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Compliance Assessment Methodology for Section 5311 Formula Funded Transportation
ProgramsSponsored by
Illinois Department of Transportationand the
Rural Transit Assistance Center Spring Conference
Presented by
John EdmondsonRLS & Associates, Inc.
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Role of Compliance Reviews
Governing Principals Ensure Consistent Progress Toward SAFETEA-LU Objective
Guidance From a Variety of Federal Agencies Federal Transit Administration (FTA) Office of Management and Budget (OMB) Federal Motor Carriers Safety Administration
(FMCSA)
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Compliance Assessment Methodology
Three-part Process Desk Review
• Examination of Requested Information Prior to Site Visit
Site Visit• Examination of Records, Facilities, and Vehicles
Interview• Administrative and Operational Personnel
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Areas of Review
Grantee Review/Eligibility Eligible Services Budget and Audit Grants Management and Requests Procurement Vehicles, Equipment, and Real Property Civil Rights (Title VI, EEO, DBE)
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Areas of Review
Section 504/Americans with Disabilities Act
Safety and Security Suspension and Debarment
/Integrity/Restrictions on Lobbying Charter Services School Bus Services
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Areas of Review
Drug Free Workplace/Drug and Alcohol Testing
Labor Buy America/New Bus Testing
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Grantee Review/Eligibility
Grantee Eligibility Appropriate Entity (County, Municipality, MTD.) as
Defined by IDOT Application Completed Appropriately Grant Agreement Executed
Pass-Through Eligibility Appropriate Pass-Through Arrangement Eligible Pass-Through Entity (not-for-profit,
human/social service, etc.)
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Eligible Services
General Public Transportation Services Exclusive Client Services are Permitted but
May Not Limit Availability to the General Public
Marketing Materials Brochures Riders Guides Driver Manifests
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Eligible Services
Participation in a Locally Developed Coordination Plan
JARC/New Freedom Grants Consistent with a Locally Developed Plan
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Common Compliance Issues
Inadequate Access to the General Public Seniors, Disabled, THEN General Public Routes Cater to Clients Only
Prioritized Trips Medical Trips Scheduled Ahead of Generic
Trips
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Budget and Audit
Chart of Accounts Administrative, Operating, and Capital Expenses
Quarterly Requisitions Line Item Figures
Independent Audits Documentation Addressing Audit Findings Two Page Annual Financial Report (IDOT
Requirement)
Cost Allocation Plans
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Budget and Audit
Transaction Documents to Ensure Proper Cost Classification Labor Fuel Maintenance
Continuing Control Cash Handling Procedures
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Common Compliance Issues
Lack of Adequate Cash Handling Procedures Driver Control Adequate Reconciliation Deposit Frequency
Local Match Funds Not Pursued
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Grants Management and Requisitions
Accounting Transactions to Determine Eligible Costs
Concurrency Documentation Indirect Cost Plans (if applicable) Requisition Submittals
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Common Compliance Issues
Requisitions Submitted Late IDOT Requires Submittal Within 30 Days of
Quarters End
Lack of Concurrence Annual Expenses in Excess of $10,000 to Any
Single Vendor
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Procurement
Procurement/Purchasing Policies Written Code of Conduct for Personnel
Engaged in Purchasing Decisions Recent Procurement Documents (RFP,
IFB, etc.) Recent Procurement Contracts
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Common Compliance Issues
Inadequate/Missing Procurement Policy No Policy Policy Does not Meet the Standards Outlined
in FTA Circular 4220.1F
Procurement Policy Not Followed No Process Followed “Gentlemen’s Agreements”
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Vehicles, Equipment, and Real Property
Fleet Roster Certification of Use FMCSA Registration (if applicable) Lease Agreements Preventive Maintenance Plans Insurance Coverage
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Common Compliance Issues
Vehicle Safety Fire Extinguisher
• Improperly Secured
• Missing/Expired Inspection Tag
