Presentation on theme: "WELCOME TO THE TRANSPORTATION DISADVANTAGED PLANNERS MEETING FEBRUARY 16 & 17, 2010 SARASOTA, FL FEBRUARY 18 & 19, 2010 LAKE CITY, FL."— Presentation transcript:
WELCOME TO THE TRANSPORTATION DISADVANTAGED PLANNERS MEETING FEBRUARY 16 & 17, 2010 SARASOTA, FL FEBRUARY 18 & 19, 2010 LAKE CITY, FL
Agenda FIRST DAY 9:00 am Welcome and Introductions 9:30 amWhat’s New TD Staff TD Day 2010 TD Conference 9:30 am Regionalization – What are Your Thoughts? 10:00 amThe What’s and When’s of Planning Grants 12:00 – 1:00 pmLUNCH 1:00 pmLocal Coordinating Boards Rock Operating Guidelines Membership CTC Evaluation Grievance Process 5:00 pmDay 1 Adjourn SECOND DAY 9:00 am The Fast Track on CTC Selections and Transportation Disadvantaged Service Plans 12:00 noonDay 2 Adjourn
WHAT’S NEW TD Staff – New Organization Chart TD Day – March 25, 2010 TD Conference – July 12 – 16, 2010, Renaissance Orlando at SeaWorld
Regionalization – What Are Your Thoughts? CTD Efforts – Surveys, Discussion Groups, Pilot(s) Local Activities – Current Transportation Arrangements, Transportation Summits Thoughts and Ideas are welcome
Designated Official Planning Agency (PA) Who are they? ¤MPOs in urbanized areas ¤For non-urbanized areas, could be county/city governments, Regional Planning Councils, MPOs from other areas, or local planning organizations who are currently performing planning activities in designated service areas.
Responsibilities (Ch 427, F.S.) For those areas who are required to have a Transportation Improvement Plan, ensure that the Transportation Disadvantaged are represented in all plans. For those areas who are not required to prepare TIPs, this information shall be addressed in the TDSP. ¤Realistic estimate of cost and revenue of transportation disadvantaged services within the service area (Goals/Objectives and Implementation Plan) ¤Identify transportation improvements (needs assessment) that can be realized with the funds.
Solicit and recommend a single Community Transportation Coordinator (CTC) to the Commission for the Transportation Disadvantaged (Commission) for approval. PA shall present recommendation to Commission Submit an Actual Expenditures Report to the Commission annually September 15 th. Responsibilities (Ch 427, F.S.)
Responsibilities (Ch 41-2, FAC) Appoint members to the Local Coordinating Board (LCB). Provide adequate staff support and resources to the LCB so it can fulfill its responsibilities. ¤For areas where the PA is also the CTC and uses the same staff for the LCB, the PA shall abstain from any official actions that represent a conflict of interest, specifically in the evaluation process of the CTC.
And, our favorite task - Work with the CTC and LCB to develop and annually update the Transportation Disadvantaged Service Plan (TDSP). Responsibilities (Ch 41-2, FAC)
How does the PA accomplish this? PAs are eligible to receive funding (planning grant) to assist the LCB fulfill their responsibilities and represent the Commission at the local level.
How to receive funding Planning Grant application packages are distributed to planning agencies each year. The application package outlines eligible activities, required tasks, other basic program management (audit requirements, invoicing, etc.), funding allocations, application deadlines, instructions on how to apply for funding and a sample contract.
