ASSESSMENT OF FHWA OVERSIGHT OF 

THE HIGHWAY BRIDGE PROGRAM AND 

THE NATIONAL BRIDGE INSPECTION 

PROGRAM

Federal Highway Administration

Report Number: MH-2010-039

Date Issued: January 14, 2010
Memorandum

U.S. Department of

Transportation

Office of the Secretary

of Transportation

Office of Inspector General

Subject: ACTION: Assessment of FHWA Oversight of the 

Highway Bridge Program and the National Bridge 

Inspection Program

Federal Highway Administration

Report Number: MH-2010-039

Date: January 14, 2010

From:

Joseph W. Comé 

Assistant Inspector General 

 for Surface and Maritime Program Audits

Reply to 

Attn. of: JA-40

To: Federal Highway Administrator

This report presents the results of our assessment of the Federal Highway 

Administration’s (FHWA) oversight of the Highway Bridge Program (HBP) and 

the National Bridge Inspection Program (NBIP), and FHWA’s efforts to monitor 

states’ use of Federal-aid for bridges. While some progress has been made in 

recent years to reduce the number of deficient bridges, maximizing Federal surface 

transportation investments to improve current bridge conditions is a major 

challenge for FHWA. According to the American Association of State Highway 

and Transportation Officials (AASHTO), the average bridge in the United States is 

43 years old and, according to FHWA, about one in four of the Nation’s more than 

600,000 bridges are deficient. FHWA has estimated that as much as $65 billion 

would be needed to address current bridge deficiencies and other needed 

improvements.1

 The collapse of the Interstate 35W (I-35W) Bridge in 

Minneapolis, Minnesota, on August 1, 2007, killing 13 people, underscored the 

importance of strong bridge safety programs and the need to maximize 

investments to improve bridge conditions. With the enactment of the American 

Recovery and Reinvestment Act (ARRA) of 20092 comes an unprecedented 

opportunity to fund $27.5 billion worth of highway infrastructure projects, 

including those related to bridges.

 1 This estimate is based on 2004 data and reported in constant 2004 dollars. 2 Pub. L. No. 111-5 (2009).
2

Our objectives were to assess FHWA’s: (1) oversight of Federal-aid funds 

provided to states through the HBP for deficient bridges and (2) enforcement of 

bridge inspection standards under the NBIP. As part of this audit, we also 

examined how FHWA could better implement data-driven, risk-based bridge 

oversight, which we addressed in our January 2009 report.3

 To address these 

objectives, we conducted site visits in Kentucky, Michigan and Pennsylvania and 

interviewed FHWA officials in 11 Division Offices. We also obtained and 

analyzed data from the Fiscal Management Information System and National

Bridge Inventory databases. 

We conducted this performance audit in accordance with Generally Accepted 

Government Auditing Standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. See details on our scope and 

methodology in exhibit A.

RESULTS IN BRIEF

FHWA lacks sufficient data to evaluate states’ use of HBP funds. Specifically, 

FHWA can not link expenditures of HBP funds to improvements made to deficient 

bridges. For example, while Michigan is using almost $3 million in HBP funds on 

a project that involves preventive maintenance on four deficient and three nondeficient bridges, FHWA’s accounting system is unable to determine how much 

Federal-aid goes toward improving the condition of deficient bridges. 

FHWA also lacks the criteria and guidance necessary to determine whether states 

demonstrate overall compliance with bridge inspection standards under the NBIP. 

While bridge inspection standards include numerous requirements to ensure bridge 

safety, FHWA has not defined how the bridge engineers conducting the annual 

compliance review should assess states’ overall compliance and what actions to 

take when states fail to comply. Consequently, Federal-aid highway funds were 

provided to states with incidents of noncompliance, including some that could 

pose serious risks to public safety. For example, based on our analysis of data 

from FHWA’s 2007 annual compliance review, a bridge engineer reported a state 

to be substantially compliant despite that state’s failure to close 96 bridges, as 

required by the bridge inspection standards. 

 3 OIG Report Number MH-2009-013, “National Bridge Inspection Program: Assessment of FHWA’s 

Implementation of Data-Driven, Risk-Based Oversight,” January 12, 2009. OIG reports and testimonies 

are available on our website: www.oig.dot.gov. 
3

We are making a series of recommendations to FHWA to strengthen its oversight 

of states’ use of HBP funding in improving the conditions of deficient bridges 

nationwide and the agency’s enforcement of state compliance with bridge 

inspection standards.

BACKGROUND

The HBP is the primary Federal program that funds the replacement and 

rehabilitation of bridges nationwide. It classifies bridges according to their 

condition, based on data collected by state and local governments during 

inspections of public highway bridges; and using a needs-based formula, it 

apportions Federal-aid among states to improve bridge conditions. States that 

demonstrate greater need receive more funding.4

 Each state’s HBP apportionment 

is based largely on the amount of deck area on deficient bridges that qualifies for 

replacement or rehabilitation. Figure 1 below illustrates the deck area of the new 

I-35W Bridge built to replace the bridge that collapsed, which was structurally 

deficient. 

