Federal Transit Administration: Progress Made in Implementing
Changes to the Job Access Program, but Evaluation and Oversight
Processes Need Improvement (17-NOV-06, GAO-07-43).
Begun in 1998, the Job Access and Reverse Commute (JARC) program
provides grants to states and localities for improving the
mobility of low-income persons seeking work. The Federal Transit
Administration (FTA) administers this program. In 2005, the Safe,
Accountable, Flexible, Efficient Transportation Equity Act--A
Legacy for Users (SAFETEA-LU) authorized $727 million for JARC
for fiscal years 2005 through 2009, changed how these funds were
to be awarded after fiscal year 2005, and required FTA to
evaluate the program by August 2008. GAO examined (1)
SAFETEA-LU's changes to JARC, (2) FTA's progress in implementing
these changes, (3) states' and localities' efforts to respond and
challenges they have encountered, and (4) FTA's proposed strategy
for evaluation and oversight. GAO's work included analyzing
program guidance as well as interviewing officials from FTA,
industry groups, and more than 30 state and local agencies.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-07-43
ACCNO: A63506
TITLE: Federal Transit Administration: Progress Made in
Implementing Changes to the Job Access Program, but Evaluation
and Oversight Processes Need Improvement
DATE: 11/17/2006
SUBJECT: Disadvantaged persons
Employment assistance programs
Federal aid for transportation
Federal aid to localities
Grants to states
Locally administered programs
Program evaluation
Program management
Public assistance programs
Reporting requirements
State-administered programs
Strategic planning
Transportation
Program goals or objectives
Program implementation
DOT Job Access and Reverse Commute
Program
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GAO-07-43
* [1]Report to Congressional Committees
* [2]November 2006
* [3]FEDERAL TRANSIT ADMINISTRATION
* [4]Progress Made in Implementing Changes to the Job Access
Program, but Evaluation and Oversight Processes Need Improvement
* [5]Contents
* [6]Results in Brief
* [7]Background
* [8]SAFETEA-LU Created a Formula for Distributing JARC Funds and
Amended Other Aspects of the Program
* [9]JARC Became a Formula Program
* [10]SAFETEA-LU Introduced Three Key Requirements for
Receiving JARC Funding and Made Other Changes
* [11]FTA Has Developed Proposed Final Guidance for JARC, but
Delays in Issuing the Final Guidance May Reduce the Time
Available to Obligate JARC Funding
* [12]FTA Has Engaged in Extensive Public Outreach to
Formulate JARC Guidance
* [13]FTA's Formulation of Guidance Has Been Delayed Due to
Extensive Public Comments on JARC Changes
* [14]Delays in Issuing Final Guidance May Reduce the Time
Available to Obligate Fiscal Year 2006 JARC Funding
* [15]States and Large Urbanized Areas Have Begun to Implement JARC
Requirements, and FTA Has Taken Steps to Alleviate Implementation
Challenges
* [16]Few States and Large Urbanized Areas Have Received
Fiscal Year 2006 JARC Funds, Although Most We Interviewed
Are in the Process of Fulfilling Funding Requirements
* [17]States and Large Urbanized Areas Have Encountered
Several Implementation Challenges, Most of Which FTA Has
Responded to in Its Proposed Final Guidance
* [18]Designated Recipient in Large Urbanized Areas
* [19]Development of Coordinated Public Transit-Human
Services Transportation Plans
* [20]Competitive Selection of JARC Projects
* [21]Other Implementation Challenges
* [22]FTA Changed Its Evaluation and Oversight Strategies but Still
Needs to Address Monitoring Issues
* [23]Past Concerns about the JARC Program Have Included
Performance Measurement, Reporting, and Evaluation
* [24]FTA Clarified Its Proposed JARC Performance Measures and
Introduced a Different Reporting Mechanism in Response to
Concerns Expressed by Program Stakeholders
* [25]Gaps in Monitoring May Limit FTA's Ability to Evaluate
and Oversee the JARC Program
* [26]Conclusions
* [27]Recommendations for Executive Action
* [28]Agency Comments and Our Evaluation
* [29]Objectives, Scope, and Methodology
* [30]Job Access and Reverse Commute Program Funding
* [31]Summary of Stakeholder Comments on FTA's Interim Guidance and
Proposed Strategies for Job Access and Reverse Commute Program
* [32]GAO Contact and Staff Acknowledgments
* [33]Related GAO Products
Report to Congressional Committees
November 2006
FEDERAL TRANSIT ADMINISTRATION
Progress Made in Implementing Changes to the Job Access Program, but
Evaluation and Oversight Processes Need Improvement
Contents
Tables
Figures
November 17, 2006
Letter
The Honorable Richard C. Shelby Chairman The Honorable Paul S. Sarbanes
Ranking Minority Member Committee on Banking, Housing, and Urban Affairs
United States Senate
The Honorable Don Young Chairman The Honorable James L. Oberstar Ranking
Democratic Member Committee on Transportation and Infrastructure House of
Representatives
Access to adequate transportation is an important factor in the ability of
low-income individuals--including those who receive government help to
become self-sufficient--to find and retain employment. However, existing
public transportation systems--originally established to allow city
residents to travel within the city and bring suburban residents to
central-city work locations--cannot always bridge the gap between where
these individuals live and where many jobs for which they would qualify
are located. Our previous work has noted that a majority of the
entry-level jobs that low-income individuals would be likely to fill are
located in suburbs that have limited or no accessibility through existing
public transportation systems.^1 Furthermore, many entry-level jobs
require shift work in the evenings or on weekends, when public transit
services are either unavailable or limited.
To increase collaboration among transit agencies, local human service
agencies, nonprofit organizations, and others, and thereby improve the
mobility of low-income individuals seeking work, the Job Access and
Reverse Commute (JARC)^2 program was first authorized under the
Transportation Equity Act for the 21^st Century (TEA-21) in 1998.
Administered by the Federal Transit Administration (FTA), this program
provides grants for such purposes as expanding public transit routes,
lengthening service hours, or providing other transportation options.
However, our previous reviews of the JARC program found a number of
challenges that arose in the program, such as difficulties in awarding
grants competitively and inconsistencies with statutory requirements of
other FTA grant programs, making implementation difficult. FTA also
experienced difficulties in evaluating the program, as TEA-21 required.^3
In 2005, the Safe, Accountable, Flexible, Efficient Transportation Equity
Act - A Legacy for Users (SAFETEA-LU) authorized $727 million for the JARC
program from fiscal years 2005 through 2009. SAFETEA-LU also made a number
of changes that, beginning with fiscal year 2006 funding, will affect FTA,
states, and urbanized areas as they administer the program. For example,
FTA will now provide grant monies through a formula to states--for
distribution to small urbanized and rural areas--and to large urbanized
areas.^4 In addition, SAFETEA-LU requires the Department of Transportation
(DOT) to evaluate the effectiveness of the JARC program and report the
results to Congress by August 2008.
SAFETEA-LU also requires us to study the JARC program, beginning 1 year
after the legislation takes effect and every 2 years thereafter. This
report, our first in compliance with this mandate, analyzes what has
happened to date in implementing program changes and installing a
framework for FTA's evaluation of program results in 2008. Our specific
reporting objectives were as follows:
oidentify changes made to the JARC program as a result of SAFETEA-LU;
oassess the progress FTA has made in implementing these changes;
odescribe the extent to which states and urbanized areas have implemented
changes to the JARC program, and challenges they have encountered; and
odetermine the extent to which FTA's proposed strategy for evaluation and
oversight of the JARC program will allow the agency to assess whether the
program is meeting its stated goals.
Our work was based in part on our analysis of program documentation,
relevant legislation, Office of Management and Budget circulars, previous
GAO reports and guidance on the JARC program and on program evaluation and
performance measurement, and over 200 comments posted to the DOT's online
docket in response to FTA's March 2006 interim guidance and proposed
strategies for the JARC program.^5 We determined that the data that FTA
provided were sufficiently reliable for the purposes of this report. We
also interviewed officials from FTA and industry associations as well as
representatives from 12 state departments of transportation, 8
metropolitan planning organizations, and 9 local transportation agencies
in 12 large urbanized areas; a transportation agency in 1 small urbanized
area; and 1 nonprofit organization that works with rural transit
providers.^6 These agencies were selected on the basis of several factors,
including changes in JARC funding from fiscal years 2005 to 2006, whether
the areas had formally designated a recipient for JARC funds, and whether
the agency was recommended to us by FTA or an industry association. The
agencies were selected to provide a distribution of the various factors;
however, we did not select them in such a way that we may project the
results as representative of the entire country. Appendix I contains a
detailed discussion of our objectives, scope, and methodology, including
more information on how we selected the state and local agencies we
contacted. We conducted our work between May and October 2006 in
accordance with generally accepted government auditing standards.
Results in Brief
SAFETEA-LU made a number of changes to the JARC program, the most
significant of which was to modify JARC from a discretionary program to a
formula-based program. Whereas in recent years, JARC projects were
competitively selected by FTA or congressionally designated for funding,
SAFETEA-LU's formula distributes funds to states and large urbanized areas
on the basis of the relative number of low-income individuals and welfare
recipients in each area. This change will significantly alter the
allocation of JARC funds, because some states and large urbanized areas
that did not formerly receive funds will now receive them, and others will
receive a different amount than they received in the past. For example,
total funds available in Florida and Virginia increased by more than 1,200
percent from fiscal years 2005 to 2006 (from $594,708 to $8.3 million and
from $84,249 to $2.5 million, respectively), while total funds available
in Alaska and Vermont decreased by more than 80 percent (from $1.7 million
to $207,503 and from $991,182 to $186,885, respectively). In addition, 18
states were apportioned JARC funds for fiscal year 2006 that did not
receive funds in fiscal year 2005. Another change is that states and large
urbanized areas have to fulfill the following three key requirements
before receiving JARC funding: (1) identify a designated recipient for
JARC funds, (2) conduct a competitive process to select projects for
funding, and (3) certify that JARC projects were selected from a
coordinated public transit-human services transportation plan. Other key
changes resulting from SAFETEA-LU include allowing JARC recipients to use
a portion of these funds for planning activities and increasing the
federal government's share of project capital costs.
As required by SAFETEA-LU, FTA has used an extensive public comment
process that has helped the agency develop and refine the guidance for
implementing changes to the JARC program, but that also has lengthened the
time needed to issue the guidance, which will likely reduce the time
states and large urbanized areas have to obligate fiscal year 2006 funds
under FTA's guidance. Beginning in late-2005, FTA solicited comments and
input from JARC stakeholders through program notices and listening
sessions. Using feedback from these initial efforts, in March 2006 FTA
released interim guidance for fiscal year 2006 JARC projects and proposed
strategies for fiscal year 2007. The agency received more than 200
comments on the March interim guidance and proposed strategies from state
and local departments of transportation, metropolitan planning
organizations, and other JARC stakeholders. FTA officials have
incorporated this feedback into the formulation of proposed final guidance
for JARC, which was issued on September 6, 2006.^7 However, due to the
60-day public comment period following issuance of the September proposed
final guidance, FTA was unable to finalize its JARC program guidance
before fiscal year 2007 began in October. FTA's March interim guidance and
proposed strategies also included a "hold harmless" provision stating that
the final guidance requirements would not apply retroactively to grants
awarded prior to the issuance of the final guidance. FTA has recognized in
its guidance that JARC funds are available for 2 years after the year of
apportionment, meaning that fiscal year 2006 funds are available through
fiscal year 2008 (Sept. 30, 2008). The time available is further reduced,
however, by the time needed to fulfill SAFETEA-LU requirements, such as
the requirement to develop coordinated plans. However, given that a number
of states and large urbanized areas we interviewed planned to wait for
final program guidance before moving forward to program implementation,
these areas will have less time available to obligate fiscal year 2006
funds.
States and large urbanized areas have initiated actions to fulfill
requirements to receive JARC funding, and although they have encountered
challenges in moving forward, FTA has taken steps to alleviate most of
these challenges in its September proposed final guidance. Nationwide, few
states and large urbanized areas have formally fulfilled the three
SAFETEA-LU requirements to receive JARC funding, as less than 4 percent of
fiscal year 2006 funding had been obligated by states and localities by
the end of fiscal year 2006. Actions to fulfill these requirements were
under way, however, in most of the 12 states and 12 large urbanized areas
we contacted. For example, all 12 of the states and 9 of the large
urbanized areas we contacted had determined which agency would serve as
the designated recipient for JARC funding, although not all of these
states and urbanized areas had formally notified FTA of this
determination. Officials we interviewed as well as other program
stakeholders had encountered a number of challenges in program
implementation, including questions regarding the selection of the
designated recipient in large urbanized areas and a lack of resources for
development of coordinated public transit-human services transportation
plans. FTA's proposed final guidance responds to most of these issues. For
example, FTA clarified information on the process for selecting designated
recipients in large urbanized areas and on whether designated recipients
could allow other organizations to conduct the competitive selection
process to avoid potential conflict-of-interest concerns if the designated
recipient competes for funding. In addition, FTA will allow a phased-in
approach for development of coordinated public transit-human services
transportation plans, in response to program stakeholders' concerns about
the time needed to develop these plans.
FTA is continuing to develop and refine its strategies for evaluation and
oversight of the JARC program in response to comments received on its
March interim guidance and proposed strategies, but a revised approach may
still be limited in its ability to assess whether the program is meeting
its goals. In response to previous concerns about FTA's measurement of
JARC program outcomes, FTA sought public comment on four new proposed
performance measures, including one measure specifically for JARC
(cumulative number of jobs accessed) and three crosscutting measures
(efficiency of operations, program effectiveness, and customer
satisfaction) that reflect SAFETEA-LU's emphasis on the coordination of
human services transportation. In addition, FTA proposed to use the
National Transit Database (NTD)^8 for tracking JARC performance data.
However, program stakeholders that we contacted reported that FTA's
proposed cumulative number of jobs accessed measure called for data that
would be difficult to collect, and noted that the crosscutting measures
may not be useful to assess JARC performance nationwide due to differences
in program operation at the local level. On the basis of these comments,
FTA eliminated the proposed broader coordination measures and clarified
that the jobs accessed measure will assess whether JARC programs are
increasing transportation system coverage for low-income people to access
jobs. FTA also proposed to add a measure on ridership, which will count
the number of rides provided for low-income individuals. FTA officials
reported that they are currently testing the JARC performance measure and
intend to obtain baseline data for use in FTA's required evaluation of the
JARC program, which will be submitted to Congress in August 2008. In
addition, FTA revised its proposal to use the NTD for collecting
performance data after some grantees reported that it may be challenging
for smaller organizations to use the system. Finally, to address grantees'
concerns about the lack of feedback on their performance, FTA officials
told us that the agency would be more explicit about how it used the JARC
performance data grantees submitted and would explore posting this
information on its Web site in the future. Even if FTA resolves its
performance measurement and reporting issues, however, we identified gaps
in FTA's processes for monitoring JARC that may affect its ability to
evaluate and oversee the program. Although FTA has proposed to use
existing oversight processes to monitor JARC recipients, these oversight
processes do not explicitly include provisions for oversight of the JARC
program. Furthermore, FTA's proposed process for oversight of agencies
that do not fall under existing processes could lead to inconsistent
oversight of JARC recipients. FTA officials said that SAFETEA-LU does not
provide project management oversight funds for the JARC program, and that
they are currently looking for alternate sources of funding for this
purpose.
