state management review overview, process, and program updates scott giering sherry snyder
TRANSCRIPT
State Management Review
Overview, process, and program updates
Scott Giering
Sherry Snyder
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Overview
Description of Program Oversight Review Programs
State Management Review: Overview and Process
State Management Review: Common Findings
Program Updates
3
Overview
Description of Program Oversight review programs
State Management Review: Overview and Process
State Management Review: Common Findings
Program Updates
4
What is Program Oversight?
• Program Oversight reviews, confirms, and promotes compliance with Federal grant requirements.
• Fiduciary responsibility to prevent and identify improper payments and to ensure every dollar counts toward improving public transit.
• Comprehensive Reviews (Triennial & State Management)o Conducted every three yearso Forward looking instead of reactiveo Assess management practices and program implementation
• Specialized Reviewso Conducted at FTA’s discretiono Focused on specific areas of Federal compliance
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Comprehensive ReviewsTriennial Review
• Mandated by Congress in 1982.• Assesses how recipients of Urbanized Area Formula Program
funds meet Federal requirements in a baseline review of 17 areas.
• New process:o A more proactive, risk-based approacho Enhanced review modules, when needed, to address high-risk
oversight areas of:Technical CapacityFinancial CapacityFinancial ManagementProcurement
MaintenanceAmericans with Disabilities ActDisadvantaged Business EnterpriseTitle VI of the Civil Rights Act
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State Management Review
• Assesses compliance with 49 USC chapter 53
• Assesses management practices and program implementation, ensuring that programs are administered in accordance with Federal Transit Law provisions and are meeting program objectives. Focuses primarily on recipients of 5311, Non-urbanized Area Formula Program, and incorporates questions regarding:• 5305 – Metropolitan & State
Planning• 5309 – Capital Investment• 5310 – Enhanced Mobility of
Seniors and Individuals with Disabilities
• 5316 – Job Access & Reverse Commute
• 5317 – New Freedom• 5339 – Bus & Bus Facilities• American Reinvestment &
Recovery Act
Comprehensive Reviews
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Specialized ReviewsFinancial Management Oversight Reviews• Assesses compliance with the Common Rule, 49 CFR Part 18.20 and
19.20.• External, independent assessment for FTA, in accordance with
established public accounting standards, on the effectiveness of the grantee's internal control environment for the management of Federal funds.
Procurement System Review• Assesses compliance with the Common Rule, 49 CFR Parts 18 & 19.• Assesses procurement policy and processes to determine if FTA
grantees are meeting Federal procurement requirements.
Civil Rights Compliance Reviews (Four Review Programs)• ADA - Assesses compliance with the Americans with Disabilities Act
of 1990.• Disadvantaged Business Enterprise - Assesses compliance with
49 CFR Part 26.• Equal Employment Opportunity - Assesses compliance with 49 USC
5332(b).• Title VI of the Civil Rights Act - Assesses compliance with 49 CFR Part
21.
20265%
186%
4414%
258%
207% Triennial
State Man-agementFinancial ManagementProcurement SystemsCivil Rights
Average Annual Program Oversight Reviews
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Chart labels indicate average # reviews/FY and average % of all reviews/FY
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Annual Program Oversight Lifecycle
• FTA established a comprehensive annual lifecycle approach to synergize program oversight activities.
• Establishes a consistent schedule on which grantees, FTA, and oversight contractors can rely.
• Interconnectivity of oversight activities promotes the use of consistent standard operating procedures across reviews.
• Allows FTA to better coordinate all program oversight reviews to avoid overlap, conflicts, and overburdening grantees.
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Review Material
Update w/ FTA Subject Matter
Experts
Information Requests Sent
to Grantees
Grantee Workshops
Schedule De-Confliction
On-Site Reviews
Report Development &
Issuance
Annual Program Oversight Lifecycle
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Overview
Description of Program Oversight review programs
State Management Review: Overview and Process
State Management Review: Common Findings
Program Updates
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Super Circular
• Took effect December 26, 2014
• Supersedes A-21, A-87, A-89, A-102, A-110, A-122, and A-133
• US DOT implementing regulation to replace 49 CFR Parts 18 and 19, 2 CFR Part 1200
• Will require updated FTA circulars implementing regulation(s)
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• Covers all Federal grant recipients
• Offers specific latitude for States to follow their own procedures in:– Financial management– Equipment management– Procurement
49 CFR Part 18 (Common Rule)
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• State program circulars– Are self-contained– Take precedence over FTA C. 5010
• FTA C. 5010 applies where state program circulars are silent
Program Guidance
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1. Program Management
2. Grant Administration
3. Project Management
4. Financial Management And Capacity
5. Procurement
6. Disadvantaged Business Enterprise
7. Asset Management
8. Charter Bus
9. School Bus
10. Americans With Disabilities Act
11. Title VI
12. Equal Employment Opportunity
13. Drug Free Workplace Act/Drug And Alcohol Programs
Review Areas
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• State’s compliance directly– Emphasis on content and implementation of State
Management Plans– Management/administration/oversight of subrecipients’
direct operation or contract for service
• Subrecipients’ compliance indirectly
State Management Review
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State Management Review Process
7 Basic Steps
Pre-Review (FTA and Contractor):
• Review grantee historical information
• Overview current status
• Answer questions in Grantee
Information Request package
• Contact grantee regarding site visit
dates
• Prepare and send information request
to grantee
Pre- Review
ReviewPackage
Site Visit Findings Summar
y
Draft Report
Final Report
Corrective Actions
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7 Basic Steps
Infromation request must be returned to the reviewer within 40 business days:
• Grantee profile
• Questions in 13 areas
• List of requested documents
• Preliminary site visit schedule
State Management Review Process
Pre- Review
ReviewPackage