Figure 1. The Deck Area* of the New I-35W Bridge

Source: Minnesota Department of Transportation. Edited by OIG. Reprinted with permission.

* A bridge’s deck area, as highlighted above, represents the amount of its surface area.

A deficient bridge is classified as either structurally deficient or functionally 

obsolete. A bridge is generally classified as structurally deficient when the bridge 

deck, superstructure, or substructure is in poor or worse condition.5

 A bridge is 

generally classified as functionally obsolete when the geometry of the bridge is no 

longer suitable for the traffic it serves.6

 4 The needs-based formula apportions a maximum of 10 percent and a minimum of 0.25 percent of the 

total HBP apportionment to each state for any one fiscal year.

 Being designated as deficient does not 

5 The deck, superstructure, and substructure represent the three components of a bridge. The deck directly 

carries traffic. The superstructure supports the deck. The substructure uses the ground to support the 

superstructure. 6 Factors that affect the geometry of a bridge include the width of the roadway on the bridge, the alignment 

of the approach roadway, and the clearances for the roadway below the bridge.
4

imply that a bridge is unsafe. Bridge inspections should identify any unsafe 

conditions and those bridges determined to be unsafe must be closed. 

Congress declared in law that HBP funds be used to improve the condition of 

deficient bridges through replacement and rehabilitation; but states are also 

allowed to use HBP funds for other activities, such as systematic preventive 

maintenance, seismic retrofitting, and scour countermeasures,7 regardless of a 

bridge’s deficiency status.8

 Furthermore, states may transfer up to 50 percent of 

their annual HBP funding to other Federal-aid highway programs and spend it on 

non-bridge projects. According to statute, FHWA is responsible for monitoring

the efficient and effective use of Federal-aid highway funds.9

 FHWA states in 

policy that it will fulfill this responsibility.10 

FHWA sets standards for states’ bridge inspection programs of public highway 

bridges through the National Bridge Inspection Standards (NBIS) under the NBIP. 

The NBIS includes requirements regarding the frequency with which states should 

conduct inspections, the qualifications of inspection personnel, and the data to be 

collected. The annual NBIS compliance review consists of a field review of 

bridges, interviews with state bridge staff, and a review of state bridge inspection 

data. The review is conducted by FHWA Division Office bridge engineers, who 

work with other Division officials to determine whether states are compliant.11 To 

enforce NBIS requirements, FHWA may require a non-compliant state to develop 

a plan to correct a deficiency and FHWA can ultimately suspend Federal-aid 

highway funds if a deficiency is not corrected. 

In response to our January 2009 report on FHWA’s implementation of datadriven, risk-based bridge oversight, FHWA concurred with our recommendation 

to develop a comprehensive plan to use data to identify and address higher priority 

bridge safety risks in coordination with states. FHWA is in the process of 

addressing this recommendation. The importance of incorporating a data-driven, 

risk-based approach in FHWA’s oversight of bridge safety was recently 

underscored by Congress in its Joint Explanatory Statement accompanying the 

fiscal year (FY) 2009 Omnibus Appropriations Act.12

 7 Scour is the erosion of material due to flowing water that can undermine a bridge’s foundation. Scour is 

the leading cause of bridge failure and an emphasis for FHWA since the collapse of the Schoharie Creek 

Bridge in New York in 1987. Scour mitigation requirements were explicitly incorporated into NBIS in 

2004.

 

8 23 U.S.C. §144 (2006). 9 23 U.S.C. §106 (2006). 10 FHWA, “Policy on Stewardship and Oversight of the Federal Highway Programs,” June 22, 2001. 11 Typically, one bridge engineer is located in each Division Office. The person responsible for conducting 

the annual review could have a title other than bridge engineer, such as structures engineer. Division 

Offices are located in each state, the District of Columbia, and Puerto Rico. 12 Joint Explanatory Statement accompanying Division I (Transportation, Housing and Urban 

Development, and Related Agencies) of the FY 2009 Omnibus Appropriations Act (2009).
5

FHWA Lacks Sufficient Data To Evaluate States' Use of HBP Funds 

To Improve the Nation's Deficient Bridges

FHWA lacks sufficient data to evaluate whether the billions of dollars apportioned 

to states to improve deficient bridges were used effectively in improving the 

condition of such bridges—a requirement of Federal statute and FHWA policy. 

After the former Federal Highway Administrator testified before Congress in 

September 2007 that the agency could obtain data on how much HBP funding was 

spent on structurally deficient bridges,13 FHWA officials determined that its 

accounting system could not link expenditures of HBP funds to improvements 

made to deficient bridges. According to state transportation officials, state 

accounting systems also lack this capability. 

We found during our field work in Kentucky, Pennsylvania, and Michigan that 

FHWA Division Offices do not evaluate whether HBP funds are invested 

effectively in improving the condition of deficient bridges. Specifically, Division 

Offices determine whether to approve projects identified in states’ multi-year 

capital improvement plans by examining a project’s scope of work, conformity to 

acceptable engineering design and construction practices, Federal-aid eligibility, 

and the availability of requested Federal funds. 