To establish adequate and consistent evaluation and oversight processes
for JARC recipients, and thereby enable FTA to determine whether projects
are meeting JARC program goals, we are recommending that the Secretary of
Transportation direct FTA to develop a plan for including the JARC program
in its established review mechanisms and to clarify how often recipients
that are not covered by those review mechanisms will be monitored. DOT,
including FTA, reviewed a draft of this report. FTA officials generally
agreed with the report's findings and said that they would consider the
recommendations as they move forward with implementing the program. FTA
officials also provided technical comments that were incorporated in the
report as appropriate to ensure accuracy.
Background
The enactment of the Personal Responsibility and Work Opportunity
Reconciliation Act of 1996 dramatically altered the nation's system to
provide assistance to low-income families with children. The act replaced
the existing entitlement program with fixed block grants to the states to
provide Temporary Assistance for Needy Families (TANF).^9 TANF provides
about $16.5 billion annually for the states to use for families to become
self-sufficient, imposes work requirements for adults, and establishes
time limits on the receipt of federal assistance. Without adequate
transportation, however, TANF recipients and other low-income individuals
face significant barriers in finding and keeping jobs. Evidence from
metropolitan areas, such as Atlanta, Boston, and Cleveland, shows that
TANF recipients disproportionately live in inner-city neighborhoods, far
from entry-level employment opportunities located in the suburbs. Although
poverty has declined in central cities, urban poverty rates were still
twice as high as suburban poverty rates in 1999 (approximately 16 percent
versus 8 percent).^10 In addition, available jobs may not be located near
central cities. For instance, one study in 2001 found that in Atlanta,
Chicago, Detroit, and a number of other metropolitan areas, more than 60
percent of the regional employment was located more than 10 miles from the
city center.^11 Similarly, the TEA-21 legislation noted that even in
metropolitan areas with excellent public transportation systems, less than
one-half of the jobs were accessible by transit. This spatial mismatch
between low-income individuals and the locations of jobs or other
employment-related services may hinder those individuals' ability to both
find and keep jobs.
These challenges are especially acute for low-income individuals who do
not own cars and for those who generally drive long distances in poorly
maintained cars. Data from the 2001 National Household Travel Survey
indicated that 26.5 percent of households that earn less than $20,000 do
not own a car, as compared with 1.2 percent of households with incomes
over $75,000.^12 Lack of adequate modes of transportation makes it
difficult to make multiple trips each day to accommodate child care and
other domestic responsibilities and employment-related services. As we
reported in 2004, many rural TANF recipients also cannot afford to own and
operate a reliable private vehicle, and public transportation to get to
and from training, services, and work is often not available. In addition,
several caseworkers and service providers in rural areas identified the
lack of valid driver's licenses as a problem for many of their clients.^13
A study from the Journal of the Transportation Research Board has shown
that access to jobs and job-related opportunities, on the other hand,
increases the employment and earnings of TANF recipients and reduces
TANF-use rates.^14
The JARC program was created in 1998 to support the nation's welfare
reform goals by filling gaps in transportation services. JARC funds can be
used to expand existing public transit routes or service hours, among
other things (see sidebars). However, JARC projects are not limited to
mass transit services; some JARC projects include ridesharing activities
and the promotion of transit voucher programs. DOT's two major goals for
the JARC program are to (1) provide transportation and related services to
urban, suburban, and rural areas to assist low-income individuals,
including welfare recipients, with access to employment and related
services, such as child care and training, and (2) increase collaboration
among transportation providers, human service agencies, employers, and
others in planning, funding, and delivering those services.
FTA experienced a number of challenges in implementing JARC under TEA-21.
For instance, we have reported that DOT had previously awarded grants to
designated parties in a noncompetitive fashion; however, in doing so, DOT
was not in compliance with the provisions of the authorizing legislation,
TEA-21, because the act called for a competitive grant selection
process.^15 Another challenge some grantees noted was that JARC funds
could not be used for planning and coordination activities, which required
grantees to find alternative sources to fund the administrative activities
done for JARC. Also, the statutory matching requirement for JARC was
inconsistent with other FTA programs because JARC projects could receive
grants for up to 50 percent of the project's capital expenses, rather than
80 percent. While we have reported that FTA had met its JARC program goal
of improving collaboration between grantees and stakeholders, we also have
reported that more collaboration is needed at the federal level to enable
grantees to obtain federal funding for JARC projects. TEA-21 required FTA
to report to Congress on the results of an evaluation of JARC; however,
FTA has struggled to develop comprehensive performance measures that
assess a national program when individual programs, operations, and
features vary.
SAFETEA-LU Created a Formula for Distributing JARC Funds and Amended Other
Aspects of the Program
SAFETEA-LU made a number of changes to the JARC program, the most notable
of which was the creation of a formula to distribute JARC funds beginning
with fiscal year 2006. Whereas in recent years, JARC projects were
competitively selected by FTA or congressionally designated for funding,
SAFETEA-LU created a formula to distribute funds to states and large
urbanized areas. This change is significant because some states and large
urbanized areas will receive substantially more funds than under the
discretionary program, while others will receive substantially less. In
addition, the formula program will result in some areas receiving JARC
funds that had not received them in the past. Other JARC changes resulting
from SAFETEA-LU include (1) the need for states and large urbanized areas
to designate a recipient for JARC funds, competitively select projects for
funding, and certify that selected projects came from a locally developed
coordinated plan and (2) the ability to use a portion of JARC funds for
planning activities. Table 1 compares key JARC provisions under SAFETEA-LU
and TEA-21.
Table 1: Comparison of SAFETEA-LU's and TEA-21's JARC Provisions
Provision Current program under SAFETEA-LU Program as previously
(since August 2005) administered under
TEA-21 (1999-August
2005)
Distribute JARC oRequires the Secretary of oThe Secretary of
funds by formula Transportation to apportion funds Transportation was
among states and designated required to conduct a
recipients of large urbanized national solicitation
areas through a formula that for applications for
considers the number of eligible grants and to select
low-income individuals^a and grantees on a
welfare recipients in each state competitive basis. In
or large urbanized area relative practice, however,
to other states or large projects were
urbanized areas. congressionally
designated in recent
oSixty percent of JARC funds is years.
apportioned to designated
recipients of urbanized areas oThe same percentage
with a population of 200,000 or of JARC funds were
more, 20 percent is apportioned allocated among large
to states for projects in urbanized areas, small
urbanized areas with a population urbanized areas, and
of fewer than 200,000, and 20 other-than-urbanized
percent is apportioned to states areas as provided
for projects in under SAFETEA-LU.
other-than-urbanized areas.
Designate JARC The governor must designate a Not required under
recipient recipient at the state level to TEA-21. Rather, FTA
competitively select and award competitively selected
funds for projects in small urban JARC projects and more
and other-than-urbanized areas, recently awarded funds
and within each large urbanized for projects that were
area to competitively select and congressionally
award funds in that area. designated.
Use coordinated oJARC projects selected for JARC projects were
public funding must be derived from a required to be part of
transit-human locally developed coordinated a coordinated public
services public transit-human services transit-human services
transportation transportation plan. Designated transportation
plan to select recipients must certify that planning process, but
projects for selected projects were derived there was no
funding from this plan. requirement to certify
that selected projects
oAdditional FTA programs that were derived from this
provide funding for services for plan.
transportation-disadvantaged
populations are also subject to
this requirement beginning in
fiscal year 2007.^b
Use competitive Designated recipients in The Secretary of
selection process urbanized areas are required to Transportation was
conduct a solicitation for required to conduct a
applications for grants in national solicitation
cooperation with the appropriate for applications for
metropolitan planning grants and to select
organization;^c designated grantees on a
recipients in states are required competitive basis. In
to conduct a statewide practice, however,
solicitation for applications for projects were
grants. Grants are to be awarded congressionally
on a competitive basis. designated in recent
years.
Allow the use of oA recipient may use up to 10 No statutory provision
funds for percent of its apportionment to for administration and
administration, administer, plan, and provide technical assistance
planning, and technical assistance for JARC under TEA-21.^d
technical projects. Planning and
assistance coordination
oPlanning is also included as an activities were
eligible expense, along with prohibited expenses.
capital and operating expenses.
Provide for States may transfer funds among No provision under
transfers of JARC the small urbanized area and TEA-21.
funds other-than-urbanized area
apportionments if the governor
certifies that JARC objectives
are being met in the specified
area. States may also transfer
funds from the small urbanized
area and other-than-urbanized
area apportionments to projects
in any area in the state if it
has a statewide program for
meeting JARC objectives. States
may also transfer funds to FTA's
Urbanized Area or Nonurbanized
Area Formula programs if the
funds are used for eligible JARC
projects.^e
Increase federal JARC grants for capital projects Grants for projects
government's may not exceed 80 percent of the could not exceed 50
share of capital net capital costs of the project. percent of the total
costs Grants for operating assistance project cost. No
may not exceed 50 percent of the differentiation
net operating costs of the between capital and
project. operating projects.
Remove limit on No limit on the amount that can No more than $10
reverse commute be used for reverse commute million could be used
project funding projects. each fiscal year for
reverse commute
project grants.
Source: GAO analysis of SAFETEA-LU and TEA-21.
^aEligible low-income individuals are those whose family income is at or
below 150 percent of the poverty line.
^bFTA programs in addition to JARC that serve these populations are the
Elderly Individuals and Individuals with Disabilities program and the New
Freedom program.
^cMetropolitan planning organizations are federally mandated regional
organizations responsible for comprehensive transportation planning and
programming in urbanized areas.
^dFTA allowed JARC grantees to use up to 10 percent of funds for
administration and technical assistance activities.
^eFTA officials explained that this transfer allows for administrative
ease of processing using a simplified single application.
JARC Became a Formula Program
A key SAFETEA-LU change to the JARC program was the creation of a formula
to distribute JARC funds. Under TEA-21, JARC was a discretionary grant
program for which FTA competitively selected JARC projects and, more
recently, awarded funds for congressionally designated projects. Under
SAFETEA-LU, states and large urbanized areas have been apportioned funding
for JARC projects through a formula that is based on the relative number
of low-income individuals and welfare recipients in
each area.^16 Forty percent of JARC funds each year is required to be
apportioned among states for projects in small urbanized and
other-than-urbanized areas, and the remaining 60 percent is required to be
apportioned among urbanized areas with a population of 200,000 or more.
For fiscal year 2006, the allocation was as follows:
ononurbanized areas - $27.3 million,
osmall urbanized areas - $27.3 million, and
olarge urbanized areas - $82.0 million.
The change to a formula program is significant because some states and
urbanized areas will receive substantially more funds than they received
under the discretionary program, while others will receive substantially
less (see fig. 1). In 22 states, the total amount of JARC funding
available decreased from fiscal years 2005 to 2006, when the formula-based
program began. The percentage decrease in funding for these 22 states
ranged from 33 percent to 88 percent. For example:
oAlaska's funding decreased approximately 88 percent, from $1.7 million in
fiscal year 2005 to $207,503 in fiscal year 2006.
oVermont also saw its JARC apportionments decrease more than 80 percent,
from $991,182 to $186,885.^17
The total amount of JARC funding available for 2 states (Michigan and West
Virginia) remained approximately the same over the 2 fiscal years, while
in 13 states, the total funding increased. The percentage increase for
these 13 states ranged from 17 percent to 2,931 percent.
oFlorida, for instance, had its JARC funds increased by more than 1,200
percent, from $594,708 in fiscal year 2005 to $8.3 million in fiscal year
2006.
oVirginia experienced the greatest percentage increase--more than 2,900
percent--from $84,249 in fiscal year 2005 to $2.5 million in fiscal year
2006.
Eighteen states were allocated fiscal year 2006 JARC funds that had not
received JARC funds for fiscal year 2005. These states represent
approximately 16 percent of the total JARC funding for fiscal year 2006.
(App. II lists the dollar amount of the fiscal year 2006 apportionments
for all of the states and large urbanized areas.)
Figure 1: Percentage Change in Job Access and Reverse Commute Funds
Apportioned to States and Large Urbanized Areas from Fiscal Years 2005 to
2006
Note: This figure includes funds congressionally designated for specific
projects in fiscal year 2005 or apportioned to states and large urbanized
areas within each state for fiscal year 2006. This figure does not include
the following 18 states that were not allocated fiscal year 2005 JARC
funds: American Samoa, Arizona, Arkansas, Guam, Hawaii, Idaho,
Mississippi, Montana, Nebraska, New Hampshire, North Carolina, Northern
Mariana Islands, Puerto Rico, South Carolina, South Dakota, Utah, Virgin
Islands, and Wyoming.
Large urbanized areas also saw substantial changes to their JARC funding
as a result of formularization. Of the 11 large urbanized areas we
interviewed that had received prior JARC grants, 1 saw its JARC funding
increase 64 percent between fiscal years 2005 and 2006, 5 had their funds
decrease from 3 percent to 88 percent between fiscal years 2005 and 2006,
and 5 had received JARC grants in the past but not in fiscal year 2005.
oFor example, Tampa/St. Petersburg was apportioned $978,029 in fiscal year
2006, a 64 percent increase from its two fiscal year 2005 grants that
totaled $594,708.
oBy contrast, Jefferson County in the Birmingham, Alabama, area had
received a JARC grant for almost $3 million in fiscal year 2005, whereas
the urbanized area was apportioned $356,107 for fiscal year 2006, a
decrease of 88 percent.^18
In addition, the formula program will result in some states and areas
receiving JARC funds that had not received them in the past. Eighteen
states received JARC funds in fiscal year 2006 that did not receive them
in fiscal year 2005.^19 For example, Wyoming, which has not received JARC
funds before, was apportioned $202,360 for fiscal year 2006 as a result of
the formula. An official from the Wyoming Department of Transportation
told us that the state will be able to use the funding to provide vanpool
and bus services to the new employment opportunities created by the
state's natural gas and mining operations, many of which are located in
areas without public transportation. Puerto Rico, also new to JARC, was
apportioned $6.6 million under the formula. Many large urbanized areas,
such as Fresno, California, will also be receiving JARC apportionments for
the first time.
Officials from the industry associations and the 29 state and local
agencies that we interviewed had mixed reactions to this change. Some of
these state and local agencies said the change from a discretionary to a
formula program would result in a more equitable distribution of funds or
that formula funding would provide a more consistent source of funding
than congressional designation. Some of the 29 agencies said that they
would likely add or expand transportation services in their area, and a
few thought that formularization would result in improved coordination
among transportation and human service agencies. By contrast, some of the
state and local agencies we interviewed said that the change to a formula
program and the associated program requirements they would need to fulfill
would increase the administrative burden on their agency, with 3 of these
agencies noting that the additional burden might outweigh the benefits of
the program. Other agencies said that the change to a formula program
would result in a loss of funds to their state or area, while 1 agency and
1 industry association said the change would spread an already small
amount of money even thinner. Several agencies also said that they might
have to reduce or eliminate services as a result. Still other agencies
said that the change to a formula program would have little or no impact
on transportation services in their area. Some indicated that the impact
would vary by location, while a few other agencies and 1 industry
association noted that it is too soon to know the impact.
