Welfare Reform: Implementing DOT's Access to Jobs Program (Letter Report,
12/08/98, GAO/RCED-99-36).

Pursuant to a legislative requirement, GAO reviewed the Department of
Transportation's (DOT) efforts to implement the Access to Jobs program,
focusing on DOT's: (1) overall plan to distribute Access to Jobs funds
among grantees in urban and rural areas; (2) criteria to award specific
Access to Jobs grants to states, localities, and other organizations;
(3) efforts to coordinate the Access to Jobs program with other
welfare-to-work programs; and (4) proposals to evaluate the program's
success.

GAO noted that: (1) DOT has decided it will distribute the $75 million
available for the program in fiscal year 1999 to as many people as
possible by setting suggested limits on the amount areas can receive on
the basis of their population levels; (2) under this approach, DOT
intends to provide first-year grants that average $1 million for large
urban areas and $150,000 for rural areas; (3) DOT will use four key
criteria for evaluating grant applications on the basis of their merits;
(4) DOT will assess each grant application and assign points on the
basis of these criteria, as well as bonus program components such as
particularly innovative transportation approaches; (5) whether these
criteria will enable DOT to make sufficient distinctions among the many
applications it expects is unclear; (6) accordingly, DOT may use other
factors; (7) however, DOT may unintentionally suggest that merit-based
are less important than other factors that are not based on merit; (8)
DOT has made efforts to coordinate its Access to Jobs program with other
welfare-to-work programs; (9) DOT established a policy council of
representatives from four other federal agencies and the White House and
it met with local human service organizations; (10) because grantees can
use other federal funds to match the DOT's grants, sustained
coordination between the Department and other federal agencies, as well
as sustained collaboration among local agencies, is critical for
ensuring the effective use of federal welfare-to-work programs; (11) as
part of its evaluation effort DOT will require Access to Jobs grantees
to collect data on four important program outputs: (a) the number of new
and expand transportation services; (b) the number of jobs made
accessible by public transportation to the targeted riders; (c) the
number of people using the new transportation services; and (d) the
level of collaboration achieved; and (12) however, the data alone will
not be sufficient to measure the program's overall success because DOT
has yet to establish goals or benchmarks against which the cumulative
data on new routes, new system users, and newly accessible jobs can be
compared.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-99-36
     TITLE:  Welfare Reform: Implementing DOT's Access to Jobs Program
      DATE:  12/08/98
   SUBJECT:  Workfare
             Public assistance programs
             Interagency relations
             Performance measures
             Transportation legislation
             Grants-in-aid
             Federal grants
             Urban transportation operations
             Program evaluation
             Federal aid for transportation
IDENTIFIER:  DOT Access to Jobs Program
             Aid to Families with Dependent Children Program
             Temporary Assistance for Needy Families Program
             AFDC
             
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Cover
================================================================ COVER


Report to Congressional Committees

December 1998

WELFARE REFORM - IMPLEMENTING
DOT'S ACCESS TO JOBS PROGRAM

GAO/RCED-99-36

Welfare Reform

(348116)


Abbreviations
=============================================================== ABBREV

  DOL - Department of Labor
  DOT - Department of Transportation
  FTA - Federal Transit Administration
  HHS - Department of Health and Human Services
  HUD - Department of Housing and Urban Development
  TANF - Temporary Assistance for Needy Families
  TEA-21 - Transportation Equity Act for the 21st Century

Letter
=============================================================== LETTER


B-280927

December 8, 1998

The Honorable Alfonse M.  D'Amato
Chairman
The Honorable Paul S.  Sarbanes
Ranking Minority Member
Committee on Banking, Housing,
 and Urban Affairs
United States Senate

The Honorable Bud Shuster
Chairman
The Honorable James L.  Oberstar
Ranking Democratic Member
Committee on Transportation
 and Infrastructure
House of Representatives

Welfare reform specialists assert that transportation is an important
element in moving people from welfare to work.  Three-fourths of
welfare recipients live in either central cities or rural areas,
while two-thirds of the new jobs are located in the suburbs.\1 The
effects of this geographic mismatch are compounded by the low rate of
car ownership among welfare recipients.  The Transportation Equity
Act for the 21st Century (TEA-21) brought attention and funding to
the transportation element of welfare reform.  The act authorized a
welfare-to-work program, known as the Access to Jobs and Reverse
Commute (Access to Jobs) program, and authorized up to $750 million
over 5 years to implement it.  The program will provide grants to
local agencies and authorities, nonprofit organizations, and transit
authorities, among others, to improve mobility for employment.  The
Department of Transportation (DOT) has begun to implement the program
by addressing issues associated with the distribution of grant funds,
selection of grantees, coordination of federal agencies' efforts, and
evaluation of the program.  These actions are intended to ensure that
the transportation funds provided by the Access to Jobs program will
be used efficiently and effectively in support of national welfare
reform goals. 

