U.S. RAILROAD RETIREMENT BOARD

OFFICE OF INSPECTOR GENERAL 

Improvements Needed for the 

Unapplied Cash Process at the 

Railroad Retirement Board

Report No. 19-08 May 16, 2019
OFFICE OF INSPECTOR GENERAL

U.S. RAILROAD RETIREMENT BOARD

Improvements Needed for the Unapplied Cash 

Process at the Railroad Retirement Board 

Report Summary May 16, 2019 Report No. 19-08

What We Found

Our audit determined that after the Program Accounts 

Receivable System (PARS) migration to the Financial 

Management Integrated System (FMIS), the Railroad 

Retirement Board’s (RRB) process for Unapplied Cash needed 

improvement. Internal controls for the unapplied cash process 

were not adequate and could not be relied on to ensure the 

proper processing of transactions. We found that the controls 

were outdated and RRB lacked a comprehensive agency-wide 

process for maintaining, monitoring, and reporting on 

unapplied cash. Because RRB did not establish and implement 

proper monitoring control activities, (1) transactions were not 

reconciled and were not always properly recorded or processed 

timely; and (2) migration efforts failed to fully automate the 

unapplied cash process.

What We Recommend

To address the weaknesses identified in this audit, we made 14

recommendations related to improving the unapplied cash 

process at the RRB, which included recommendations related to 

internal controls over unapplied cash; recording, processing and 

reconciling unapplied cash; and controls over the interface 

process between the Overpayment Recovery Correspondence 

System Unapplied Cash Application and the Financial 

Management Integrated System. RRB management concurred 

with five recommendations and did not concur with nine

recommendations. Although RRB management did not concur 

with a significant number of our audit recommendations, we 

continue to see the need for these corrective actions, as 

explained in various sections of the report titled Management’s 

Comments and Our Response.

What We Did 

Our objective was to: (1) assess the 

adequacy of controls over the 

unapplied cash process; (2) 

determine if unapplied cash was 

being properly recorded and 

reconciled in an accurate and 

timely manner; and (3) assess the 

impact of the PARS to FMIS 

migration on the unapplied cash 

process. 

In order to complete this work, we 

considered laws, regulations, and 

guidance, compared criteria to RRB 

policies, procedures, and 

documentation, and reviewed and 

tested RRB documentation to 

assess the adequacy of internal 

controls. We also interviewed 

applicable RRB staff and conducted 

data analysis and walkthroughs. 

The scope of the audit was 

unapplied cash transactions in 

FMIS for fiscal year 2017.
OFFICE OF INSPECTOR GENERAL – U.S. RAILROAD RETIREMENT BOARD 

 

Contents

INTRODUCTION 1

OBJECTIVE(S), SCOPE, AND METHODOLOGY 1

BACKGROUND 2

RESULTS OF AUDIT 6

INTERNAL CONTROLS NOT ADEQUATE 6

RAILROAD RETIREMENT BOARD LACKED A COMPREHENSIVE AGENCY-WIDE PROCESS FOR 

MAINTAINING, MONITORING, AND REPORTING ON UNAPPLIED CASH 7

EXISTING CONTROLS WERE OUTDATED AND WERE NOT ALWAYS COMPLETE 7

RECOMMENDATIONS 7

MANAGEMENT’S COMMENTS AND OUR RESPONSE 8

TRANSACTIONS WERE NOT RECONCILED AND WERE NOT ALWAYS PROPERLY RECORDED OR PROCESSED 

TIMELY 9

NO UNIVERSE OF UNAPPLIED CASH RECEIPTS 10

NO RECONCILIATION PROCESS IN PLACE 10

FINANCIAL MANAGEMENT INTEGRATED SYSTEM UNAPPLIED CASH POSTING LOGIC ERRORS 11

QUESTIONABLE $15 MILLION UNAPPLIED CASH ADJUSTMENT AND UNCORRECTED UNAPPLIED 

CASH BALANCE AT SEPTEMBER 30, 2017 11

BUREAU OF FISCAL OPERATIONS MAINTAINED NO AGING REPORTS 11

RECOMMENDATIONS 12

MANAGEMENT’S COMMENTS AND OUR RESPONSE 13

MIGRATION EFFORTS FAILED TO PRODUCE A FUNCTIONAL UNAPPLIED CASH APPLICATION 15

INADEQUATE UNAPPLIED CASH MIGRATION CONTROL ACTIVITIES 16

LACK OF ASSIGNMENT OF OVERALL RESPONSIBILITIES FOR COORDINATING AND OVERSEEING 

UNAPPLIED CASH PROCESS ACROSS APPLICABLE ORGANIZATIONS 17

RECOMMENDATIONS 17

MANAGEMENT’S COMMENTS AND OUR RESPONSE 18

APPENDIX I: MANAGEMENT COMMENTS 20
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Improvements Needed for the Unapplied Cash Process at the RRB - Report No. 19-08 1

INTRODUCTION

This report presents the results of the Office of Inspector General’s audit of the unapplied cash 

process at the Railroad Retirement Board (RRB).

Objective(s), Scope, and Methodology

The objectives of this audit were to: (1) assess the adequacy of controls over the unapplied cash 

process; (2) determine if unapplied cash was being properly recorded and reconciled in an 

accurate and timely manner; and (3) assess the impact of the PARS to FMIS migration on the 

unapplied cash process. 

To accomplish our objective, we

 identified criteria provided in applicable laws and regulations related to unapplied cash; 

 identified, reviewed, and evaluated RRB policies and procedures related to the 

unapplied cash process;

 interviewed key management and staff and conducted walkthroughs; 

 identified and tested controls and transactions related to unapplied cash; 

 conducted data analysis on unapplied cash general ledger transactions;

 reviewed contract documentation for the PARS to FMIS migration; and 

 reviewed email documentation related to the processing of unapplied cash cases. 