SAFETEA-LU Introduced Three Key Requirements for Receiving JARC Funding
and Made Other Changes
In addition to creating a formula for distributing JARC funds, SAFETEA-LU
also requires states and large urbanized areas to fulfill the following
three key requirements before applying to FTA to receive their apportioned
JARC funding: (1) identify a designated recipient for JARC funds, (2)
conduct a competitive process to select projects for funding, and (3)
certify that JARC projects were derived from a coordinated public
transit-human services transportation plan (see fig. 2).
Figure 2: Key Requirements under SAFETEA-LU for Receiving JARC Funding
Under SAFETEA-LU, the governor of each state must designate a recipient
for JARC funds at the state level to competitively select and award funds
for projects in small urban and other-than-urbanized areas within the
state. In large urbanized areas, the recipient must be jointly designated
by the governor, local officials, and publicly owned operators of public
transportation. These designated recipients will then solicit applications
and develop and conduct a competitive process for selecting projects for
funding. SAFETEA-LU also extended a JARC coordinated planning requirement
to additional FTA programs. In the past, JARC projects were required to be
part of a coordinated public transit-human services transportation plan; a
similar requirement is included in SAFETEA-LU. However, this requirement
will apply in fiscal year 2007 to two other FTA programs that provide
funding for transportation-disadvantaged populations.^20 In addition,
recipients in states and urbanized areas that select JARC projects must
now certify that their selections were based on this plan.
SAFETEA-LU made a number of other changes to the JARC program, several of
which address issues that we have raised in past reports on JARC and the
coordination of transportation services for transportation-disadvantaged
populations. One such change is the ability of a recipient to use up to 10
percent of its JARC allocation for administration, planning, and technical
assistance.^21 SAFETEA-LU also expanded the definition of eligible
activities to include planning as well as capital and operating
activities. In 2004, we reported that a majority of the JARC grantees we
interviewed supported this proposed change because planning activities
could increase coordination with potential partners.^22 We also reported
in 2003 that the overall costs of coordination, which can include
additional staff members and staff time needed for maintaining and
overseeing coordination efforts, can be significant.^23 According to FTA,
the 10 percent of JARC funds that will now be available for
administration, planning, and technical assistance can be used for
coordination activities, which can help state and local agencies improve
services and achieve cost savings.
SAFETEA-LU also increased the federal government's share of capital costs
and removed a restriction on the amount of funding available for reverse
commute projects to help individuals gain access to suburban employment
opportunities. In 2004, we reported that the change in the matching fund
requirement for JARC would make that program consistent with the matching
requirements for other FTA programs.^24 Under TEA-21, projects could
receive a grant for up to 50 percent of the project's capital expenses,
which are used to purchase capital equipment such as buses. Grantees will
now be able to receive a grant for up to 80 percent of the project's
capital expenses.^25 FTA officials had told us that this change would
lessen any confusion about matching requirements among grant recipients
who participate in multiple FTA programs.
FTA Has Developed Proposed Final Guidance for JARC, but Delays in Issuing
the Final Guidance May Reduce the Time Available to Obligate JARC Funding
FTA has been developing guidance to help JARC recipients implement changes
to the program resulting from the enactment of SAFETEA-LU, but delays in
releasing final guidance will reduce the window of availability of fiscal
year 2006 funding. To formulate JARC guidance, FTA has been using an
extensive public participation process, including notices, commenting
periods, listening sessions, and focus groups. This strategy has provided
FTA with an abundance of feedback, and the agency has incorporated these
comments into its September proposed final guidance.^26 However, an
extension of the public comment period and the volume of public input have
also contributed to delays in issuing guidance, which meant that FTA was
not able to release final program guidance prior to the beginning of
fiscal year 2007. Given that FTA allows 3 years to obligate fiscal year
2006 funds, this delay results in 1 less year for states and urbanized
areas to obligate JARC funding.
FTA Has Engaged in Extensive Public Outreach to Formulate JARC Guidance
As required by SAFETEA-LU, FTA has used an extensive notice and comment
process to gain public input to formulate guidance for the JARC program.
In November 2005, FTA published a notice of changes to JARC and other
relevant programs.^27 This notice provided information on changes to the
JARC program and solicited public comment on aspects of the program, such
as technical assistance needs and the coordinated planning requirements.
In addition, FTA held five public listening sessions across the country on
a number of programs, including JARC, to obtain comments and input on the
issues that should be addressed in future guidance. The agency also
convened a focus group to discuss possible changes to the implementation
of JARC. In March 2006, drawing on information received in comments and
the listening sessions, FTA released interim JARC guidance for fiscal year
2006 and requested comments on its proposed implementation strategies.
When the interim guidance and proposed strategies was released, it
generated many questions and concerns among stakeholders. FTA received
more than 200 comments on its March interim guidance and proposed
strategies from state and local departments of transportation,
metropolitan planning organizations, private transportation service
providers, interest groups, and other JARC stakeholders. FTA officials
reviewed this feedback and addressed many of the stakeholders' issues in
the proposed final guidance for JARC, which was released in September. We
will discuss these comments in more detail later in this report, and
appendix III provides a summary of these comments.
FTA's Formulation of Guidance Has Been Delayed Due to Extensive Public
Comments on JARC Changes
FTA has been incorporating stakeholder concerns into its formulation of
guidance, but the volume of this input has contributed to delays. FTA
officials originally stated that they planned to issue proposed final
guidance in the early summer of 2006. However, FTA extended the comment
period for the March 2006 interim guidance and proposed strategies from
April 21 to May 22 to accommodate additional comments, and more than 100
comments were submitted on or after the last day of the comment period.
Because of these additional comments, FTA officials later told us that
they expected to issue the proposed final guidance in late July or early
August. FTA ultimately issued the proposed final guidance on September 6,
2006 (see fig. 3). Public comments were accepted for 60 days following the
release of the September proposed final guidance, after which FTA began
reviewing the comments to inform its final guidance. Consequently, FTA was
not able to release its final guidance prior to the start of the 2007
fiscal year in October. FTA officials said that they currently plan to
release final program guidance in March 2007.
Figure 3: Timeline for FTA's Implementation of SAFETEA-LU Changes to the
JARC Program
Delays in Issuing Final Guidance May Reduce the Time Available to Obligate
Fiscal Year 2006 JARC Funding
FTA's issuance of final guidance for JARC has been delayed, and this may
reduce the time available to projects to access fiscal year 2006 funding.
FTA officials noted that although the notice and comment process has
affected the timeliness of the program guidance, they feel that it has
enriched the development of guidance. However, the delays associated with
taking this approach have reduced the time between issuing the final
guidance on how to apply for fiscal year 2006 funds and the deadline for
obligating these funds by the end of fiscal year 2008.
A number of states and large urbanized areas have proceeded to implement
JARC's requirements using the interim guidance and proposed strategies.
Nineteen of the 29 state and local agencies we interviewed in the summer
of 2006 were proceeding with the implementation of JARC in the absence of
proposed final guidance. Many of these agencies are required to comply
with local and state planning and budget schedules, which have compelled
them to move ahead with JARC implementation. FTA officials told us that
they encouraged states and urbanized areas to begin implementing changes
to the JARC program on the basis of the March interim guidance and
proposed strategies, and that FTA is accepting applications for funding
prior to issuance of final guidance. In addition, FTA's March 2006 interim
guidance and proposed strategies included a "hold harmless" provision
stating that the final guidance requirements would not apply retroactively
to grants awarded prior to the issuance of the final guidance. FTA later
extended this "hold harmless" provision to grant applications submitted in
fiscal year 2007 on the basis of coordinated planning or competitive
selection processes that were substantially complete before the issuance
of final guidance.^28
Even if the delay in issuing the final guidance does not affect the
efforts already under way, states and large urbanized areas will need to
keep the remaining window of time in mind, or their ability to secure
fiscal year 2006 funding allocated to them could be affected. Through the
guidance, FTA implemented a 3-year period to obligate JARC funds for a
given fiscal year (the fiscal year of apportionment plus an additional 2
years). Under this view, the availability of fiscal year 2006 funding
would expire at the end of fiscal year 2008, and those agencies that chose
to wait for the final guidance to be released before applying for fiscal
year 2006 JARC funds
would have only 2 years in which to obligate those funds. A number of
state and local agencies we interviewed indicated that they are waiting on
FTA's final program guidance before moving forward to program
implementation. While these areas will benefit from having the final
guidance before they submit their JARC applications, given that the
guidance was not available by the beginning of fiscal year 2007, they will
have less time available to obligate fiscal year 2006 funds.
States and Large Urbanized Areas Have Begun to Implement JARC
Requirements, and FTA Has Taken Steps to Alleviate Implementation
Challenges
States and large urbanized areas that were apportioned JARC funds have
generally begun to implement requirements to receive this funding. As they
have done so, they have encountered challenges, most of which FTA has
taken steps to alleviate. To date, few states and large urbanized areas
have fulfilled the necessary SAFETEA-LU requirements to receive fiscal
year 2006 JARC funds, but most states and large urbanized areas we
contacted reported that they are in the process of fulfilling these
requirements. Officials we interviewed as well as other program
stakeholders have encountered several challenges in program
implementation, such as questions regarding the selection of the
designated recipient in large urbanized areas. FTA responded to most of
these issues in its September 2006 proposed final guidance.
Few States and Large Urbanized Areas Have Received Fiscal Year 2006 JARC
Funds, Although Most We Interviewed Are in the Process of Fulfilling
Funding Requirements
As we previously noted, states and large urbanized areas must fulfill
three SAFETEA-LU requirements prior to applying to FTA to receive JARC
funds to award for projects: identify a designated recipient for JARC
funds, conduct a competitive selection process, and certify that JARC
projects were derived from a coordinated public transit-human services
transportation plan. To date, few states and urbanized areas have
fulfilled these requirements and received fiscal year 2006 JARC funding.
Nationwide, 3 states and 9 of the 152 large urbanized areas that were
apportioned JARC funding had received fiscal year 2006 funds as of the end
of fiscal year 2006.^30 These obligated funds constitute less than 4
percent ^29,of the total fiscal year 2006 JARC funding apportioned to
states and large urbanized areas.
While few states and large urbanized areas have fulfilled the requirements
to receive JARC funds, officials in most of the 12 states and 12 large
urbanized areas we contacted in June, July, and August 2006 reported that
they have begun to implement these requirements to receive funding.
Specifically:
oIdentifying the JARC designated recipient. Officials in each of the 12
states we contacted reported that the state had determined its designated
recipient for JARC. In 7 of these states, officials reported that the
governor had signed a letter to formally designate the recipient, as
required by SAFETEA-LU, although not all of these states had submitted the
letter to FTA. The other 5 states reported that their formal designation
was in-progress. Officials in 9 of the 12 large urbanized areas we
contacted also reported that the area had determined which agency would
serve as the designated recipient for JARC funds, although none had
submitted a designation letter to FTA at the time of our interviews. There
is some variety in the agencies that will serve as the designated
recipient in the large urbanized areas we contacted. A metropolitan
planning organization will be the designated recipient in 4 of the areas
we contacted, while a transit agency will be the designated recipient in
the other 5 areas. The other 3 areas had not yet decided on the likely
designated recipient.
oDeveloping coordinated plans. Almost all of the states and large
urbanized areas we contacted had taken actions related to the
establishment of locally developed coordinated public transit-human
services transportation plans. SAFETEA-LU requires states and urbanized
areas to certify that they derived JARC projects from these plans. In 11
of the 12 large urbanized areas we contacted, officials reported that they
either had determined their strategy for meeting the coordinated plan
requirement or had initiated a coordinated planning process. In addition,
officials in all 12 states we contacted reported that the state will be
involved in coordinated planning for the JARC program, although the extent
of their participation varied. For example, one state official we
interviewed reported that his agency will lead the coordinated planning
process for small urbanized and rural areas within the state, while
another state official reported that rural areas will be responsible for
developing plans while the state provides assistance on a case-by-case
basis. In a majority of the states and large urbanized areas we contacted,
officials anticipated completing these plans in early- to mid-2007. While
FTA has allowed states and large urbanized areas to apply for up to 10
percent of their apportionment for administration, planning, and technical
assistance prior to applying for funding for project implementation, only
1 of the states and 1 large urbanized area we contacted had received this
funding, and another large urbanized area we contacted was in the process
of applying for the funding. Reasons that officials we interviewed cited
for not applying for this funding included the intention to wait until
fiscal year 2007 to use the funding, and the use of other funding sources
for these activities.
oConducting a competitive selection process. Few states and large
urbanized areas we contacted had conducted a competitive selection process
to award fiscal year 2006 JARC funds. Officials in 2 large urbanized areas
reported that they had conducted a competitive selection process to award
fiscal year 2006 funds. In addition, 3 states we contacted had
competitively selected JARC projects, but at the time of our interviews,
none had yet applied to FTA for the state's fiscal year 2006 funding to
award for project implementation. Officials in a majority of the remaining
states and large urbanized areas anticipated competitively selecting
projects in early- to mid-2007. More than half of the states and large
urbanized areas we contacted reported that they considered or may consider
a project's prior receipt of JARC funding to some extent in selecting
projects for funding. For example, officials from 2 metropolitan planning
organizations we interviewed noted that they would consider a project's
prior receipt of JARC funds to continue successful projects. Other
criteria that officials anticipated they would consider in selecting
projects included the capacity of the organization to administer the
funds, whether the project had matching funds, and how the project would
address the needs of the community.
States and Large Urbanized Areas Have Encountered Several Implementation
Challenges, Most of Which FTA Has Responded to in Its Proposed Final
Guidance
In comments submitted on FTA's March interim guidance and proposed
strategies and in interviews with selected state and local officials,
program stakeholders expressed several implementation challenges they had
encountered or concerns they had as the program moves forward. These
issues included questions regarding the designated recipient in large
urbanized areas, and challenges in ensuring stakeholder participation and
adequate resources for the development of coordinated public transit-human
services transportation plans. FTA responded to many of these issues in
its proposed final guidance, which it issued in September 2006. Table 2
below summarizes stakeholders' key implementation challenges and concerns
and FTA's actions to respond to these issues.
Table 2: Stakeholders' Key Implementation Challenges and Concerns and
FTA's Response
Implementation Challenges and concerns FTA's response in
information in FTA's expressed by program proposed final JARC
notice of program stakeholders guidance (September 2006)
changes (November
2005) and interim JARC
guidance and proposed
strategies (March
2006)
Designated recipients
in large urbanized
areas
Large urbanized areas oConfusion regarding the oClarifies that a
are to designate the need for a designation of designation of the JARC
JARC recipient under a recipient separate from recipient is needed
the same process that the FTA Section 5307 separate from the Section
governs the program. 5307 program.
designation of
recipients for FTA's oStakeholder comments
Urbanized Area Formula that SAFETEA-LU
program, known as the identified existing
Section 5307 Section 5307 designated
program.^a recipients as the
intended JARC designated
recipients.