As part of the program's authorization, TEA-21 directed DOT to
evaluate the Access to Jobs program within 2 years of the act's
enactment.  TEA-21 also required us to review the program every 6
months.  This is the first report in response to this requirement. 
This report describes DOT's (1) overall plan to distribute Access to
Jobs funds among grantees in urban and rural areas; (2) criteria to
award specific Access to Jobs grants to states, localities, and other
organizations; (3) efforts to coordinate the Access to Jobs program
with other welfare-to-work programs; and (4) proposals to evaluate
the program's success. 


--------------------
\1 The need for transportation services to move people from welfare
to work is discussed in our report Welfare Reform:  Transportation's
Role in Moving From Welfare to Work (GAO/RCED-98-161, May 29, 1998). 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

Since the Transportation Equity Act for the 21st Century authorized
the Access to Jobs program in June 1998, the Department of
Transportation has made several important decisions about the
program's basic structure and operating procedures, including a
decision about how it will distribute the $75 million available for
the program in fiscal year 1999.  The Department has decided that it
will distribute the funds to as many areas as possible by setting
suggested limits on the amounts areas can receive on the basis of
their population levels.  Under this approach, the Department intends
to provide first-year grants that average $1 million for large urban
areas and $150,000 for rural areas. 

The Department of Transportation will use four key criteria for
evaluating grant applications on the basis of their merits.  These
four weighted criteria are a project's effectiveness, an area's need
for services, the degree of local coordination, and the project's
financial sustainability.  The Department will assess each grant
application and assign points on the basis of these criteria, as well
as bonus points for program components such as particularly
innovative transportation approaches.  Whether these criteria will
enable the Department to make sufficient distinctions among the many
applications it expects to receive is unclear.  Accordingly, the
Department may use other factors, such as geographic distribution, to
make the final grant selections.  While using these factors may
provide the Department with the means to break ties among projects of
comparable merit, it may unintentionally suggest that the merit-based
criteria used to develop and score the applications are less
important than other factors that are not based on merit. 

The Department of Transportation has made important efforts to
coordinate its Access to Jobs program with other welfare-to-work
programs.  It established a policy council with representatives from
four other federal agencies and the White House to develop its
program.  In May 1998, the Secretaries of Transportation, Health and
Human Services, and Labor issued joint guidance explaining how human
service organizations can use federal funds to provide transportation
services for people moving from welfare to work.  The Department
plans to continue working with other federal agencies to help review
applications for Access to Jobs grants.  In addition, the Department
has met with local human service organizations both to obtain their
input on the program's design and to educate them about the
importance of working with local transportation agencies to develop
an integrated planning process for developing Access to Jobs
projects.  Because grantees can use other federal funds to match the
Department's grants, sustained coordination between the Department
and other federal agencies, as well as sustained collaboration among
local agencies, is critical for ensuring the effective use of federal
welfare-to-work funds. 

Department officials acknowledge that welfare-to-work programs must
establish performance measures to evaluate success.  As part of its
evaluation effort, the Department will require Access to Jobs
grantees to collect data on four important program outputs:  (1) the
number of new and expanded transportation services (service
frequency, hours, and miles), (2) the number of jobs made accessible
by public transportation to the targeted riders, (3) the number of
people using the new transportation services, and (4) the level of
collaboration achieved.  These data will provide the Department with
good information for monitoring Access to Jobs projects, and
collecting the data will serve as a step in developing an evaluation
plan.  However, the data alone will not be sufficient to measure the
program's overall performance or success because the Department has
yet to establish goals or benchmarks against which the cumulative
data on new routes, new system users, and newly accessible jobs can
be compared. 


   BACKGROUND
------------------------------------------------------------ Letter :2

The enactment of the Personal Responsibility and Work Opportunity
Reconciliation Act of 1996 (P.L.  104-193) dramatically altered the
nation's system to provide assistance to the poor.  Among many
changes, title I of the act replaced the existing entitlement program
for poor families (Aid to Families With Dependent Children) with
fixed block grants to the states to provide Temporary Assistance for
Needy Families (TANF).  TANF provides about $16.5 billion annually
for the states to use in helping families become self-sufficient. 
TANF imposes work requirements for adults and establishes time limits
on the receipt of federal assistance.  In addition, other federal
programs are designed to help individuals move from welfare to work. 
For example, the Department of Labor (DOL) has a 2-year, $3 billion
grant program, the Welfare-to-Work program, to help people with poor
work histories, little or no education, or substance abuse problems
obtain jobs. 

