Transcript State Management Review

State Management Review
Overview, process, and program updates
Scott Giering
Sherry Snyder
Overview
 Description of Program Oversight Review Programs
 State Management Review: Overview and Process
 State Management Review: Common Findings
 Program Updates
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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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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 years
o Forward looking instead of reactive
o Assess management practices and program implementation
• Specialized Reviews
o Conducted at FTA’s discretion
o Focused on specific areas of Federal compliance
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Comprehensive Reviews
Triennial 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 approach
o Enhanced review modules, when needed, to address high-risk oversight areas of:
Technical Capacity
Financial Capacity
Financial Management
Procurement
Maintenance
Americans with Disabilities Act
Disadvantaged Business Enterprise
Title VI of the Civil Rights Act
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Comprehensive Reviews
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:
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5305 – Metropolitan & State Planning
5309 – Capital Investment
5310 – Enhanced Mobility of Seniors
and Individuals with Disabilities
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5316 – Job Access & Reverse Commute
5317 – New Freedom
5339 – Bus & Bus Facilities
American Reinvestment & Recovery Act
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Specialized Reviews
Financial Management Oversight Reviews
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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
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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)
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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.
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Average Annual Program Oversight Reviews
Triennial
20
25
7%
8%
State Management
44
14%
18
6%
202
65%
Financial
Management
Procurement
Systems
Civil Rights
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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Annual Program Oversight Lifecycle
Review
Material
Update w/ FTA
Subject Matter
Experts
Information
Requests Sent
to Grantees
Grantee
Workshops
Schedule
De-Confliction
On-Site
Reviews
Report
Development &
Issuance
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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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49 CFR Part 18 (Common Rule)
• Covers all Federal grant recipients
• Offers specific latitude for States to follow their own procedures in:
– Financial management
– Equipment management
– Procurement
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Program Guidance
• State program circulars
– Are self-contained
– Take precedence over FTA C. 5010
• FTA C. 5010 applies where state program circulars are silent
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Review Areas
1.
Program Management
8.
Charter Bus
2.
Grant Administration
9.
School Bus
3.
Project Management
10. Americans With Disabilities Act
4.
Financial Management And Capacity 11. Title VI
5.
Procurement
6.
Disadvantaged Business Enterprise 13. Drug Free Workplace Act/Drug And
Alcohol Programs
Asset Management
7.
12. Equal Employment Opportunity
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State Management Review
• 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
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State Management Review Process
7 Basic Steps
PreReview
Review
Package
Site Visit
Findings
Summary
Draft
Report
Final
Report
Corrective
Actions
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
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State Management Review Process
7 Basic Steps
PreReview
Review
Package
Site Visit
Findings
Summary
Draft
Report
Final
Report
Corrective
Actions
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
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State
Review
Process
StateManagement
Management
Review
Process
7 Basic Steps
PreReview
Review
Package
Site Visit
Findings
Summary
Draft
Report
Final
Report
Corrective
Actions
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
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State
Review
Process
StateManagement
Management
Review
Process
7 Basic Steps
PreReview
Review
Package
Site Visit
Findings
Summary
Draft
Report
Final
Report
Corrective
Actions
Exit Conference:
• Preliminary list of findings and corrective actions
provided
• Realistic corrective action deadlines discussed
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State
Review
Process
StateManagement
Management
Review
Process
7 Basic Steps
PreReview
Review
Package
Site Visit
Findings
Summary
Draft
Report
Final
Report
Corrective
Actions
Draft Report
• Issued within 21 business days of exit conference
• Grantee asked to check for accuracy and comment
within 10 business days
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State
Review
Process
StateManagement
Management
Review
Process
7 Basic Steps
PreReview
Review
Package
Site Visit
Findings
Summary
Draft
Report
Final
Report
Corrective
Actions
Final Report
• Issued by FTA within 14 business days of grantee’s
response
• Includes final determination of findings, corrective
actions, and closed findings
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State
Review
Process
StateManagement
Management
Review
Process
7 Basic Steps
PreReview
Review
Package
Site Visit
Findings
Summary
Draft
Report
Final
Report
Corrective
Actions
Corrective Actions
• Submit corrective actions by due date or earlier
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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 reviews
o 4 combined SMR/TR reviews
o Grantee information requests sent out in early Fall 2015
o Site visits to begin in early Spring 2016
• 8 SMR workshops (October – December 2015)
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Atlanta, GA
Baltimore, MD (joint SMR/TR workshop)
Boston, MA
Chicago, IL
Dallas, TX
Denver, CO
Sacramento, CA
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
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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 %
378
Does not equal100% due to rounding
Total
*Drug and Alcohol Program, Equal Employment Opportunity,
Lobbying, Charter Bus, Drug-Free Workplace, Project Management
Top SMR Findings FY12-FY14
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
No verification that excluded parties are not
Procurement
participating
Grant Administration Inactive grants / untimely grant closeouts
14
Program Management Inadequate oversight system
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Procurement
9
Insufficient oversight of procurement
Grant Administration FFATA reporting deficiencies
Inadequate oversight of contracted or
Asset Management
subrecipient maintenance activities
DBE goal achievement analysis not completed
DBE
or not submitted
For Internal Discussion Purposes Only
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9
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Overview
 Description of Program Oversight review programs
 State Management Review common findings
 Program Updates
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Grantees Receiving Multiple Reviews*
60
48
50
43
# of
Grantees
40
30
25
23
20
15
8
10
0
FY10
FY11
FY12
FY13
FY14
FY15
*Excludes Drug & Alcohol Compliance Audits, which will be incorporated into the process in FY16.
Oversight Process Improvement
Enhance 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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Oversight Initiatives
Increase information sharing
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Provide clear and concise overviews of FTA’s oversight programs and programmatic
changes
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Generate and share trend reports on major issues and findings among grantees and
highlight grantee best practices
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Leverage FTA presence at regional and national conferences
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Publicize and clarify the results of reviews of the FTA
o Findings from the OIG, GAO, NTSB, and others
o Recommendations and corrective actions
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Explain the impacts for grantees of oversight program changes and audit
recommendations
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Oversight Initiatives
Enhance education, training opportunities, and assistance for
grantees
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Identify and implement new, interactive approaches to traditional grantee workshops:
o Webinars and web-based training
o Greater involvement of grantees in oversight workshops
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Promote and expand the training and technical assistance provided by the FTA to
grantees
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Continue efforts of HQ and regional staff to improve nationwide consistency in
oversight review processes
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