FHWA can identify the overall amount of HBP funds apportioned to states to 

improve deficient bridges using its accounting system, the Fiscal Management 

Information System (FMIS). However, FMIS tracks expenditures only at the 

project level and lacks the details necessary to link expenditures to improvements 

made to deficient bridges. That is, data on project-level expenditures do not 

include sufficient details on how states use HBP funds on the individual elements 

within a project. Depending on a project’s size, it could include deficient and nondeficient bridges, tunnels, roads, and other elements not related to bridges.14

 13 Hearing on Structurally Deficient Bridges held September 5, 2007, before the U.S. House of 

Representatives Committee on Transportation and Infrastructure.

 For 

example, Michigan is using almost $3 million in HBP funds on a project that 

involves preventive maintenance on four deficient and three non-deficient bridges. 

A Pennsylvania project was approved for $82 million in non-HBP Federal-aid 

highway funds that involves five deficient and five non-deficient bridges. 

However, FMIS lacks the capability to determine how much Federal-aid goes 

toward improving the condition of these states’ deficient bridges. In interviewing 

state officials in Kentucky, Pennsylvania, and Michigan, we found that states rely 

on project-based accounting systems, which also lack specific details on 

expenditures.

14 A project is defined as an undertaking by a state highway department for highway construction, 

including preliminary engineering, acquisition of rights-of-way and actual construction, for highway 

planning and research, or for any other work or activity to carry out the provisions of the Federal laws for 

the administration of Federal aid for highways (23 C.F.R. §1.2 (2008)).
6

Data in FHWA’s National Bridge Inventory (NBI)15 may indicate whether HBP 

funding has had an impact on improving the condition of deficient bridges. From 

FY 2001 to FY 2008, Michigan received $1.1 billion in HBP funds; and the 

number of deficient bridges and the deck area of deficient bridges in the state 

declined. In contrast, Kentucky received $535 million and Pennsylvania received 

$3.5 billion and yet the number of and deck area of deficient bridges in both states

increased. However, the NBI lacks information on states’ use of Federal-aid 

highway funds, and therefore, cannot be used to determine whether states made 

effective use of HBP funds.16 Table 1 below compares the amount of HBP 

funding received to the condition of bridges in each state.

Table 1. A Comparison of HBP Funding and Bridge Condition Data

HBP Funding

Received

(2001 – 2008)

Change in

Deficient Bridges

(2001 – 2008)

Change in Deck Area (m2) on 

Deficient Bridges

(2001 – 2008)

Kentucky $535 Million 359 321,466

Michigan $1.1 Billion (536) (274,077)

Pennsylvania $3.5 Billion 963 453,999

Source: OIG analysis using FHWA Notices and NBI data

The need for further evaluation of states’ use of funds is underscored in the case of 

Pennsylvania. From FY 2001 to FY 2008, the state chose to transfer 

approximately $1.2 billion to other Federal-aid highway programs. Although 

states have the statutory authority to perform these transfers, the transfers run 

counter to the intent of the HBP, which is to improve the Nation’s bridges. 

According to state officials, the transferred HBP funds were used to improve 

bridge conditions; but they could not provide documentation to prove this. 

FHWA uses NBI data to establish performance goals at the state and national 

levels for improving the condition of deficient bridges. However, FHWA lacks a 

systematic method of coordinating with states to establish such goals. For 

example, FHWA Headquarters provides a baseline of states’ current performance 

with performance targets to Division Offices but does not require them to 

coordinate or share the results with states. Ensuring the effective use of HBP 

funding in improving the condition of deficient bridges nationwide requires that 

FHWA coordinate with states because states determine which projects will be 

federally financed. Further, reports on progress made in achieving goals for 

 15 The National Bridge Inventory is a database maintained by FHWA using data states submit annually on 

the Nation’s approximately 600,000 public highway bridges. 16 According to FHWA officials, FMIS and the NBI were not originally designed to store data linking 

expenditures of HBP funds to improvements made to deficient bridges.
7

improving the condition of deficient bridges can be a source of valuable 

information to internal and external stakeholders on how well the program is 

functioning. For example, FHWA regularly issues a report to Congress that 

provides information on the operational performance of the highway system, 

which could potentially be used to report progress each state has made in 

achieving its goals.17

Critical examination of the effectiveness of bridge funding is necessary given the 

deteriorating condition of structurally deficient bridges on the National Highway 

System (NHS) that carry the majority of the Nation’s bridge traffic. Despite 

increases in HBP funding, from $4.3 billion in FY 2001 to $5.1 billion in 

FY 2008, the deck area of structurally deficient NHS bridges increased by 

5 percent, although the overall number of structurally deficient bridges declined. 

(Additional information on historical trends related to structurally deficient 

bridges is in exhibit B.)

FHWA Lacks the Criteria and Guidance Necessary To Determine 

States' Compliance With Bridge Inspection Standards

Inconsistencies in FHWA’s enforcement of bridge inspection standards under the 

NBIP are attributable to a lack of standard criteria defining how bridge engineers 

should assess states’ overall compliance. Further, FHWA lacks clear and 

comprehensive guidance on what actions bridge engineers should take when states 

fail to substantially comply. As a result, FHWA has little assurance that states 

receiving Federal-aid highway funds adequately comply with bridge inspection 

standards and that bridge engineers consistently address higher priority safety 

risks. FHWA officials stated that initiatives are underway to improve states 

compliance with the NBIS, including the development and implementation of 

criteria and guidance that incorporate data-driven, risk-based bridge oversight. 

