The same audit contains two different concentrations

A new federal purchase-card audit’s largest dollar categories point in opposite directions. Nearly all the value of sampled invoices paid late was outside the Federal Aviation Administration, while nearly all the value of sampled purchases that failed competition requirements was inside the FAA, an analysis of the inspector general’s transaction table shows.

What’s the Scoop With Broach recalculated the September 28 Transportation Department report’s findings by type and agency group. Other DOT operating administrations accounted for $337,386 of $347,115 in late-invoice transactions, or 97.2%. FAA accounted for $267,295 of $280,775 in transactions that did not meet competition requirements, or 95.2%.

These are concentrations in the inspected transactions, not estimates of which agency has the higher overall error rate. The inspector general explicitly says the sample was drawn for DOT as a combined population, including FAA, and does not support separate statistical projections for the two programs. The comparison instead identifies where the documented dollar problems lie and why one undifferentiated spending total can obscure the corrective work needed.

Our calculations from DOT OIG’s sampled transaction table, printed page 9. Categories can overlap.
FindingFAA dollarsOther DOT dollarsConcentration
Late invoices$9,729$337,38697.2% outside FAA
Competition requirements unmet$267,295$13,48095.2% within FAA

Invoice value is different from money lost

The late-payment category consisted of seven transactions. Four FAA transactions totaled $9,729; three elsewhere in DOT totaled $337,386. Thus, the group with fewer identified late transactions carried far more of their dollar value. Counting violations alone would miss that distinction.

The report says those invoices were paid after their due dates without the required interest penalties. It describes an FAA transcription-services invoice paid more than three months after submission and a Great Lakes St. Lawrence Seaway Development Corporation invoice paid nearly three weeks late. The $347,115 is the value of the underlying purchases. It is not a calculation of interest owed, theft or financial loss.

Competition failures require a different remedy. Nine FAA transactions and one other DOT transaction made up that category. Auditors described simulator rentals and a multi-monitor purchase for which officials neither sought competing offers nor obtained the required sole-source justification. Those failures reduce assurance of a fair price, but the table does not measure how much cheaper a compliant purchase would have been.

The requirements must also be read in their historical context. The transactions came from fiscal 2023 and 2024. The report applies the procurement rules relevant to that period and notes that DOT’s micro-purchase threshold increased from $10,000 to $15,000 in October 2025. Treating the older threshold as today’s rule would misstate the finding.

The $123 million disagreement turns on that distinction

Across its 107 sampled transactions, the inspector general found 45 with at least one control failure, totaling $778,977. Its statistical projection placed approximately $123 million in the category of funds that could be put to better use. The agency disputed that interpretation in its formal response, saying the goods and services were operational necessities and that any potential missed savings should instead be based on the ten competition-related transactions.

The inspector general maintained its broader estimate. Its position is that weaknesses involving authorizations, procurement and post-purchase controls expose public money to improper use and that the estimate should reflect that combined exposure. The dispute concerns the financial meaning assigned to control failures; it does not mean DOT rejected the recommended corrective work.

Late invoices were the largest single dollar category in the published table. Their $347,115 equals 44.6% of the unique noncompliant sample’s dollar value. But readers should not add that category to every other row: some transactions violated multiple controls, and the inspector general specifically warns that both counts and dollar amounts overlap.

DOT agreed with the first ten recommendations and accepted the corrective actions underlying the eleventh while disputing its projected savings. Its September response sets March 31, 2027, as the planned completion date and describes a unified purchase-card policy. The report classifies all eleven recommendations as resolved but open pending completion, a distinction between an accepted plan and demonstrated implementation.

The practical follow-up differs by finding. Late-payment controls need a way to identify overdue invoices and calculate required interest. Competition controls need documented bids or an approved exception before purchase. Training certificates and account-closure procedures address other risks. This records analysis isolates the sampled dollar concentrations without projecting them onto either agency’s full spending or presenting the $123 million as proven waste. No interviews were conducted; the agency’s position comes from its published response.

Sources and further reading

DOT OIG FI2026038 full report — printed p9/PDF p12 table; printed pp12–14 procurement/payment details; p18 agency response; pp19–20 method; pp24–25 signed response ↗

DOT OIG report landing page — September28,2026 release and eleven recommendations ↗

Photograph reuse license — CC BY-SA 3.0 ↗