Transportation and welfare studies show that without adequate
transportation, welfare recipients face significant barriers in
trying to move from welfare to work.  Existing public transportation
systems cannot always bridge the gap between where the poor live and
where jobs are located.  These existing systems were originally
established to transport inner-city residents to city locations and
bring suburban residents to central-city work locations.  However,
many of the entry-level jobs that welfare recipients and low-income
individuals would likely fill are located in suburbs that have
limited or no access to existing public transportation systems. 
Furthermore, many entry-level jobs require shift work in the evenings
or on weekends, when public transit services are either unavailable
or limited.\2

With the enactment of TEA-21, which established the Access to Jobs
and Reverse Commute program, DOT became an important sponsor of
welfare-to-work initiatives.\3 In general, this program will provide
grants to local agencies and authorities, nonprofit organizations,
and transit authorities, among others, to improve mobility for
low-income individuals seeking employment.  TEA-21 authorized up to
$750 million from fiscal year 1999 through fiscal year 2003 for the
Access to Jobs program.  Some of the funds are "guaranteed," that is,
subject to a procedural mechanism designed to ensure that minimum
amounts of funding are provided each year.  The amount of funds
subject to the "guarantee" increases each year so that by fiscal year
2003, the authorized funds are all "guaranteed." The Department of
Transportation and Related Agencies Appropriations Act for fiscal
year 1999 provided $75 million for the program rather than the $50
million subject to the "guarantee" and the maximum $150 million
authorized.  TEA-21 limits funding to 50 percent of each grantee's
project.  The remaining 50 percent can be obtained from a variety of
sources, including some welfare programs administered by other
federal agencies. 

Since TEA-21 established the Access to Jobs program in June 1998, DOT
has begun establishing the program's basic structure and operating
procedures.\4 In May 1998, DOT established a task force of DOT
officials to address several issues needing resolution before the
program's implementation.  The task force was divided into four
working groups focusing on the (1) distribution of funds, (2)
criteria for selecting grantees and administrative requirements, (3)
coordination among federal agencies and public outreach, and (4)
program's evaluation.  Each working group was assigned several
subsidiary issues.  For example, the group working on the
distribution of funds was tasked with determining the size of the
program's grants.  On October 22, 1998, DOT officially released
guidance detailing how potential grant applicants can request Access
to Jobs funds.  According to the guidance, grant applications are to
be submitted by December 31, 1998.  DOT plans to evaluate the
applications and notify the successful applicants in February 1999. 


--------------------
\2 According to DOT and DOL officials, DOT's Access to Jobs and DOL's
Welfare-to-Work funds cannot be used to help individuals purchase
cars. 

\3 TEA-21 provides that DOT shall use not more than $10 million of
the funds available each year for reverse commute projects.  TEA-21
defines reverse commute projects as those related to the development
of transportation services designed to transport residents of urban
areas, urbanized areas, and areas other than urbanized areas to
suburban employment opportunities. 

\4 The Federal Transit Administration is responsible for managing the
program. 


   DOT PLANS TO MAXIMIZE THE
   NUMBER OF GRANTS AWARDED
------------------------------------------------------------ Letter :3

Although TEA-21 established a framework for allocating Access to Jobs
funds to applicants, it gave DOT the discretion to decide how best to
distribute the funds each year.  Since the program began in June
1998, the Department has made preliminary decisions to maximize the
number of first-year grants by setting suggested limits on the amount
of grants available to areas with different population levels, such
as areas with over 1 million people. 

TEA-21 requires DOT to allocate the available funding between urban
and rural areas.  Specifically, the act requires DOT to allocate 60
percent of the program's funds each year to projects in urban areas
with populations of at least 200,000; 20 percent of the program's
funds to projects in urban areas with populations of less than
200,000; and 20 percent of the program's funds to projects in areas
other than urban.  In addition, the conference report on the
Department of Transportation and Related Agencies Appropriations Act
for fiscal year 1999 directed DOT to give high priority to rural
counties that are not served or are underserved by public
transportation. 

The Department of Transportation and Related Agencies Appropriations
Act for fiscal year 1999 provided DOT with $75 million for its Access
to Jobs program.  To maximize the number of grants awarded, DOT is
asking areas with specified populations to apply for grants limited
to specified funding targets.  DOT suggests that urban areas with
populations of over 1 million should generally limit their requests
to about $1 million, while rural areas with populations of less than
50,000 should request about $150,000.  DOT also suggests average
grant sizes for areas with populations ranging from 1 million to
200,000 and from 200,000 to 50,000.  According to information from
DOT, these recommended grant amounts would permit the Access to Jobs
program to award grants to about 74 percent of the largest
metropolitan areas in the country (about 25 locations), about 38
percent of the areas with populations from 200,000 to 1 million
(about 35 locations), about 21 percent of the areas with populations
from 50,000 to 200,000 (about 60 locations), and about 3 percent of
small rural areas (about 99 locations). 