Application Forms Required ¤Grant Acknowledgement Form ¤Form to Request Transfer of Planning Money to CTC ¤Estimated Budget ¤Standard Assurances ¤Sample Authorizing Resolution How to receive funding
Upon receipt of the completed application, the Commission will prepare a grant agreement and return to the PA for signature. IMPORTANT – contracts must be fully executed prior to July 1 and are based on the state fiscal year. How to receive funding
Planning Grant Tasks TaskReferencesDue Dates Planning Grant Application41-2.014(2)(b)Annually CTC Evaluation41-2.012 (5)(b) Annually (Evaluation for previous Fiscal Year) TD SP Updates 41-2.011(3) Annually/4th Quarter 41-2.011(9) 41-2.009(4) Progress Report & Reimbursement Invoice Planning ContractQuarterly Annual Public HearingPlanning ContractAnnually Annual Actual Budget Expenditures 41-2.007(5) September 15 41-2.0162(6) Audit ReportPlanning ContractAnnually Review AOR Data and submit to LCB for Approval Planning ContractAnnually/1st Quarter By-Laws (Approved)41-2.012(5)(a)Annually/1st Quarter
Planning Grant Tasks TaskReferencesDue Dates LCB Membership List41-2.012(5)(a) Annually/1st Quarter and when membership changes Grievance Procedures (Approved) Planning ContractAnnually/1st Quarter CTC Evaluation 41-2.012(5)(b) / Planning Contract Annually LCB Meeting Agendas/Meeting Packages Planning Contract/LCB & Planning Agency Operating Guidelines One week prior to meeting LCB Meeting Minutes (Approved) 41-2.012(5)(a) Quarterly (with quarterly report) Elect the Vice Chairperson41-2.012(2)Annually CTC Selection41-2.010Every five (5) years
Other Requirements LCB Meeting ¤Shall be advertised, at a minimum, in the Florida Administrative Weekly (FAW) two weeks prior to meeting. The date the meeting notice appeared in the FAW shall be reflected in the Quarterly Report. Public Hearing ¤Required to conduct annually. Cannot be a part of the actual LCB meeting but can be held in conjunction with the LCB meeting. The date shall be reflected in the Quarterly Report.
Must attend at least one Commission- sponsored training/workshop each year. Attendance at one Commission meeting each year is encouraged. Provide training to LCB members. Assist the LCB in the evaluation of the CTC annually. If the planning agency is also the CTC, the staff responsible for both functions should not be an evaluator. Other Requirements
Notify Commission staff of TD concerns that may require special investigation. Work with growth management planners (local and state) to incorporate TD issues. Encourage CTC to work with regional workforce boards and provide assistance in the development of innovative transportation service for participants in the welfare transition program. Other Requirements
Review and comment on the CTC’s Annual Operating Report for submittal to the LCB and forward comments/concerns to the Commission. Provide quarterly reports of TD accomplish- ments and expenditures to the LCB. Provide assistance to the CTC, purchasing agencies and others regarding TD issues such as needs, service evaluation and potential improvements. Other Requirements
When possible, collect and review proposed funding applications involving TD funds consistent with Ch 427, FS and Rule 41-2, FAC, and make recommendations to the LCB. Ensure LCB annually reviews coordination contracts. When requested, assist the Commission in joint reviews of the CTC. Other Requirements
LCB/PA Operating Guidelines Purpose of Guidelines: ¤Provide Instructions & Guidance to LCB/PA Purpose of LCB: ¤Develop local service needs ¤Provide info, advice, direction to CTC ¤LCB=Advisory Body Purpose of PA = Staff support & resources to LCB
Administration of LCB LCB Meetings – ¤Must meet at minimum quarterly or as often as necessary. ¤Under “Government in Sunshine Law” ¤Public Comments on the agenda ¤Teleconference meetings not allowed
All Meeting Notices ¤At minimum must be in Florida Administration Weekly (FAW) 2 weeks prior to meeting ¤Shall include date, time, location, subject, and a contact person Administration of LCB
Meeting Agenda & meeting packages shall be provided 1 week in advance of meeting to: ¤Commission ¤LCB Members ¤Interested Parties Special consideration should be given to certain technical/detailed documents=more than 1 week to review. Agenda must include opportunity for public participation. Administration of LCB
Emergency & Committee Meeting Notices ¤ 1 week advance notice of all, if possible ¤Date, time, location, agenda, contact information ¤Meeting materials provided ASAP ¤Emergency & Committee LCB Mtgs. must be advertised in FAW ¤Medicaid Expedited Appeals Meetings would be exempt from above requirements. Administration of LCB
Minutes ¤Shall be prepared regardless of quorum ¤Shall be prepared in a reasonable time ¤Shall include attendance roster and voting record ¤Shall include a summary of official actions ¤Shall be included in the next meeting package ¤Approved minutes shall be submitted to the Commission along with quarterly report Administration of LCB
Planning Agency shall appoint members to the LCB in accordance with the Guidelines. ¤Chair shall be a local elected official from the county that the LCB serves. Vice Chair shall be elected by the LCB members. ¤For Multiple County LCB, the Chair shall be from ONE of the counties involved. The Vice Chair shall be a local elected official from one of the other counties served. LCB Membership
Alternate Members ¤Shall be appointed in writing to the Planning Agency by the primary LCB member. ¤Must represent same interest ¤May only vote in the absence of the primary member. LCB Membership
Terms of Appointment ¤Must be in accordance with 41-2.012(4), FAC. Attendance ¤PA shall consider rescinding appointment of any LCB member who fails to attend 3 consecutive meetings. ¤Must notify the Commission LCB Membership
By-Laws ¤Shall develop, review and adopt annually. ¤Roberts Rule of Order ¤Approved and submitted to the Commission (first quarter). LCB Membership
LCB Duties Approval of MOA Annually review, make recommendations and approve the TDSP Annual evaluation of the CTC Review and provide recommendations for all applications for transportation funding Establish eligibility guidelines and trip priorities.