However, FHWA has not conducted a workforce assessment to determine what 

resources are needed to implement these initiatives.

Lack of Standard Criteria to Assess States’ Overall Compliance

Despite serious incidents of states’ noncompliance, FHWA Division Offices 

concluded that states are substantially compliant with bridge inspection standards 

because FHWA has not developed standard criteria to assess states’ overall 

compliance. NBIS consists of approximately five general areas of compliance 

with each including numerous requirements to ensure bridge safety. For example, 

the area of inspection frequency includes a requirement that bridges undergo a 

routine inspection at least every 24 months. However, FHWA has not defined 

how the bridge engineers conducting the annual compliance review should make a 

 17 FHWA, “2006 Status of the Nation’s Highways, Bridges, and Transit: Conditions and Performance,” 

January 22, 2007. 
8

determination of states’ overall compliance, such as which areas require greater 

consideration because they pose higher priority bridge safety risks. Consequently, 

Federal-aid highway funds were provided to states with serious incidents of 

noncompliance.

FHWA bridge engineers must report whether a state department of transportation

is, or is not, in substantial compliance with the requirements of the NBIS, but have 

no standard criteria to help them make this determination. Figure 2 below is an 

excerpt from FHWA’s report template that the 52 Division Offices use to record 

the results of the annual NBIS compliance review. The excerpt illustrates that a 

determination of overall compliance is required as part of the review and that no 

explanation is provided as to how bridge engineers should make their 

determination on states’ substantial compliance. 

Figure 2. Excerpt from FHWA’s NBIS Compliance Review Report Template

Source: NBIS Annual Program Review Report Form for 2009, FHWA (emphasis added)

We surveyed Division Office bridge engineers who identified themselves as 

having dealt with compliance-related problems as part of the 2007 and 2008 

annual NBIS compliance reviews and found that they generally agreed that 

FHWA needs better criteria to assess states’ overall compliance. Of the 11 

engineers surveyed, 9 responded that FHWA lacked adequate criteria. We also 

found that respondents were using widely different approaches in completing their 

assessments of states’ compliance. For example, there were respondents who did 

not differentiate between substantial and non-substantial deficiencies when 

assessing compliance and there were differences in how respondents assessed the 

timeliness of bridge inspections. Additionally, based on our analysis of data from 

FHWA’s 2007 annual NBIS compliance review, we found some cases where 

bridge engineers reported substantial compliance in spite of deficiencies that could 

pose serious risks to public safety. For example, one bridge engineer judged a 

state to be substantially compliant despite reporting that the state failed to close 96 

bridges, as required by NBIS. Similarly, a different bridge engineer in another 

state reported that 47 bridges were not closed, as required; but concluded that the 

state was substantially compliant. In two other examples, bridge engineers 

reported states as substantially compliant even though 200 bridges in one case and 
9

over 500 bridges in the other case were not posted with maximum weight limit 

signs, as required.18

Lack of Clear and Comprehensive Guidance Impedes Enforcement 

Actions 

 

FHWA’s lack of clear and comprehensive guidance defining procedures Division 

Offices should follow to enforce compliance has led to inconsistencies in 

enforcement activities and delays in states’ remediation of deficiencies. 

According to FHWA, failure to substantially comply with bridge inspection 

standards is grounds for a suspension of Federal-aid highway funds19 in 

accordance with a statute that authorizes the U.S. Secretary of Transportation to 

withhold funding if Federal-aid highway projects are not being properly 

maintained.20 However, our survey of 11 bridge engineers found that, generally, 

engineers were unclear about when noncompliance could lead to a suspension. 

For example, of the 11 bridge engineers we surveyed, 7 responded that FHWA’s 

guidance did not adequately define when to suspend funds. Further, eight 

responded that noncompliance with any NBIS requirement could be used to justify 

a suspension, whereas three others identified only select NBIS requirements as 

justification for a suspension. 

Survey respondents also supplied evidence that the lack of adequate guidance 

contributes to delays in states’ remediation of deficiencies. For example, two 

bridge engineers reported that they had notified their respective states of scourrelated deficiencies. One state’s corrective action plan adhered to the timeline 

FHWA suggested; but the other state rejected FHWA’s recommended dates and 

extended the deadlines by up to 2 years. In a separate example, it took about 

2 years for a state to comply with NBIS requirements on procedures related to 

critical inspection findings. According to the NBIS, a critical finding is a 

structural or safety-related deficiency that requires immediate follow-up inspection 

or action.