According to DOT officials, this approach for distributing the
program's funding may discourage the legislative designation, or
earmarking, of funds for specific projects, as is done for some other
DOT programs, such as the Federal Transit Administration's (FTA) New
Starts program for fixed guideway systems.\5 In addition, DOT
officials noted that an average of $150,000 for each rural applicant
is in line with the potential need of these areas.  For example, the
Community Transportation Association of America, a nonprofit
organization, told DOT that Access to Jobs grants of $150,000 would
be adequate for many smaller rural areas.  Finally, a group of rural
counties in southern Illinois told DOT that $127,000 would be
adequate to extend bus service on all their existing lines on
evenings and weekends, thereby greatly benefiting welfare-to-work
programs in the area. 

Grants of $1 million for large urban areas are smaller than those
awarded by other federal agencies, such as DOL.\6 For example, three
Chicago-area grantees received DOL grants totaling almost $11
million, including a $3 million grant focusing on welfare-to-work
transit services.  Under DOT's suggested funding levels, the Chicago
area may receive only $1 million in Access to Jobs funds.  But if an
Access to Jobs grant is combined with other welfare reform funding
for projects supporting transportation, the combined funding may help
to address welfare-to-work transportation needs in urban areas.  For
example, the Chicago area has received federal grants that support
transportation for welfare recipients and low-income individuals from
both DOL's $3 million competitive Welfare-to-Work grant program and
the Department of Housing and Urban Development's (HUD) Bridges to
Work program.\7

Finally, DOT's guidance acknowledges that some potential grantees may
have developed plans for job access activities whose implementation
costs exceed the grant sizes suggested for fiscal year 1999.  Such
grantees may choose to fund their high-priority activities in the
first year and use subsequent grants to fund additional elements of
their plans.  Applicants may also elect to use their grants for
fiscal year 1999 to cover the initial costs of job access activities
and use subsequent grants for carry-on activities.  According to
DOT's guidance, a multiyear approach will be subject to an annual
review of the grantee's progress as well as the annual budget and
appropriations process, among other things.  According to DOT
officials, potential grantees have expressed an interest in a
multiyear approach because they need several years to fully develop,
implement, and see results from their welfare-to-work projects.  For
example, several years may be needed to incorporate new transit
service into communities' existing transportation systems. 


--------------------
\5 This program provides funding for capital projects for new fixed
guideway systems and extensions to existing fixed guideway systems. 

\6 The Balanced Budget Act of 1997 established a 2-year, $3 billion
grant program, the Welfare-to-Work program, administered by DOL. 
Among other things, the program provides funding for job placement,
on-the-job training, and support services (including transportation)
for those who face significant barriers, such as substance abuse, in
moving from welfare to work.  About 25 percent of the funds are
available for competitive grants. 

\7 HUD's Bridges to Work program provided about $1.6 million for
Chicago's Bridges to Work project.  This $17 million program, which
provides job placement and other support services in addition to
transportation, is designed to place about 3,000 participants in jobs
in five cities--Baltimore, Chicago, Denver, Milwaukee, and St. 
Louis. 


   DOT PROPOSES FOUR KEY CRITERIA
   FOR AWARDING GRANTS
------------------------------------------------------------ Letter :4

TEA-21 specifies several factors that the Secretary must consider
when evaluating applications for Access to Jobs grants and making
final selections.  In implementing TEA-21, DOT has synthesized these
factors into four essential elements that an application must
address:  a project's effectiveness, an area's need for services, the
degree of local coordination, and the project's financial
sustainability.  In addition, DOT will give bonus points for other
program elements, such as innovation.  While the Department announced
final guidance on the selection process in October 1998, it is not
clear whether these criteria will allow DOT to differentiate
sufficiently among the many applications it may receive.  DOT's
guidance indicates that in addition to the specified weighted
criteria, the Department may consider other factors, such as the
geographic distribution of grantees, in awarding the grants.  The
weighted, merit-based factors may be sufficient to rank projects
according to their relative merits; however, if the additional
factors are needed, their use may imply that the merit-based criteria
are less important than other factors, such as a project's location,
that are not based on merit. 

TEA-21 requires the Secretary to conduct a national solicitation for
grant applications and competitively select grant recipients.  For
areas with populations of at least 200,000, each area's metropolitan
planning organization will screen the applications.  States will
perform the same function for areas with populations of less than
200,000.  TEA-21 specified eight factors for the Secretary of
Transportation to consider when awarding Access to Jobs grants. 
These factors are the percentage of welfare recipients in the
population of the area to be served; the need for transportation
services; the extent of coordination with, and the financial
commitment of, existing transportation service providers and the
state welfare agency; the extent of coordination with the community
to be served; the use of existing transportation services; the use of
innovative approaches; the existence of regional transportation
plans; and the existence of long-term financing strategies. 