Notes stakeholders' oDifferent opinions among oClarifies that
concerns that a program stakeholders designated recipients may
potential conflict of regarding the potential establish partnerships
interest could exist for a conflict of with other organizations
in large urbanized interest. to competitively select
areas when the projects to address
designated recipient oClaims that there was potential
both conducts the inconsistent information conflict-of-interest
competitive selection from FTA staff regarding concerns.
process and is the designated
eligible to receive recipient's ability to oStates that the
funds. Interim allow another designated recipient may
guidance describes organization to conduct be an existing Section
strategies and the competitive selection 5307 program designated
policies to ensure process, to avoid recipient or that another
that projects are potential agency may be a preferred
selected through a conflict-of-interest choice that is based on
fair and equitable issues. local circumstances.
process.
Development of
coordinated public
transit-human services
transportation plans
Recommended that the oChallenges in getting oNotes that FTA is
lead agency developing other organizations, such working with other
the coordinated plan as human service federal agencies on the
include a number of agencies, to participate Federal Interagency
groups in the process, in the planning process. Coordinating Council on
including nonprofit Access and Mobility to
transportation encourage organizations
providers, private that receive other
transportation sources of human service
providers, and human transportation funding to
service agencies. participate in
coordinated
transportation planning.
oNotes that the extent of
outreach and
participation in the
planning process will be
based on local
circumstances.
Areas must derive JARC oDifficulties in oAllows a phased-in
projects receiving developing plans within approach to the
fiscal year 2006 established time frames. development of
funding from a coordinated plans.
coordinated public
transit-human services
plan. This requirement
applies to the New
Freedom program and
the Elderly
Individuals and
Individuals with
Disabilities program,
known as the Section
5310 program, in
fiscal year 2007.^b
Program funding
Up to 10 percent of a oThe cost of developing oIdentifies other sources
state or large coordinated plans exceeds of FTA funding that
urbanized area's available resources. states and urbanized
apportionment is areas can use for
available for oAreas will incur higher administration and to
administration, initial costs to develop coordinated
planning, and implement new program plans.
technical assistance. requirements.
Recipients may apply oProposes that recipients
for this funding prior can combine the
to applying for administrative funding
project available under the
implementation. Section 5310, JARC, and
New Freedom programs to
develop a single
coordinated public
transit-human services
transportation plan.
oNotes that
administrative funds are
not specific to one year,
and that recipients may
roll over administrative
funding into a subsequent
year for the anticipated
future costs of current
projects.
oNotes that planning
activities are an
eligible expense for the
JARC program.
Grantees may use oDifficulties in securing oLists potential sources
federal JARC funding matching funds for JARC of matching funds,
for 80 percent of projects. including other federal
capital expenses and programs that provide
50 percent of funding for
operating expenses. transportation.
Source: GAO analysis of FTA information.
^aThe Section 5307 program makes federal resources available to urbanized
areas and to governors for transit capital and operating assistance in
urbanized areas and for transportation-related planning. For urbanized
areas with a population of 200,000 or more, funds are apportioned and flow
directly to a designated recipient selected locally to apply for and
receive federal funds.
^bThe Section 5310 program provides formula funding to states for capital
projects to assist in meeting the transportation needs of the elderly and
persons with disabilities.
Designated Recipient in Large Urbanized Areas
Selected urbanized area officials we interviewed and stakeholder comments
on FTA's interim JARC guidance raised several questions and issues
regarding the designated recipient in large urbanized areas. For example,
transit agency officials we interviewed in 2 large urbanized areas were
under the impression that their agency's status as the designated
recipient for FTA's Urbanized Area Formula program (Section 5307 program)
automatically made the agency the JARC designated recipient. In addition,
two comments on FTA's March 2006 interim guidance and proposed strategies
noted the stakeholders' belief that SAFETEA-LU identified existing Section
5307 designated recipients as the intended JARC designated recipients. FTA
officials acknowledged that on the basis of the interim guidance and
proposed strategies, there was some confusion about the process to
designate the JARC recipient. To clarify this issue, the preamble of the
September proposed final guidance notes that in large urbanized areas, a
new designation letter shall be issued for the JARC program, regardless of
whether the designated recipient is the same or different than the Section
5307 designated recipient.
Officials we interviewed in large urbanized areas and several stakeholder
comments on FTA's interim guidance and proposed strategies also raised the
issue of a potential conflict of interest with respect to the designated
recipient in large urbanized areas, and noted uncertainty about the
ability of designated recipients to allow other organizations to conduct
the competitive selection process. In its March interim guidance and
proposed strategies, FTA noted that many comments on its November 2005
Notice of Program Changes expressed concern that a conflict of interest
could exist in large urbanized areas when the designated recipient,
specifically a provider of transportation services, conducts the
competitive selection process and is eligible for funding. In addition,
officials at 12 of the 17 agencies we contacted in large urbanized areas
and 18 stakeholder comments on FTA's March 2006 interim guidance and
proposed strategies believed there would be a potential conflict of
interest or the appearance of a conflict of interest in this arrangement.
Eight other stakeholder comments stated that a transparent competitive
selection process or the involvement of metropolitan planning
organizations in the selection process would ameliorate any
conflict-of-interest concerns. While officials we interviewed in 2 large
urbanized areas raised the possibility of the designated recipients
allowing another organization to conduct the competitive selection process
to avoid potential conflict-of-interest issues, officials in 1 of these
areas said that prior to the release of FTA's proposed final guidance,
they received inconsistent information from FTA staff regarding this
issue.
The ability of designated recipients to both conduct the competitive
selection process and compete for funds through this process does present
potential conflict-of-interest concerns. However, FTA outlined a number of
strategies and controls in its JARC guidance that, if adhered to by
designated recipients, should address many of these potential
conflict-of-interest concerns and minimize perceptions of unfairness in
the competitive selection process. These controls relate to GAO's internal
control standards for the federal government, one of which addresses the
policies and procedures in place within an agency to ensure proper
stewardship and accountability for government resources.^31 These
strategies and controls were as follows:
oSelection of the designated recipient. To address stakeholders' concerns
of a potential conflict of interest, FTA recommended in its March interim
guidance and proposed strategies that the designated recipient not be a
provider of transportation services. FTA noted that it received a wide
range of comments on this proposal, and, in response, the September
proposed final guidance stated that the designated recipient may be the
same as the area's existing Section 5307 program designated recipient or
that another agency may be a preferred choice that is based on local
circumstances.
oStrategies for a transparent competitive selection process. FTA's interim
guidance and proposed strategies and proposed final guidance advised that
the designated recipient follow a simple and straightforward selection
process that is transparent, and provided several potential strategies for
areas to consider when implementing a competitive selection process. These
strategies include ensuring greater inclusion at the onset of the
coordinated planning process to alleviate concerns about a level playing
field, and ranking projects using methods such as third-party review, peer
review, or review by a panel of planning partners.
oAllowing other organizations to conduct the competitive selection
process. While officials we interviewed in 1 large urbanized area said
that FTA officials had previously provided conflicting information about
the ability of designated recipients to allow other organizations to
conduct the competitive selection process, FTA's September proposed final
guidance affirms that designated recipients can work with other
organizations to conduct the competitive selection process to alleviate
conflict-of-interest concerns. FTA's proposed final guidance also notes
that the SAFETEA-LU requirement for designated recipients to conduct the
competitive selection process in cooperation with the metropolitan
planning organization in large urbanized areas should mitigate this
potential conflict-of-interest concern.
oFTA oversight of the competitive selection process. Once designated
recipients select projects and submit applications to FTA for funding for
project implementation, FTA officials reported that they will review the
applications to ensure that areas used a competitive process to select
projects. In addition, at the time of submitting an application for
funding, designated recipients are required to certify that they
distributed funds on a fair and equitable basis, and FTA has advised that
a transparent and inclusive competitive selection process should serve as
the basis for this certification.
Development of Coordinated Public Transit-Human Services Transportation
Plans
State and local officials we interviewed and stakeholder comments on FTA's
interim guidance and proposed strategies also cited several challenges and
concerns related to the development of the coordinated public
transit-human services transportation plans. These issues included
participation in the planning process and the amount of time needed to
develop coordinated plans. For example, officials in 3 large urbanized
areas and 5 states we contacted noted challenges in getting other
organizations, such as human service agencies, to participate in the
planning process. One of these officials noted her concern that
organizations that do not want to receive FTA funding will have no reason
to participate in the planning process. In addition, five comments on
FTA's interim guidance and proposed strategies suggested that federal
agencies that provide other sources of federal funds for transportation
services should require their grantees to participate in coordinated
planning efforts. FTA officials reported that they have been working with
members of the Federal Interagency Coordinating Council on Access and
Mobility to encourage federal grantees that receive other sources of human
service transportation funding to participate in coordinated
transportation planning.^32 Although it will take time to put coordination
provisions in place within each agency, FTA officials said they were
encouraged by this progress.
Program stakeholders also expressed concern about their ability to develop
coordinated plans within FTA's time frames. For JARC, the requirement to
derive projects from a coordinated public transit-human services
transportation plan was in place for fiscal year 2006 and applied to the
New Freedom program and the Elderly Individuals and Individuals with
Disabilities program beginning in fiscal year 2007. Seven stakeholder
comments on FTA's interim guidance and proposed strategies noted that it
would be difficult to develop a plan within this time frame. Officials in
2 large urbanized areas we contacted shared similar concerns. In its
proposed final guidance, FTA focuses on a phased-in approach to the
development of coordinated plans through fiscal year 2007, with full
implementation of the coordinated planning requirements for projects
funded in fiscal year 2008. FTA officials also said they are encouraging
areas to build on existing planning efforts to fulfill SAFETEA-LU
requirements.
Competitive Selection of JARC Projects
State and local officials we interviewed cited fewer challenges related to
the competitive selection of JARC projects. The reason could be because
few state and local agencies we contacted had completed a competitive
selection process, and many did not anticipate selecting projects until
early- to mid-2007. However, officials in 1 large urbanized area and 1
state we contacted noted the difficulty in initiating a competitive
selection process without additional FTA guidance. One of these officials
said that they did not want to have to begin a new process if their
actions contradict any future FTA guidance. Another state official with
whom we spoke said that he would like FTA to clarify questions his agency
had about the competitive selection process, such as what it means to
certify that the state derived projects that were based on a coordinated
plan. FTA's proposed final guidance provided recipients with additional
information on how to certify that they selected projects that were based
on a coordinated plan.
Other Implementation Challenges
In addition to challenges related to the designated recipient, coordinated
planning, and competitive selection of JARC projects, state and local
officials we interviewed also cited implementation challenges related to
funding and their communication with FTA. Officials in nearly half of the
states and large urbanized areas we contacted did not believe that the 10
percent of an area's JARC apportionment available for administration,
planning, and technical assistance would be sufficient for these
activities, although the reasons for these beliefs varied. For example,
officials in 1 state and in 1 large urbanized area did not believe these
funds would be sufficient because they will incur higher initial costs to
meet the new program requirements, while officials in 2 other states and 1
large urbanized area did not believe this funding would be sufficient due
to the costs of developing coordinated plans. FTA received a number of
comments about funding for administration, planning, and technical
assistance, and the September proposed final guidance informs recipients
of other sources of FTA funding that are available for planning
activities. These sources include funding from FTA's Urbanized and
Non-urbanized Area Formula programs as well as its Metropolitan and
Statewide Planning programs. The proposed final guidance also proposes
that recipients may combine the administrative funding available under the
Elderly Individuals and Individuals with Disabilities (known as Section
5310), JARC, and New Freedom programs to develop a single coordinated
public transit-human services transportation plan.^33 In addition, the
proposed final guidance notes that the 10 percent of an apportionment
available for these activities is not specific to one year, and that
recipients may roll over administrative funding into a subsequent year for
the anticipated future costs of projects. Lastly, the proposed final
guidance notes that planning activities are an eligible expense for the
JARC program, beyond the 10 percent of an apportionment available for
administration, planning, and technical assistance.
Several officials we interviewed also cited challenges in meeting the JARC
program matching requirements. Under SAFETEA-LU, grantees may use federal
JARC funding for 80 percent of capital expenses and 50 percent of
operating expenses. Matching funds may come from other federal programs
that are not administered by DOT, such as the Temporary Assistance for
Needy Families (TANF) block grant, as well as from noncash sources, such
as in-kind contributions and volunteer services. One state official we
interviewed, whose agency previously received JARC funding, noted that the
agency had struggled in the past to secure matching funds and, as a
result, has yet to spend all of its past federal JARC funding. A
metropolitan planning organization official we interviewed noted that the
ability of smaller nonprofit organizations in her area to secure the
required matching funds was an issue, because these organizations have
limited resources to use for matching funds. In addition, 1 state official
and officials in 1 large urbanized area said that their areas anticipated
or had seen cutbacks in matching funding they had received in the past
from agencies that provided funding from programs such as TANF.^34 As a
result, these officials said they will have less state and local matching
funding available for projects. Although the JARC matching requirements
are set in the SAFETEA-LU legislation, FTA's proposed final guidance
provides information on potential sources of matching funds for JARC
projects.
While several officials we interviewed had positive comments about FTA's
efforts to solicit public input as it implements changes to JARC and other
programs, some officials also noted challenges they had encountered in
communicating with FTA regarding JARC implementation. Receiving consistent
information from FTA was one challenge cited by officials we interviewed.
As we previously noted, officials from one metropolitan planning
organization reported that they received inconsistent information from
different FTA staff in response to a question about the responsibilities
of the designated recipient. In addition, officials we interviewed in 1
state said they received different answers regarding the timeline for
completing a coordinated plan. Other officials we interviewed cited
challenges in receiving information to answer implementation questions.
Officials in 2 states we contacted noted difficulties in getting specific
answers to their implementation questions, with 1 state official noting
that with new programs, FTA should be prepared to answer specific
questions about program implementation instead of providing general
information.
FTA Changed Its Evaluation and Oversight Strategies but Still Needs to
Address Monitoring Issues
Although FTA revised its original JARC evaluation and oversight proposals
to respond to current and past concerns raised by program stakeholders,
gaps in monitoring may limit FTA's ability to assess whether the program
is meeting its goals. In previous work, we and others have reported that
FTA could better measure and communicate the outcomes of the JARC program
to program stakeholders, including Congress and JARC grantees. To address
these issues, FTA sought public comment on four new performance
measures--one specifically for JARC and three crosscutting measures--and
an existing data collection mechanism to track JARC performance data, the
National Transit Database (NTD). However, several program stakeholders
noted various obstacles to collecting reliable data on FTA's proposed
measures, and some state and local officials we interviewed reported that
it would be challenging to use the NTD system. In addition, state and
local officials expressed ongoing concerns about the lack of feedback on
their performance after submitting their data to FTA. In response to these
concerns, FTA clarified the performance measures, introduced a plan to use
its existing grant management system for collecting performance data, and
proposed to be more explicit with grantees about how reported JARC
performance data were being used. FTA officials also reported that they
are testing the JARC performance measure and obtaining baseline data for
use in the required evaluation of the JARC program, which will be
submitted to Congress in August 2008. Even if FTA resolves its performance
measurement and reporting issues, gaps in monitoring may continue to limit
FTA's ability to evaluate and oversee the JARC program. FTA plans to use
existing oversight processes for monitoring JARC recipients; however, FTA
officials also noted that SAFETEA-LU did not specifically provide project
management oversight funds for the JARC program. As a result, FTA
officials are looking for alternate sources of funding--such as the
agency's administrative funding--to provide program oversight for JARC.