The development of guidance defining FHWA’s procedural steps for enforcing 

compliance with the NBIS is critical to the agency’s efforts to implement datadriven, risk-based bridge oversight. As stated in our January 2009 report, 

FHWA’s annual NBIS compliance review lacked a systematic, data-driven 

method of assessing risks and determining, in coordination with states, what 

 18 Division Office officials informed us that these deficiencies could be attributable to errors in states’ 

bridge databases. However, we found no evidence of concerns about the accuracy of state data in the 

compliance review reports submitted to FHWA Headquarters or of efforts to assess data quality prior to 

concluding that a state was compliant. 19 FHWA, “Compliance with the National Bridge Inspection Standards, Frequency of Inspection and Load 

Posting of Bridges,” May 14, 1985. 20 23 U.S.C. §116 (2006).
10

actions to take to address them. A risk analysis generally involves estimating a 

risk’s significance, assessing the likelihood of its occurrence, and deciding what 

actions should be taken to address it. FHWA’s enforcement actions, such as how 

much time states are given to remediate deficiencies and whether to suspend 

Federal-aid highway funds, should reflect the results of a data-driven assessment 

of a risk’s significance and its possible effect on the safety of the traveling public. 

More assertive enforcement actions would be necessary in those cases where 

higher priority safety risks are identified. 

Lack of a Workforce Assessment Impedes FHWA’s Oversight Initiatives

Although FHWA has initiatives underway to improve states’ compliance with 

bridge inspection standards, it has not conducted a comprehensive workforce 

assessment that prioritizes staffing and training needs. Such an assessment would 

enable the agency to more effectively direct limited funds to higher priority needs. 

Funding for bridge inspector training and workshops is limited because FHWA 

relies exclusively on general operating funds to cover human resource and training 

costs rather than use HBP funds to help cover these costs. However, our review of 

Title 23 found that section 151(d) would permit the use of HBP funds to carry out 

the NBIP.21

CONCLUSIONS

 

Given the needs of the Nation’s approximately 600,000 bridges and the limited 

funding available to invest in their replacement and rehabilitation, FHWA must 

strengthen its efforts to evaluate states’ use of HBP funds in improving the 

condition of deficient bridges nationwide. Current practices do not provide 

assurance that states are using HBP funding effectively in improving the condition 

of deficient bridges. Further, given the potentially catastrophic risks of not 

properly inspecting bridges, FHWA must determine with greater consistency 

whether states complied with the NBIS and define procedural steps for enforcing 

compliance. 

RECOMMENDATIONS

To strengthen its oversight of Federal-aid funds, we recommend that the Federal 

Highway Administrator:

1. Collect and analyze HBP expenditure data on a regular basis to identify 

activities undertaken by states, such as bridge replacement and rehabilitation, 

to improve the condition of the Nation’s deficient bridges.

 21 23 U.S.C. §151 (2006).
11

2. Collaborate with states in setting quantifiable performance targets to measure 

progress in improving the condition of deficient bridges.

3. Report regularly to internal and external stakeholders on the effectiveness of 

states’ efforts to improve the condition of the Nation’s deficient bridges based 

on the analysis of HBP expenditure data and an evaluation of progress made in 

achieving performance targets.

4. Develop detailed criteria to help bridge engineers determine with greater 

consistency whether states demonstrate overall compliance with the NBIS.

5. Develop a policy providing clear, comprehensive, risk-based guidance that 

defines procedures Division Offices should follow to enforce compliance with 

the NBIS.

6. Conduct a workforce assessment so that FHWA can identify strategic needs 

and target limited funding to higher priority staffing and training needs in 

implementing data-driven, risk-based bridge oversight.

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE

We provided a draft of this report to FHWA for review and comment on 

October 22, 2009. FHWA provided us formal comments on December 11, 2009. 

Those comments are included as an appendix to this report.

FHWA concurred with all our recommendations, and its planned actions include 

evaluating the integration of current stand alone systems to improve bridge project 

information, as well as the establishment of clear, comprehensive, risk-based 

guidance for enforcing compliance with the NBIS. FHWA noted that it seeks to 

strike a balance between what is possible and achievable in the near term with 

existing resources, systems, and data and what may be achievable in the future. 

Specifically, FHWA stated that its efforts to obtain information on state use of 

Federal funding for deficient bridges and their resulting improvement in condition 

could be significantly affected by changes to the Federal-aid program and the HBP 

as a result of reauthorization. 

We recognize that potential reauthorization changes, such as modifications to the 

HBP, could impact the specific information gathered on states’ use of bridge 

funding, but we also maintain that taking action prior to reauthorization will make 

it easier to carry out the expected mandates. Based on our analysis of a pending 

congressional proposal for the reauthorization, expected new requirements include 

monitoring each state’s use of Federal funding, setting performance targets for 
12

each state to reduce the deck area of bridges classified as structurally deficient, 

and directing states to report on their use of Federal funding and progress made 

towards meeting performance targets. Consequently, through its efforts in 

response to our recommendations, FHWA should be better prepared for 

implementation of these new requirements as part of the reauthorization. 

ACTION REQUIRED 

FHWA’s actions taken and planned for recommendations 1 through 5 are 

reasonable and subject to our follow-up provisions. In its response to 

recommendation 6, FHWA stated that it conducted a workforce assessment in 

February 2009. In accordance with Department of Transportation Order 8000.1C., 

we request that FHWA provide additional information on the workforce 

assessment and its results within 30 calendar days of the date of this report in 

order for us to determine if it meets the intent of our recommendation and whether 

to close the recommendation. 