Seek innovative ways to improve cost effectiveness, efficiency, safety, work hours, and types of service Appoint Grievance Committee Annually review and approve the Grievance Procedures. Annually review Coordination Contracts LCB Duties
Annually hold, at a minimum, one public hearing Comply with Section 112.3143, FS, regarding conflicts of interest Work with regional workforce boards Evaluate multi-county or regional transportation opportunities LCB Duties
Rule 41-2.012 (5) (b) Coordinating Board Structure and Duties LCB provides the MPO or PA with an evaluation of the CTC’s performance LCB sets an annual percentage goal increase for the number of trips provided within the system for ridership on public transit, where applicable PA submits evaluation to the Commission upon approval by the LCB
CTC Evaluation Workbook The Commission shall provide evaluation criteria for the LCB to use relative to the performance of the CTC. The evaluation criteria are as follows: ¤CTC Evaluation Workbook ¤CTC Review Report and Attachment ¤Annual QA Self Certification ¤Format for the Status Report
May use entire Workbook Required items – Cover page – include Review Period/FY (p. 1) – Entrance Interview Questions (p. 5) – Contractor Monitoring (p. 12) – School Bus and transit utilization (p. 13) – Insurance (p. 19) – Cost effectiveness (p. 23) – Commission and Local Standards (p. 25) CTC Evaluation Workbook
CTC Review Report with Attachment PA shall provide CTC with draft report within ten working days, with the draft report provided within seven working days. Upon receipt of final report (after LCB approval), CTC will provide status report within fifteen working days to PA. Standardizes all reports
Annual QA Self Certification Due to the Commission by January 15 th ¤Must be signed and dated by CTC Attach to Review Covered items ¤Drug and Alcohol ¤Operator Monitoring ¤Safety Review ¤Driver Training
Format for the Status Report Upon receipt of final report, CTC will provide status report within thirty working days to PA. Standardizes all reports
Notes to Remember The CTC should not conduct the evaluation or surveys. If the CTC is also the PA, the PA should contract with an outside source to assist the LCB during the review process. Attach a copy of the Annual QA Self Certification. PA should submit complete Evaluation after LCB approval.
Grievance Procedures Background In past, Medicaid and TD Grievance Procedures basically mirrored each other. New Medicaid contract requires additional steps in Grievance Process. Medicaid Grievance Procedures are Federal Mandated & cannot be modified by State or Local Agencies.
Grievance Procedures Background Medicaid defines the process for addressing Complaints, Appeals, Grievances, and Fair Hearings as “Medicaid Grievance System.” The PAs & LCBs are the extension of the Commission in each locale, tasked with implementing the TD program at the local level.
Medicaid Grievance System Complaint process – How concerns regarding quality of service are addressed locally. (i.e. late pick-ups, driver concerns, vehicle condition) Grievance process – How quality of service complaints that are unresolved to the satisfaction of the customer are addressed locally. Action – Some form of reduction, limit, or denial of transportation services by CTC/STP. Appeal process – The local procedure for addressing customer’s concerns regarding “actions” that have been taken. Medicaid Fair Hearing process – The administrative process which allows a Medicaid Beneficiary to request the State to reconsider an adverse decision made by the CTC/STP.
