1. U. S. General Services Administration. Federal Acquisition Service
U.S. General Services Administration. Federal Acquisition Service. Transportation Service Provider Quarterly Meeting George Thomas Transportation Audits Division, GSA August 14, 2013

2. Agenda Status Audit Initiatives Overcharge Process
Protest Program (Web-TARPS)
Overcharge Process
Notice of Overcharge
TSP Dispute
Dispute Decision
Collection of Overcharge
What Can Carriers do to Avoid Overpayments?
Common Mistakes
Top 5 Overcharges
How is GSA working with Govt. Shippers to get Paper Work Right on the Front End?

3. Summarize statutes that apply to audit process
Prepayment audits were mandated by Public Law under the “Travel and Transportation Reform Act of 1998” ( ) and require that all federal agencies conduct pre-payment audits of all transportation billings. By auditing prior to payment, agencies can avoid excess transportation charges and use the consequent savings to procure additional transportation services.
Post payment audits were mandated by “The Transportation Act of 1940 as amended 31 USC 3726” ( ). Post-payment audit occurs once a transportation service provider (TSP) bill has undergone a pre-payment audit and has subsequently been paid. Upon receipt of transportation bills, each one is examined and audited to confirm that it contains the lowest charges applicable. These audits ensure that the bills are valid and proper, while in compliance with rates, tariffs, quotations, agreements, tenders, and/or other applicable rate authorities.
Three Year Rule: 31USC § Payment for transportation, (d) Not later than 3 years (excluding time of war) after the time a bill is paid, the Government may deduct from an amount subsequently due a carrier or freight forwarder an amount paid on the bill that was greater than the rate allowed under…

4. Status of Protest Program (Web-TARPS)
GSA developed a process in which Transportation Service Providers (TSPs) can log in their own overcharge protests into the TARPS system via the internet
Apr 11, First protest was entered into TARPS by the TSP and backup documentation was received in TSP protest mailbox
Jul 31, GSA extended the opportunity to participate to all TSPs
To date, 351 TSPs are participating (19) are Freight
Anyone interested in participating contact
or, (703)
This process was created to provide the TSPs with the ability to input and keep track of their overcharge protests

5. Notice of Overcharge (NOC) Process
Notice of Overcharge (GSA Form 7925)
A Notice of Overcharge is issued when an auditor determines that a TSP has charged more than the proper rate for the services rendered. In addition to certain general information, a NOC states the:
Amount paid to the TSP by the Government d. Basis for the proper charge
Amount that should have been paid by the Government e. Applicable tariff and/or tender references
Amount of the overcharge

6. TSP Protest Process
TSPs can respond to a Notice of Overcharge in a variety of ways:
Protest the Notice of Overcharge
Refund the total amount overcharged to the Government
Refund part of the overcharge and protest part of the overcharge
Take no action regarding the Notice of Overcharge
If a TSP disagrees with a NOC, the TSP may protest within 30 days by ,
fax, hard copy print to GSA or enter into WebTARPS (pilot)
A letter of protest must contain the basis for the TSP’s objection to the
overcharge and any substantiating documentation
A letter is sent to each TSP filing a protest, to acknowledge receipt of their
protests
The Audit Contractor evaluates the protest within thirty (30) calendar days of
receipt

7. NOC Protest Process
Decision Process
The Audit Contractor evaluates the protest within thirty (30) calendar days of receipt.
Prepares a response in defense of the audit position and identified billing error or over
billing and enters the protest decision into TARPS, where GSA’s final determination will be
listed on the protest.
The three options for protest responses are:
(1) Allow: admit that the TSP is correct and cancel the Government’s overcharge claim;
(2) Deny: sustain the overcharge, and require the TSP to pay the total amount claimed to be due
to the Government.
(3) Amend: increase or decrease the total amount due to the Government.
Denial of TSP protests
Once GSA’s decision is entered into TARPs, an automatically-generated decision letter is
printed at QMCA if the protest was denied. This letter advises the TSP that the protest
was denied and that deduction action will begin. If the protest is denied, GSA will initiate
collection procedures.
Accepting the Protest and Canceling the Notice of Overcharge
If an auditor admits that a TSP is correct in its assertion that there was no overcharge for
services:
(1) The account is closed and considered to be reconciled.
(2) The updated information is logged into TARPS and removed from the receivables file.
(3) The auditor then prints the automatically generated letter, which advises the TSP that the
overcharge was dismissed.

8. Overcharge Collection Process
When a TSP fails to pay or protest an overcharge, based on his date of issuance
parameter (30, 60, 90 days) in TARPS, collection of the debt is commenced by
GSA.
The following are the general collection methods used:
All or any portion of any funds held by GSA owed to the TSP is applied to
outstanding overcharges.
One or more Government agencies are instructed to deduct the amount due
from the TSP’s unpaid bills.
If the previous collection approaches fail, the TSP is found to be delinquent,
and the Collections Section initiates the delinquency process.
GSA issues the first demand letter to the TSP requesting a refund or an
acceptable explanation be made within 30 days.

9. Common Mistakes
Freight Shipments 1.  Not using the applicable tender to rate the shipment. 2.  If more than one tender applies, not applying the tender that results in the lowest cost to the government. 3.  Incorrect mileage used to compute charges. 4.  Did not apply the bumping rule, where applicable. (Higher weight-lower rate) 5.  Accessorial charges billed and not authorized. 6.  Incorrect Fuel Surcharge applied. Air Cargo 1.  Service requested and billed but not provided by the carrier. (Overnight, 2nd day, etc)

10. Top Issues Issues Top Freight Overcharges Tender/Rate Alternation
14,043
Fuel Surcharge (Syncada)
1,871
Service Failure
1,563
Fuel Surcharge (Paper)
1,214
Services Not Authorized
984
TENDER/RATE ALTERNATION - Two tenders apply-lowest tender/rate applies
FUEL SURCHARGE - Wrong fuel surcharge percentage applied
SERVICE FAILURE - Example-Next day delivery requested and billed.-not provided
SERVICES NOT AUTHORIZED - Expedited service billed-not authorized

11. What can carriers do to avoid overpayments?
Ensure rates, dates, weights, origins and destinations are correct on invoices
Ensure data in shipper system and payment system matches
Work with shipper to ensure data is accurate
Provide documentation or data to support billings

12. How is GSA working with govt
How is GSA working with govt. shippers to get paper work right on the front end? 
Participate in meetings with Federal Agencies
Identify issues to DoD and GSA Transportation Program Managers and obtain clarification on application of rates and rules to ensure overcharges are being issued correctly
Advise Federal Agencies to ensure rates, dates, weights, origins and destinations are correct on invoices
Manage the Agency Review and Assistance Program to ensure compliance with prepayment and post payment audit requirements

13. Points of Contact Director Joyce Clark (703) 605-9420
Deputy Director
Vacant
Accounts & Collections
Branch Chief
Jeffrey Adcock
(703) 605-xxxx
Audit Policy and Review
Donna Jack
(703)
Disputes Resolution
George Thomas, Jr.
(703)
Carrier Claims Status Inquiry
Cynthia Pope
(703)
Director
Mary Bates
(703)
Deputy Director
Joyce Clark
(703)
Accounts & Collections
Branch Chief
Annie Scott
(703)
Audit Policy and Review
Donna Jack
(703)
Disputes Resolution
George Thomas, Jr.
Carrier Claims Status Inquiry

14. Questions?

15. Flowcharts of the audit process
Pre-payment Audit
Flowcharts of the audit process

16. Pre-Payment Audit (Paper Process)