We appreciate the cooperation and assistance provided by FHWA representatives 

during our audit. If you have any questions concerning this report, please call me 

at (202) 366-5630.

#
13

Exhibit A. Scope and Methodology

EXHIBIT A. SCOPE AND METHODOLOGY

We evaluated the Highway Bridge Program (HBP) and the National Bridge 

Inspection Program (NBIP) to assess FHWA’s: (1) oversight of Federal-aid funds 

provided to states through the HBP for deficient bridges and (2) enforcement of 

bridge inspection standards under the NBIP, such as suspending Federal-aid 

highway funds when states fail to adequately comply with standards. As part of 

this audit, we examined how FHWA could better implement data-driven, riskbased bridge oversight and incorporated related information from our January 

2009 report as appropriate. This report concludes our audit work for the two 

remaining efforts announced in August 2007 related to FHWA’s oversight of the 

Nation’s bridges.22 

To conduct this audit, we interviewed staff members of FHWA’s Office of Bridge 

Technology, Office of Asset Management, Office of the Chief Financial Officer, 

Office of Policy and Governmental Affairs, and the American Association of State 

Highway Transportation Officials. We conducted site visits in Michigan, 

Kentucky, and Pennsylvania to perform standardized in-depth, in-person 

interviews with FHWA Division Office staff and state transportation officials. 

These states were selected based on our analysis of NBI data from 2001 to 2007 

using a measure of the percentage of deck area on structurally deficient bridges. 

We began our audit with a specific focus on structurally deficient bridges, and 

later added functionally obsolete bridges in our evaluation of FHWA’s oversight 

of HBP funds for all deficient bridges. We identified a substantial reduction in the 

percentage of deck area on structurally deficient bridges for Michigan, an increase 

for Kentucky, and almost no change for Pennsylvania. We also selected 

Pennsylvania because of its unusually high net transfers of HBP funding from 

FY 2001 through FY 2007, which were almost half of all net transfers out of HBP 

for the time period. In addition, we reviewed relevant laws, regulations, policies, 

program documents, and other documentary evidence, including performance 

measures.

We analyzed the results of FHWA’s 2007 annual NBIS compliance review to 

identify compliance-related problems and contacted Division Offices as necessary 

to validate data obtained from the compliance review reports. We also conducted 

two surveys of Division Office staff—an initial survey of all Division Office 

bridge engineers and then a more in-depth, follow-up survey of the 11 engineers 

who identified themselves as having dealt with compliance-related problems as 

part of the 2007 or 2008 annual NBIS compliance reviews. In the follow-up 

survey, we obtained information related to FHWA’s enforcement activities and 

 22 OIG, “Inspector General’s Response to Secretary Peters’ Request for an Assessment of the National 

Bridge Inspection Program,” August 3, 2007.
14

Exhibit A. Scope and Methodology

correspondence regarding enforcement actions taken during 2007 and 2008. We 

conducted the surveys using standardized questionnaires sent via email. 

Further, we obtained and reviewed FMIS data. We intended to use the data to 

identify the impact of HBP funding on structurally deficient bridges. However, 

after we learned that FMIS lacked sufficient data to perform this analysis, we 

focused on identifying the total amount of HBP funding received by the states 

selected for site visits. In evaluating the reliability of FMIS data, we reviewed a 

recent audit performed by an independent auditor, which determined that financial 

statements produced by FMIS were accurate.23 Based on those results, we 

concluded that the data were sufficiently accurate for our purposes.

We started our audit using NBI data from 2001 to 2006 and incorporated 2007 and 

2008 data as they became available. We used data from 2001 to 2007 to select 

states for our site visits and used NBI data over the entire time period in 

developing our findings. Our past work and the work of others have identified 

limitations with NBI data. However, we determined that despite its limitations, 

the NBI is the most comprehensive source of data on bridges nationwide and that 

the data were sufficiently reliable for the purposes of helping to target our 

interviews and, together with other evidence, establish sufficient support for our 

findings and recommendations. We tested a random sample of 2008 NBI data for 

30 highway bridge records, including 10 each from Michigan, Kentucky, and 

Pennsylvania. We also tested several data points used to support our audit 

findings, including bridge condition, dimensions, alignment, and highway system. 

This limited testing of FHWA’s NBI data indicated the data were complete and 

adequately reflected the source data from the states’ bridge records. 

Our audit was conducted from August 2007 through July 2009. We conducted 

this performance audit in accordance with Generally Accepted Government 

Auditing Standards as prescribed by the Comptroller General of the United States. 

Those standards require that we plan and perform the audit to obtain sufficient, 

appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based on our audit 

objectives. 