After internal and external discussions, DOT arrived at four
"essential" criteria for evaluating and scoring applications:  (1) a
project's effectiveness, (2) an area's need for services, (3) the
degree of local coordination, and (4) the project's financial
sustainability.  Table 1 shows the weight DOT has assigned to each
criterion.  In applying the criterion for the project's
effectiveness, DOT officials will attempt to ensure that the approach
described in the grant application addresses the transportation
problem the grant is trying to alleviate.  Similarly, the criterion
for need, measured by things such as the number of low-income
individuals to be helped and the types of transportation services to
be added, is intended to ensure that the application identifies the
need for a DOT grant. 

DOT also believes that its criterion on local coordination will help
providers of transportation and human services understand the
importance of local coordination to a project's success.  DOT
officials noted that it may still be difficult to determine if there
is "real," or merely perfunctory, coordination among these groups. 
DOT also included a criterion to evaluate an applicant's ability to
obtain sustained funding for a project after the grant funds have
been expended.  Finally, DOT will give bonus points for applications
that use, among other things, innovative approaches, links to
employment support services, and employer-based strategies (such as
employer-run shuttles).  According to DOT officials, because DOT will
give bonus points to projects that address how their proposed
transportation services will be supported by employment and human
services, these points will encourage local coordination. 



                                Table 1
                
                    DOT's Grant Evaluation Criteria

Criterion                                                       Weight
----------------------------------------  ----------------------------
Project's effectiveness                                             35
Need for services                                                   30
Local coordination                                                  25
Sustainability                                                      10
Subtotal                                                           100
Bonus points                                                        10
Total                                                              110
----------------------------------------------------------------------
Source:  DOT. 

DOT officials developed these criteria by combining legislative
criteria and adding other specific components.  For example, DOT
combined the two legislative criteria for coordination with the one
criterion for regional plans to develop one criterion for a
coordinated human services/transportation planning process and plan. 
DOT also added a criterion for employers' involvement.  Finally, DOT
added weights to the revised list of criteria and discussed this list
with leaders of other federal agencies, including the Department of
Health and Human Services (HHS) and DOL.  After their discussions,
DOT reduced the criteria to the four listed in table 1. 

DOT staff believe that their weighted evaluation criteria will
provide clear breaks among application scores if, because of limited
funds, the Department is required to choose among eligible projects. 
However, DOT's guidance also indicates that, in addition to the
weighted criteria, the Department will consider other factors in
selecting grantees--(1) the schedule for implementing the project,
(2) the availability of funds, and (3) the geographic distribution of
grants throughout the country.  When DOL evaluated applications for
grants during the first year of its Welfare-to-Work program, it had
more applications that were deemed "competitive" (scoring over 80
points) than available funds.  Even after using bonus points, DOL had
more applications than available money.  Accordingly, DOL used
additional factors, such as geographic location and rural/urban
representation, to help make the final selection.  Until DOT receives
and begins scoring Access to Jobs grant applications, it will not
know if its weighted criteria will be sufficient to distinguish among
applications or if it will need to rely on the additional factors it
identified, such as geographic dispersion. 


   COORDINATION IS KEY TO THE
   PROGRAM'S SUCCESS
------------------------------------------------------------ Letter :5

The Congress recognized the importance of coordinating
welfare-to-work activities to help ensure the success of welfare
reform.  DOT has taken a number of steps to coordinate its Access to
Jobs program with the welfare activities of HHS, DOL, and HUD.  DOT
invited executive-level representatives from these departments to
join a policy council to provide a forum for discussing Access to
Jobs implementation issues.  In addition, before the Access to Jobs
program was authorized, the Secretaries of Transportation, HHS, and
Labor issued joint guidance to states and localities describing how
each department's programs could be used together to implement
transportation services under welfare reform.  DOT plans to sustain
its working relationship with federal social service agencies by
using their expertise to help select grants that will support welfare
reform's goals.  Finally, DOT addressed the need for local
coordination by requiring grant applicants to submit projects that
are the result of a regional planning process that includes
representatives from both transit and social service providers. 

TEA-21 requires DOT to coordinate its Access to Jobs activities with
other federal agencies' welfare-to-work programs.  In May 1998, we
reported on the role of transportation in welfare reform and
recommended that DOT work with other federal agencies, such as HHS,
DOL, and HUD, to coordinate all of their welfare-to-work activities. 
DOT agreed with our recommendation, noting that coordination is
important to ensure the success of welfare-to-work programs.  First,
federal agencies can encourage state and local transportation and
human service agencies and other local organizations to combine their
expertise to develop comprehensive welfare-to-work projects that
include a transportation component.  Second, federal agencies need to
work together to ensure that their funds for welfare-to-work programs
are used to complement, rather than duplicate, one another.  Such
coordination is particularly important for the recipients of Access
to Jobs grants because these grants fund only 50 percent of a
project's total costs.  Grantees can use federal funds such as HHS'
TANF funds or DOL's Welfare-to-Work grants to fund the remaining 50
percent. 

