Compliance Assessment Methodology for Section 5311 Formula Funded

Compliance Assessment Methodology for Section 5311 Formula Funded Transportation Programs Sponsored by Illinois Department of Transportation and the Rural Transit Assistance Center Spring Conference Presented by John Edmondson RLS & Associates, Inc.

Role of Compliance Reviews PGoverning Principals Ensure Consistent Progress Toward SAFETEA-LU Objective PGuidance From a Variety of Federal Agencies u Federal Transit Administration (FTA) u Office of Management and Budget (OMB) u Federal Motor Carriers Safety Administration (FMCSA) 2 of 39

Compliance Assessment Methodology PThree-part Process u Desk Review • Examination of Requested Information Prior to Site Visit u Site Visit • Examination of Records, Facilities, and Vehicles u Interview • Administrative and Operational Personnel 3 of 39

Areas of Review PGrantee Review/Eligibility PEligible Services PBudget and Audit PGrants Management and Requests PProcurement PVehicles, Equipment, and Real Property PCivil Rights (Title VI, EEO, DBE) 4 of 39

Areas of Review PSection 504/Americans with Disabilities Act PSafety and Security PSuspension and Debarment /Integrity/Restrictions on Lobbying PCharter Services PSchool Bus Services 5 of 39

Areas of Review PDrug Free Workplace/Drug and Alcohol Testing PLabor PBuy America/New Bus Testing 6 of 39

Grantee Review/Eligibility PGrantee Eligibility Appropriate Entity (County, Municipality, MTD. ) as Defined by IDOT u Application Completed Appropriately u Grant Agreement Executed u PPass-Through Eligibility Appropriate Pass-Through Arrangement u Eligible Pass-Through Entity (not-for-profit, human/social service, etc. ) u 7 of 39

Eligible Services PGeneral Public Transportation Services u Exclusive Client Services are Permitted but May Not Limit Availability to the General Public PMarketing Materials u Brochures u Riders Guides u Driver Manifests 8 of 39

Eligible Services PParticipation in a Locally Developed Coordination Plan PJARC/New Freedom Grants u Consistent with a Locally Developed Plan 9 of 39

Common Compliance Issues PInadequate Access to the General Public u Seniors, Disabled, THEN General Public u Routes Cater to Clients Only PPrioritized Trips u Medical Trips Scheduled Ahead of Generic Trips 10 of 39

Budget and Audit PChart of Accounts u Administrative, Operating, and Capital Expenses PQuarterly Requisitions u Line Item Figures PIndependent Audits Documentation Addressing Audit Findings u Two Page Annual Financial Report (IDOT Requirement) u PCost Allocation Plans 11 of 39

Budget and Audit PTransaction Documents to Ensure Proper Cost Classification u Labor u Fuel u Maintenance PContinuing Control u Cash Handling Procedures 12 of 39

Common Compliance Issues PLack of Adequate Cash Handling Procedures u Driver Control u Adequate Reconciliation u Deposit Frequency PLocal Match Funds Not Pursued 13 of 39

Grants Management and Requisitions PAccounting Transactions to Determine Eligible Costs PConcurrency Documentation PIndirect Cost Plans (if applicable) PRequisition Submittals 14 of 39

Common Compliance Issues PRequisitions Submitted Late u IDOT Requires Submittal Within 30 Days of Quarters End PLack of Concurrence u Annual Expenses in Excess of $10, 000 to Any Single Vendor 15 of 39

Procurement PProcurement/Purchasing Policies PWritten Code of Conduct for Personnel Engaged in Purchasing Decisions PRecent Procurement Documents (RFP, IFB, etc. ) PRecent Procurement Contracts 16 of 39

Common Compliance Issues PInadequate/Missing Procurement Policy u No Policy u Policy Does not Meet the Standards Outlined in FTA Circular 4220. 1 F PProcurement Policy Not Followed u No Process Followed u “Gentlemen’s Agreements” 17 of 39

Vehicles, Equipment, and Real Property PFleet Roster PCertification of Use PFMCSA Registration (if applicable) PLease Agreements PPreventive Maintenance Plans PInsurance Coverage 18 of 39