We assessed the reliability of unapplied cash receipt transaction data provided by the RRB 

through data extract by (1) reviewing data for obvious errors in accuracy and completeness; 

(2) reviewing systems from which data was obtained; and (3) communicating with RRB officials 

knowledgeable about the data. In addition, we traced unapplied cash receipt transaction data 

to source documents and systems. Because the data provided was outside the scope of our 

review, and we were unable to obtain data for the scope of our review, we determined that we 

would not rely on computer processed data to materially support our findings, conclusions, or 

recommendations.

Our scope was unapplied cash transactions in FMIS for fiscal year 2017.

We conducted this performance audit in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions 

based on our audit objective. We believe that the evidence obtained provides a reasonable 

basis for our findings and conclusions based on our audit objective. 
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Improvements Needed for the Unapplied Cash Process at the RRB - Report No. 19-08 2

We conducted our fieldwork at RRB headquarters in Chicago, Illinois from January 2018 through 

July 2018 and December 2018 through February 2019. This audit was suspended from 

August 2018 through November 2018 due to resources needed to perform mandated audits.

Background

The RRB, an independent agency in the executive branch of the federal government, 

administers retirement/survivor and unemployment/sickness insurance benefit programs for 

railroad workers and their families under the Railroad Retirement Act (RRA) and the Railroad 

Unemployment Insurance Act (RUIA). During fiscal year 2017, benefit payments under the RRA 

and RUIA totaled approximately $12.5 billion and $104.6 million, respectively. 

One of the RRB’s comprehensive strategic goals is to serve as responsible stewards for 

customers’ trust funds and agency resources. The objective is to ensure that trust fund assets 

are protected, collected, recorded, and reported appropriately. To address this objective, the 

RRB states that “In instances where erroneous payments occur, the RRB will apply its debt 

collection and management policies in a fair and equitable manner.”

Within the RRB, the Bureau of Fiscal Operations (BFO) contains several organizational units, two 

of which are the Debt Recovery Section (DRS) and the Accounting Section. The Chief Financial 

Officer is responsible for oversight of BFO. The responsibilities of these component units are 

noted below.

The mission of DRS is to record, collect, and account for all debts (owed to the RRB) under the 

RRA and RUIA. This mission also includes promptly and correctly employing all appropriate 

collection tools, accurately and efficiently accounting for all collections, adjudicating waiver 

requests, and reporting on the status of debts and collections. A DRS control objective states 

that amounts collected should be properly monitored, accurately and timely deposited, 

attributed to the correct fund, and posted accurately and timely to the correct account by 

authorized personnel or systems.

BFO’s Accounting Section is responsible for the RRB's financial accounting, including the design, 

review, and implementation of automated accounting and financial management systems; and 

for providing advisory services to operating officials, both within and outside the RRB. These 

responsibilities also include ensuring that transactions are posted to the correct accounts, and 

periodically reconciling the different accounts for accuracy.

Within the RRB, the Office of Programs contains several organizational units, two of which are 

the Retirement/Survivor Benefits Division (referred to as RRA) and the Unemployment and 

Program Support Division (referred to as RUIA). RRA is responsible for retirement/survivor 

benefit claims operations. RUIA is responsible for the unemployment, sickness, taxation, and 

Medicare claims operations, and also provides clerical support to the Office of Programs.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Improvements Needed for the Unapplied Cash Process at the RRB - Report No. 19-08 3

RRB management and internal control policies and structures are governed by:

 The Executive Committee functions as the RRB’s senior management council that 

assesses and monitors deficiencies in internal control. Under the direction and 

leadership of the Senior Executive Officer, the Executive Committee oversees daily RRB

operations and is responsible for oversight and problem solving regarding cross 

organizational internal control issues.

 Management Control Review Committee (MCRC) also has agency-wide internal control 

responsibilities. The MCRC prepares internal control documents required by the Federal 

Managers’ Financial Integrity Act of 1982 for inclusion in the agency’s annual 

Performance and Accountability Report.1 The purpose of the MCRC is to establish and 

oversee a process to identify and eliminate management control weaknesses and 

financial nonconformance.

 RRB organizational heads are responsible for installing, maintaining, monitoring, 

revising, and enforcing management controls within their organizations. The RRB 

defines assessable units for agency activities that can impact its mission.

For debt collection purposes, unapplied cash are cash remittances deposited into the RRA or 

RUIA accounts and recorded in the Financial Management Integrated System (FMIS) as a cash 

receipt transaction that cannot be applied to debts for generally two reasons: (1) the 

remittance was received before the corresponding debt has been established in FMIS or (2) the 

remittance does not match an existing open debt in FMIS [i.e. does not match the amount of an 

open debt, billing document identification number, or social security number]. 

After cash remittances are categorized as unapplied cash, the disposition may include any 

combination of the following for all or some of the remittance: (1) apply it to an open debt, 

(2) refund it to the claimant, annuitant, or payer, or (3) transfer it to the appropriate benefit

fund (i.e. RRA to RUIA or RUIA to RRA).

While unapplied cash is not considered material to the RRB’s financial statements, cash is an 

asset that is highly susceptible to theft. Therefore, every effort should be made to ensure that 

trust fund assets are protected, collected, recorded, and reported appropriately, as is stated in 

the RRB’s strategic goals.

In the past, benefit receivables were processed in the RRB’s Program Accounts Receivable 

System (PARS) and transactions were manually posted into the RRB’s previous financial system, 

the Federal Financial System, and then into FMIS starting in October 2014. In June 2016, all 

balances in PARS, along with most of its debt receivable functionality, were migrated to FMIS 

when PARS was retired.

 1 Pub. L. No. 97-255, 96 Stat. 814 (1982) Federal Managers’ Financial Integrity Act.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Improvements Needed for the Unapplied Cash Process at the RRB - Report No. 19-08 4

When RRB began planning for the PARS to FMIS migration, the RRB intended for debt collection 

operations previously provided by PARS to migrate to FMIS utilizing existing accounts receivable 

functionalities. The system was intended to: (1) achieve compliance with RRB applicable laws, 

regulations, standards, and requirements; (2) improve and facilitate user access to financial 

information through online inquiries and reporting tools; (3) reduce redundancy in data entry, 

storage, and processing; (4) improve security, control, and disaster recovery capability; and 

(5) reduce manually intensive business processes.

