Surface Transportation Board

The STB does not maintain its own financial management system but uses a shared service provider, ESC, to process all accounting transactions and the DOI processes payroll and benefits. ESC is subject to external audit in accordance with the Standards for Attestation Engagements (SSAE) 18, Attestation Standards: Clarification and Recodification. The STB examines the SSAE No. 18 audit results annually to determine if the shared service provider’s internal controls are operating effectively. The Board also evaluates the internal controls required to supplement the shared service provider’s controls as outlined in the SSAE 18. Intra-governmental transactions, accounts payables, and payments to agency employees are reviewed as part of the agency’s internal control program under OMB Circular A-123, Appendix A, Internal Control over Financial Reporting and Appendix C, Requirements for Payment Integrity Improvement. Based on OMB Circular A-123, the STB’s program was reviewed to identify those activities that were susceptible to significant improper payments. For FY 2025, the STB Federal and non- Federal payment was $17.2 million, and payroll was $28.8 million for a combined total of $46 million. The Payment Integrity Information Act defines “significant” as either (1) improper payments that exceed both $10 million and 1.5% of program disbursements; or (2) improper payments in excess of $100 million. Significant improper payments in the STB’s program needed to exceed both $0.6 million (1.5% improper payment rate) and $10 million of all non- Federal payments and payments to Federal employees. No material improper payments were identified by the STB in FY 2025 for significant improper payment reporting. In addition, the following risk factors, likely to contribute to improper payments, were applied to the STB’s appropriated funds. • Any new programs or activity in the agency. • Complexity of the activity with respect to correct payments amounts. • Volume of payments made annually. • Recent major changes in activity funding, authority, practice, or procedures. • Level, experience, and quality of training for personnel responsible for certifying that payments are accurate. • Inherent risks of improper payments due to the nature of agency operations. • Significant deficiencies in the audit reports of the agency that included Inspector General audit findings or external financial audit findings. • Results from prior improper payment work. In FY 2025, zero (-) improper payments were discovered. The STB will continue evaluating its programs based on identified risk factors to prevent improper payments from occurring, but the overall risk is low/not significant.