Transcript Office of the Inspector General Audit Report

Opportunities Exist to Strengthen FHWA’s
Coordination Guidance and Oversight of the
Tribal Transportation Program
October 30, 2013

Purpose
◦ To assess whether FHWA is:
 effectively coordinating with BIA to administer and
manage the TTP; and
 Providing adequate oversight of TTP projects under
agreements with Tribes


Between May 12, 2012 and August 13, 2013
Interviews
◦
◦
◦
◦
◦
◦
◦

FLH TTP Staff
BIA DOT
BIA Regional Offices
DOI Office of Self-Governance
DOI Office of the Inspector General
10 Tribes
Western Federal Lands
Reviewed
◦ Regulations, agreements, project documentation,
FHWA data files


FLH and BIA routinely coordinate in key areas
such as coordinating reviews, fund
distribution, and consulting with tribal
organizations.
Opportunities for improvement
◦ NEPA Approvals
◦ Final Acceptance of TTP Projects
 Results could be improved with a updated interagency
agreement

FHWA should conduct more formal reviews
based on data assessing tribal program risks
and needs
◦ Effects both new and existing Tribes working with
FHWA

Unclear Guidance hinders FHWA in carrying
out:
◦
◦
◦
◦
Effective workload analysis;
Project and program monitoring;
Assessment of tribal capabilities; and
Limited scope during site visits
1. Coordinate with BIA to update the
Memorandum of Agreement and Stewardship
Plan to reflect FHWA’s role to directly assist
Tribes, and define coordination between FHWA
and BIA Regional Offices.
ACTIONS: New National Business Plan being
developed
◦ Identifies roles, responsibilities, procedures,
communications
2. Create a centralized database to capture
financial and status information for tribal
transportation projects.
ACTIONS: FHWA is looking at various database
options including BIA Alaska Region’s system
as well as developing a new database
internally.
3. Develop a process that ensures sufficient
consultation with BIA fro tribes transitioning to
FHWA and requires FHWA to consistently
assess tribal capabilities and associated risks in
administering transportation projects
ACTIONS:
◦ Formal on boarding process developed
◦ Risk assessment similar to G2G assessment
◦ Requires significant discussion/coordination with
BIA Regions
4. Develop a process that ensures consistent
and comprehensive reviews of tribal projects,
including a standard site visit checklist of key
risk areas for tribes.
ACTIONS:
- Risk based project/program reviews
- Project review checklist for each visit
- what is reviewed each visit
- Updated Program Guide
5. Coordinate with BIA to revise TTP
Regulations to reflect FHWA’s role to directly
assist Tribes and clarify the requirements for
eligible uses of funds
ACTIONS: FHWA and BIA have developed an
update to 25 CFR 170 and NPRM process
should be underway after January 1.
6. Develop a series of remedial actions that
FHWA officials can take for a Tribe that may
not be meeting program requirements.
ACTION:
◦ Actions being developed and will be discussed with
each FHWA Tribe after development.
◦ Will focus on non-responsiveness and nonreporting
◦ Will be included in Program Guide and Program
Agreements
7. Revise TTP Guidance to ensure consistent
definitions of key terminology, particularly
financial constraint, and require Tribes to
provide more detailed information on project
scope and funding source.
ACTIONS:
◦ Training on TIP Requirements and development
 Consistent definitions (Program Guide)
◦ TIPS will require additional information
 Identification of additional funding sources
 Reasonableness of project funding

FHWA and BIA will be working on resolution
and actions so as to have all of the new
procedures in place by the end of FY 14.


Thank you to all that were involved
FHWA recognizes the importance of the TTP and
is committed to work with the all of the Tribes
and BIA to deliver transportation projects that
provide access to community services.
Bob Sparrow
Director – FHWA TTP
Washington, DC
(202) 366-9483
[email protected]