In connection with the migration, the RRB planned to develop a separate unapplied cash 

processing application, to replace the unapplied cash processing table in PARS, which would 

interface with FMIS for the processing of unapplied cash receipts. However, this application for 

unapplied cash processing was not completed prior to the migration from PARS to FMIS in 

June 2016.

As a result, each unapplied cash item that DRS could not match or apply to a related transaction 

in FMIS, was forwarded through email to the Office of Programs with all related documents for 

follow up. The Office of Programs (RRA and RUIA) then conducted their adjudicative review to 

determine the proper disposition of the unapplied cash receipt items and email DRS the 

disposition actions that would require manual processing in FMIS.

The PARS to FMIS migration project proceeded according to the following timeline:

 In January 2016, the RRB’s Bureau of Information Services was tasked with modifying 

two applications pertaining to unapplied cash. The Universal System Tracking and 

Reporting System application was to be modified to “track” unapplied cash, and the 

Overpayment Recovery Correspondence System (ORCS) was to be used for disposition 

of unapplied cash. Both applications were to be modified in order to pass unapplied 

cash activity into FMIS when PARS migrated to FMIS in June 2016.

 In June 2016, PARS was retired and outstanding receivable balances were migrated to 

FMIS. This completed the final phase to move all receivables and collections to an 

integrated financial management system maintained by RRB’s contracted service 

provider. 

 In July 2016, the PARS to FMIS migration was completed.

 In November 2016, the RRB determined that the Universal System Tracking and 

Reporting System application could not support the unapplied cash process. At this 

point, Office of Programs and the Bureau of Information Services decided to expand the 

ORCS application to include a new unapplied cash process. 

 From November 2016 to August 2017, ORCS was in development and operated on a test 

basis from August 2017 to January 2018. 

 The separate ORCS Unapplied Cash Application went live on January 19, 2018, which 

was approximately 18 months after the PARS to FMIS migration. 
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Improvements Needed for the Unapplied Cash Process at the RRB - Report No. 19-08 5

From the time of the migration in June 2016 until January 19, 2018, DRS, RRA, and RUIA were 

responsible for the following:

 DRS reviewed lockbox cash receipts to apply all receipts to the proper debt receivable 

accounts in FMIS. All receipts that DRS could not readily match or apply to the proper 

account would be classified in the unapplied cash account in FMIS. In most cases, cash 

receipts that did not have a corresponding billing document number were designated as 

an unapplied cash item. If the cash receipt was more than the related debt, it was also 

classified under unapplied cash in FMIS.

 For all cash receipts that DRS could not match or apply to an existing receivable, DRS 

would either forward them to RRA and RUIA by email for follow-up or RRA and RUIA 

would query FMIS for follow-up. 

 RRA and RUIA conducted adjudicative reviews to determine the proper disposition 

action for the unapplied cash receipts.

 After RRA and RUIA completed their adjudicative review, they notified DRS of the 

proper disposition actions required in FMIS. Notification was usually provided by email. 

 DRS then manually processed all unapplied cash disposition requests from RRA and 

RUIA into FMIS. 

 After DRS’s disposition actions were entered in FMIS, the Accounting Section ensured 

the proper posting of general ledger account transactions in FMIS.

After the ORCS Unapplied Cash Application was released in January 2018, DRS, RRA, and RUIA 

unapplied cash responsibilities essentially remained the same, but unapplied cash processing 

became fully automated, eliminating the need for manual entries and allowing RRA’s and 

RUIA’s adjudicative reviews and dispositions to be documented in the ORCS Unapplied Cash 

Application.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Improvements Needed for the Unapplied Cash Process at the RRB - Report No. 19-08 6

RESULTS OF AUDIT

Our audit determined that after the PARS to FMIS migration: (1) RRB’s controls over the 

unapplied cash process were not adequate; (2) transactions were not being reconciled, and 

were not always properly recorded or processed timely; and (3) migration efforts failed to 

produce a functional unapplied cash application that fully automated the processing of 

unapplied cash.

We made 14 recommendations to address these weaknesses. The details of the audit findings 

and recommendations for corrective action follow. The full text of RRB management’s response 

is included in this report as Appendix I.

Internal Controls Not Adequate

We determined that internal controls for the unapplied cash process were not adequate and 

could not be relied on to ensure the proper processing of transactions. We found that

 the RRB lacked a comprehensive agency-wide process for maintaining, monitoring, and 

reporting on unapplied cash; and 

 existing controls were outdated and were not always complete.

These conditions occurred because RRB did not: (1) identify the need for a comprehensive 

agency-wide process over unapplied cash, or (2) identify, analyze, and respond to significant 

unapplied cash process changes.

The Government Accountability Office's Standards for Internal Control in the Federal 

Government (GAO Standards) require that management: (1) identifies changes in the internal 

control system that either have occurred or are needed because of changes in the entity and its 

environment; (2) considers whether current controls address the identified issues and modifies 

controls if necessary; (3) documents in policies the internal control responsibilities of the 

organization; and (4) communicates to personnel the policies and procedures so that personnel 

can implement the control activities for their assigned responsibilities.2 This includes 

management documenting, in policies for each unit, its responsibility for process objectives and 

risks, control activity design, implementation, and operating effectiveness. Each unit also 

documents policies in the appropriate level of detail to allow management to effectively 

monitor the control activity.

The RRB's Management Control Guide states that all levels of management are accountable for 

implementation of the management and internal control policies and objectives at the RRB.3 It 

also states that management control documentation should be updated when warranted in the 

judgment of the responsible official. To ensure that documentation is complete, current, and 

accurate, it needs to be updated as changes occur.