 23 Independent Auditors’ Report issued by KPMG for U.S. Department of Transportation Highway Trust 

Fund as of September 30, 2007 and 2006.
15

Exhibit B. Background on Historical Trends Related To Structurally Deficient 

Bridges

EXHIBIT B. BACKGROUND ON HISTORICAL TRENDS RELATED 

TO STRUCTURALLY DEFICIENT BRIDGES

According to the National Bridge Inventory (NBI), the number of structurally 

deficient bridges decreased from 83,630 to 71,469, or about 15 percent, from 2001 

through 2008. However, these figures can be misleading in assessing 

improvement in bridge conditions because they do not take into account other 

important factors, such as the size of structurally deficient bridges as measured by 

deck area and the amount of bridge traffic. Table 2 below compares the condition 

of bridges nationwide from 2001 through 2008. During this time frame, although 

the number of structurally deficient bridges declined almost 15 percent, the deck 

area of structurally deficient bridges declined nationwide by a comparatively much 

smaller amount of 2 percent. When focusing specifically on National Highway 

System (NHS) bridges, which carry a large majority of the Nation’s bridge traffic, 

conditions have actually worsened as the deck area of structurally deficient NHS 

bridges increased by 5 percent.

Table 2. Structurally Deficient Bridges

Comparison between 2001 and 2008

Bridges Change

2001 2008 Number Percentage

All Highway Systems 83,630 71,469 (12,161) (14.5%)

NHS 6,643 6,051 (592) (8.9%)

Deck Area (m2) Change

2001 2008 Deck Area (m2) Percentage

All Highway Systems 31,505,907 30,890,605 (615,302) (2.0%)

NHS 12,455,463 13,079,674 624,211 5.0%

Source: OIG analysis using NBI data
16

Exhibit C. Major Contributors to this Report

EXHIBIT C. MAJOR CONTRIBUTORS TO THIS REPORT 

Name Title

Eric Mader Program Director

Christopher Brothers Project Manager

Stephen Gruner Project Manager

Kimberley Bolding Senior Auditor

Michael Dzandza Auditor

Regan Maund Analyst

Jean Tanaka Analyst

Rodolfo Pérez Engineer Advisor

Aron Wedekind Engineer
17 

Appendix. Management Comments

APPENDIX. MANAGEMENT COMMENTS

Subject: INFORMATION: Federal Highway Administration (FHWA) Date: December 11, 2009

 Response to Office of Inspector General (OIG) Draft Report, 

 “Assessment of FHWA Oversight of the Highway Bridge Program

 and the National Bridge Inspection Program” 

From: Victor M. Mendez Reply to

 Administrator Attn. of: HIF/HAIM

 

To: Calvin L. Scovel III

 Inspector General (JA-40) 

 

The FHWA has long recognized the critical importance of highway bridges to the safe and effective 

functioning of our Nation’s highway system. For that reason, the FHWA has established programs 

intended to help States identify deficient bridges, track the condition of those bridges, and target 

funding for bridges. The FHWA’s efforts in this regard have met with some success in improving the 

condition of the Nation’s highway bridges. Over the last 10 years the number of deficient bridges in 

the Nation’s inventory decreased from 31.4 percent to 26.9 percent. 

The FHWA’s existing systems, including the Fiscal Management Information System (FMIS), which 

tracks expenditures, and the National Bridge Inventory (NBI), which tracks bridge specific 

information, have served their intended purpose well for many years. These stand-alone legacy 

systems have enabled the creation and use of the performance measures used to monitor bridge 

conditions today. Creating new performance measures targeted at spending on the structurally 

deficient subset of the Nation’s bridges will challenge the capabilities of these systems. Such 

targeted performance measures will likely require additional data, increased capabilities, and 

potentially new authorities that may be considered through the surface program reauthorization. 

Memorandum
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Appendix. Management Comments

In responding to the report’s recommendations, we are seeking to strike a balance between what is 

possible and achievable in the near term with existing resources, systems and data, and that which 

may be achievable in the future. As we proceed through the course of surface reauthorization, the 

FHWA will be mindful of the report’s findings and recommendations and as possible, will seek those 

enhancements that could enable more detailed tracking of fund use by States on the subset of 

deficient bridges and their accompanying change in condition. The FHWA also agrees that assessing 

and enforcing National Bridge Inspection Standards (NBIS) compliance with greater consistency is 

achievable through data-driven, risk-based bridge oversight. In response to the Phase I OIG audit 

recommendations from January 2009, the FHWA moved forward in developing detailed criteria and 

policy to achieve greater uniformity for determining compliance. 

The following are the OIG draft report’s specific recommendations and our responses.

Recommendation 1: Collect and analyze Highway Bridge Program (HBP) expenditure data on a 

regular basis to identify activities undertaken by states, such as bridge replacement and rehabilitation, 

to improve the condition of the Nation’s bridges. 

Response: Concur. Using the existing legacy systems, the FHWA has fulfilled the Federal-aid 

program requirements under Title 23 of the United States Code. Specifically, the FHWA administers 

the HBP through use of the NBI. The NBI data is utilized to determine States’ bridge needs and 

apportion HBP funds. Additionally, the FHWA monitors and tracks the condition of the Nation’s 

bridges through the NBI. As discussed above, these measures indicate that there is some 

improvement in the overall condition of the nation’s highway bridges. While we recognize that 

potentially useful and effective information could be derived with the collection of more specific 

information on State use of Federal funding on deficient bridges and the resulting improvement in 

condition, it is not clear that this level of specificity is achievable in the near term. 

