2. 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.

3. 2 of 39 Role of Compliance Reviews P Governing Principals Ensure Consistent Progress Toward SAFETEA-LU Objective P Guidance 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)

4. 3 of 39 Compliance Assessment Methodology P Three-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

5. 4 of 39 Areas of Review P Grantee Review/Eligibility P Eligible Services P Budget and Audit P Grants Management and Requests P Procurement P Vehicles, Equipment, and Real Property P Civil Rights (Title VI, EEO, DBE)

6. 5 of 39 Areas of Review P Section 504/Americans with Disabilities Act P Safety and Security P Suspension and Debarment /Integrity/Restrictions on Lobbying P Charter Services P School Bus Services

7. 6 of 39 Areas of Review P Drug Free Workplace/Drug and Alcohol Testing P Labor P Buy America/New Bus Testing

8. 7 of 39 Grantee Review/Eligibility P Grantee Eligibility u Appropriate Entity (County, Municipality, MTD.) as Defined by IDOT u Application Completed Appropriately u Grant Agreement Executed P Pass-Through Eligibility u Appropriate Pass-Through Arrangement u Eligible Pass-Through Entity (not-for-profit, human/social service, etc.)

9. 8 of 39 Eligible Services P General Public Transportation Services u Exclusive Client Services are Permitted but May Not Limit Availability to the General Public P Marketing Materials u Brochures u Riders Guides u Driver Manifests

10. 9 of 39 Eligible Services P Participation in a Locally Developed Coordination Plan P JARC/New Freedom Grants u Consistent with a Locally Developed Plan

11. 10 of 39 Common Compliance Issues P Inadequate Access to the General Public u Seniors, Disabled, THEN General Public u Routes Cater to Clients Only P Prioritized Trips u Medical Trips Scheduled Ahead of Generic Trips

12. 11 of 39 Budget and Audit P Chart of Accounts u Administrative, Operating, and Capital Expenses P Quarterly Requisitions u Line Item Figures P Independent Audits u Documentation Addressing Audit Findings u Two Page Annual Financial Report (IDOT Requirement) P Cost Allocation Plans

13. 12 of 39 Budget and Audit P Transaction Documents to Ensure Proper Cost Classification u Labor u Fuel u Maintenance P Continuing Control u Cash Handling Procedures

14. 13 of 39 Common Compliance Issues P Lack of Adequate Cash Handling Procedures u Driver Control u Adequate Reconciliation u Deposit Frequency P Local Match Funds Not Pursued

15. 14 of 39 Grants Management and Requisitions P Accounting Transactions to Determine Eligible Costs P Concurrency Documentation P Indirect Cost Plans (if applicable) P Requisition Submittals

16. 15 of 39 Common Compliance Issues P Requisitions Submitted Late u IDOT Requires Submittal Within 30 Days of Quarters End P Lack of Concurrence u Annual Expenses in Excess of $10,000 to Any Single Vendor

17. 16 of 39 Procurement P Procurement/Purchasing Policies P Written Code of Conduct for Personnel Engaged in Purchasing Decisions P Recent Procurement Documents (RFP, IFB, etc.) P Recent Procurement Contracts

18. 17 of 39 Common Compliance Issues P Inadequate/Missing Procurement Policy u No Policy u Policy Does not Meet the Standards Outlined in FTA Circular 4220.1F P Procurement Policy Not Followed u No Process Followed u “Gentlemen’s Agreements”

19. 18 of 39 Vehicles, Equipment, and Real Property P Fleet Roster P Certification of Use P FMCSA Registration (if applicable) P Lease Agreements P Preventive Maintenance Plans P Insurance Coverage

20. 19 of 39 Common Compliance Issues P Vehicle Safety u Fire Extinguisher Improperly Secured Missing/Expired Inspection Tag u 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

21. 20 of 39 Common Compliance Issues P Vehicle Maintenance u Missing/Inadequate Preventive Maintenance Plan u Inadequate Pre- and Post-Trip Inspection Form u Missing Mileage on Maintenance Records

22. 21 of 39 Common Compliance Issues P Missing Lease Agreements u Grantee to Lower Tier Subcontractor (Operator) P Missing FMCSA Registration P No Written Maintenance Plan for Lift Equipment u Pre-Trip Inspection is NOT Adequate

23. 22 of 39 Civil Rights P Title VI P Equal Employment Opportunities u $1,000,000 in Previous Federal Fiscal Year u 50 or More Mass Transit Employees P Disadvantaged Business Enterprise u $250,000 in Contracting Opportunities

24. 23 of 39 Common Compliance Issues P DBE Reporting Inaccurate P Missing/Inadequate DBE Plan P No EEO Officer Identified

25. 24 of 39 Section 504/Americans with Disabilities Act P Complimentary Paratransit Plan (if applicable) P Trip Denial Logs P Fare Structure P Information Disseminated to the Public u Brochures u Riders Guides

26. 25 of 39 Common Compliance Issues P Information Disseminated to the Public u Not Available in Alternative Formats u Inaccurate Information u Key Information Missing P Service Denials Not Tracked u Required for Complimentary Paratransit Service u Useful Tool in Demand Response Service

27. 26 of 39 Common Compliance Issues P Consequential 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

28. 27 of 39 Common Compliance Issues P Personal Care Attendants u MUST Ride for Free u No Certification Process P Service Animals u Must Be Permitted On-Board u No Certification Process P Common Mobility Devices

29. 28 of 39 Safety and Security P Safety and Security Plans u HSP Template Followed u Participation in Emergency Preparedness Drills P Training Documentation u Training Policy u Master Log u Individual Log

30. 29 of 39 Common Compliance Issues P No Written Hazard and Safety Plan u Follow the HSP Template Located at: www.transit-safety.volpe.dot.gov/Security/SecurityInitiatives P Training Records Difficult to Follow u Lack of Logs u Incomplete Policy

31. 30 of 39 Debarment/Integrity/Restrictions on Lobbying P Certification Part of Section 5311 Application P Contracts in Excess of $100,000 P Compliance Issues are Rare

32. 31 of 39 Charter Service P Annual Notices P Willing and Able Solicitation Responses P Cost Allocation Methodology for Recovery P Exception Certification

33. 32 of 39 Common Compliance Issues P “No, We Don’t Do Charter” P Public Participation Process Not Followed P No Cost Allocation Plan for Recovery u Must Recover 100%

34. 33 of 39 School Bus Service P Copies of Purchase of Service Contracts with School Systems P Driver Manifests P Compliance Issues are Rare

35. 34 of 39 Drug Free Workplace Drug & Alcohol Testing P Part of Overall Compliance P Review Performed Separately by IDOT Staff P Common Compliance Issues u Identifiable Testing Pattern (mornings, Tuesdays, etc.) u No Service Agent Oversight

36. 35 of 39 Labor P Section 5333(b) Special Warranty P Signed as Part of the Section 5311 Application P Common Compliance Issue u Warranty Not Posted

37. 36 of 39 Buy America P Compliance Oversight Established as Part of CVP Process P No Site Review P Compliance Issues at Provider/Grantee Level are Rare

38. 37 of 39 Implementation P Compliance 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) P Annual Element Review u Compliance Follow-Up

39. 38 of 39 Implementation P Additional Suggestions u Recommended but not Required Action Items u Best Practices u Management Analysis Tools P IDOT Staff P RTAC Technical Assistance P RLS Technical Assistance

40. 39 of 39 Questions??? Thank You!!! John Edmondson RLS & Associates, Inc. 300 W. Adams, 2 nd Floor Chicago, IL 60606 312-793-2257