 2 Government Accountability Office (GAO), Standards for Internal Controls in the Federal Government,

GAO-14-704G (Washington, D.C.: September 2014).

3 Railroad Retirement Board (RRB), Management Control Guide (Chicago, IL: February 2015).
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Improvements Needed for the Unapplied Cash Process at the RRB - Report No. 19-08 7

Railroad Retirement Board Lacked a Comprehensive Agency-Wide Process for 

Maintaining, Monitoring, and Reporting on Unapplied Cash

Although RRB had processes for establishing internal controls, we found that RRB did not have 

a comprehensive agency-wide process for maintaining, monitoring, and reporting on unapplied 

cash. For example, we found that existing controls for each applicable organizational unit were 

not being updated on a timely basis to reflect current unapplied cash business processes 

resulting from the PARS to FMIS migration. In addition, existing controls were not always 

complete across the organizational units. 

Because procedures can become less effective over time, or the application of controls can 

change, RRB’s senior management should continually assess and evaluate internal controls 

agency-wide. 

Having a comprehensive agency-wide process for maintaining, monitoring, and reporting 

unapplied cash will help RRB to: (1) ensure that the internal controls implemented are current, 

adequately designed; and that control failures and risks are identified, corrected, and mitigated 

on a timely basis; (2) facilitate organizational cohesiveness in providing effective oversight; 

(3) significantly improve accountability over the entire unapplied cash process; and 

(4) effectively and efficiently achieve its mission, goals, and objectives of ensuring that trust 

fund assets are protected, collected, recorded, and reported appropriately.

Existing Controls were Outdated and Were Not Always Complete

The migration to FMIS in June 2016 represented a significant change in the processing and 

internal controls over unapplied cash. During our review, we found that the RRB’s charts of 

controls (for DRS, RRA, and RUIA), and BFO’s Accounting Procedures Guide had not been 

updated to reflect the current unapplied cash business processes subsequent to the PARS/FMIS 

migration. In addition, the controls that we identified were either implied, incomplete, or 

poorly documented.

Because RRB did not identify, analyze, and respond to significant changes that impacted the 

internal control system, the following occurred: (1) unapplied cash data were inaccurate; 

(2) processing was delayed; (3) payments due to beneficiaries were not promptly sent back; and 

(4) receivables were not properly reduced. As a result, the RRB’s objective, to ensure that trust 

fund assets are protected, recorded, and reported appropriately, was not met for unapplied 

cash.

Recommendations

1. We recommend that the Executive Committee develop a comprehensive agency-wide 

process for maintaining, monitoring and reporting on unapplied cash to ensure that all 

unapplied cash items are properly identified, recorded, monitored, reconciled, 

investigated, and resolved.

 
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Improvements Needed for the Unapplied Cash Process at the RRB - Report No. 19-08 8

We recommend that the Bureau of Fiscal Operations:

2. update all control documentation (including policies and procedures, charts of controls, 

and other related documentation) to reflect the changes that occurred to unapplied 

cash as a result of the migration to the Financial Management Integrated System; and

3. test the updated unapplied cash controls to ensure that they are present and operating 

as intended.

We recommend that the Office of Programs:

4. update all control documentation (including policies and procedures, charts of controls, 

and other related documentation) to reflect the changes that occurred to unapplied 

cash as a result of the migration to the Financial Management Integrated System; and

5. test the updated unapplied cash controls to ensure that they are present and operating 

as intended.

Management’s Comments and Our Response

In its comments, RRB management stated that on page 5 of the draft audit report the first 

bullet point was not correct. The bullet stated “[t]he Accounting Section then posted the 

transaction in FMIS based on disposition received from DRS.” RRB management also stated, the 

accounting section was not involved in this process; therefore, this bullet should be removed 

from the report in its entirety.

During our audit fieldwork, Accounting Section management stated that the Accounting 

Section’s involvement was limited to preparing the standard voucher for the recording of 

unapplied cash receipts and the disposition of such receipts based on disposition data from 

DRS. Based on these statements, we clarified the content of this bullet, now the last bullet on 

page 5 of this report, accordingly for the readers’ understanding.

BFO management concurred with recommendations 2 and 3, and the Office of Programs 

concurred with recommendations 4 and 5.

For recommendation 1, the SEO, on behalf of the Executive Committee, nonconcurred. RRB 

management stated that “as acknowledged by the auditors, ‘unapplied cash is not material to 

the RRB’s financial statements...’ Therefore, suggesting that a comprehensive agency-wide 

process is necessary to manage unapplied cash is not reasonable, warranted, or cost effective. 

As communicated to the OIG verbally and via formal memo on March 6, 2019, two Executive 

Committee (EC) members, the Chief Financial Officer and the Acting Director for the Office of 

Programs (OP), have appropriate responsibility for unapplied cash and are both actively 

engaged in continuous monitoring activities.” Management also stated that internal control 

documentation may need to be updated and tested, but the notion that a comprehensive 

agency-wide process, monitored by the SEO on behalf of the Board, overstates the importance 

of the subject matter and is not an effective or efficient use of RRB’s resources.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Improvements Needed for the Unapplied Cash Process at the RRB - Report No. 19-08 9

The OIG continues to assert that this recommendation is warranted. Although unapplied cash is 

not considered material to the RRB’s financial statements taken as a whole, this does not 

negate the need for establishing effective control activities for the entire unapplied cash 

process, as this process impacts program integrity and customer service. Although RRB 

management is responsible for this area, our findings show that control activities are needed to 

address the cited deficiencies. While RRB management’s comments stated that the

management staff for Office of Programs and the Bureau of Fiscal Operations have appropriate 

responsibility for unapplied cash, it was evident during the course of our audit that there was 

no unified system of oversight for the unapplied cash process. It was clear from our 

observations that each unit’s responsibilities were limited to their involvement in the unapplied 

cash process. As a result, issues documented in this audit report remained unresolved. We 

believe that an agency-wide process for unapplied cash could help facilitate organizational 

cohesiveness and provide effective oversight for the unapplied cash process.