Grievance Process Resolve each Grievance within ninety (90) Calendar Days PA/LCB shall notify the customer, in writing, within thirty (30) Calendar Days of the resolution of the Grievance. Notice of resolution shall include the results and date of the resolution. In addition it must include: ¤Notice of the right and information on how to request a Medicaid Fair Hearing; ¤Provide the Commission with a copy of the written notice of resolution upon request;
Grievance Process No punitive action will be taken against a beneficiary, physician or other Health Care Provider. CTC/STP must provide the Commission with a report detailing the total number of Grievances received. The PA/LCB may extend the Grievance resolution time frame by up to fourteen (14) Calendar Days. If the LCB/CTC/STP requests the extension, you must give the beneficiary written notice of the reason for the delay.
Grievance Process Filing Requirement ¤The beneficiary or provider must file a Grievance, verbally or in writing, within one (1) year after the date of occurrence that initiated the Grievance.
Appeal Process Confirm in writing all inquiries seeking an Appeal, unless the beneficiary or provider requests an expedited resolution. If the resolution is in favor of the beneficiary, provide the services as quickly as the customer’s health condition requires. A reasonable opportunity must be provided to present evidence in person or in writing. Allow the beneficiary an opportunity to examine the beneficiary’s case file. The beneficiary (or rep) shall be considered parties to the Appeal.
Appeal Process Continue the beneficiary’s Transportation Services if: ¤The beneficiary files the Appeal in a timely manner, meaning on or before the later of the following: ¤Within ten (10) Business Days of the date on the notice of Action (add five  Business Days if the notice is sent via Surface Mail); or ¤The intended effective date of the CTC/STP proposed Action ¤The Appeal involves the termination, suspension, or reduction of a previously authorized Transportation service; ¤The Transportation was for a Medicaid compensable service ordered; ¤The authorization period has not expired; and/or ¤The Medicaid Beneficiary requests extension of Transportation Services.
Appeal Process Provide written notice of the resolution of the Appeal, including the results and date of the resolution within two (2) Business Days after the resolution. For decisions not wholly in the customer’s favor, the notice of resolution shall include: ¤Notice of the right to request a Medicaid Fair Hearing; ¤Information about how to request a Medicaid Fair Hearing, including the DCF address necessary for pursuing a Medicaid Fair Hearing; ¤Notice of the right to continue to receive Transportation Services pending a Medicaid Fair Hearing; ¤Information about how to request the continuation of Transportation Services; and ¤Notice that if the CTC/STP Action is upheld in a Medicaid Fair Hearing, the customer may be liable for the cost of any continued Transportation Services.
Appeal Process Provide the Commission with a copy of the written notice of disposition upon request. No punitive action will be taken against a beneficiary, physician or other Health Care Provider. Provide the Commission with a report detailing the total number of Appeals received. If the CTC/STP continues or reinstates the beneficiary’s Transportation Services while the Appeal is pending, the CTC/STP must continue providing the Transportation Services until one (1) of the following occurs: ¤The beneficiary withdraws the Appeal; ¤Ten (10) Business Days pass from the date of the STP’s notice of resolution of the Appeal if the resolution is adverse to the customer and if the customer has not requested a Medicaid Fair Hearing with continuation of Transportation Services until a Medicaid Fair Hearing decision is reached;
Appeal Process ¤The Medicaid Fair Hearing panel’s decision is adverse to the beneficiary; or ¤The authorization to provide services expires, or the beneficiary meets the authorized service limits. If the final resolution of the Appeal is adverse to the beneficiary, the CTC/STP may recover the costs of the services furnished from the beneficiary while the Appeal was pending, to the extent that the CTC/STP furnished the services solely because of the requirements of this Section. If the CTC/STP did not furnish services while the Appeal was pending and the Appeal panel reverses the CTC/STP decision to deny, limit or delay services, the CTC/STP must authorize or provide the disputed services promptly and as quickly as the beneficiary’s health condition requires. If the CTC/STP furnished services while the Appeal was pending and the Appeal panel reverses the CTC/STP decision to deny, limit or delay services, the CTC/STP must pay for disputed services in accordance with State policy and regulations.
Appeal Process Filing Requirements ¤The beneficiary must file an Appeal within thirty (30) Calendar Days of receipt of the notice of the CTC/STP’s Action. ¤The beneficiary may file an Appeal either verbally or in writing. If the filing is verbal, the beneficiary must also file a written, signed Appeal within thirty (30) Calendar Days of the verbal filing. The CTC/STP shall notify the requesting party that it must file the written request within ten (10) Business Days after receipt of the verbal request. For verbal filings, time frames for resolution of the Appeal begin on the date the CTC/STP receives the verbal filing. ¤The PA/LCB shall resolve each Appeal not to exceed forty-five (45) Calendar Days from the day the PA/LCB received the initial Appeal request. ¤If the resolution is in favor of the beneficiary, the CTC/STP shall provide the services as quickly as the beneficiary’s health condition requires.