Past Concerns about the JARC Program Have Included Performance
Measurement, Reporting, and Evaluation
The need for agencies to measure performance is based upon the Government
Performance and Results Act of 1993 (GPRA),^35 which was intended to
improve federal program effectiveness, accountability, and service
delivery. GPRA helped create a governmentwide focus on results by
establishing a statutory framework for performance management and
accountability, with the necessary infrastructure to generate meaningful
performance information. This act required federal agencies to develop
strategic plans and annual performance plans, link them with
outcome-oriented goals, and measure agency performance in achieving these
goals. The Office of Management and Budget also plays a role in GPRA
implementation and reviews agencies' strategic plans, annual performance
plans, and annual performance reports. Overall, GPRA's requirements have
laid a solid foundation for results-oriented agency planning, measurement,
and reporting by providing more objective information on achieving goals
and on the relative effectiveness and efficiency of federal programs and
spending.
Past GAO reports on performance measurement and performance budgeting have
noted the importance of using outcome-oriented measures to assess the
extent to which a program achieves its objectives on an ongoing basis and
the importance of linking resources to results.^36 However, our previous
reviews of the JARC program have found that FTA lacked the data needed to
evaluate and report on the program as required by Congress. For example,
in May 1998, we recommended that FTA establish specific objectives,
performance criteria, and measurable goals to assess how the JARC program
would improve mobility for low-income workers.^37 In response, FTA
instituted an evaluation plan and selected access to employment sites as
the sole measure of program success. However, we later found that this
measure did not address key aspects of the program, such as increasing
collaboration between grantees and stakeholders and establishing
transportation-related services that help low-income individuals.^38 We
also reported in August 2004 that grantees found it difficult to obtain
the data requested by FTA, such as the number of potential employers
reached by JARC services. Furthermore, the grantee reports used to
evaluate the JARC program contained self-reported information, which FTA
did not verify. As a result, we stated that FTA's 2003 evaluation of JARC
was limited because it lacked consistent, generalizable, and complete
information, thereby making it difficult to use these data to draw any
definitive conclusions about the program as a whole.^39 In recognition of
these concerns, FTA began taking steps to consider ways to improve its
evaluation process, such as revising the JARC performance measures.
In previous reports on the JARC program, we and others have also
highlighted issues with FTA's reporting mechanism and lack of
communication with grantees about their performance. Performance reporting
is a critical element for establishing accountability and evaluating
whether and to what extent program managers are meeting the goals
contained within agency strategic and performance plans. In 2004, we
reported that JARC grantees were required to report quarterly data using a
database that many found to be burdensome. We also noted that specific
information in FTA's JARC evaluation may not have been consistent because
grantees did not follow a standardized reporting system.^40 Our past work
on data quality has highlighted the importance of ensuring that reported
performance data are sufficiently credible for decision making.^41 In a
2003 FTA-contracted study of JARC evaluation efforts, some grantees
recommended that FTA allow agencies to report performance data using
existing systems, such as the NTD, and that the reporting structure be
flexible enough to enter qualitative or narrative information to reflect
the
different types of services provided by JARC programs.^42 Grantees also
stated that they would be interested in receiving feedback from FTA on the
JARC evaluation process and stressed the importance of communicating
program findings to help them assess and improve their performance.^43 We
previously have identified the distribution of information in a form and
time frame that allows managers, staff, and external stakeholders to
perform their duties and to provide them with a basis for focusing their
efforts and improving performance as a critical practice for managing
program results.^44
FTA Clarified Its Proposed JARC Performance Measures and Introduced a
Different Reporting Mechanism in Response to Concerns Expressed by Program
Stakeholders
FTA's extensive public participation process helped to inform changes made
to the proposed final guidance issued in September, including the
introduction of new performance measures to evaluate the JARC program as
well as a different reporting mechanism for collecting data. In its March
2006 interim guidance and proposed strategies, FTA had proposed using one
JARC-specific measure and three crosscutting measures to assess the JARC
program's outcomes and impacts:
oCumulative number of jobs accessed (JARC-specific): Cumulative number of
jobs reached through the provision of JARC-related services for low-income
individuals and welfare recipients.
oEfficiency of operations (crosscutting measure): Number of communities
and states reporting the use of shared resources between different
agencies and organizations so they can provide more rides for people with
disabilities, older adults, and individuals with lower incomes at the same
or lower cost.
oProgram effectiveness (crosscutting measure): Number of communities that
have a simple point of entry-coordinated human service transportation
system for people with disabilities, older adults, and individuals with
lower incomes so they have easier access to transportation services.
oCustomer satisfaction (crosscutting measure): Level of customer
satisfaction reported in areas related to the availability, affordability,
acceptability, and accessibility of transportation services for people
with disabilities, older adults, and individuals with lower incomes.
According to FTA, the JARC-specific measure was intended to reduce the
numerous JARC data requirements, while the three crosscutting measures
reflected SAFETEA-LU's emphasis on the coordination of human services
transportation and would apply to the JARC, New Freedom, and Elderly
Individuals and Individuals with Disabilities (Section 5310) programs. In
addition, FTA proposed to address past concerns regarding the burden of
collecting program data on JARC by using existing mechanisms, including
the NTD, which is used to track operational, service, and financial data
on other transit formula programs.
In both the docket comments and in our interviews, program stakeholders
cited potential obstacles to collecting accurate data on the number of
jobs accessed measure, such as a lack of guidance from FTA and limited
resources (see table 3 for a summary of stakeholder concerns regarding the
proposed measures). For example, 7 state and local officials we
interviewed reported that FTA's definition for the number of jobs accessed
was unclear, or that they did not know how to determine this measure.
Specifically, one metropolitan planning organization official wanted FTA
to clarify whether the jobs accessed measure referred to the number of
low-income people using a JARC-funded service to travel to their jobs or
to the total number of jobs available in the area being served by a
JARC-funded service. Three state transportation officials that we
contacted were also concerned that they did not have sufficient staff to
conduct the required data collection. Program stakeholders expressed
similar concerns in their docket comments. For example, 2 stakeholders
noted in their written comments to FTA that collecting data on the
proposed performance measures may be overly burdensome for small agencies.
Table 3: Summary of Program Stakeholders' Challenges and Concerns and
FTA's Response to the Proposed JARC Performance Measures and Reporting
Mechanism
Implementation Challenges and FTA's response in
information in FTA's concerns expressed by proposed final guidance
interim guidance and program stakeholders (September 2006)
proposed strategies
(March 2006)
JARC-Specific Performance oCollecting data on FTA clarified that the
Measure: Cumulative the number of jobs proposed cumulative
number of jobs accessed accessed is hard number of jobs accessed
because it is measure in its proposed
Cumulative number of jobs difficult to isolate final guidance will
reached through the JARC riders from other measure the following:
provision of JARC-related transit customers. (1) the increase in
services for low-income access to jobs related to
individuals and welfare oTracking whether JARC geographic coverage
recipients. riders are using and/or service times that
fixed-route systems^a impact the availability
to access jobs or for of transportation
other purposes is services for low-income
challenging. individuals as a result
of the JARC projects
oFactors outside of implemented in the
agencies' control may current reporting year
make it difficult to and (2) the number of
measure the number of rides provided for low-
jobs accessed. income individuals as a
result of the JARC
oFTA's definition of projects implemented in
"number of jobs the current reporting
accessed" is unclear, year.
and it is difficult to
know how this measure FTA has also hired a
will be determined. contractor to test the
feasibility of
oAdministrative burden implementing the new
of collecting data on increase in access to
measures (e.g., number jobs measure.
of jobs accessed) is
high for the amount of
JARC funds available.
oData collection will
be burdensome for some
agencies (e.g., rural
or small
organizations) with
limited staff capacity
or resources.
Crosscutting Performance oProposed measure does FTA officials did not
Measure 1: Efficiency of not translate well for include this measure in
Operations measuring performance the proposed final
in some areas (e.g., guidance on the basis of
Number of communities and rural areas) and for comments received.
states reporting the use providing service to However, FTA officials
of shared resources underserved reported that they are
between different populations. developing a tool and
agencies and plan to provide technical
organizations so they can oConcerned that assistance through the
provide more rides for operational efficiency United We Ride Initiative
people with disabilities, is viewed as a "more to help states and local
older adults, and service for lower areas measure their own
individuals with lower dollars" approach. performance.
incomes at the same or
lower cost. oProposed measure
reflects the number of
coordination
relationships between
communities and states
reporting the use of
shared resources,
rather than the
increase in the total
number of rides
provided to the
different populations.
oLocal areas need
flexibility to develop
performance measures
that meet and reflect
the unique needs and
conditions of their
communities.
Crosscutting Performance oProposed measure FTA officials did not
Measure 2: Program appears to give include this measure in
Effectiveness preference to projects the proposed final
with a "simple point guidance on the basis of
Number of communities of entry coordinated comments received.
that have a simple point human service However, FTA officials
of entry-coordinated transportation reported that they are
human service system," which may not developing a tool and
transportation system for be the only way to plan to provide technical
people with disabilities, achieve coordination assistance through the
older adults, and in different local United We Ride Initiative
individuals with lower areas. to help states and local
incomes so they have areas measure their own
easier access to oFTA's definition of performance.
transportation services. "communities" is
vague.
oLocal areas need
flexibility to develop
performance measures
that meet and reflect
the unique needs and
conditions of their
communities.
Crosscutting Performance oProposed customer FTA officials did not
Measure 3: Customer satisfaction measure include this measure in
Satisfaction is very subjective and the proposed final
amorphous. guidance on the basis of
Level of customer comments received.
satisfaction reported in oSome agencies do not However, FTA officials
areas related to the have the staff or reported that they are
availability, resources to survey developing a tool and
affordability, riders to measure plan to provide technical
acceptability, and customer satisfaction. assistance through the
accessibility of United We Ride Initiative
transportation services oOn-board transit to help states and local
for people with surveys for some areas measure their own
disabilities, older measures, such as performance.
adults, and individuals customer service, are
with lower incomes. expensive and
labor-intensive to
conduct.
oLocal areas need
flexibility to develop
performance measures
that meet and reflect
the unique needs and
conditions of their
communities.
JARC Reporting Mechanism: oSome providers, FTA will not require
including rural and grantees to use the NTD
National Transit nontraditional for data collection and
Database^b recipients, may find reporting. Instead, FTA
the NTD difficult to proposes that grantees
JARC grantees would use use for collecting and use their existing
the existing NTD system managing data. Transportation Electronic
to collect and report Award and Management
JARC performance data. oSmaller agencies may system for JARC
need staff training to reporting. This system
use the NTD. can be used to record
qualitative information.
oNot all JARC
information can be
easily translated into
the data elements
contained in the NTD.
Source: GAO analysis of FTA guidance, comments submitted to FTA's docket,
and interviews with state and local officials.
^aFixed-route systems refer to a system providing designated public
transportation on which a vehicle is operated along a prescribed route
according to a fixed schedule.
^bFTA currently uses the NTD to collect uniform operational, service, and
financial data on existing department programs, including the Urbanized
Area and Nonurbanized Area Formula programs.
^cUnited We Ride is an interagency federal national initiative that
supports states and their localities in developing coordinated human
service delivery systems. In addition to state coordination grants, United
We Ride provides state and local agencies with a
transportation-coordination and planning self-assessment tool, help along
the way, technical assistance, and other resources to help their
communities with these efforts.
FTA officials acknowledged that there was confusion among program
stakeholders about the JARC-specific measure and how it should be
measured, and they subsequently clarified the original proposal on the
basis of the comments received. FTA's proposed final guidance stated that
the JARC-specific measure would assess the following:
oJob access: The increase in access to jobs related to geographic coverage
and/or service times that impact the availability of transportation
services for low-income individuals as a result of the JARC projects
implemented in the current reporting year.
oRides provided: The number of rides provided for low-income individuals
as a result of the JARC projects implemented in the current reporting
year.
According to FTA, the jobs accessed measure is a measure of "system
coverage," describing the number of jobs reachable by JARC-funded
services. FTA also clarified that the new measure is not a determination
of an actual number of riders who are getting and going to jobs, which was
a concern raised by some program stakeholders in their docket comments and
in our interviews. FTA also intends to monitor JARC service use by
measuring the number of rides actually provided by the JARC service
annually.
In addition to clarifying the JARC measure, FTA is also taking steps to
test its JARC performance measure and to collect baseline data for its
upcoming evaluation of the program. For example, FTA has hired a
contractor to examine the feasibility of collecting data for the increase
in the jobs accessed measure and is currently analyzing the strategies for
capturing this more precise measure and testing its implementation. FTA
also is soliciting public comments on the revised JARC performance
measures, which will be used to formulate the final JARC guidance. Once
the measures are finalized, FTA will test the JARC-specific performance
measure and plans to obtain baseline data for fiscal year 2006 and beyond
using JARC grants active during fiscal year 2005.^45 FTA officials plan to
use these data to conduct the required evaluation of the JARC program,
which must be submitted to Congress in August 2008.^46 FTA's proposed
final guidance states that it will conduct independent evaluations of the
JARC program focused on specific data elements to better understand the
implementation strategies and related outcomes associated with the
program. This approach is supported by our recent report on grants
management, in which we recommended that performance data should be tested
to make sure they are credible, reliable, and valid.^47 An FTA official we
spoke with told us that FTA hopes to have a formal reporting methodology
targeted to be in place by spring 2007.
Program stakeholders also reported potential difficulties with FTA's
proposed crosscutting national coordination measures to assess program
performance. (See table 3 for a summary of stakeholder concerns regarding
the proposed performance measures.) For example, some program stakeholders
stated in their docket comments that the performance measures would be too
prescriptive and would stifle local creativity, while 13 stakeholders
recommended that performance measures should be developed locally to
address local conditions and needs. Specifically, two commenters noted
that FTA's proposed crosscutting performance measures did not necessarily
acknowledge the differences in providing JARC services in urbanized areas
compared with rural areas, where the number of transit providers may be
limited and the routes typically serve fewer people at a higher cost. In
addition, two local officials and one state department of transportation
official that we interviewed reported that measuring customer satisfaction
would likely require administering a survey, which could be expensive or
labor-intensive.