Transactions Were Not Reconciled and Were Not Always Properly 

Recorded or Processed Timely

We determined that after the PARS to FMIS migration, unapplied cash transactions were not 

being reconciled and were not always properly recorded or processed timely. We found the 

following:

 BFO was unable to provide a universe of unapplied cash receipts for fiscal year 2017.

 There was no reconciliation process in place for unapplied cash transactions.

 FMIS contained errors in the posting logic for unapplied cash. Therefore, transactions 

were not being posted to the proper accounts.

 In July 2017, BFO recorded a questionable adjustment of $15 million for unapplied cash. 

Despite this adjustment, the unapplied cash balance as of September 30, 2017 was 

incorrect.

 BFO maintained no aging reports for the unapplied cash account. 

These deficiencies occurred because: (1) RRB did not establish and implement proper 

monitoring control activities for the unapplied cash process; and (2) RRB’s FMIS and ORCS 

Unapplied Cash Application systems could not provide historical unapplied cash data.

GAO's Standards state that management should

 design control activities so that all transactions are completely and accurately recorded;

 perform ongoing monitoring of the design and operating effectiveness of the internal 

control system as part of the normal course of operations. Ongoing monitoring includes 

regular management and supervisory activities, comparisons, reconciliations, and other 

routine actions. Ongoing monitoring may include automated tools, which can increase 

objectivity and efficiency by electronically compiling evaluations of controls and 

transactions; 
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Improvements Needed for the Unapplied Cash Process at the RRB - Report No. 19-08 10

 evaluate and document the results of ongoing monitoring and separate evaluations to 

identify internal control issues. Management uses this evaluation to determine the 

effectiveness of the internal control system. Differences between the results of 

monitoring activities and the previously established baseline may indicate internal 

control issues, including undocumented changes in the internal control system or 

potential internal control deficiencies; and

 design control activities over the information technology infrastructure to support the 

completeness, accuracy, and validity of information processing by information 

technology.

4

The RRB’s Management Control Guide states that the Federal Managers’ Financial Integrity Act 

of 1982 provides that the objectives of internal accounting and administrative controls are to 

provide reasonable assurance that revenues and expenditures applicable to RRB operations are 

recorded and accounted for properly so that accounts and reliable financial and statistical 

reports may be prepared and accountability of the assets may be maintained. 

No Universe of Unapplied Cash Receipts

To determine the reliability of unapplied cash balances, we asked BFO to provide a complete 

universe of unapplied cash receipts for fiscal year 2017 for our review. BFO told us that this 

information could not be provided because FMIS does not track the history of individual cash 

receipt documents. This was confirmed by the FMIS contractor. We requested that the Office of 

Programs provide similar information (unapplied cash receipts received, carried over from prior 

year, and receipts disposed of) from the ORCS Unapplied Cash Application, but the Office of 

Programs could not provide this information due to limitations in the ORCS Unapplied Cash 

Application. As a result, RRB was unable to provide a complete data universe of unapplied cash 

receipts for fiscal year 2017.

No Reconciliation Process in Place

From the time that PARS was retired in June 2016 until January 2018, DRS, RRA, and RUIA were 

processing unapplied cash cases manually. This process began with DRS forwarding by email, all 

unapplied cash cases that they could not match to a debt receivable to RRA and RUIA for follow 

up and proper disposition action. RRA and RUIA would then email the disposition actions 

needed back to DRS for manual input into FMIS. 

Because the process was manual rather than automated, and because they could not provide a 

complete universe of unapplied cash receipts, we asked the RRB if they could provide any 

reports to show that they monitored, tracked, controlled, or reconciled unapplied cash 

transactions to ensure their completeness and accuracy. They could not provide these reports, 

and there was no documentation to show that they had ever performed reconciliations related 

to the unapplied cash account.

 4 GAO, GAO-14-704G.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Improvements Needed for the Unapplied Cash Process at the RRB - Report No. 19-08 11

Financial Management Integrated System Unapplied Cash Posting Logic Errors

During our audit, we determined that the FMIS posting logic for recording unapplied cash 

transactions was incorrect, and BFO remained unaware of the problem until several months 

after the PARS to FMIS migration. As a result, during fiscal year 2017, the unapplied cash 

account reached an unusually high balance of $15 million. BFO initially told us that the 

significant build up in the balance of the unapplied cash account was probably attributable to 

the use of incorrect posting logic codes between FMIS and the ORCS Unapplied Cash 

Application. 

BFO later confirmed that when the benefit receivable functions were migrated into FMIS, the 

posting logic for unapplied cash receipt transactions was incorrect. Specifically, they told us that 

when an unapplied cash transaction occurred, FMIS recorded the entry into the incorrect 

standard general ledger (SGL) accounts. FMIS was recording the transaction(s) to the Benefits 

Expense SGL account instead of the unapplied cash SGL account. For financial reporting 

purposes, the erroneous entries caused both expenses and liabilities to be understated.

Questionable $15 Million Unapplied Cash Adjustment and Uncorrected 

Unapplied Cash Balance at September 30, 2017

In July of 2017, BFO made a questionable adjustment of approximately $15 million to the 

unapplied cash account based on the assumption that manual entries to this account were 

duplicating the automated entries already posted by FMIS. At the time of this adjustment a

complete documented verification or reconciliation had not been made to determine whether 

or not all the manual entries were actually duplicate entries. In addition, the adjustment 

reduced the unapplied cash account balance from a $15.9 million credit balance to 

approximately a $51,800 credit balance at June 30, 2017 which appears questionable. As of 

September 30, 2017, the balance was a debit balance of approximately $12,200 which is not 

considered a reasonable balance for this account. 

According to the schedule of outstanding unapplied cash cases at September 30, 2017, the 

balance in the unapplied cash account should have approximated a credit balance of at least 

$2 million. We found that there was no complete documented determination or reconciliation 

as to what the proper adjustment to unapplied cash should have been to correct the balance at 

September 30, 2017.

