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Compliance Reviews

Compliance Review Preparation

The Public Transit Division operates two oversight programs that operated independently. On-site compliance reviews assess how your agency is complying with federal and state laws, rules, requirements, and regulations.  Drug and Alcohol (D&A) Compliance Reviews are focused only on D&A topical areas.  D&A compliance reviews are scheduled and conducted separately from on-site compliance reviews.

Prepare for D&A compliance review

On-site compliance reviews assess how your agency is complying with federal and state laws, rules, requirements, and regulations that guide and inform how agencies administer public transportation programs. The goal of the Public Transportation Division's Compliance Review Program is to improve agency compliance with required regulations while strengthening transit staff management abilities.

There are three types of site review: ODOT determines the type of review for each public transportation provider based on their activities and structure:
  • Direct Provider Review for agencies that directly provide transit service (Direct Provider)
  • Pass-Through Review for agencies that give Federal Transit Administration funds to service providers (Pass-through Provider)
  • Urban Recipient Review for agencies that receive 5307 funds directly from FTA

About Compliance Reviews

All compliance reviews have two parts:

  1. A desk review, conducted by the consultant based on data submitted by the transit agency.
  2. A one to two day site visit to the agency.

About the Direct-Provider Review

There are 10 areas of the direct-provider review associated with Federal and state regulations and guidance:

  1. Program Management;
  2. Financial Management;
  3. Operations Management;
  4. Procurement;
  5. Use and Maintenance of Project Equipment;
  6. Civil Rights;
  7. Americans with Disabilities Act, (ADA);
  8. Charter and School Bus;
  9. Statewide Transportation Improvement Fund (STIF);
  10. Special Transportation Fund;
  11. Monitoring of Lower-Tier Subrecipients; and
  12. Other Elements of Review.

For complete information read the Direct Provider Compliance Field Guide.


About the Pass-Through Provider Review

There are six areas of the pass-through provider review associated with Federal and state regulations and guidance:

  1. Program Management;
  2. Financial Management;
  3. Civil Rights;
  4. Americans with Disabilities Act (ADA);
  5. Statewide Transportation Improvement Fund (STIF);
  6. Special Transportation Fund;
  7. Monitoring of Lower-Tier Subrecipients; and
  8. Other Elements of the Review

For complete information read the Pass-Through Compliance Field Guide.


About the Urban Recipient Review

Urban recipients of state funds will receive an abbreviated review in an effort to not duplicate FTA oversight already performed. These reviews will primarily focus on state funding programs. There are six areas of the Urban recipient review associated with Federal and state regulations and guidance.

  1. Statewide Transportation Improvement Fund (STIF);
  2. Special Transportation Fund;
  3. Financial Management;
  4. Requirements for STIF-Funded Assets;
  5. American Disabilities Act (ADA); and 
  6. Monitoring of Lower-Tier Subrecipients.
For complete information read the Urban Recipient Compliance Field Guide.

STIF Qualified Entity Oversight of Formula Fund Subrecipients

STIF recipients of Formula Funds that enter into lower tier agreements with Subrecipients or Vendors to carry out the project have responsibility for conducting oversight of these entities. Recipients must ensure all Subrecipients have:

  • A system of internal controls that provides reasonable assurance that the Subrecipient is managing the STIF project in compliance with rules adopted by The Oregon Transportation Commission and the terms and conditions of the contractual agreement with the Recipient.
  • Managerial and technical capacity in required areas including, but not necessarily limited to:
    • Financial Management
    • Eligible use of STIF funds
    • Procurement
    • Use and maintenance of project facilities and equipment
    • Record and document management
    • Civil rights
    • Americans with Disabilities Act

This Guide represents a tool that Recipients can use to provide effective oversight of its Subrecipients. Recipients may expand on this guide, as appropriate, to provide an appropriate level of oversight consistent with local needs. Alternative methods of Subrecipient compliance are acceptable, subject to approval by the Agency.

STIF Formula QE-Subrecipient Oversight Guide
For end-users who only use Adobe Reader up to version 7.0, please download the STIF Formula Guide for Reader document.

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Contact

Email EmailEmailEmail David Campbell
Compliance Program Coordinator
Telephone 971-304-4915

Resources

D&A compliance review

Learn about and contact your
Regional Transit Coordinators