For FTA funds identified at elevated risk for misuse, implement written procedures to strengthen the Agency's ability to assess expense eligibility prior to recipients receiving payments. Implementing this recommendation could put up to $446.9 million in Region 9 funds to better use by improving FTA's ability to identify unsupported costs and ineligible expenses before issuing CARES Act payments. This could also result in hundreds of millions in Agency funds put to better use among the other nine FTA regions.