Bureau of Fiscal Operations Maintained No Aging Reports

To determine the amount of time that unapplied cash receipt items remained unresolved, we 

asked BFO and the Office of Programs to provide an unapplied cash aging report for 

fiscal year 2017. BFO and the Office of Programs told us there were no aging reports for 

fiscal year 2017. Data for unapplied cash receipts that were processed during fiscal year 2017 

were not available.
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After further discussions, DRS was able to provide a listing of unapplied cash receipts that 

remained outstanding on September 30, 2017. Although the listing had deposit and receipt 

dates, the listing did not provide a calculation of the age of the unapplied cash receipt items 

listed. Therefore, we calculated the age of the unapplied cash receipts using the deposit and 

receipt dates. 

While we could not verify the completeness of the listing of outstanding unapplied cash 

receipts that we were given, based on our calculations, taking the difference in days between 

the cash receipt deposit date and September 30, 2017, we determined that the majority of 

outstanding unapplied cash receipts (approximately 1,200 out of 2,000 items) ranged in age 

from 6 months to 4 years old, with the average age of about 13 months old. The age of these 

open unapplied cash receipts confirms the absence of monitoring controls that were needed to 

ensure the timely processing of unapplied cash receipts. 

The absence of an aging report reduced the amount of control over unapplied cash cases, 

which resulted in untimely processing of unapplied cash transactions. Because transactions 

were not reconciled and were not always properly recorded or processed timely, delays 

occurred for the application of beneficiary debts and for returning payments to beneficiaries 

that no longer had outstanding debts. 

Recommendations

We recommend that the Bureau of Fiscal Operations:

6. work with the Railroad Retirement Board’s Financial Management Integrated System 

contracted service provider to implement Financial Management Integrated System 

modifications to ensure that all unapplied cash transactions [unapplied cash receipts 

received, carried over from prior year, and receipts disposed of (applied to debt)] are

maintained going forward, for completeness and accountability;

7. develop and implement a formal reconciliation process to ensure accountability, 

completeness, and accuracy of unapplied cash transactions;

8. work with the Railroad Retirement Board’s Financial Management Integrated System

contracted service provider to correct Financial Management Integrated System posting 

logic for unapplied cash to ensure that unapplied cash transactions are properly 

recorded;

9. establish internal controls over accounting adjustments for unapplied cash to ensure 

that the adjustments are proper and that balances are accurate; and

10. develop and maintain an unapplied cash aging report to ensure proper monitoring and 

timely processing of unapplied cash receipts.
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We recommend that the Office of Programs:

11. work with the Railroad Retirement Board’s Bureau of Information Services to implement 

Overpayment Recovery Correspondence System modifications to ensure that unapplied 

cash historical files [carried over from prior years, and receipts disposed of (applied to 

debt)] are maintained for completeness and accountability.

Management’s Comments and Our Response

The Bureau of Fiscal Operations concurred with recommendation 7, but did not concur with 

recommendations 6, 8, 9, and 10.

For recommendation 6, BFO management stated that BFO coordinated with CGI (the 

contracted service provider) to implement posting logic fixes in fiscal year 2018. As a result of 

this completed corrective effort, all unapplied cash activity flows through the unapplied cash GL

(general ledger) account, as such BFO staff has the ability to generate a general ledger report to 

show all unapplied activity. As described above, the BFO provided the OIG evidence of the 

posting logic fixes during the course of the OIG’s audit fieldwork. Therefore, BFO considers 

corrective action taken sufficient to address this recommendation and will therefore, not take 

any additional corrective action on this matter.

OIG disagrees with BFO management’s response to recommendation 6 which focuses on the 

need for system modifications to the Financial Management Integrated System (FMIS) to 

ensure that all unapplied cash transactions are maintained going forward, for completeness 

and accountability. Based on a documented response from RRB management, we were 

informed by BFO and CGI that FMIS could not track historical data for unapplied cash 

transactions. Given this, although BFO may have implemented posting logic fixes in fiscal year 

2018, it is not clear or certain as to whether the posting logic fixes alone have fully addressed 

our concerns regarding the completeness and accountability of the universe of unapplied cash 

transactions. In addition, any posting logic corrections made would have been well after the 

scope of our audit, which was fiscal year 2017.

For recommendation 8, BFO management stated that while they acknowledged that corrective 

action (regarding the posting logic) was necessary, they stated that correction was completed, 

and the evidence was provided to the audit team during their fieldwork period.

OIG disagrees with BFO management’s response to recommendation 8. This recommendation 

remains valid based on the fact that: (1) the posting logic problem existed during the scope of 

our audit, which was fiscal year 2017; and (2) we were unable to verify that the posting logic 

fixes which occurred in fiscal year 2018, were indeed successful regarding the completeness 

and accuracy of all unapplied cash data. 
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For recommendation 9, BFO management stated that they non-concurred with the OIG’s 

characterization of the ($15 million Unapplied Cash Adjustment) as ‘questionable.’ They further 

stated that “In 2017, BFO internal control procedures determined that the manual voucher 

SV517 entries to record cash receipts to the FBWT (Fund Balance With Treasury) General 

Ledger (GL) account was duplicating entries that were also being recorded automatically each 

accounting period due to the FMIS PAR migration.”

The SV517 records cash activity associated with Intragovernmental Payment and Collection 

(IPAC) activity for Debt Management Service, Treasury Receivable and Collection System and 

Department of Justice as well as Treasury’s Collections Information Repository (CIR). Based on 

the results of BFO’s internal review, BFO reversed the SV517 vouchers for periods July 2016 

through June 2017 that totaled approximately $15 million; the primary focus of the entry was 

to correct the FBWT GL account. Adjustments to the unapplied cash account were a byproduct 

of correcting duplicative entries in the FBWT GL account. Further, in FMIS BFO included the 

detailed documentation to support the SV517 reversal entries. Through FMIS, this information 

was available to the OIG. Further, verbally during the exit conference on March 6, 2019 and via 

formal memorandum to the OIG, BFO clarified the focus of the 15 million dollar entry.”

