Each Federal agency is responsible for ensuring that transportation bills are audited and paid according to statutory and regulatory requirements. This page answers some foundational questions about U.S. Government transportation invoice audit and payment and provides related documentation and resources.

What is a prepayment audit?
According to 41 CFR Part 102-118, a prepayment audit is an audit of transportation billing documents before payment to determine their validity, propriety, and conformity of rates with tariffs, quotations, agreements, contracts, or tenders (31 U.S.C. 3726).
Auditech audits to ensure that requirements found in 41 CFR Part 102-118, tariff/rules application, documentation requirements and agency-specific requests are met. Some of these requirements are listed below:
- All documentation requirements outlined in tariffs and rules are met (e.g. weight tickets, accessorial services certifications, storage receipts, delivery receipts etc.).
- If an SF 1113 is required, verification that voucher preparation requirements are met (e.g. SCAC, TIN and signature inclusion on document).
- No payments have already been made for the services provided and billed (duplicate check).
- Checking invoice charges against rates agreed-upon between the TSP and the agency.
- Invoice charges represent the lowest charges available to the government via lawfully filed tariffs, tenders, and rates.
- Proper rules applications have been followed.
- Correct weights are used (e.g. gross weight or volume weight for UAB shipments v. net weight for household goods shipments.).
- Invoice compliance with Tariff/Rules requirements related to Cargo Preference.
- Invoice compliance with transit time and delivery guarantee requirements.
Why is a prepayment audit important?
The most prominent reason is that it is the law. 31 U.S.C. 3726 mandates that each agency that receives a bill from a carrier or freight forwarder for transporting an individual or property for the United States Government shall verify its correctness (to include transportation rates, freight classifications, or proper combinations thereof), using prepayment audit, prior to payment…
41 CFR § 102-118.135 further outlines its importance by stating that Pre-payment audits focus on preventing overpayments by identifying invoice errors before payment. They help prevent overspending, ensure payments align with contracts, reduce administrative burdens, and strengthen carrier relationships by promoting transparency and accuracy.
Which bills need to undergo a prepayment audit?
Any transportation bill including, but not limited to:
- LTL Freight (Motor)
- Truckload Freight (Motor)
- Bulk Freight (Motor)
- Foreign Household Goods (PCS)
- Domestic Household Goods (PCS)
- Air Cargo
- Ocean Cargo
- Rail Cargo
- Piepline
- Parcel (FedEx, UPS, DHL, etc.)
- Passenger Travel
What is a Statement of Difference?
According to 41 CFR Part 102-118, a statement of difference is a statement issued by an agency or its designated audit contractor during a prepayment audit when it has been determined that a TSP has billed the agency for more than the proper amount for the services. This statement tells the TSP the amount allowed and the basis for the proper charges. The statement also cites the applicable rate references and other data relied on for support. The agency issues a separate statement of difference for each transportation transaction…
Auditech issues statements of difference in standard format for the purposes of informing a TSP of an apparent error, defect or impropriety in an invoice received by the Government. These statements will include the above required information.
What if a TSP disagrees with a statement of difference?
If there is further documentation, evidence, approval, etc. that substantiates the TSP’s billing position, this information can be provided along with resubmitted billing packet(s) or electronic billing documentation and it will be reviewed by our auditors to ensure that it satisfies the stringent requirements set forth in the laws, regulations, and rules set forth by the Government.
41 CFR § 102-118.165 and § 102-118.170 outline the appeals and disputes procedures to be followed if there are further disagreements.
Can other services be provided as part of a prepayment audit?
Yes! Services such as reporting, data capture/entry, TSP correspondence/training, administrative reviews of documents, online data access, and other services are often requested by individual agencies and provided as part of a prepayment audit service.
Who should perform the prepayment audit for an agency?
The rates and rules that apply to and govern the movement of motor, air, rail, and ocean freight, household goods (foreign and domestic), and air passenger travel are complex and numerous. Having qualified professionals perform a prepayment audit that are seasoned and experienced in government rate and rules application is vital to ensure that the proper charges are paid and overcharges are recovered. Auditech & Associates, Inc. is one of a select few companies to hold such experience. We have dedicated 20+ years to the study, application, and performance of audits for the United States Government.
What is a post-payment audit?
According to 41 CFR Part 102-118, a post-payment audit is an audit of transportation billing documents, and all related transportation documents after payment, to decide their validity, propriety, and conformity of rates with tariffs, quotations, agreements, contracts, or tenders. The audit process may also include subsequent adjustments and collection actions taken against a TSP by the Government (31 U.S.C. 3726).
Auditech’s post-payment audit service seeks to identify U.S Government transportation bills that are improper and/or overcharged through an in-depth audit of payment files and rules/rate information and assist in the collection of overcharged funds through documentation of identified overcharges.
Why is a post-payment audit important?
According to 41 CFR § 102-118.135, post-payment audits…serve as a second line of defense after payments are made. They recover overcharges, uncover systemic issues and trends, and provide valuable data for negotiating better carrier contracts and optimizing freight processes through continuous improvement.
What type of bills need to undergo a post-payment audit?
Any transportation bill including, but not limited to:
- LTL Freight (Motor)
- Truckload Freight (Motor)
- Bulk Freight (Motor)
- Foreign Household Goods (PCS)
- Domestic Household Goods (PCS)
- Air Cargo
- Ocean Cargo
- Rail Cargo
- Pipeline
- Parcel (FedEx, UPS, DHL, etc.)
- Passenger Travel
Does GSA Perform post-payment audits of transportation bills?
GSA issued Directive 5450.39D ADM CHGE 183 on July 2, 2025 delegating the authority to audit transportation bills, make deductions from those bills, and adjudicate related claims from GSA to all Federal agencies. GSA no longer performs post-payment audits of transportation bills for agencies. The responsibility to ensure that improper billings and overcharges are identified and recovered resides with each individual agency.
If I have a prepayment audit do I need a post-payment audit?
Yes! Estimates put the rate of improper or overcharged spend at 3-5% of an organization’s transportation spend, even after a prepayment audit is performed.
41 CFR § 102-118.135 further outlines that jointly, these audits form a complementary strategy: pre-payment audits minimize upfront errors and spending, while post-payment audits recover missed costs and drive long-term optimization. Combining both approaches enhances overall freight cost control and operational efficiency.
Can your agency afford to forego recovering overcharged billings of 3-5% or more of your total spend?
Who should perform the post-payment audit for an agency?
The rates and rules that apply to and govern the movement of motor, air, rail, and ocean freight, household goods (foreign and domestic), and air passenger travel are complex and numerous. Having qualified professionals perform a post-payment audit that are seasoned and experienced in government rate and rules application is vital to ensure that the proper charges are paid and overcharges are recovered. Auditech & Associates, Inc. is one of a select few companies to hold such experience. We have dedicated 20+ years to the study, application, and performance of audits for the United States Government.

Auditech & Associates, Inc. provides the U.S. Government with prepayment and post-payment audits under General Services Administration Multiple Award Schedule Contract GS-23F-0087W. Our company has provided these services to Federal agencies for 20+ years.