To facilitate coordination among federal welfare-to-work programs,
FTA initiated a policy council in July 1998 and invited
representatives from DOL, HHS, HUD, the Office of Management and
Budget, and the White House to join.  (App.  I lists the council's
membership).  According to DOT, the council was established to advise
the Department on implementing the Access to Jobs program, as well as
to keep other agencies apprised of DOT's actions.  Members of the
council have worked on a number of issues associated with
implementing the Access to Jobs program and have reviewed the
program's draft guidance prior to issuance.  In addition, DOT and
DOL, according to DOT officials, are working together to ensure that
Access to Jobs grantees adhere to statutory labor protection
requirements.\8

The Secretaries of Transportation, HHS, and Labor have also worked to
coordinate their welfare-to-work programs.  In May 1998, the
Secretaries issued joint guidance explaining how human service
organizations can use HHS' TANF funds and DOL's Welfare-to-Work
grants to provide transportation services for people moving from
welfare to work.  For example, the guidance notes that state human
service organizations can use TANF funds to provide transit passes
for welfare recipients or reimburse TANF recipients for work-related
transportation expenses.  The guidance also encourages local
transportation, workforce development, and social service providers
to coordinate their activities to ensure the most efficient use of
federal funds.  Now that Access to Jobs funds are available, DOT
officials said, HHS, DOL, and DOT will issue updated guidance
explaining how their welfare-to-work programs can be coordinated. 

In addition, DOT's guidance states that the Department will establish
an interagency work group to help it review applications for Access
to Jobs grants.  These applications should include information on how
transportation services will be coordinated with social services,
such as the job placement activities that DOL provides for TANF
recipients.  DOT officials expect that staff from other federal
agencies like DOL and HHS will be able to help DOT assess the
viability of the proposed coordination efforts.  In this way, DOT
will be able to take advantage of the other agencies' experience with
welfare reform projects to help determine which transportation
projects will benefit welfare recipients seeking jobs. 

Finally, the Congress and DOT believe local coordination among social
service and transportation organizations is important for a project's
success.  Both the metropolitan planning provisions and the Access to
Jobs provisions of TEA-21 emphasize the importance of involving a
wide variety of local groups in the coordination of transportation
services.  For example, TEA-21 states that each Access to Jobs grant
project shall be part of a coordinated transportation planning
process, involving both public transit and human service agencies. 
DOT's Access to Jobs guidance also states that grantees must include
transportation and human service groups in their planning process. 
DOT's published grant award criteria encourage local coordination by
providing 25 points for a coordinated human services/transportation
planning process and regional job access transportation plan, as well
as bonus points for grant projects linked to employment-related
support services.  Finally, DOT officials said that they have sought
to encourage local coordination through their outreach efforts,
including presentations and meetings on TEA-21 and the Access to Jobs
program held throughout the country. 


--------------------
\8 Federal transit grants are generally required to include
provisions for fair and equitable arrangements to protect the
interests of affected transit employees. 


   DOT HAS NOT PUT AN EVALUATION
   PLAN IN PLACE
------------------------------------------------------------ Letter :6

Evaluation is important because the Congress, program officials, the
business community, advocacy groups, and taxpayers need to know if
newly designed welfare reform programs, such as the Access to Jobs
program, are working.  When it announced the program's guidance in
October 1998, DOT provided information on how it would monitor
projects funded through the program.  Specifically, DOT said that it
expects grantees to monitor the performance of their projects and
provide DOT with data on four project outputs.  However, the data
collected by the grantees may not measure the program's overall
performance until DOT establishes goals or benchmarks to evaluate the
information it receives from the grantees. 


      EXPERTS CITE EVALUATION AS A
      CRITICAL COMPONENT OF
      WELFARE-TO-WORK INITIATIVES
---------------------------------------------------------- Letter :6.1

Experts say that evaluation is critical in determining the effect of
welfare reform.  However, an early look at welfare reform initiatives
suggests that such evaluations are not routinely done. 
Transportation experts at the University of California are assessing
how public agencies in California charged with developing and/or
implementing transportation policies and programs are evaluating
transportation efforts in welfare reform.\9 In their project
proposal, the experts stated that evaluation was a critical component
of welfare-to-work programs; however, few welfare-to-work programs
contained an evaluation component.  Consequently, the experts
concluded that administrators have implemented some welfare-to-work
transportation policies and programs without plans to evaluate their
effectiveness. 

Other experts expressed concern about evaluating welfare reform
programs before the Subcommittee on Human Resources, House Committee
on Ways and Means, in a March 1998 hearing.  The hearing focused on
how policymakers could be informed of the effects of welfare reform,
given the wide variation in program design and the growing number of
agencies involved.  The Director of the Research Forum on Children,
Families, and the New Federalism--an initiative of the National
Center for Children in Poverty--was a witness at this hearing. 
According to the Forum, as new welfare programs are implemented
across the country, the conceptual framework and methods must change
and adapt; research must be flexible to study diverse combinations of
programs, policies, and funding.  Since policy and program changes
occur frequently, the Forum concluded that research must provide
information quickly to be most useful, particularly so that
practitioners can identify and address problems early in the process. 