Recognizing the potential for useful modification to existing performance information, by May 1, 

2010, the FHWA will evaluate possible enhancements for collecting and analyzing expenditures on 

the Nation’s bridges, such as integration of current stand alone systems and collection of more 

detailed project information. Once feasible near term enhancements are identified, the FHWA will 

develop an implementation schedule. It is important to recognize that the outcome of these 

considerations could be significantly affected by any changes to the Federal-aid program and the 

HBP as a result of reauthorization. 

Recommendation 2: Collaborate with States in setting quantifiable performance targets to measure 

progress in improving the condition of deficient bridges.

Response: Concur. Currently, the FHWA strategic plan identifies bridge conditions on all public 

roads as an outcome measure. The FHWA tracks the deck area on deficient bridges as the bridge 

condition outcome measure and has established annual performance targets. In anticipation of an 

increased performance focus moving forward, the FHWA established the Performance Management 

Transition Team, comprised of cross-functional, geographically dispersed members representing 

various FHWA offices, to outline a plan for the Agency to transition to a performance-based Federalaid program, which would include system performance goals and measures. The FHWA will ensure 
19

Appendix. Management Comments

that the goals and performance measures address improvements to bridge conditions, to the extent 

that data and systems are capable. Completion of this effort will be subsequent to the next surface 

authorization, in order to ensure that these goals and measures are in accord with any new 

requirements.

Recommendation 3: Report regularly to internal and external stakeholders on the effectiveness of 

States’ efforts to improve the condition of the Nation’s deficient bridges based on the analysis of the 

HBP expenditure data and an evaluation of progress made in achieving performance targets. 

Response: Concur. Currently, the FHWA regularly issues a report to Congress that provides 

information on the operational performance of the Nation’s highway system – Status of the Nation’s 

Highways, Bridges, and Transit: Conditions and Performance (C&P Report). By May 1, 2010, the 

FHWA will evaluate the possible use of this publication to report on the effectiveness of States’ 

efforts to improve the condition of the Nation’s bridges. Information on States efforts to improve the 

condition of deficient bridges will be offered to the extent possible within the limitations discussed 

above. 

Recommendation 4: Develop detailed criteria to help bridge engineers determine with greater 

consistency whether States demonstrate overall compliance with the NBIS.

Response: Concur. Our comprehensive approach to addressing the Phase I OIG audit 

recommendations from January 2009 incorporates actions that specifically address this 

recommendation. During the 2011 annual review cycle, the FHWA plans to implement a new 

National Bridge Inspection Program (NBIP) oversight process and procedures. The process will 

include specific risk-based criteria for assessing compliance. The FHWA has drafted detailed criteria 

designed to achieve the goal of this recommendation. The draft criteria consists of more than 20 

specific metrics linked to the NBIS regulatory provisions, such as inspection frequency and inspector 

qualifications, with defined risk tolerance levels for compliance, substantial compliance, and noncompliance determination. Application of the defined criteria will improve the consistency in 

determining compliance with the NBIS. The current schedule calls for a number of Division Offices 

to pilot the new process and procedures in 2010 followed by full implementation during 2011. The 

target date for completion of the new process and procedures is December 31, 2010.

Recommendation 5: Develop a policy providing clear, comprehensive, risk-based guidance that 

defines procedures Division Offices should follow to enforce compliance with the NBIS.

Response: Concur. The FHWA has drafted a policy that provides clear, comprehensive, risk-based 

guidance for defining procedures for Division Offices to follow when enforcing compliance with the 

NBIS. It will be introduced in 2011 as part of the new oversight process described in response to 

recommendation 4.

Recommendation 6: Conduct a workforce assessment so that the FHWA can identify strategic 

needs and target limited funding to higher priority staffing and training needs in implementing datadriven, risk-based bridge oversight.
20

Appendix. Management Comments

Response: Concur. The FHWA conducted a workforce assessment in February 2009, and the 

structures discipline was included in the assessment. The results of the assessment are being used for 

multiple purposes including the identification of staff training needs and gaps in knowledge areas and 

skills. Additionally, as noted above, the FHWA plans to conduct a pilot of the new NBIP oversight 

process and procedures during 2010. As part of the pilot, the FHWA will assess the impact of the 

changes on our bridge workforce and identify training needs. Our goal is to implement an approach 

to oversight that is achievable using existing resources. We have begun to explore the use of 

program funds to support oversight of the NBIP. Should additional resources become available in the 

future, we will revisit resource allocation among the higher bridge risk areas faced by the Agency. 

Given the workforce assessments already completed and the plan to assess the impacts associated 

with implementation of the new oversight process, the FHWA considers this recommendation closed.

In closing, the FHWA expresses its appreciation and support of the OIG’s efforts to further improve 

the FHWA’s oversight of the National Bridge Inspection and Highway Bridge Programs. If you have 

any questions or comments regarding this response, please contact Mr. Myint Lwin at (202) 366-

4589.