OIG disagrees with BFO management’s response to recommendation 9. Our review of the 

supporting documentation provided for the $15 million adjustment did not identify a complete 

verification or reconciliation of duplicate entries. Furthermore, BFO claims in their management 

response above, that the adjustment to unapplied cash account was a byproduct of correcting 

duplicate entries in the Fund Balance with Treasury. We question the purpose of such an 

adjustment that was intended to correct the balance in the Fund Balance with Treasury general 

ledger (GL) account while the Unapplied Cash Account balance remained substantially 

incorrect.

For recommendation 10, BFO management stated that “BFO non-concurs with the assertion 

that a specific unapplied cash aging report is necessary to ensure timely processing of 

unapplied cash transactions. FMIS tracks and records the deposit and receipt dates for all 

unapplied cash items and, as demonstrated in the draft audit report, this information can be 

used to determine the age of the unapplied cash items. Further, as previously communicated to 

the OIG, the posting logic fixes implemented during fiscal year 2018 (discussed above), allow for 

additional visibility through review of the unapplied cash GL account. Given that the OIG 

acknowledges that unapplied cash transactions, are immaterial to the RRB’s financial 

statements and considering the current FMIS query capabilities, it is not cost effective to pursue

development of a specific aging report for unapplied cash.”

OIG disagrees with BFO management’s response to recommendation 10. While we could not 

verify the completeness of the listing of outstanding unapplied cash receipts that we were 

provided, we calculated the average age of outstanding unapplied cash receipts at 

September 30, 2017 to be approximately 13 months old. We believe this observation speaks to 

the need for the utilization of an aging report. A clearly defined aging report that is reviewed on 

a periodic basis is an effective monitoring control that can provide the awareness needed to 

ensure the timely processing of unapplied cash items.
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The Office of Programs non-concurred with recommendation 11. Office of Programs 

management referred to a separate discussion in their comments regarding the “Aging Report.” 

They further stated that “Additionally, in the context of RRB’s re-engineering/IT modernization 

efforts, the Office of Programs will assess the viability of the Unapplied Cash application and 

future archiving capabilities and take appropriate action.”

OIG disagrees with the Office of Programs response to recommendation 11. We are not clear as 

to how RRB management’s comments regarding the “aging report” relates to recommendation 

11, which recommended that system modifications be made to the Overpayment Recovery 

Correspondence System to ensure that all unapplied cash historical files related to disposition 

actions are maintained for completeness and accountability. By stating that they “will assess 

the viability of the Unapplied Cash Application and future archiving capabilities and take 

appropriate action”, it is our hope that management will see the value in our concern regarding 

the need for completeness and accountability over the entire unapplied cash process, to 

include all data related to unapplied cash in the Overpayment Recovery Correspondence 

System.

Migration Efforts Failed to Produce a Functional Unapplied Cash 

Application

The RRB’s plan for the PARS to FMIS migration was to transfer all of the debt collection 

operations previously provided by PARS to FMIS utilizing existing accounts receivable 

functionalities. The PARS to FMIS migration was intended to: (1) achieve compliance with 

applicable laws, regulations, standards, and requirements; (2) improve and facilitate user 

access to financial information through online inquiries and reporting tools; (3) reduce 

redundancy in data entry, storage, and processing; (4) improve security, control, and disaster 

recovery capability; and (5) reduce manually intensive business processes. 

In connection with the migration, an unapplied cash application was to be designed to interface 

with FMIS to process the disposition of all unapplied cash receipts and properly record the 

transactions in FMIS. Although all of the balances in PARS, including unapplied cash, were 

transferred to FMIS during the migration in June 2016, migration efforts failed to produce an 

unapplied cash application to fully automate the unapplied cash process using the same 

functionalities as PARS.

A fully automated unapplied cash process was not created after the migration as planned due 

to

 inadequate migration control activities in place to ensure appropriate coverage of 

objectives and risks related to the unapplied cash migration process; and

 the lack of assigning a key role to an appropriate person for overall responsibility of 

coordinating and overseeing all control activities for the unapplied cash process across 

applicable organizations and assessable units.
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GAO Standards state that:

 Management should design control activities for appropriate coverage of objectives and 

risks in the operations. Operational processes transform inputs into outputs to achieve 

the organization’s objectives. Management designs entity-level control activities, 

transaction control activities, or both depending on the level of precision needed so that 

the entity meets its objectives and addresses related risks.

 To achieve the entity’s objectives, management should assign responsibility and 

delegate authority to key roles throughout the entity. A key role is a position in the 

organizational structure that is assigned an overall responsibility of the entity. Generally, 

key roles relate to senior management positions within an entity.5

Inadequate Unapplied Cash Migration Control Activities

Our review of the migration process related to unapplied cash, and discussions with BFO staff, 

determined that RRB could not provide evidence of 

 a complete formal project management plan or any other project monitoring and 

evaluation documents used in the PARS migration to FMIS;

 a risk assessment performed by the contracted service provider or RRB for the PARS to 

FMIS migration system implementation;

 proper management of contract or project requirements by contracted service provider 

or RRB;

 documented sign-offs for deliverables, user acceptance testing, or final project;

 monitoring and required system implementation testing by the contracted service 

provider or RRB as noted in the contract Statement of Work; or 

 documented system migration controls. 

The Office of Programs staff continued to manually adjudicate unapplied cash cases until the 

ORCS Unapplied Cash Application became fully functional in January 2018, approximately 

18 months after the PARS to FMIS system migration in July 2016.

The absence of such control activities reduced the RRB’s effectiveness in meeting its unapplied 

cash migration objectives of: (1) improving and facilitating user access to financial information; 

(2) reducing redundancy of data entry; and (3) reducing manually intensive business processes.