Site Visit Findings Summar
y
Draft Report
Final Report
Corrective Actions
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State Management Review Process
7 Basic Steps
Site Visit (4-5 days depending on size and complexity)• Prior to site visit, annotated information request sent
to grantee along with additional questions or requests for information
• Entrance conference
• 13 areas reviewed• Subrecipient site visits - Facilities toured, bus(es)
inspected and equipment records sampled, informally discuss compliance with FTA requirements, review procurement file, maintenance records, back-up documentation for invoice to State, Title VI notice, and drug and alcohol policy
• Exit conference
State Management Review Process
Pre- Review
ReviewPackage
Site Visit Findings Summar
y
Draft Report
Final Report
Corrective Actions
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State Management Review Process
7 Basic Steps
Exit Conference:• Preliminary list of findings and corrective
actions provided
• Realistic corrective action deadlines discussed
State Management Review Process
Pre- Review
ReviewPackage
Site Visit Findings Summar
y
Draft Report
Final Report
Corrective Actions
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State Management Review Process
7 Basic Steps
Draft Report• Issued within 21 business days of exit
conference
• Grantee asked to check for accuracy and comment within 10 business days
State Management Review Process
Pre- Review
ReviewPackage
Site Visit Findings Summar
y
Draft Report
Final Report
Corrective Actions
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State Management Review Process
7 Basic Steps
Final Report• Issued by FTA within 14 business days of
grantee’s response
• Includes final determination of findings, corrective actions, and closed findings
State Management Review Process
Pre- Review
ReviewPackage
Site Visit Findings Summar
y
Draft Report
Final Report
Corrective Actions
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State Management Review Process
7 Basic Steps
Corrective Actions
• Submit corrective actions by due date or
earlier
State Management Review Process
Pre- Review
ReviewPackage
Site Visit Findings Summar
y
Draft Report
Final Report
Corrective Actions
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Getting Ready for Your Review
• Send requested documents
• Ensure staff availability
• Ensure staff and/or documentation from other offices are available
• Work with FTA/contractor to select subrecipients
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After Your Review
• Implement corrective actions
• Submit documentation to FTA regional office
• Use the regional office as a technical resource
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FY16 SMR Highlights
• 17 planned reviewso 4 combined SMR/TR reviewso Grantee information requests sent out in early Fall 2015o Site visits to begin in early Spring 2016
• 8 SMR workshops (October – December 2015)o Atlanta, GAo Baltimore, MD (joint SMR/TR workshop)o Boston, MAo Chicago, ILo Dallas, TXo Denver, COo Sacramento, CAo Seattle, WA
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Resources
• State Management Review Workbook
• FTA website
• National RTAP
• MTAP/AASHTO
• CTAA/APTA
• TRB/NCHRP
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Overview
Description of Program Oversight review programs
State Management Review: Overview and Process
State Management Review: Common Findings
Program Updates
Most Frequent Areas with Findings (FY12-14 SMRs)
Review Area # of Findings
% of All Findings
Program Management 66 17 %
Procurement 53 14 %
Grant Administration 51 13 %
Disadvantaged Business Enterprise
51 13 %
Title VI 33 9 %
Asset Management 33 9 %
Americans with Disabilities Act
30 8 %
Financial Management 23 6 %
All Others (6 Areas)* 38 10 %
Total 378 Does not equal100% due to rounding
*Drug and Alcohol Program, Equal Employment Opportunity,Lobbying, Charter Bus, Drug-Free Workplace, Project Management
Top SMR Findings FY12-FY14
For Internal Discussion Purposes Only
Review Area Program Management # of Findings
Program Management
State Management Plan out of date/incomplete
23
Grant Administration
Incorrect Federal Financial Reporting 16
Title VI Insufficient oversight of Title VI 14
ProcurementNo verification that excluded parties are not participating
13
Grant Administration
Inactive grants / untimely grant closeouts
12
Program Management
Inadequate oversight system 11
Procurement Insufficient oversight of procurement 9Grant Administration
FFATA reporting deficiencies 9
Asset Management
Inadequate oversight of contracted or subrecipient maintenance activities
9
DBEDBE goal achievement analysis not completed or not submitted
8
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Overview
Description of Program Oversight review programs
State Management Review common findings
Program Updates
Grantees Receiving Multiple Reviews*
FY10 FY11 FY12 FY13 FY14 FY150
10
20
30
40
50
60
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4348
25
15
8
# of Grantees
*Excludes Drug & Alcohol Compliance Audits, which will be incorporated into the process in FY16.
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Oversight Process ImprovementEnhance the consistency, effectiveness, and
efficiency of grantee program oversight.
• Forward-looking instead of reactive
• Ask the “right” questions
• Enhanced Review Modules in the Triennial Review improve our ability to rapidly address areas of concern to help grantees get out ahead of problems
• Focus closely on findings in high risk areas and reduce repeat findings in these areas through targeted technical assistance
• Decrease the need for multiple reviews of a grantee within a fiscal year
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Increase information sharing
• Provide clear and concise overviews of FTA’s oversight programs and programmatic changes
• Generate and share trend reports on major issues and findings among grantees and highlight grantee best practices
• Leverage FTA presence at regional and national conferences
• Publicize and clarify the results of reviews of the FTAo Findings from the OIG, GAO, NTSB, and otherso Recommendations and corrective actions
• Explain the impacts for grantees of oversight program changes and audit recommendations
Oversight Initiatives
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Enhance education, training opportunities, and assistance for grantees
• Identify and implement new, interactive approaches to traditional grantee workshops:o Webinars and web-based trainingo Greater involvement of grantees in oversight workshops
• Promote and expand the training and technical assistance provided by the FTA to grantees
• Continue efforts of HQ and regional staff to improve nationwide consistency in oversight review processes
Oversight Initiatives