In recognition of these concerns, FTA did not include the three
crosscutting coordination measures in its proposed final guidance, noting
instead that individual communities will have the option to include
evaluation strategies for their own activities. We have previously
observed that designing results-oriented performance measures for
intergovernmental programs, such as JARC, is complicated by the broad
range of objectives identified for some programs and the discretion states
and localities have in achieving those objectives. According to FTA, the
crosscutting measures were created in response to recommendations stemming
from the Interagency Coordinating Council on Access and Mobility's United
We Ride initiative to develop a national performance measure for
coordination. After reviewing the comments, however, FTA officials that we
interviewed told us that they realized the difficulty of devising national
measures and determined that measuring coordination should be done at the
local level. FTA also clarified that the intent of the crosscutting
measures was to capture a national picture of JARC-funded services, rather
than compare individual communities or service systems. However, FTA
officials reported that they will encourage grantees to develop additional
measures for evaluating whether their programs are meeting their intended
state or local goals. This proposal is supported by our past work, in
which we reported that performance measures should tell each
organizational level how well it is achieving its goals.^48 In addition,
the United We Ride initiative is developing a tool and plans to provide
technical assistance to assist with these efforts in the future.
Program stakeholders expressed mixed opinions about FTA's proposal to use
the NTD to streamline data collection. For example, 5 state and local
agencies that we interviewed were generally positive about FTA's proposal
to use the NTD for JARC reporting, in part because they were familiar with
using this system to collect and report data on other FTA programs.
However, 5 agencies that we interviewed told us that small and rural
agencies may find it difficult to use the NTD for collecting and managing
data. In addition, two agency officials we interviewed reported that NTD
can be cumbersome to use, while two program stakeholders noted in their
docket comments that smaller agencies may need staff training to use the
NTD.
Due in part to the comments received, FTA decided not to use the NTD for
JARC reporting.^49 FTA told us that while the NTD is in place, it is
currently not set up or designed to collect the qualitative measures that
are important for understanding the trends related to human service
transportation. FTA proposed that JARC grantees report their data as an
attachment to their annual report submissions in the Transportation
Electronic Award and Management (TEAM) system, which the agency uses to
manage and track its grants. One FTA official told us that TEAM would be
better suited for collecting JARC data because it can track qualitative
information, and that JARC grantees that receive funding through other FTA
programs would be familiar with how to collect and report data using TEAM.
Finally, state and local officials that we interviewed also expressed
ongoing concerns about the lack of feedback on their JARC performance
after they report data to FTA, which may limit their ability to manage
program performance. For example, 19 of the 23 states and large urbanized
areas that had received JARC grants in the past commented that FTA had not
provided them with any feedback on their performance data after it was
submitted. Three state and local officials also told us that they would
like to know how the performance data they report is being used by FTA.
Meanwhile, two state transportation officials and two local officials said
that receiving feedback from FTA would be helpful to know how they are
performing and to make improvements or corrections. Previous reports by
GAO and others^50 have found that providing frequent and effective
feedback on performance information can enhance its use for decision
making.^51 According to FTA, the JARC data collected to date have not been
intended to be used to evaluate individual projects, but rather were
geared toward assessing how the program was achieving goals nationally, as
required by GPRA and the Office of Management and Budget. However, during
a recent interview with FTA officials, they said that they would be more
explicit with grantees about how they are using JARC performance data, and
that they are open to exploring the possibility of posting this
information on the FTA Web site in the future.
Gaps in Monitoring May Limit FTA's Ability to Evaluate and Oversee the
JARC Program
Even if FTA resolves its performance measurement and reporting issues,
gaps in its plan for monitoring JARC recipients may continue to limit
FTA's ability to evaluate and oversee the program. While FTA has proposed
using existing oversight processes to monitor JARC recipients, these
oversight processes do not explicitly include provisions for oversight of
the JARC program. Furthermore, FTA's proposed process for oversight of
agencies that do not fall under existing processes could lead to
inconsistent oversight of JARC recipients.
FTA does not have a complete plan for oversight of the JARC program.
Monitoring of policies and procedures to ensure proper stewardship of
government resources is an important aspect of internal control. FTA is
responsible for ensuring that grantees follow federal mandates along with
statutory and administrative requirements. In its March interim guidance
and proposed strategies, FTA stated that it would monitor implementation
of JARC and other programs using pre- and post-award review processes used
for grant applications and grant management, including
self-certifications, progress reports, and site visits. FTA's proposed
final guidance states that FTA will also use existing oversight processes
for other FTA programs to conduct JARC oversight. These processes are as
follows:
oState Management Reviews: These reviews assess states' implementation and
management of the Elderly Individuals and Individuals with Disabilities
program (Section 5310) and the Nonurbanized Area Formula program (Section
5311).
oTriennial Reviews: These reviews assess grantees receiving Urbanized Area
Formula program (Section 5307) grants. These grantees are primarily
transit agencies and some metropolitan planning organizations.
FTA has proposed using these processes--which FTA uses for oversight of
programs that award funding to states, transit agencies, and metropolitan
planning organizations--to oversee the JARC program because they should
cover most JARC designated recipients. FTA's proposed final guidance also
notes that JARC designated recipients that are not a state or a Section
5307 recipient may be subjected to periodic spot reviews of their
administration of the program. However, two issues with FTA's monitoring
proposal may result in gaps in its oversight of the JARC program.
First, the use of periodic spot reviews of designated recipients that are
not states or Section 5307 recipients may result in inconsistent
monitoring of JARC recipients. For example, while some metropolitan
planning organizations that serve as JARC designated recipients also
receive Section 5307 funding and will be subject to FTA oversight through
its triennial review process, other metropolitan planning organizations
serving as JARC designated recipients do not receive Section 5307 funding,
and will be subject to FTA oversight through its proposed periodic spot
reviews. It is not clear from FTA's proposed final guidance if these
periodic reviews will be more or less frequent than the 3-year cycle of
FTA's triennial reviews and state management reviews. As a result, JARC
designated recipients may be held to different oversight standards on the
basis of what other types of FTA funding they receive.
Second, FTA's existing oversight processes currently do not include
provisions for JARC program oversight. For example, FTA's State Management
Review guidance, which contains information on the Section 5311 program
and the Elderly Individuals and Individuals with Disabilities program,
does not include JARC program requirements and information, such as the
requirement to distribute funds on a fair and equitable basis. We
previously noted that this requirement would be important for recipients
to adhere to in order to address potential conflict-of-interest concerns.
While FTA officials said that they have begun to work to incorporate JARC
into their existing oversight processes, they noted that SAFETEA-LU
omitted JARC from the list of programs for which FTA may specifically use
appropriated funds to obtain contractual support for project management
oversight and review of major capital projects.^52 They are presently
researching other sources of funding--such as the agency's general
administrative funding--that can be used to ask detailed programmatic
questions of JARC recipients and to conduct site visits and project
reviews. FTA officials also said that they currently do not know how much
of a problem this will pose, because they do not yet know which entities
will be the designated recipients for most of the areas receiving JARC
funds. As a result, they are uncertain of how many JARC designated
recipients will already be covered by existing oversight processes because
they receive funds for other FTA programs, such as Section 5307. Given
this issue, FTA officials said that they were still determining the
frequency and level of JARC oversight that could be supported with their
current resources. Until it develops a complete plan for implementing and
funding JARC oversight, FTA's key oversight processes will not provide
assurance that recipients are meeting program requirements.
Conclusions
FTA has made progress in implementing changes to the JARC program,
gathering extensive public input to develop program guidance for states
and large urbanized areas. However, FTA lacks an important element of
program accountability and performance measurement for the JARC program,
specifically related to monitoring. FTA officials have proposed to use the
agency's oversight mechanisms for other FTA programs for JARC monitoring,
but acknowledged that they have not finalized how this will work. Without
the inclusion of JARC program requirements--such as the fair and equitable
distribution of funding--in these existing oversight processes, FTA will
have limited assurances that JARC recipients are administering the program
in accordance with FTA's requirements and are meeting program objectives.
In addition, FTA has proposed an alternative oversight process for
recipients that are not covered by its existing Triennial Reviews and
State Management Reviews, but FTA has not specified how often these
recipients will be subject to its oversight, which may result in
inconsistent or infrequent oversight of JARC recipients.
Recommendations for Executive Action
To establish adequate and consistent oversight processes that will enable
FTA to evaluate and oversee JARC projects and determine whether they are
meeting JARC program goals, we recommend that the Secretary of
Transportation direct the Administrator, FTA, to take the following two
actions:
oDevelop a plan for including the JARC program in Triennial Reviews and
State Management Reviews, and update monitoring guidance and information
accordingly.
oSpecify in the JARC final guidance how frequently FTA will perform spot
reviews of designated recipients that are not subject to FTA's Triennial
Reviews and State Management Reviews, and make the interval for conducting
spot reviews consistent with the 3-year cycles for Triennial Reviews and
State Management Reviews, or more frequently if FTA determines it
necessary.
Agency Comments and Our Evaluation
We provided a draft of this report to the Department of Transportation for
review and comment. Officials from the department and FTA generally agreed
with the report's findings and said that they would consider the
recommendations as they move forward in implementing the JARC program.
Although FTA officials recognized the need for program oversight and
indicated that they are already taking steps to incorporate the JARC
program into their existing review processes, they reiterated their
concerns that SAFETEA-LU did not provide them with a specific source of
oversight funding for the JARC program. As a result, they are seeking
other sources of funding--such as the agency's general administrative
funds--to carry out this activity. Finally, FTA officials provided
technical clarifications, which we incorporated in the report as
appropriate.
We are sending copies of this report to congressional committees with
responsibility for transit issues; the Secretary of Transportation; the
Administrator, Federal Transit Administration; and the Director, Office of
Management and Budget. We will also make copies available to others upon
request. In addition, the report will be available at no charge on the GAO
Web site at http://www.gao.gov .
If you have any questions regarding this report, please contact me on
(202) 512-2834 or at [email protected] . Contact points for our
Offices of Congressional Relations and Public Affairs may be found on the
last page of this report. GAO staff who made major contributions to this
report are listed in appendix IV.
Katherine Siggerud
Director, Physical Infrastructure Issues
Appendix I
Objectives, Scope, and Methodology
This report addresses the following four objectives: (1) changes that were
made to the Job Access and Reverse Commute (JARC) program as a result of
the Safe, Accountable, Flexible, Efficient Transportation Equity Act - A
Legacy for Users (SAFETEA-LU); (2) progress that the Federal Transit
Administration (FTA) has made in implementing these changes; (3) the
extent to which states and large urbanized areas have implemented changes
to the JARC program, and challenges they have encountered; and (4) whether
FTA's proposed strategy for evaluating and overseeing the JARC program
will allow the agency to assess the extent to which the program is meeting
its stated goals.
To identify the changes that SAFETEA-LU made to the JARC program, we
reviewed the provisions of SAFETEA-LU and of its predecessor, the
Transportation Equity Act for the 21st Century (TEA-21), dealing with the
JARC program. We also reviewed previous GAO reports on JARC and
interviewed officials from FTA's headquarters and one regional office. To
summarize financial information for JARC for fiscal years 1999 through
2009, we gathered and analyzed data from FTA's Web site and agency
officials on dollar amounts authorized, appropriated, rescinded,
obligated, and unobligated. To assess the reliability of these data, we
interviewed FTA officials about FTA's policies and procedures for data
collection and verification. Specifically, we asked them whether their
policies and procedures had changed significantly since we reviewed them
for our 2004 report on JARC.^1 FTA officials told us that there were no
significant changes in their data collection and verification procedures
for JARC information. We also compared these data with data published in
the Federal Register and data on FTA's Web site for obvious errors in
completeness and accuracy. Therefore, we determined that the FTA
information presented was sufficiently reliable for the purposes of this
report.
To describe the progress FTA has made in implementing changes to JARC, we
interviewed FTA officials and officials from industry associations,
including the American Association of State Highway and Transportation
Officials, the American Public Transportation Association, the Association
of Metropolitan Planning Organizations, the Community Transportation
Association of America, and the National Association of Regional Councils,
to obtain their views on FTA's progress in implementing the program
changes. We also reviewed FTA's JARC interim program guidance for fiscal
year 2006 and proposed strategies for fiscal year 2007 (issued in March
2006), and its proposed final guidance for fiscal year 2007 (issued in
September 2006).^2
To describe the extent to which states and large urbanized areas have
implemented changes to the JARC program and any challenges they have
encountered in doing so, we obtained data from FTA officials on the number
of states and large urbanized areas that had officially designated a
recipient for JARC funds, selected projects and applied for funding, and
obligated funds.
To determine whether FTA's proposed strategy for evaluating and overseeing
the JARC program will allow the agency to assess whether the program is
meeting its stated goals, we interviewed FTA officials about their
performance measurement and evaluation plans. We reviewed FTA's earlier
JARC program evaluation, Job Access and Reverse Commute Program: Report to
Congress (May 2003). We also reviewed relevant legislation, FTA program
guidance, Office of Management and Budget circulars and guidance on
performance measurement, prior GAO JARC reports, and GAO reports and
guidance on performance measurement and program evaluation. We did not
evaluate FTA's proposed performance measures, because those measures were
too preliminary at the time of our review to allow meaningful comparison
with our criteria for successful performance measures. In addition, FTA
had recently hired a contractor to evaluate the feasibility of collecting
data for one of the proposed measures.
To address the third and fourth objectives, we also designed and conducted
semistructured telephone interviews with officials from 24 of the 209
states and large urbanized areas that were apportioned fiscal year 2006
JARC funds. The interviews were designed to gain state and local
officials' perspectives on a number of topics, including the effect of
changing from a discretionary program to a formula-based program on JARC
services in their area; the process of selecting a designated recipient,
developing a coordinated public transit-human services transportation
plan, and conducting a competitive selection process for JARC projects;
FTA's proposed performance measures and program oversight mechanisms for
JARC; and any challenges they may have encountered in implementing changes
to the JARC program. After conducting the interviews with all 24 states
and large urbanized areas, we used a content analysis to systematically
determine the state and local officials' views on key interview questions
and identify common themes in their responses. Two analysts reached
consensus on the coding of the responses, and a third reviewer was
consulted in case of disagreements, to ensure that the codes were
reliable. The interviews included officials from the departments of
transportation of 12 states and from 8 metropolitan planning organizations
and 9 transportation agencies from 12 large urbanized areas. We conducted
the interviews in June, July, and August 2006.
We selected the 12 states to obtain diversity in a range of criteria, as
follows:
oChange in JARC funding: Analyzed the percentage change and selected 4
states that received an increase in their federal JARC funds from fiscal
years 2005 to 2006, 5 states whose JARC funds decreased from 2005 to 2006,
1 state that received approximately the same amount of funding in fiscal
years 2005 and 2006, and 2 states that did not receive JARC funds in 2005.
oComments: Whether a state department of transportation had submitted
comments to the Department of Transportation's (DOT) online docket on
FTA's interim JARC program guidance for fiscal year 2006 and proposed
strategies for fiscal year 2007.
oStatewide program: Whether a state was identified in FTA's fiscal year
2005 grant apportionment notice as having a statewide JARC program, which
meant that the state likely had previous experience in administering JARC
funds.
oDesignated recipient: Whether a state had notified FTA of its designated
recipient (as of June 2006) for the JARC funds, from which we inferred
that a state had taken some action to implement the JARC program.
oPlanning funds: Whether a state had applied to FTA for 10 percent of its
apportionment for planning/administration/technical assistance, as allowed
by statute, from which we inferred that a state had taken some action to
implement the JARC program.
oRecommendations: Referral by FTA or industry associations.