Missing/Expired Insurance Card Missing Roadside Emergency Triangles Missing/Inadequate First Aid Kit Missing/Inadequate Biohazard Kit Wheelchair Securements Left in Channels
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Common Compliance Issues
Vehicle Maintenance Missing/Inadequate Preventive Maintenance
Plan Inadequate Pre- and Post-Trip Inspection
Form Missing Mileage on Maintenance Records
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Common Compliance Issues
Missing Lease Agreements Grantee to Lower Tier Subcontractor
(Operator)
Missing FMCSA Registration No Written Maintenance Plan for Lift
Equipment Pre-Trip Inspection is NOT Adequate
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Civil Rights
Title VI Equal Employment Opportunities
$1,000,000 in Previous Federal Fiscal Year 50 or More Mass Transit Employees
Disadvantaged Business Enterprise $250,000 in Contracting Opportunities
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Common Compliance Issues
DBE Reporting Inaccurate Missing/Inadequate DBE Plan No EEO Officer Identified
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Section 504/Americans with Disabilities Act
Complimentary Paratransit Plan (if applicable)
Trip Denial Logs Fare Structure Information Disseminated to the Public
Brochures Riders Guides
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Common Compliance Issues
Information Disseminated to the Public Not Available in Alternative Formats Inaccurate Information Key Information Missing
Service Denials Not Tracked Required for Complimentary Paratransit
Service Useful Tool in Demand Response Service
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Common Compliance Issues
Consequential Behavior Not Disseminated to Passengers No-Show Policy Disruptive Behavior Any Expectation Placed on the Passenger
Must Be Communicated to the Passenger Along With Associated Consequences
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Common Compliance Issues
Personal Care Attendants MUST Ride for Free No Certification Process
Service Animals Must Be Permitted On-Board No Certification Process
Common Mobility Devices
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Safety and Security
Safety and Security Plans HSP Template Followed Participation in Emergency Preparedness
Drills Training Documentation
Training Policy Master Log Individual Log
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Common Compliance Issues
No Written Hazard and Safety Plan Follow the HSP Template Located at:www.transit-safety.volpe.dot.gov/Security/SecurityInitiatives
Training Records Difficult to Follow Lack of Logs Incomplete Policy
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Debarment/Integrity/Restrictions on Lobbying
Certification Part of Section 5311 Application
Contracts in Excess of $100,000 Compliance Issues are Rare
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Charter Service
Annual Notices Willing and Able Solicitation Responses Cost Allocation Methodology for
Recovery Exception Certification
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Common Compliance Issues
“No, We Don’t Do Charter” Public Participation Process Not Followed No Cost Allocation Plan for Recovery
Must Recover 100%
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School Bus Service
Copies of Purchase of Service Contracts with School Systems
Driver Manifests Compliance Issues are Rare
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Drug Free WorkplaceDrug & Alcohol Testing
Part of Overall Compliance Review Performed Separately by IDOT
Staff Common Compliance Issues
Identifiable Testing Pattern (mornings, Tuesdays, etc.)
No Service Agent Oversight
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Labor
Section 5333(b) Special Warranty Signed as Part of the Section 5311
Application Common Compliance Issue
Warranty Not Posted
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Buy America
Compliance Oversight Established as Part of CVP Process
No Site Review Compliance Issues at Provider/Grantee
Level are Rare
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Implementation
Compliance Findings 1-3 Months (Immediate Solutions Available) 3-6 Months (Circumstantial Incidents) 6-9 Months (Annual Evaluations) On-going (Routine Analysis/Oversight)
Annual Element Review Compliance Follow-Up
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Implementation
Additional Suggestions Recommended but not Required Action Items Best Practices Management Analysis Tools
IDOT Staff RTAC Technical Assistance RLS Technical Assistance
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Questions???
Thank You!!!
John Edmondson
RLS & Associates, Inc.
300 W. Adams, 2nd Floor
Chicago, IL 60606
312-793-2257