The untimely development of the Unapplied Cash Application delayed RRB’s ability to process 

unapplied cash receipts in the most accurate, timely, and efficient manner. 

 5 GAO, GAO-14-704G.
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Lack of Assignment of Overall Responsibilities for Coordinating and Overseeing 

Unapplied Cash Process Across Applicable Organizations

The RRB had not designated a responsible official to oversee the entire unapplied cash process. 

While the RRB was facing unapplied cash migration challenges, we noted that crossorganizational coordination and oversight responsibilities had not been assigned to one 

individual. Assignment of the appropriate personnel to this key role would have facilitated 

better oversight and accountability among applicable organizations regarding the processing of 

unapplied cash cases in FMIS.

Because the RRB had not assigned an appropriate person the overall responsibility for the 

entire unapplied cash process, RRB experienced: (1) significant delays in the development of a 

functional Unapplied Cash Processing Application; and (2) further challenges in processing 

unapplied cash transactions accurately, timely, and efficiently.

Because the RRB developed an ORCS Unapplied Cash Processing Application in January 2018, 

after our scope ended, our recommendations are limited accordingly. 

Recommendations

12. We recommend that Bureau of Fiscal Operations establish and implement unapplied 

cash control activities to ensure that a qualified person is assigned a key role for the 

overall responsibility of coordinating and overseeing all control activities for the 

unapplied cash process across organizations and assessable units.

13. We recommend that the Office of Programs work with the Bureau of Fiscal Operations 

to establish and implement control activities to ensure that the Overpayment Recovery 

Correspondence System Unapplied Cash Application is fully interfaced with the Financial 

Management Integrated System so that all unapplied cash transactions are properly 

processed and recorded in the Overpayment Recovery Correspondence System 

Unapplied Cash Application.

14. We recommend that the Bureau of Fiscal Operations work with the Office of Programs 

to establish and implement control activities to ensure that the Financial Management 

Integrated System is fully interfaced with the Overpayment Recovery Correspondence 

System Unapplied Cash Application so that all unapplied cash transactions are properly 

processed and recorded in the Financial Management Integrated System.
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Management’s Comments and Our Response

RRB Management did not concur with these recommendations.

For recommendation 12, BFO management stated that “this recommendation is redundant to 

recommendation 1, with which the SEO non-concurred. To reiterate the OIG acknowledges the 

unapplied cash amount is immaterial to the RRB’s financial statements as demonstrated by the 

balance at the time of PAR conversion, which was $326,293. The BFO non-concurs with this 

recommendation. The BFO cannot assign ‘an appropriate person’ the ‘overall responsibility of 

coordinating and overseeing all controls activities for unapplied cash process across 

bureaus/offices/assessable units.’ As was reiterated verbally and via formal memorandum on 

March 6, 2019, the beginning to end unapplied cash process spans both the BFO and OP; as 

such, the Chief Financial Officer and the Acting Director of the Office of Programs already have 

responsibility for unapplied cash.”

OIG disagrees with BFO management’s response to recommendation 12 and that it is 

redundant to recommendation 1. Recommendation 1 relates to the need for developing an 

agency wide internal control process for maintaining, monitoring, and reporting on unapplied 

cash. Recommendation 12 relates to the need for assigning a qualified person to a key role to 

provide effective oversight over the entire unapplied cash process. Although unapplied cash is 

not considered material to the RRB’s financial statements taken as a whole, this does not 

negate the need for establishing effective control activities over unapplied cash. While 

management has identified multiple Executive Committee members that are involved in the 

unapplied cash process, the results of our audit have identified inadequate controls, processing 

and reporting concerns, and an unapplied cash migration failure, which strongly confirms the 

need for management to consider the assignment of a qualified person to a key role to provide 

stronger oversight and accountability across organizations and assessable units.

For recommendation 13, the Office of Programs stated that they non-concur that “control 

activities are necessary to ensure that the Overpayment Recovery Correspondence System 

Unapplied Cash Application is fully interfaced with the Financial Management Integrated 

System. Additionally, in the context of RRB’s re-engineering/IT modernization efforts the Office 

of Programs will assess the viability of the Unapplied Cash application and take appropriate 

action as resources permit.”

OIG disagrees with the Office of Programs management’s response to recommendation 13.

Although the Office of Programs stated that they will assess the viability of the unapplied cash 

application in connection with RRB’s re-engineering/IT modernization efforts, we are not 

certain as to whether this assessment will fully address our concerns. In regards to the Office of 

Programs statement as to whether control activities are necessary for implementing 

recommendations 13 and 14, GAO standards states that management should design control 

activities for appropriate coverage of objectives and risks in the operations. The fact that the 

results of our audit have identified inadequate controls, processing and reporting concerns, and 

an unapplied cash migration failure strongly supports the need for control activities related to 

the Overpayment Recovery Correspondence System Unapplied Cash Application and FMIS.
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For recommendation 14, BFO management stated that they non-concur “because this 

recommendation is redundant to recommendation 13. Additionally, control activities are not 

necessary to ensure that the FMIS fully interfaces with the ORCS Unapplied Cash Application. As 

the Contracting Officer Representative (COR) for FMIS the BFO will provide all support 

necessary to ensure the RRB’s automated solution for unapplied cash properly interfaces with 

FMIS.”

OIG disagrees with BFO management’s response to recommendation 14 and that it is 

redundant to recommendation 13. The two recommendations differ as each relates to a 

different system. In our draft report, we addressed a recommendation for corrective action to

BFO. Subsequent to that draft report, RRB Management asked us to redirect recommendation 

13 to the Office of Programs because the Office of Programs is the owner of the Overpayment 

Recovery Correspondence System Unapplied Cash Application. So, we redirected 

recommendation 13 to the Office of Programs. However, in doing this, we recognized the 

continued need for FMIS to properly interface with ORCS. Because BFO is the owner, or COR,

for FMIS, we addressed recommendation 14 to BFO.
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APPENDIX I: MANAGEMENT COMMENTS
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