Appeal Process ¤The PA/LCB may extend the resolution time frames by up to fourteen (14) Calendar Days if the beneficiary requests an extension, or the PA/LCB documents that there is a need for additional information and that the delay is in the beneficiary’s best interest. ¤If the PA/LCB requests the extension, the PA/LCB must give the beneficiary written notice of the reason for the delay. ¤The PA/LCB must provide written notice of the extension to the beneficiary within five (5) Business Days of determining the need for an extension.
Expedited Appeal Process The PA/LCB shall establish and maintain an expedited review process for Appeals when the CTC/STP determines, the beneficiary requests or the provider indicates (in making the request on the beneficiary’s behalf or supporting the beneficiary’s request) that taking the time for a standard resolution could seriously jeopardize the beneficiary’s life, health or ability to attain, maintain or regain maximum function. The beneficiary may file an expedited Appeal either verbally or in writing. CTC/STP must inform the beneficiary of the limited time available for the beneficiary to present evidence and allegations of fact or law, in person and in writing;
Expedited Appeal Process Expedited Appeal must be resolved within seventy- two (72) hours after the CTC/STP receives the Appeal request; Provide written notice of the resolution to the beneficiary; Make reasonable efforts to provide verbal notice of disposition/ resolution to the beneficiary immediately after the Appeal panel renders a decision; and No punitive action will be taken against a beneficiary, physician or other Health Care Provider.
Expedited Appeal Process If the CTC/STP denies a request for an expedited resolution of an Appeal, the CTC/STP must: ¤Transfer the Appeal to the standard time frame of no longer than forty-five (45) Calendar Days from the day the CTC/STP received the request for Appeal (with a possible fourteen  day extension); ¤Make reasonable efforts to provide immediate verbal notification of the CTC/STP denial for expedited resolution of the Appeal; ¤Provide written notice of the denial of the expedited Appeal within two (2) Calendar Days; and ¤Fulfill all requirements set forth in the Appeal Process.
Expedited Appeal Committee Recommendations for Members One LCB Member Planning Agency Staff Representative CTC/STP Staff that was not involved in initial action.
Things to Consider Committee Members cannot have been involved in the decision to take “action.” Committee Members need to have all background information. Committee Members must be able to meet and make a decision within 72 hours. Two LCB Members cannot be on Exp. Appeal Committee due to Sunshine Law restrictions on meeting notice timeframes.
Things to Consider We are ALWAYS available to assist you!
The Fast Track on CTC Selection and Transportation Disadvantaged Service Plans
Selection of the Community Transportation Coordinator
Community Transportation Coordinator means a transportation entity recommended by a metropolitan planning organization, or by the appropriate designated official planning agency as provided for in ss. 427.011-427.017 in an area outside the purview of a metropolitan planning organization, to ensure that coordinated transportation services are provided to the transportation disadvantaged population in a designated area.
Preparation for Selection The following are not subject to the competitive-solicitation requirements, according to 287.057(5)(f) ¤Governmental ¤Single Source ¤Emergency Draft RFP Advertisement
Transportation Disadvantaged Service Plan Instructions
General Information Initial TDSP submitted within 120 days after MOA is signed. ¤TDSP is jointly developed by PA and CTC to be reviewed and approved by the LCB. TDSP is a 5 year document that is required to be updated on an ANNUAL basis.
What is the PA responsible for? Ensuring that the TDSP is completed, approved and signed by the LCB. Completing the Development and QA components. What is the CTC responsible for? Completing the Service Element of the TDSP.
Guidelines for TDSP submission to the CTD Provide a cover page identifying the service area, the time period of the service plan, and the parties submitting the plan; Table of contents that follows the format provided in the manual. All pages must be numbered; A roll call voting sheet identifying all LCB members, their affiliation, and whether they voted for or against the submittal of the TDSP, and indicate those members that were absent from the meeting; All signatures must be originals. Do not use rubber stamps; Submit 2 signed copies to the CTD. A copy of the approved TDSP will be furnished to the CTC and PA after it has been executed by the Commission.