--------------------
\9 Faculty at the Lewis Center for Regional Policy Studies and
Institute of Transportation Studies, University of California, Los
Angeles, will conduct the research.  The grant for this research is
from the University of California Transportation Center. 


      DOT HAS MADE LIMITED
      PROGRESS IN ESTABLISHING AN
      EVALUATION FRAMEWORK
---------------------------------------------------------- Letter :6.2

TEA-21 requires DOT to evaluate the program 2 years after the act's
enactment.  In May 1998, we recommended that DOT establish specific
objectives, performance criteria, and measurable goals for the Access
to Jobs program.  DOT concurred with our recommendation.  In
addition, the Government Performance and Results Act of 1993 (Results
Act), enacted to improve the effectiveness of and accountability for
federal programs, requires agencies to identify annual performance
goals and measures for their program activities. 

In announcing the Access to Jobs program in October 1998, DOT
established two major goals for it--(1) to provide transportation
services to assist welfare recipients and low-income persons in
gaining access to employment opportunities and (2) to increase
collaboration among transportation providers, human service agencies,
employers, metropolitan planning organizations, states, and affected
communities and individuals.  DOT expects grantees to monitor the
performance of their Access to Jobs project and to provide the
Department with data on (1) how many transportation services the
project added (service frequency, hours, and miles); (2) how the
target area's accessibility to jobs and support services improved
(i.e., how the percentage of available jobs accessible to the target
population by public transportation increased with the program); (3)
how many people are using these expanded services; and (4) how the
project's sponsors collaborated.  These measures relate specifically
to transportation services--not to other related services, such as
those matching people to available jobs--and reflect DOT's philosophy
that transportation alone will not ensure successful employment for
the target population. 

However, these steps set up a data collection plan without
establishing how the program's success will be evaluated.  DOT's
guidance does not specify key measurable goals for the program, such
as increasing by an appropriate percentage the number of jobs
accessible by public transportation.  As a result, once the data are
collected, DOT has no standard for measuring success and no method
for determining whether the data are indicative of the program's
success.  In responding to our May 1998 report, DOT agreed to revisit
and refine its strategic plan as it applies to the Access to Jobs
program and to develop performance goals and performance measures for
incorporation into the Department's fiscal year 2000 Performance
Plan.\10 While DOT's activities mark progress towards an evaluation
process, DOT has begun to implement the Access to Jobs program
without plans for evaluating its effectiveness. 

According to DOT's Access to Jobs coordinator, DOT recognizes that
evaluation is important to the Access to Jobs program.  DOT had
included a specific provision on evaluation in its program
proposal.\11 But because DOT wanted to distribute the money to start
projects as quickly as possible, it chose to save evaluation issues
until later.  However, DOT is not currently certain how it will
analyze the collected data to evaluate the nationwide success of the
Access to Jobs program or what additional information it may request
from grantees for this purpose.  While the program's guidance is
essentially complete for fiscal year 1999, the Department may add
further details on performance measurement when it awards funds to
the fiscal year 1999 grantees.  Department officials said they plan
to provide additional guidance on performance indicators for future
applicants. 


--------------------
\10 DOT's fiscal year 2000 Performance Plan should be submitted to
the Congress by the spring of 1999. 

\11 DOT's 1997 proposed surface transportation reauthorization
legislation included a 6-year, $600 million Access to Jobs program to
support new transportation services for low-income people seeking
jobs.  This proposal would have specifically authorized grants for
project evaluations and technical assistance for recipients. 


   CONCLUSIONS
------------------------------------------------------------ Letter :7

Since TEA-21 established the Access to Jobs program in June 1998, DOT
has made important strides in developing an overall framework for
implementing this new program.  The Department has resolved many of
the program implementation challenges we cited in our May 1998
report.  Specifically, it has made some important decisions about how
it will distribute the program's funds, what criteria it will use to
review grant applications, and how it will coordinate the program
with other federal agencies' efforts.  However, the Department has
not yet fully set forth the methods it will use to evaluate the
program's success, as we recommended in our earlier report. 
Establishing performance measures for the Access to Jobs program is
important because doing so will enable the Department to have
benchmarks for evaluating the data it will receive from Access to
Jobs grantees.  Establishing performance measures will also enable
the Department to begin its own legislatively required evaluation of
the program's success.  If the Department implements our
recommendation, it will establish specific objectives, performance
criteria, and measurable goals for this new program and include them
in its fiscal year 2000 Performance Plan.  Since this plan will be
submitted to the Congress in connection with the fiscal year 2000
budget in the spring of 1999, Access to Jobs grantees would be aware
of these objectives, criteria, and goals as they began to implement
their projects. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :8