Table 4 lists the 12 states that we selected on the basis of these
criteria.
Table 4: State Agencies Interviewed for Our Review
State Agency
Alabama Alabama Department of Transportation
Alaska Alaska Department of Transportation and Public Facilities
Arkansas Arkansas State Highway and Transportation Department
California California Department of Transportation
Maryland Maryland Transit Administration
New Mexico New Mexico Department of Transportation
Oklahoma Oklahoma Department of Transportation
Texas Texas Department of Transportation
Virginia Virginia Department of Rail and Public Transportation
Washington Washington State Department of Transportation
West Virginia West Virginia Department of Transportation
Wyoming Wyoming Department of Transportation
Source: GAO.
To obtain the perspectives of small urbanized areas and rural areas that
had previously received JARC grants directly and would now have to apply
to the state designated recipient for funding, we supplemented the state
interviews with interviews with officials from a transportation agency in
Galveston, Texas--a small urbanized area--and from a nonprofit agency in
Stigler, Oklahoma, that provides transportation in rural areas of the
state.
We selected 12 large urbanized areas to obtain diversity in a range of
criteria, as follows:
oPrior receipt of JARC funding: Whether a large urbanized area had
received a JARC grant prior to fiscal year 2006.^3
oReceipt of fiscal year 2006 funding: Whether a large urbanized area had
successfully applied to FTA for its fiscal year 2006 JARC funding (as of
July 2006).
oComments: Whether a metropolitan planning organization or local
transportation agency in a large urbanized area had submitted comments to
the DOT's online docket on FTA's interim JARC program guidance for fiscal
year 2006 and proposed strategies for fiscal year 2007.
oDesignated recipient: Whether a large urbanized area had notified FTA of
its designated recipient (as of July 2006) for the JARC funds, from which
we inferred that the area had taken some action to implement the JARC
program.
oRecommendations: Referral by FTA or industry associations.
oPopulation: Whether a large urbanized area had a population over 1
million.
oMultistate area: Whether the large urbanized area covers multiple states,
which we assumed could present unique issues for an area in implementing
the JARC program.
oLocation: Whether the large urbanized area was in a state that we had
already selected for interviews.
Table 5 lists the 12 large urbanized areas we selected on the basis of
these criteria, and the agencies that we interviewed.
Table 5: Large Urbanized Area Agencies Interviewed for Our Review
Location Agency
Albuquerque, New Mexico Mid-Region Council of Governments
ABQ Ride
Birmingham, Alabama Birmingham Jefferson County Transit
Authority
Denver, Colorado Denver Regional Council of Governments
Denver Regional Transportation District
Fresno, California Fresno Council of Governments
City of Fresno Department of Transportation
Kansas City, Missouri Mid-America Regional Council
Los Angeles, California Los Angeles Metropolitan Transportation
Authority
Lubbock, Texas Citibus
Memphis, Tennessee Memphis Area Transit Authority
Riverside/San Bernardino, Southern California Association of
California Governments
Seattle, Washington Puget Sound Regional Council
Tampa/St. Petersburg, Florida Pinellas County Metropolitan Planning
Organization
Hillsborough Area Regional Transit Authority
Washington, D.C. Metropolitan Washington Council of
Governments
Washington Metropolitan Area Transit
Authority
Source: GAO.
It is important to note that these interviews cannot be generalized to the
entire JARC recipient population because they were selected from a
nonprobability sample.
We supplemented the information obtained from these semistructured
interviews by analyzing the more than 200 public comments submitted to
DOT's online docket regarding FTA's interim program guidance for fiscal
year 2006 and proposed guidance for fiscal year 2007. We used a content
analysis to systematically identify common themes in the comments
submitted. Two analysts reached consensus on the coding of the responses,
and a third reviewer was consulted in case of disagreements, to ensure
that the codes were reliable. In summarizing the comments for appendix
III, we only included comments that were made by more than one entity.
We conducted our work from May through October 2006 in accordance with
generally accepted government auditing standards.
Appendix II
Job Access and Reverse Commute Program Funding
Table 6: Total JARC Apportionments for States and Large Urbanized Areas,
Fiscal Years 2004-2006
Fiscal year
State 2004 2005 2006
Alabama $4,460,669 $6,046,205 $2,391,281
Alaska 1,610,797 1,709,786 207,503
American Samoa 0** 0 82,198
Arizona 1,734,705 0 2,646,131
Arkansas 446,067 0 1,406,220
California 5,515,370 10,010,929 19,573,127
Colorado 0 3,221,339 1,670,641
Connecticut 3,221,594 2,477,954 1,126,113
Delaware 743,445 743,386 263,929
District of Columbia 1,982,520 3,716,930 379,168
Florida 3,469,409 594,708 8,292,479
Georgia 991,260 2,180,598 3,726,294
Guam 0 0 82,308
Hawaii 0 0 456,441
Idaho 0 0 629,153
Illinois 817,789 1,120,034 5,042,471
Indiana 743,445 1,377,741 2,303,911
Iowa 991,260 1,982,362 1,034,427
Kansas 2,914,304 1,387,653 927,663
Kentucky 297,378 1,139,859 1,844,076
Louisiana 0 2,477,954 2,888,701
Maine 489,682 1,486,772 505,003
Maryland 5,253,677 2,676,190 1,774,151
Massachusetts 674,056 991,182 2,325,356
Michigan 3,667,662 4,162,961 3,979,218
Minnesota 495,630 3,147,001 1,414,253
Mississippi 0 0 1,457,627
Missouri 4,460,669 6,393,119 2,233,393
Montana 0 0 456,288
Nebraska 0 0 561,622
Nevada 495,630 1,982,362 857,434
New Hampshire 0 0 352,447
New Jersey 5,005,862 5,203,702 2,838,709
New Mexico 594,756 2,527,513 1,094,686
New York 8,846,994 1,833,685 9,760,182
North Carolina 0 0 3,355,608
North Dakota 0 198,236 291,404
Northern Mariana Islands 0 0 125,962
Ohio 2,081,646 2,131,039 4,425,095
Oklahoma 5,947,550 7,929,461 1,625,985
Oregon 1,090,386 2,676,189 1,467,897
Pennsylvania 8,072,819 14,553,514 5,022,975
Puerto Rico 0 0 6,632,323
Rhode Island 1,399,659 1,635,449 466,849
South Carolina 0 0 1,872,308
South Dakota 247,815 0 312,746
Tennessee 7,112,288 7,681,654 2,670,486
Texas 5,457,846 2,329,275 12,423,907
Utah 0 0 890,393
Vermont 247,815 991,182 186,885
Virgin Islands 0 0 82,637
Virginia 1,645,492 84,249 2,553,291
Washington 4,708,484 4,782,450 2,479,628
West Virginia 991,260 991,182 1,059,097
Wisconsin 2,577,275 3,855,696 1,887,559
Wyoming 0 0 202,360
Community Transportation 2,478,149 3,270,899 0
Association of America's national
Joblinks program
Technical assistance support and 298,230 297,600 0
performance reviews of the JARC
grants program (DC)
Total $104,380,500 $124,000,000 $136,620,000
Source: FTA.
Table 7: Job Access and Reverse Commute Apportionments for Fiscal Year
2006
Urbanized area/state Apportionment
200,000 or more in population (large urbanized areas) $81,972,000
50,000-199,999 in population (small urbanized areas) 27,324,000
Nonurbanized areas 27,324,000
National Total $136,620,000
Source: FTA.
Table 8: Amounts Apportioned to Large Urbanized Areas 200,000 or More in
Population
Urbanized area/state Apportionment
Aguadilla--Isabela--San Sebastian, PR $530,843
Akron, OH 248,837
Albany, NY 230,802
Albuquerque, NM 326,277
Allentown--Bethlehem, PA--NJ 216,401
Anchorage, AK 83,959
Ann Arbor, MI 121,240
Antioch, CA 84,732
Asheville, NC 114,045
Atlanta, GA 1,343,016
Atlantic City, NJ 97,112
Augusta-Richmond County, GA--SC 191,466
Austin, TX 406,084
Bakersfield, CA 318,265
Baltimore, MD 871,013
Barnstable Town, MA 75,115
Baton Rouge, LA 294,683
Birmingham, AL 356,107
Boise City, ID 97,255
Bonita Springs--Naples, FL 73,314
Boston, MA--NH--RI 1,373,901
Bridgeport--Stamford, CT--NY 260,506
Buffalo, NY 484,616
Canton, OH 112,893
Cape Coral, FL 147,513
Charleston--North Charleston, SC 219,710
Charlotte, NC--SC 277,956
Chattanooga, TN--GA 168,882
Chicago, IL--IN 3,537,943
Cincinnati, OH--KY--IN 579,180
Cleveland, OH 777,417
Colorado Springs, CO 169,456
Columbia, SC 191,671
Columbus, GA--AL 149,168
Columbus, OH 487,856
Concord, CA 100,625
Corpus Christi, TX 200,511
Dallas--Fort Worth--Arlington, TX 1,987,478
Davenport, IA--IL 125,901
Dayton, OH 303,522
Daytona Beach--Port Orange, FL 136,539
Denton--Lewisville, TX 83,301
Denver--Aurora, CO 698,475
Des Moines, IA 127,421
Detroit, MI 1,684,895
Durham, NC 152,453
El Paso, TX--NM 640,747
Eugene, OR 133,005
Evansville, IN--KY 99,338
Fayetteville, NC 152,079
Flint, MI 207,202
Fort Collins, CO 85,767
Fort Wayne, IN 120,203
Fresno, CA 479,768
Grand Rapids, MI 207,260
Greensboro, NC 115,730
Greenville, SC 154,803
Gulfport--Biloxi, MS 116,718
Harrisburg, PA 118,352
Hartford, CT 314,651
Honolulu, HI 296,056
Houston, TX 2,225,913
Huntsville, AL 91,103
Indianapolis, IN 462,916
Indio--Cathedral City--Palm Springs, CA 167,671
Jackson, MS 188,181
Jacksonville, FL 395,633
Kansas City, MO--KS 520,534
Knoxville, TN 210,450
Lancaster, PA 109,172
Lancaster--Palmdale, CA 163,748
Lansing, MI 150,738
Las Vegas, NV 611,063
Lexington-Fayette, KY 125,080
Lincoln, NE 93,940
Little Rock, AR 193,589
Los Angeles--Long Beach--Santa Ana, CA 8,008,861
Louisville, KY--IN 402,958
Lubbock, TX 143,142
Madison, WI 141,053
McAllen, TX 667,460
Memphis, TN--MS--AR 582,443
Miami, FL 2,798,658
Milwaukee, WI 586,353
Minneapolis--St. Paul, MN 713,835
Mission Viejo, CA 110,760
Mobile, AL 230,386
Modesto, CA 206,464
Nashville-Davidson, TN 333,424
New Haven, CT 200,291
New Orleans, LA 747,095
New York--Newark, NY--NJ--CT 9,052,591
Ogden--Layton, UT 140,657
Oklahoma City, OK 425,034
Omaha, NE--IA 258,026
Orlando, FL 549,368
Oxnard, CA 186,082
Palm Bay--Melbourne, FL 162,591
Pensacola, FL--AL 178,078
Peoria, IL 118,652
Philadelphia, PA--NJ--DE--MD 2,177,282
Phoenix--Mesa, AZ 1,437,345
Pittsburgh, PA 755,115
Port St. Lucie, FL 134,102
Portland, OR--WA 651,875
Poughkeepsie--Newburgh, NY 138,244
Providence, RI--MA 550,347
Provo--Orem, UT 165,680
Raleigh, NC 167,695
Reading, PA 108,520
Reno, NV 135,396
Richmond, VA 325,063
Riverside--San Bernardino, CA 1,025,531
Rochester, NY 302,343
Rockford, IL 111,425
Round Lake Beach--McHenry--Grayslake, IL--WI 46,165
Sacramento, CA 735,658
Salem, OR 204,737
Salt Lake City, UT 323,584
San Antonio, TX 860,804
San Diego, CA 1,401,052
San Francisco--Oakland, CA 1,250,507
San Jose, CA 461,635
San Juan, PR 3,175,710
Santa Rosa, CA 105,190
Sarasota--Bradenton, FL 224,190
Savannah, GA 134,548
Scranton, PA 192,821
Seattle, WA 961,747
Shreveport, LA 199,860
South Bend, IN--MI 122,001
Spokane, WA--ID 178,704
Springfield, MA--CT 276,090
Springfield, MO 118,633
St. Louis, MO--IL 853,416
Stockton, CA 263,196
Syracuse, NY 204,341
Tallahassee, FL 132,584
Tampa--St. Petersburg, FL 978,029
Temecula--Murrieta, CA 87,126
Thousand Oaks, CA 47,093
Toledo, OH--MI 252,191
Trenton, NJ 99,038
Tucson, AZ 441,408
Tulsa, OK 285,281
Victorville--Hesperia--Apple Valley, CA 130,784
Virginia Beach, VA 617,451
Washington, DC--VA--MD 1,192,035
Wichita, KS 181,906
Winston-Salem, NC 132,231
Worcester, MA--CT 179,318
Youngstown, OH--PA 218,946
Total $81,972,000
Source: FTA.
Table 9: Amounts Apportioned to State Governors for Small Urbanized Areas
50,000 to 199,999 in Population
State Apportionment
Alabama $764,603
Alaska 34,455
Arizona 275,606
Arkansas 491,466
California 2,846,331
Colorado 458,275
Connecticut 279,431
Delaware 47,028
Florida 1,592,836
Georgia 872,603
Hawaii 51,652
Idaho 295,735
Illinois 628,307
Indiana 672,488
Iowa 404,283
Kansas 184,930
Kentucky 251,401
Louisiana 793,743
Maine 241,388
Maryland 300,190
Massachusetts 256,565
Michigan 851,344
Minnesota 231,017
Mississippi 142,431
Missouri 284,808
Montana 218,262
Nebraska 14,563
Nevada 37,708
New Hampshire 218,838
New Jersey 140,132
New Mexico 270,568
New York 513,343
North Carolina 871,922
North Dakota 165,554
Northern Mariana Islands 79,198
Ohio 640,802
Oklahoma 173,538
Oregon 221,712
Pennsylvania 839,555
Puerto Rico 2,571,505
South Carolina 490,363
South Dakota 123,942
Tennessee 569,892
Texas 3,065,349
Utah 126,160
Vermont 65,427
Virginia 582,583
Washington 758,209
West Virginia 519,275
Wisconsin 695,169
Wyoming 97,515
Total $27,324,000
Source: FTA.
