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Section 4: District Compliance Monitoring

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Background

It is the Texas Department of Transportation (TxDOT) Traffic Operations Division’s (TRF’s) responsibility to monitor each TxDOT Traffic Safety Specialist (TSS) located in a district office that manages local, federally-funded projects in order to review compliance with TxDOT’s established project management procedures and with other state and federal regulations and laws. Periodic monitoring reviews help provide operational consistency. In addition to TxDOT’s normal compliance audit and management review function, TRF assists the TSSs with procedural compliance and provides appropriate assistance and training.

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Frequency

To determine the need for and frequency of district compliance monitoring visits or other types of review, TRF uses a risk assessment process and the Grant Management Risk Assessment Form. This process and form focuses on the following risk factors:

  • the district’s total number of grants
  • the district’s total dollar amount in grants
  • the time since the last monitoring visit
  • significant identified problems and actions taken to correct the problems.

Identifying these risk factors allows the prioritization of districts representing the greatest need for compliance monitoring, which helps TRF better allocate its resources.

For districts with a large number of projects and identified problems, a compliance monitoring visit may be necessary every one or two years. Less frequent review may be indicated if compliance is considered satisfactory (see Section 5 of this chapter, “Resolution of Findings”); however, all districts will be reviewed at least every five years.

During the district compliance monitoring review, it is desirable for TRF to observe the TSS performing at least one or two project on-site monitoring visits. TRF will coordinate with the TSS to arrange these visits.

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Items to be Reviewed

The following lists include the more important items and issues that should be reviewed by TxDOT TRF. Reviews are not limited to these items.

The following should be reviewed by TRF:

  • program area management (including project proposal review and selection, Request for Reimbursement (RFR) review and processing, Performance Report review and processing, program module project-by-project oversight)
  • completeness and timeliness of report and document submission
  • grant files maintenance
  • backup documentation
  • inventory records
  • publications and audio-visual library maintenance
  • previous year’s final Performance Report
  • on-site monitoring of active projects
  • professional development, training, and assistance needs
  • exemplary projects and best practices (from contacts and reports).

The following should be reviewed by the TSS in the districts:

  • oversight of project management (including Performance Report and RFR review and processing)
  • completeness and timeliness of report and document submission
  • previous year’s final Performance Report
  • grant file maintenance
  • backup documentation
  • current and planned district traffic safety activities
  • on-site monitoring of active projects
  • assistance and training needed or requested at the project level
  • professional development, training, and assistance needs of district and project personnel
  • exemplary projects and best practices (from contacts and reports).
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Advance Preparation

Prior to each district TSS compliance monitoring visit, the TxDOT TRF compliance monitor will:

  • schedule each visit at least one month in advance and send appropriate information, including a project status report, to the district for all current projects from the Traffic Safety Database.
  • use the Traffic Safety On-Site Project Monitoring Checklist and Report in preparation for and in conducting the monitoring visit (see information following this list).
  • review project Performance Reports, RFRs, final Performance Reports, and other documents in the file of record to determine if there are any problem areas that need detailed scrutiny or questioning during the visit.
  • complete the Preparing for Compliance Monitoring Visits: File Review Checklist for each project file reviewed. It is recommended that the review extend back at least one year.
  • check the division inventory log to determine if it contains items purchased with federal funds that need to be verified.
  • make travel arrangements and set up appointments with the TSS, who will set up all on-site monitoring visits of selected projects.
  • provide the TSS with an outline of discussion topics, projects, and documents to be reviewed.
  • with the project and program manager, determine which projects will receive an on-site monitoring visit. Visits to several diverse types of projects are recommended. The project manager will set up the on-site monitoring visits.
  • note any follow-up items from previous compliance monitoring visits, audits, or management reviews and any record of actions on these items.
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Review of Source Documents

When participating in an on-site monitoring visit or when reviewing an on-site monitoring visit report, the TRF compliance monitor may attach sample copies of documents reviewed to the report. See “ Review of Source Documents” in Section 3 of this chapter for details on types of documents to be reviewed.

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Review of Project Files

The TxDOT TRF compliance monitor will review the contents of grant files for selected projects managed by the TSS. Items to be reviewed include:

  • the copy of the signed grant agreement with all required pages, attachments, any amendments, transmittal correspondence, and jurisdiction ordinance or resolution, if appropriate
  • the completed grant delivery form, on-site monitoring checklist and reports, project Performance Reports, RFRs with appropriate documentation
  • copies of all required documents, including vehicle mileage reimbursement policy
  • Cost Assumption Plan (submitted with the proposal)
  • routine correspondence and other records of communication between the project manager and the subgrantee organization.
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Direct Observations

The TRF compliance monitor should directly observe the project or program manager in the performance of one or more on-site monitoring visits to ensure that the monitoring procedures listed in Section 3 of this chapter are followed correctly. Key project management and fiscal staff should both attend these meetings. If possible, project activity will also be observed, such as enforcement efforts, ongoing classroom or field training activity, or project personnel performing project-related activities. In addition, the compliance monitor will review the subsequent on-site monitoring reports for completeness.

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Documentation

The TxDOT TRF compliance monitor will complete a report of the monitoring visit covering each of the topics listed earlier in this section under the subheading “ Items to be Reviewed”. The report should include the following:

  • the location visited
  • the dates of the visit
  • the participants contacted during the visit
  • the items covered or observed during the traffic safety operations review
  • a list of the items observed during the compliance review, including the project on-site monitoring visits performed by the project manager
  • a descriptive report of any assistance or training requested, provided, or needed
  • best practices identified
  • a detailed explanation of any problems or procedural non-compliance noted and recommendations for corrective actions
  • the proposed date for next monitoring review.

When all information has been gathered and the report has been completed, it will be disseminated to the TxDOT district office and any other appropriate personnel. The reports can be found in eGrants, which serves as TRF’s file of record.. The TSS is expected to respond in writing within 30 business days to the items identified in the report, with specific actions to be taken and dates.

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