Define the population
Establish the complete paid transportation-invoice population before testing begins so charges cannot disappear from scope.
GSA Order 5450.39D ADM CHGE 183
The audit authority moved.
The obligation did not.
Effective July 2, 2025, GSA Order 5450.39D ADM CHGE 183 delegated Section 3726 transportation-audit authority to the federal agency where each transportation invoice was paid.
The order explained
What GSA Order 5450.39D ADM CHGE 183 does.
Issued July 2, 2025, the active GSA delegation implements 31 U.S.C. § 3726(g) by assigning Section 3726 authority to all federal agencies. For a transportation invoice, the authority rests with the agency where that invoice was paid.
The delegated powers include auditing transportation bills, making deductions from those bills, and adjudicating related claims. The order also directs agencies to read references to the “GSA Transportation Audits Division” in 41 CFR Part 102-118 as references to the responsible agency.
GSA retains its underlying authority, but the order states that GSA currently has no plans to exercise those powers and anticipates that agencies will perform the delegated functions.
The practical result: each agency needs a complete and defensible post-payment transportation-audit function—operated internally or supported by a qualified contractor.
01 / Agency impact
What changed—and what did not
The operating responsibility changed hands.
The statutory and regulatory framework did not disappear. Federal transportation payments remain subject to 31 U.S.C. § 3726 and 41 CFR Part 102-118. What changed is who must exercise the audit and claims authorities previously associated with GSA’s Transportation Audits Division.
Verify the authority
Test every charge against the controlling contract, tender, tariff, quotation, regulation, and customer-specific pricing.
Support deductions
Document overcharges and improper payments with evidence sufficient to support deductions, claims, and recovery.
Adjudicate and track
Maintain a clear record of carrier responses, claim decisions, recoveries, corrective action, and unresolved exposure.
Eagle Auditing
A ready federal transportation-audit function.
Eagle brings 12 years of continuous federal freight-audit performance and more than 50 years of combined transportation and audit experience. Reviews cover 100% of the paid invoice population—not a sample—and include every transportation mode.
Eagle independently verifies carrier-side evidence, quantifies findings to the penny, prepares and tracks claims, and produces documentation built for contracting, finance, Inspector General, and oversight review.
Federal agencies can access Eagle through GSA Multiple Award Schedule contract 47QRAA19D007S, SIN 541211 Auditing Services.
Contracting officers & program managers
Build the audit function before the overcharges build themselves.
Eagle can help define the population, evidence requirements, workflow, reporting, and recovery process for your transportation program.
Amy Sherman · Point of Contact
amy.sherman@eagleauditingllc.com
(816) 351-0317
8am–5pm CT, Monday–Saturday
Stanberry, Missouri