The North Carolina Department of Transportation, Integrated Mobility Division in accordance with federal and state requirements conducts Compliance Reviews of all subrecipients of grant funding provided by the Federal Government and/or the State of North Carolina that the Integrated Mobility Division has oversight of (to include 5307, 5310, 5311, CARES, ARP, CRRSAA, 5304, 5305, 5316, 5317, ROAP and any other similar funding).
These reviews include but are not limited to assessing the following sections for policy compliance with State and Federal (FTA) requirements:
· Financial Management,
· Technical Capacity,
· The Americans with Disabilities Act (ADA),
· Title VI,
· Disadvantaged Business Enterprise (DBE),
· Satisfactory Continuing Control,
· Planning and Coordination,
· Public Comment Process on Fare Increases and Service Reductions,
· Half Fare,
· Charter Bus,
· School Bus,
· Safety and Security,
· Drug Free Workplace/Drug and Alcohol Testing Program,
· Equal Employment Opportunity (EEO),
· Other Service Requirements.
The North Carolina Department of Transportation emphasizes safety throughout the entire organization, across all modal units. It is important residents feel safe when riding public transit vehicles. The Integrated Mobility Division is responsible for ensuring the federal and state financial assistance received is being used to provide a safe public transportation network for all North Carolinians. To ensure that the subrecipients operating and/or providing transportations services to North Carolina are safe and in compliance the NCDOT-IMD has developed the following review process. This process is reviewed annually by IMD and one or more of its contracted consultant firms to ensure that the review process is up-to-date and accurate. All data collected in the review process will be housed and maintained in the Compliance Review Smartsheet Workspace.
All subrecipients are subject to receiving a comprehensive Compliance Review every three (3) years or sooner based on risk factors as determined and defined by IMD. In Calendar Year 2022, Compliance Reviews replaced both the legacy Proficiency Reviews and Safety and Security Reviews. This allowed for more efficient oversight and reduced administrative burdens on transit agencies by removing redundancies and requiring less time to complete.
Agencies subject to review will be notified during the 1st quarter of the calendar year. Notifications will come in the form of an official letter being sent to the Director and the Accountable Executive of the Transit Agency. NCDOT-IMD will assign the agency to a Consultant Review Team that has been contracted by IMD. Consultant Review Teams will be rotated so that transit agencies will be reviewed by different Consultant Review Teams over time.
The Consultant Review Team will contact the agency, agree upon a review date(s) and send written notification of the review. The notification will include instructions on how to log into their Smartsheet application, instructions on completing the Compliance Workbook and information on which documents must be submitted by the agency prior to the review.
All documents including the Workbook must be completed by a due date determined by the Consultant Review Team and agreed upon by the transit agency (agencies are typically given 6 weeks to complete before the Compliance Review Visit is conducted).
Once all documents have been received the Consultant Review Team will examine all the documentation submitted as well as the completed Workbook. The Consultant Review Team may reach back out to the agencies if additional information is needed prior to the review date.
On the date of the review the consultant team will meet with representation from the agency. This could be either in-person or virtual depending on the current policies of IMD. Once the review is completed the consultant will review all data collected and determine if compliance deficiencies were identified. The consultants will complete a deficiency report and submit to IMD for review and concurrence. The Consultant Review Team will also upload to Smartsheet their signed Workbook, complete with their notes. The IMD Compliance team will review the deficiency report submitted by the Consultant Review Team, make corrections/changes as needed and then sign via DocuSign.
IMD will issue a Compliance Review Report Letter and a Deficiency Report to the Transit Agency. The subrecipient will have ninety (90) days from the date of the letter to address and correct the deficiencies identified during the review. During that time the IMD Compliance unit will be available to provide technical assistances and in some cases resources to assist the transit agency. Extensions can be granted for an additional 30 days if requested in writing and approved in writing by IMD before the 90 days has expired.
Once all deficiencies have been corrected IMD will issue a Compliance Review Closure Letter officially stating that at the time of the letter the agency is in compliance.
These reviews are intended to ensure that subrecipients are implementing a compliant Drug and Alcohol Program. There will be a review of testing methods, recordkeeping and policy enforcement. This review will be conducted on a three (3) year cycle.
The Compliance Specialist will obtain quarterly vehicle and lift preventive maintenance reports from the Trapeze EAM to determine whether a grantee is achieving the standard of 80% or above compliance with preventive maintenance requirements.
An annual facility maintenance checklist must be completed if any Federal funding was used to construct the facility. The Procurement Specialist will review the Facility Inspections Checklist and will determine if further inspection is warranted.
Subrecipients are required to maintain the financial capacity to administer a project throughout its duration. Financial reviews may be conducted by IMD without notice. Potential triggers for review include but are not limited to: delinquent reimbursement requests, inadequate documentation of expenditures, excessive revisions, unsatisfactory progress, delinquent reports, audit findings, and/or the repeated failure to procure funded capital items.
The Integrated Mobility Division (IMD) provides technical assistance to guide grantees through the acquisition process for new facilities and upgrades of existing facilities to ensure compliance with Federal and state regulations.