing these changes by the third quarter of FY18. During this process, FRA 

also recommends Amtrak review its internal guidelines for initiating capital projects and identifying

appropriate allocation methods for projects at the outset, with input from Amtrak Engineering, Corporate 

Planning, and Enterprise Project Management. Improving these processes will also confirm that capital 

projects are linked to passenger and Service Line needs. 

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5.2.2 FRA Response to Amtrak’s Recommendations

Amtrak has also recommended several updates to labeling within the Account Structure reports,

21 such as 

renaming NEC Intercity Operations to NEC Service Line, as well as Train Operations Asset Line to 

Transportation Asset Line, and presenting commuter operations as a type of revenue within the Amtrak 

Services portfolio. These proposed changes were coordinated with and approved by FRA, and are reflected 

in Account Structure reports as of March 2018. FRA and Amtrak will continue to coordinate on any 

changes to the subcategories within the Service or Asset Lines.

5.3 Other Recommendations 

5.3.1 FRA Recommendations

FRA recommends further research on adopting a standard definition of the NEC. 

FRA has identified an issue with a standard definition of the NEC. The FAST Act and Section 11201 

define the Northeast Corridor as “the Northeast Corridor main line between Boston, Massachusetts, and 

the District of Columbia and facilities and services used to operate and maintain that line.” However, 

Section 212 of PRIIA required that a standard cost-allocation methodology apply to the “Northeast 

Corridor main line between Boston, Massachusetts, and Washington, District of Columbia, and the 

Northeast Corridor branch lines connecting to Harrisburg, Pennsylvania, Springfield, Massachusetts, and 

Spuyten Duyvil, New York.”22 As a result, in the Account Structure, the costs and revenues associated 

with the branch lines listed above are classified as the National Network. A standard definition of the NEC 

would reduce confusion with these geographies, particularly the capital allocations assigned to individual 

projects. 

5.3.2 FRA Response to Amtrak’s Recommendations

In its December 2017 report to the Secretary, Amtrak recommended two improvements to the grant 

process to provide additional reporting clarity and reduce duplicative work. First, Amtrak recommended 

one annual grant with two accounts (one account for the NEC, another for the NN) in place of two separate 

grants (one for the NEC account and another for the NN account). Following enactment of the FAST Act, 

FRA determined the FAST Act authorizations of appropriations (Section 11101) and subsequent 

appropriations prescribe specific amounts for separate NEC and NN accounts, and therefore require two 

separate grant agreements. At this time, FRA recommends maintaining the two grant structure. FRA has 

potential technical concerns about invoice tracking and matching lines of accounting from two 

appropriated sources in one consolidated grant. FRA will continue to work with Amtrak to streamline 

reporting to eliminate redundancy. 

Establishing two separate grants also supports a key principle requested by Amtrak and other funding 

partners: Amtrak’s ability to retain NEC revenues for capital investment in the corridor. From an FRA

accounting perspective, the separate NEC and NN grants support the assignment of revenues and costs to 

the appropriate Service Lines. Two different grant agreements provide better FRA management and 

oversight for transfers between accounts subject to specific financial controls. 

Second, Amtrak recommended a new authorization of appropriations (split between the NEC and NN 

accounts) on an annual basis instead of the current authorization split, which was based on FY15 estimates. 

 

21 See Amtrak Report to the Secretary of Transportation, December 4, 2017, in Appendix A. 22 PRIIA Section 212, codified at 49 U.S.C. § 24905, (c)(1)(a). 

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While FRA agrees that a more precise estimate of NEC and NN needs in Amtrak’s authorization would 

be beneficial to the Federal budgeting and appropriations process, this issue would be more appropriate 

for consideration during the next reauthorization of surface transportation programs. According to 

Amtrak’s FY19 Grant and Legislative Request, a difference of only $14 million dollars was identified that 

should be transferred from the NEC to the NN account – less than 1 percent of Amtrak’s FY19 authorized 

funding. 

5.4 Next Steps

The goals established by FRA and Amtrak during the development of the Account Structure have also 

served the implementation phase of the Account Structure. Amtrak has made significant progress since 

the Account Structure’s initial implementation in January 2017, despite the corporate challenges 

associated with changes in leadership, company reorganization, and staff downsizing. 

This assessment has outlined key recommendations that FRA will pursue to improve the usefulness of the 

Account Structure. These recommendations can be divided into the following near- and long-term next 

steps. 

FRA will continue to work with Amtrak to make improvements to the Account Structure and reports, as 

needed. The initial implementation has been successful, despite significant challenges for Amtrak. The 

next phases will allow FRA and Amtrak to build on an already strong foundation. 

Near-Term Improvements (One Year)

• Improve coordination between Amtrak

finance and other divisions to better

integrate Account Structure reports into

business practices

• Complete the integration of the capital

allocations into Amtrak’s Performance

Tracking (APT) financial system

• Assess the need to make policy and

organizational changes to the Account

Structure to align with Amtrak’s

corporate organization

• Refine and expand the internal controls

process

• Improve annual grant reporting to

better align with Account Structure

reporting

Long-Term Improvements

• Improve Amtrak’s financial systems to better

support reporting in the Account Structure

• Standardize financial reporting to minimize

variances between the Account Structure

and other reports, including those used by

external stakeholders

• Consider legislative recommendations that

would align the NEC territory with PRIIA

Section 212 territory

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APPENDIX A 

Amtrak Report to the Secretary of Transportation, December 4, 2017

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16
17
18
19
20
21
 

APPENDIX B 

Amtrak Letter to FRA, Delivered December 5, 2016

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23
24
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