Common Compliance Issues PVehicle Safety u Fire Extinguisher • Improperly Secured • Missing/Expired Inspection Tag Missing/Expired Insurance Card u Missing Roadside Emergency Triangles u Missing/Inadequate First Aid Kit u Missing/Inadequate Biohazard Kit u Wheelchair Securements Left in Channels u 19 of 39

Common Compliance Issues PVehicle Maintenance u Missing/Inadequate Preventive Maintenance Plan u Inadequate Pre- and Post-Trip Inspection Form u Missing Mileage on Maintenance Records 20 of 39

Common Compliance Issues PMissing Lease Agreements u Grantee to Lower Tier Subcontractor (Operator) PMissing FMCSA Registration PNo Written Maintenance Plan for Lift Equipment u Pre-Trip Inspection is NOT Adequate 21 of 39

Civil Rights PTitle VI PEqual Employment Opportunities u $1, 000 in Previous Federal Fiscal Year u 50 or More Mass Transit Employees PDisadvantaged Business Enterprise u $250, 000 in Contracting Opportunities 22 of 39

Common Compliance Issues PDBE Reporting Inaccurate PMissing/Inadequate DBE Plan PNo EEO Officer Identified 23 of 39

Section 504/Americans with Disabilities Act PComplimentary Paratransit Plan (if applicable) PTrip Denial Logs PFare Structure PInformation Disseminated to the Public u Brochures u Riders Guides 24 of 39

Common Compliance Issues PInformation Disseminated to the Public u Not Available in Alternative Formats u Inaccurate Information u Key Information Missing PService Denials Not Tracked u Required for Complimentary Paratransit Service u Useful Tool in Demand Response Service 25 of 39

Common Compliance Issues PConsequential Behavior Not Disseminated to Passengers u No-Show Policy u Disruptive Behavior u Any Expectation Placed on the Passenger Must Be Communicated to the Passenger Along With Associated Consequences 26 of 39

Common Compliance Issues PPersonal Care Attendants u MUST Ride for Free u No Certification Process PService Animals u Must Be Permitted On-Board u No Certification Process PCommon Mobility Devices 27 of 39

Safety and Security Plans u HSP Template Followed u Participation in Emergency Preparedness Drills PTraining Documentation u Training Policy u Master Log u Individual Log 28 of 39

Common Compliance Issues PNo Written Hazard and Safety Plan u Follow the HSP Template Located at: www. transit-safety. volpe. dot. gov/Security. Initiatives PTraining Records Difficult to Follow u Lack of Logs u Incomplete Policy 29 of 39

Debarment/Integrity/Restrictions on Lobbying PCertification Part of Section 5311 Application PContracts in Excess of $100, 000 PCompliance Issues are Rare 30 of 39

Charter Service PAnnual Notices PWilling and Able Solicitation Responses PCost Allocation Methodology for Recovery PException Certification 31 of 39

Common Compliance Issues P“No, We Don’t Do Charter” PPublic Participation Process Not Followed PNo Cost Allocation Plan for Recovery u Must Recover 100% 32 of 39

School Bus Service PCopies of Purchase of Service Contracts with School Systems PDriver Manifests PCompliance Issues are Rare 33 of 39

Drug Free Workplace Drug & Alcohol Testing PPart of Overall Compliance PReview Performed Separately by IDOT Staff PCommon Compliance Issues u Identifiable Testing Pattern (mornings, Tuesdays, etc. ) u No Service Agent Oversight 34 of 39

Labor PSection 5333(b) Special Warranty PSigned as Part of the Section 5311 Application PCommon Compliance Issue u Warranty Not Posted 35 of 39

Buy America PCompliance Oversight Established as Part of CVP Process PNo Site Review PCompliance Issues at Provider/Grantee Level are Rare 36 of 39

Implementation PCompliance Findings u 1 -3 Months (Immediate Solutions Available) u 3 -6 Months (Circumstantial Incidents) u 6 -9 Months (Annual Evaluations) u On-going (Routine Analysis/Oversight) PAnnual Element Review u Compliance Follow-Up 37 of 39

Implementation PAdditional Suggestions u Recommended but not Required Action Items u Best Practices u Management Analysis Tools PIDOT Staff PRTAC Technical Assistance PRLS Technical Assistance 38 of 39

Questions? ? ? Thank You!!! John Edmondson RLS & Associates, Inc. 300 W. Adams, 2 nd Floor Chicago, IL 60606 312 -793 -2257 39 of 39