An airport authority reduces compliance risk and protects continued federal funding with a tailored attestation engagement from MGO.
Background
A major regional airport authority, serving one of the nation’s busiest metropolitan areas and connecting millions of travelers annually, was undertaking a large-scale terminal construction project funded in part through Federal Aviation Administration (FAA) grants. That funding came with complex compliance obligations — certified payroll regulations, Buy America Build America (BABA) provisions, and FAA-specific grant conditions — each a common target in Office of Inspector General (OIG) audits.
Challenge
The authority needed assurance that all costs submitted for federal reimbursement were fully compliant, and that its processes could hold up to OIG scrutiny. The authority engaged MGO to help build that confidence.
Key objectives included:
- Develop a clear understanding of federal compliance requirements
- Identify potential risk areas aligned with OIG priorities
- Evaluate current processes and documentation practices to identify potential compliance gaps
- Design an agreed-upon procedures (AUP) framework to guide compliance reviews of past and future invoices
Approach
MGO began with a deep dive into federal regulations governing airport construction projects, including certified payroll requirements, BABA provisions, OIG audit criteria, and FAA grant compliance standards.
Working collaboratively with the authority’s team, MGO then went to work developing a tailored AUP framework to guide compliance reviews. This involved:
- Performing a risk assessment of relevant compliance requirements
- Conducting extensive research and reviewing all applicable grant agreements
- Engaging the authority’s contractors to understand their interpretation of federal requirements and existing processes for meeting them
The resulting AUP framework was tailored to support both historical invoice testing and ongoing compliance monitoring.
MGO also provided audit risk considerations to the authority’s project management firm, helping stakeholders get ahead of potential issues before they became problems.
Value to Client
By implementing the AUP framework, the airport authority made targeted improvements to its existing invoice review process, including:
- Requiring contractors subject to BABA provisions to submit a certification with each invoice
- Supporting contractors in enhancing their certified payroll review process, including ongoing audits and validation of historical payroll data
- Reconciling invoice amounts to supporting documentation and reviewing contract language to confirm federal requirements were clearly communicated to contractors
As a result, the authority strengthened internal controls, reduced compliance risk, and improved its ability to demonstrate adherence to federal requirements — helping protect eligibility for FAA funding throughout the life of the project.
Protect Your Federal Funding
For airport authorities and other public entities managing federally funded construction projects, proactive compliance planning can make a measurable difference. If you need support navigating grant requirements, audit readiness, or ongoing compliance monitoring, reach out to our team today.