Table 10: Amounts Apportioned to State Governors for Nonurbanized Areas
Fewer Than 50,000 in Population
State Apportionment
Alabama $914,681
Alaska 89,089
American Samoa 82,198
Arizona 491,772
Arkansas 689,681
California 1,392,047
Colorado 258,668
Connecticut 66,653
Delaware 60,739
Florida 789,522
Georgia 1,083,301
Guam 82,309
Hawaii 108,733
Idaho 236,073
Illinois 615,969
Indiana 547,252
Iowa 393,228
Kansas 391,699
Kentucky 996,767
Louisiana 853,320
Maine 263,615
Maryland 170,073
Massachusetts 106,263
Michigan 733,405
Minnesota 469,403
Mississippi 988,678
Missouri 804,275
Montana 238,026
Nebraska 244,224
Nevada 73,267
New Hampshire 114,174
New Jersey 90,750
New Mexico 460,625
New York 876,414
North Carolina 1,377,832
North Dakota 125,851
Northern Mariana Islands 46,764
Ohio 937,886
Oklahoma 742,132
Oregon 375,739
Pennsylvania 996,074
Puerto Rico 354,265
Rhode Island 15,592
South Carolina 763,722
South Dakota 188,804
Tennessee 890,321
Texas 2,180,328
Utah 134,311
Vermont 121,458
Virgin Islands 82,637
Virginia 640,772
Washington 461,887
West Virginia 539,821
Wisconsin 466,065
Wyoming 104,846
Total $27,324,000
Source: FTA.
Appendix III
Summary of Stakeholder Comments on FTA's Interim Guidance and Proposed
Strategies for Job Access and Reverse Commute Program
In its March 15, 2006, interim guidance and proposed strategies, FTA
proposed several changes that would affect the operation of the JARC
program. FTA allowed for a 30-day comment period, and after a request for
an extension, the agency allowed approximately 1 month for comments. FTA
received over 200 comments, and program stakeholders that commented
included the following: state transportation agencies, trade associations,
metropolitan planning organizations, public transit providers, private
transit providers, individuals, and advocates. Table 11 summarizes FTA's
proposed changes to the coordinated planning process, the designated
recipient and competitive selection process, and the performance
measurement and reporting requirements.
Table 11: Changes to the JARC Program Proposed in FTA's March 2006 Interim
Guidance and Proposed Strategies and Program Stakeholder Responses
Proposed change Comments submitted by JARC
program stakeholders and number
of similar comments
Coordinated plan
Elements: FTA identified five key oAgree that local communities
elements of a coordinated plan: (1) an should have flexibility in
assessment of transportation needs for developing the coordinated plan
individuals with disabilities, older (12)
adults, and persons with limited incomes;
(2) an inventory of available services oAgree with the key elements of
that identifies areas of redundant the coordinated plan (9)
service and gaps in service; (3)
strategies to address the identified gaps oSuggest that minimization of
in service; (4) identification of duplication of services should
coordination actions to eliminate or be a key element (10)
reduce duplication in services and
strategies for more efficient utilization oSuggest that an evaluation plan
of resources; and (5) prioritization of should be another key element
implementation strategies. FTA proposed (2)
that choosing a lead agency be a local
decision and defining "local" is a oIt is unrealistic to expect
decision to be made at the state, that coordinated plans will be
regional, and local levels. completed by the fiscal year
2007 funding cycle (7)
oSatisfying FTA's requirements
is a time-consuming process for
coordinated plans (2)
oAgencies may not have available
staff resources to develop
coordinated plans (2)
oFTA requirements may cost more
to produce than the available
resources will allow (2)
oAny planning requirements
should be commensurate with the
level of funding provided (3)
oAgree that designation of a
"lead agency" should be a local
decision (2)
oAppreciate the flexibility of
defining "local" (2)
oStates should be involved in
determining the definition of
"local" (2)
Elements - Framework for Action: FTA oFramework for Action is a
suggested states and communities utilize useful and helpful tool (3)
the United We Ride Framework for Action
when developing a coordinated plan. oConcern that local coordinating
entities may be at a
disadvantage if they do not use
the Framework for Action tool
(2)
oThe guidance should continue to
indicate use of the Framework
for Action tool as a suggestion,
not a requirement (2)
Participation: FTA provided examples of oSupport local communities
groups and organizations that may be having flexibility to coordinate
included in the planning process, participation (3)
recognizing that this proposed list would
not limit or require participation. FTA oSuggest other federal agencies
also suggested allowing many ways to should require their grantees to
participate and making good-faith efforts fully participate in the
for inclusion as well as documenting the coordinated planning effort (5)
efforts. FTA also proposed that it would
coordinate with other federal agencies to oEncourage FTA to work with its
facilitate other funding sources. partners on the Federal
Interagency Coordinating Council
(5)
oFTA should make it clear that
private operators must be
represented (14)
oFTA should affirm that the
private sector may participate
in the planning process and also
propose on projects (12)
oAgree that lead agencies should
document their outreach efforts
(3)
oFTA should require rather than
suggest more proactive outreach
(23)
Designated recipient
In urbanized areas with populations fewer oThe designated recipient for
than 200,000 and other than urbanized JARC should be the same as for
areas, FTA proposed that the state be the FTA's other formula programs
designated recipient. In urbanized areas (e.g., Sections 5307, 5310, or
of over 200,000 in population, FTA 5311), and FTA should not create
proposed that a recipient of JARC funds separate designated recipients
must be officially designated through a for JARC (8)
process consistent with the provision in
Section 5307. FTA also proposed that the oHaving a JARC designated
designated recipient for JARC does not recipient separate from the
have to be the same as the designated Section 5307 designated
recipient for Section 5307 funds. recipient is counterproductive
because it will not encourage
coordination and cooperation (3)
oThe JARC designated recipient
should not be the same entity as
the designated recipient for
5307 funds due to potential
conflict of interest (2)
oThe metropolitan planning
organization (MPO) should be the
designated recipient (6)
oThe MPO is ill-equipped to
function as the designated
recipient (2)
oFTA should clarify the roles
and responsibilities of the
designated recipient (6)
Competitive Selection: A recipient oThe competitive selection
charged in administering the JARC process should not be managed by
programs should be designated by the a transportation provider in
chief executive officer of a state, large urbanized areas (2)
responsible local officials, and publicly
owned operators of public transportation. oThere could be a conflict of
To address concerns that a "conflict of interest if a transportation
interest" could exist, FTA recommended provider is the designated
that the designated recipient of funds recipient, so the MPO should
not be a provider of transportation conduct the competitive
services. FTA also proposed that when the selection process (18)
MPO is the designated recipient of these
funds, the MPO be responsible for the oConcerns about a conflict of
competitive selection process. FTA also interest would be ameliorated by
provided a list of potential strategies a transparent competitive
for the competitive selection process. selection process or by the
MPO's oversight (8)
oWhen the designated recipient
is also a provider of
transportation, the designated
recipient should document how it
selected projects and avoided
conflicts of interest, and
should demonstrate that all
projects were given equal
opportunity (23)
oThe competitive selection
process and criteria should be
derived at the local level (7)
Performance measures
To evaluate all three programs, Sections oThe specific definitions
5310, 5316, and 5317, FTA recommended proposed for the performance
three crosscutting performance measures: measures seem to have a tenuous
(1) Efficiency of Operations, (2) Program connection to the goals they are
Effectiveness, and (3) Customer designed to address (2)
Satisfaction. FTA also recommended one
JARC-specific performance measure, oProposing performance measures
Cumulative Number of Jobs Accessed. that are too narrow and
prescriptive will stifle local
ability and creativity (4)
oEstablishing specific
performance measures is
premature (4)
oPerformance measures should be
developed locally to address
local conditions and needs (13)
oCost-effectiveness should be
taken into consideration (16)
oThe proposed strategies for
evaluation and performance
measurement are burdensome,
especially for small operators
and systems (2)
oIt is difficult and sensitive
to identify income and other
personal information among
passengers (3)
oRegarding performance measure
one: It may be more costly to
provide transportation for
difficult-to-serve populations,
especially in small and rural
areas (2)
oThe proposed measures are
sensitive to external factors,
such as local economic
circumstances (2)
oRegarding performance measure
two: The definition of
"communities" is too vague and
difficult to understand (2)
oRegarding performance measure
three: "Customer satisfaction"
is very subjective and
amorphous, and the performance
measure should be more objective
or technical (4)
oFTA should consider
administration costs; funding
should be commensurate with
performance measurement
strategies, such as surveys (3)
Reporting requirements
FTA proposed reporting requirements to oCompliance with burdensome
focus on the minimum data needed to meet reporting requirements could
the requirements of various performance easily cost more than the grant
initiatives set forth by Congress and the amounts in many communities (2)
Office of Management and Budget, such as
the Government Performance and Results oSuggest grantees should only
Act of 1993. FTA also proposed building report simplified or basic
on existing infrastructure and data information (3)
collection mechanisms, including the use
of the National Transit Database. oReporting requirements should
focus on readily available or
existing information mechanisms
(2)
oMany smaller agencies and areas
may need staff training to use
the National Transit Database
(2)
Source: GAO analysis of FTA guidance and public comments posted on FTA's
docket.
Appendix IV
GAO Contact and Staff Acknowledgments
GAO Contact
Katherine Siggerud, (202) 512-2834 or [email protected]
Staff Acknowledgments
Other key contributors to this report were John Finedore (Assistant
Director), Vidhya Ananthakrishnan, Lauren Heft, Foster Kerrison, Jessica
Lucas-Judy, Nancy Lueke, Kimanh Nguyen, and Stan Stenersen.
Related GAO Products
Public Transportation: Preliminary Information on FTA's Implementation of
SAFETEA-LU Changes. GAO-06-910T. Washington, D.C.: June 27, 2006.
Transportation-Disadvantaged Seniors: Efforts to Enhance Senior Mobility
Could Benefit from Additional Guidance and
Information. GAO-04-971. Washington, D.C.: August 30, 2004.
Job Access and Reverse Commute: Program Status and Potential Effects of
Proposed Legislative Changes. GAO-04-934R. Washington, D.C.: August 20,
2004.
Transportation-Disadvantaged Populations: Federal Agencies Are Taking
Steps to Assist States and Local Agencies in Coordinating Transportation
Services. GAO-04-420R. Washington, D.C.: February 24, 2004.
Transportation-Disadvantaged Populations: Some Coordination Efforts Among
Programs Providing Transportation Services, but Obstacles
Persist. GAO-03-697. Washington, D.C.: June 30, 2003.
Welfare Reform: Job Access Program Improves Local Service Coordination,
but Evaluation Should Be Completed. GAO-03-204. Washington, D.C.:
December 6, 2002.
Welfare Reform: DOT Has Made Progress in Implementing the Job Access
Program but Has Not Evaluated the Impact. GAO-02-640T. Washington, D.C.:
April 17, 2002.
Welfare Reform: Competitive Grant Selection Requirement for DOT's Job
Access Program Was Not Followed. GAO-02-213. Washington, D.C.: December
7, 2001.
Welfare Reform: GAO's Recent and Ongoing Work on DOT's Access to Jobs
Program. GAO-01-996R. Washington, D.C.: August 17, 2001.
Welfare Reform: DOT Is Making Progress in Implementing the Job Access
Program. GAO-01-133. Washington, D.C.: December 4, 2000.
Welfare Reform: Implementing DOT's Access to Jobs Program in Its First
Year. GAO/RCED-00-14. Washington, D.C.: November 26, 1999.
(542092)
www.gao.gov/cgi-bin/getrpt?GAO-07-43 .
To view the full product, including the scope
and methodology, click on the link above.
For more information, contact Katherine Siggerud at (202) 512-2834 or
[email protected].
Highlights of [38]GAO-07-43 , a report to congressional committees
November 2006
FEDERAL TRANSIT ADMINISTRATION
Progress Made in Implementing Changes to the Job Access Program, but
Evaluation and Oversight Processes Need Improvement
Begun in 1998, the Job Access and Reverse Commute (JARC) program provides
grants to states and localities for improving the mobility of low-income
persons seeking work. The Federal Transit Administration (FTA) administers
this program. In 2005, the Safe, Accountable, Flexible, Efficient
Transportation Equity Act - A Legacy for Users (SAFETEA-LU) authorized
$727 million for JARC for fiscal years 2005 through 2009, changed how
these funds were to be awarded after fiscal year 2005, and required FTA to
evaluate the program by August 2008.
GAO examined (1) SAFETEA-LU's changes to JARC, (2) FTA's progress in
implementing these changes, (3) states' and localities' efforts to respond
and challenges they have encountered, and
(4) FTA's proposed strategy for evaluation and oversight. GAO's work
included analyzing program guidance as well as interviewing officials from
FTA, industry groups, and more than 30 state and local agencies.
[39]What GAO Recommends
GAO recommends that FTA update its existing oversight processes to include
the JARC program and specify how often it will monitor recipients that are
not subject to its existing oversight processes, to help FTA more
adequately evaluate and oversee the JARC program. FTA agreed to consider
the report's recommendations.
SAFETEA-LU created a formula for distributing JARC funds starting in
fiscal year 2006, substantially altering funding allocations provided
under earlier grants. Funding in some states increased, with 2 states
receiving increases of more than 1,200 percent between fiscal years 2005
and 2006. Funding in other states decreased as much as 80 percent, while
18 other states received funds that had not received them in fiscal year
2005. To receive funds, SAFETEA-LU required that states and localities
designate a recipient agency to administer JARC funds, award grants on a
competitive basis, and certify that projects were derived from a
coordinated public transit-human services transportation plan.
In March 2006, FTA issued interim guidance and proposed strategies for
implementing these new requirements, but delays in issuing final guidance
have reduced the window of opportunity for states and localities to
obligate fiscal year 2006 funding. As required by SAFETEA-LU, FTA
requested public comment on its interim guidance and proposed strategies,
and responding to the more than 200 comments took more time than FTA had
initially planned. FTA has specified in its guidance that states and
localities have until the end of fiscal year 2008 to obligate fiscal year
2006 funds, so their ability to use the funds is not imminently
jeopardized. FTA also encouraged states and localities to implement their
programs on the basis of the interim guidance. However, given that
officials in a number of areas we interviewed planned to wait for final
guidance before moving forward, these areas will have less time available
to obligate fiscal year 2006 funds.
Most states and localities are in the process of trying to meet these new
requirements, and although they have encountered challenges in doing so,
FTA is taking steps to alleviate most of these challenges. As of the end
of fiscal year 2006, about 4 percent of fiscal year 2006 funding
apportioned to states and localities had been obligated. States and
localities have raised a number of questions or concerns about the new
requirements, such as whether an agency serving as the designated
recipient would also be eligible to receive funds. In response, FTA
proposed several actions that localities could take to reduce the
potential conflict of interest in such situations.
FTA is continuing to develop and refine its strategies for evaluation and
oversight of JARC. FTA, which has had difficulty assessing this program in
the past, proposed a new approach, but states and localities found
problems with it. FTA is revising its approach and gathering baseline data
for its required evaluation of the JARC program. Even if FTA resolves the
concerns that have been raised, gaps in monitoring may still limit its
ability to evaluate and oversee the program. FTA plans to use existing
oversight processes for monitoring JARC recipients; however, FTA officials
noted that SAFETEA-LU did not provide specific program management
oversight funds for the JARC program and said that they are looking for
alternate sources of funding.
References
Visible links
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