TGC has gained a reputation in the industry as one of the foremost experts in federal and state regulatory compliance for FTA and state funded projects. We regularly provide clients with information, training, and guidance on FTA transit program compliance requirements. With our guidance Civil Rights and DBE programs, NTD reporting, procurement processes, grant management, and other programs are in full compliance at all times.
Areas of Expertise
- FTA Triennial Review – An FTA grantee must demonstrate the legal, financial, and technical capacity to carry out its transit program. To put this to the test, a review of federal compliance requirements is performed by FTA every three years. TGC is very familiar with the FTA triennial review process which focuses on 17 areas of compliance. In preparation of an FTA pre-site visit review, TGC collects and organizes information for the initial document submittal. TGC provides staff support during the scheduled on-site FTA visit to elaborate on any aspects of a client’s program. Any deficiencies associated with FTA reviewer findings are also addressed by TGC in a timely matter.
- Implementation Support – TGC federal compliance assistance extends to all FTA funded projects. TGC collaborates with client project/construction management/design teams to ensure that all procurement and post-award obligations meet federal and state requirements. Specific activities include continued bid package review, provision of all federally required components, plan set review, and bid process oversight. During constructon of FTA-funded projects, TGC works with construction managers to ensure required compliance activities are taking place. This includes federal wage rate compliance (Davis-Bacon field interviews), assistance with substantial completion field inspection, follow-up punch list corrective measures and warranties, evaluation of unforeseen construction circumstances, and Texas Department of Licensing and Regulation inspections.
- ADA Plans – TGC develops ADA Complementary Paratransit Service Plans for multiple clients. Plan development includes service information and ADA Paratransit certification and recertification documents. In concert with plan development, TGC assists with the implementation of Complementary ADA Paratransit Service as required under the Americans with Disability Act of 1990.
- Title VI Programs – TGC provides assistance to clients to ensure Civil Rights programs are current and submited to FTA on a timely basis. Compliance reports include Title VI, Equal Employment Opportunity, and Disadvantaged Business Enterprise. TGC develops Title VI Programs in compliance with the FTA Circular 4702.1 B. Part of this program involves Limited English Proficiency (LEP) determinations. TGC provides translations of vital information, including the Title VI Compliant forms and Title VI Notice, into languages identified in the LEP determinations. TGC provides support related to implementation of Title VI public outreach and Language Assistance Programs. TGC develops DBE Programs and goals in compliance with 49 CFR Part 26. Support is provided to client related to monitoring and public participation sections of the program. Training of individuals working with the program is also essential.
- Policies and Procedures – A FTA grantee is responsible for ensuring that its financial management system meets the requirements of OMB A-87 / 2CFR Part 225, Cost Principles of State, Local and Indian Tribal government, otherwise known as the Common Rule. Part 18 addresses the uniform administrative requirements for grants and cooperative agreements to State and local governments. These requirements are more fully defined for FTA-purposes within Circulars which provide more specific guidance. The guidance relating to grant and financial management is concentrated in Circular 5010.D Grant Management Guidelines and 4220.1F Third Party Contracting Requirements. The Common Rule is not a choice or an option; it is required for all grant recipients and sub-recipients and its standards cannot be waived.TGC is familiar with Common Rule standards addressed by 49 CFR 18.20 and can prepare procedures manuals to help clients avoid common deficiencies found among FTA grantees. The document focuses on eight areas of a clients’ financial management system: accounting, cash management, fixed asset, procurement, budget, grants, project management and information technology.TGC also provides assessments of client financial oversight policies, procedures, and practices related to: financial reporting, accounting records, internal control, budget control, allowable costs, source documentation, cash management, and project management are also provided by TGC. These assessments examine the effectiveness of client internal control systems and identify potential weaknesses or deficiencies that may lead to potential misrepresentation of internal financial condition.
- Service and Fare Equity Analysis – From time to time a transit agency will need to make fare or service changes. To ensure Title VI requirements are met, TGC can conduct a service and fair equity analysis to assess the level of impact those changes may have and develop a strategy to minimize any potential adverse effects. This analysis safeguards clients from implementing policies, procedures, and activities that may discriminate based on age, color, or national origin.
- Service Reduction and Fare Change Policy – TGC understands that providing affordable public transportation while maintaining operations can be a challenge for transit providers. The decision to adjust fares and make service reductions is often difficult, but can be mitigated by having policies in place that strive to provide equitable public transportation service that takes into account the socioeconomic make-up of customers. TGC can draft these required policies for our clients to ensure compliance with the Title VI Program.