Component Requirements Development Plan A.Introduction to the service area. 1.Background to the TD Program 2.CTC designation date/history 3.Organization chart 4.Consistency review of other plans
5.Public participation a.Transportation partners b.Passengers and advocates c.Human service partners d.Others It is important that stakeholders be included in the development, implementation and updates of the local coordinated transportation disadvantaged service plan. This should include the annual public hearing as required of the LCB. Component Requirements Development Plan
B.Service area profile/demographics. 1.Service area description 2.Demographics a.Land use b.Population/composition c.Employment d.Major trip generators/attractors e.Inventory of Available Transportation Services Component Requirements Development Plan
C.Service Analysis 1.Forecasts of TD population 2.Needs assessment 3.Barriers to coordination D.Goals, Objectives and Strategies E.Implementation Schedule Component Requirements Development Plan
Component Requirements Service Plan A.Operations 1.Types, hours and days of service 2.Accessing services 3.Transportation operators and coordination contractors 4.Public transit utilization (where applicable) 5.School bus utilization 6.Vehicle inventory 7.System safety program plan certification 8.Intercounty services 9.Emergency preparedness and response 10.Educational efforts/marketing 11.Acceptable alternatives
12.Service Standards a.Drug and alcohol policy- CTD b.Escorts and children- Local c.Child restraints- Local d.Rider property- Local e.Vehicle transfer points- CTD f.Local toll free number for consumer comment- CTD g.Out of service area trips- Local h.Vehicle cleanliness - CTD i.Billing requirements to contracted operators- CTD j.Rider/trip data- CTD k.Adequate seating- CTD l.Driver identification- CTD/Local Component Requirements Service Plan
m.Passenger assistance- CTD n.Smoking and eating on vehicles- CTD/Local o.No-show policies- Local p.Communication equipment- CTD q.Vehicle air conditioning and heating equipment- CTD r.First aid policy-Local s.Cardiopulmonary resuscitation- Local t.Pick-up windows- Local u.On-time performance- Local v.Advance reservation requirements- Local w.Public transit ridership (if applicable)- Local x.Complaints- Local y.Accidents- Local z.Roadcalls- Local aa.Call hold time- Local Component Requirements Service Plan
13.Local complaint and grievance procedure process 14.CTC monitoring procedures of operators and coordination contractors 15.Coordination contract evaluation criteria B.Cost/revenue allocation and rate structure justification. Component Requirements Service Plan
Component Requirement Quality Assurance A.Provide information on the evaluation process utilized at the local level. B.Address what steps the LCB will take to monitor and evaluate the services provided. C.Coordinators can only be evaluated against the established standards for service. The criteria used should include: 1.Service effectiveness 2.Cost efficiency and effectiveness 3.Vehicle utilization 4.Service availability 5.Reliability; and 6.Safety and training
Updates or Amendments A.The LCB must approve any changes to the plan. The following sections of the plan MUST be reviewed and updated ANNUALLY: 1.Development Plan a.Needs assessment b.Goals, Objectives and Strategies i.Objectives must include an implementation date/accomplishment date ii.Note deficiencies and corrective actions iii.Note service improvements or expansions c.Implementation Plan i.Identify progress, setbacks, adhere to schedules ii.Revise implementation schedule as necessary.
B.Cost/Revenue Allocation and Rate Structure Justification 1.Review current and updated projected expenses, revenues and levels of service and make adjustments accordingly. A new Service Rates Summary page as well as Rate Model Worksheets must be submitted. Other areas that may require updating may include: 1.Development Plan A.Organization chart B.LCB certification C.Changes to major trip generators/attractors Updates or Amendments
2.Service Plan A.Changes in types or hours of service B.Significant changes in system policies C.New service innovations or cancellations of services D.Changes in operators or coordination contractors E.Changes in vehicle inventory F.SSPP certification G.Include new acceptable alternatives H.Changes in narrative for adoption of new service standards I.Changes to the Grievance and Evaluation process 3.Quality Assurance A.Any evaluation process changes and update to the summary of the latest coordinator evaluation. Updates or Amendments
A.Any changes to the Plan after July 1 of each year will be considered an amendment. B.Rate amendments which result in an increase that is greater than 3% must go before the Commission for review and approval. The only exceptions to this is an increase in rates for fixed schedule/fixed route systems, i.e. bus passes or tokens. Updates or Amendments