We provided a draft of this report to DOT for review and comment.  We
met with DOT officials--including the Acting Director of the Office
of Policy, Office of the Secretary, and the coordinator for the
Access to Jobs program, Federal Transit Administration--to discuss
the Department's comments on the draft report.  Overall, DOT agreed
with our findings.  However, the officials stated that while the
report accurately describes the decisions the Department has made
since the program's inception, it does not sufficiently describe the
program's rapid development.  They noted that the program was
recently authorized, in June 1998, and they have rapidly made
important decisions to ensure that fiscal year 1999 grants are
awarded quickly.  They also provided the following points to clarify
certain aspects of the new program.  First, they said that they had
conducted extensive outreach efforts intended to provide the public
with information on the program's implementation and to involve
nontraditional groups, such as human service organizations and
community-based organizations, in the process.  Second, DOT officials
noted that in addition to coordinating the program at the federal
level, they have stressed local coordination as an equally important
component of the Access to Jobs program.  Officials noted that the
program's guidance should encourage localities to build upon local
transportation planning processes as well as increase opportunities
to incorporate new players in the planning process.  Finally, the
officials acknowledged the importance of further developing DOT's
plans to evaluate the program and affirmed that the Department will
include performance measures for the program in its fiscal year 2000
Performance Plan.  On the basis of DOT's comments, we included
additional information in the report on the Department's efforts to
encourage local coordination and to obtain guidance from
transportation and nontraditional partners.  DOT had additional
technical comments that we incorporated throughout the report, where
appropriate. 

For its review and comment, we also provided DOL with sections of the
draft report that specifically dealt with issues pertaining to it. 
Overall, officials agreed with the information.  We incorporated
DOL's technical comments throughout the report, where appropriate. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :9

To obtain information on the steps DOT has taken to implement the
Access to Jobs program--specifically, to distribute funds and select
criteria for awarding grants--we interviewed DOT officials; examined
program documentation, preliminary reports, and other descriptive
materials; and attended the October 22, 1998, conference in which DOT
announced the Access to Jobs program, as well as a September 23,
1998, listening session on TEA-21, sponsored by FTA.  To identify the
efforts DOT has made to coordinate its work with that of other
federal agencies, we interviewed key officials in FTA and DOL and
kept abreast of efforts by members of our staff working on related
projects.  To address the evaluation issue, we interviewed DOT, FTA,
and DOL officials; reviewed relevant program documentation; and
gathered opinions from selected outside organizations and
universities.  In addition, we visited the Metropolitan Area Planning
Council in Boston, a DOL Welfare-to-Work program grantee, to obtain
its views on implementing the Welfare-to-Work program and evaluating
its results. 

We performed our review from June 1998 through November 1998 in
accordance with generally accepted government auditing standards. 


---------------------------------------------------------- Letter :9.1

We are sending copies of this report to interested congressional
committees, the Secretary of Transportation, the Secretary of Labor,
and the Administrator of FTA.  We will also make copies available to
others on request. 

If you have any questions about this report, please call me at (202)
512-2834.  Major contributors to this report were Ruthann Balciunas,
Joseph Christoff, Catherine Colwell, and Phyllis Scheinberg. 

John H.  Anderson, Jr.

DIRECTOR, TRANSPORTATION ISSUES
============================================================== Letter 


MEMBERS OF THE DEPARTMENT OF
TRANSPORTATION'S EXECUTIVE-LEVEL
POLICY COUNCIL
=========================================================== Appendix I


   DEPARTMENT OF TRANSPORTATION
--------------------------------------------------------- Appendix I:1

Gordon Linton, Administrator, Federal Transit Administration

Nuria Fernandez, Deputy Administrator, Federal Transit Administration

Joseph Canny, Deputy Assistant Secretary for Transportation Policy

Ken Wykle, Administrator, Federal Highway Administration

Steve Palmer, Assistant Secretary for Governmental Affairs

John Horsley, Associate Deputy Secretary and Director, Office of
Intermodalism


   OTHER AGENCIES
--------------------------------------------------------- Appendix I:2

Cynthia Rice, Domestic Policy Council, White House

Andrea Kane, Domestic Policy Council, White House

Emil Parker, National Economic Council, White House

Barbara Chow, Associate Director, Office of Management and Budget

Michael Deich, Associate Director, Office of Management and Budget

John Monahan, Principal Deputy Assistant Secretary for Children and
Families, Department of Health and Human Services

Jill Khadduri, Acting Assistant Secretary for Policy Development and
Research, Department of Housing and Urban Development

Ray Uhalde, Acting Assistant Secretary for Employment and Training,
Department of Labor


*** End of document. ***