BEST PRACTICES FOR IMPROVING 

OVERSIGHT OF STATE HIGHWAY SAFETY 

PROGRAMS 

National Highway Traffic Safety Administration 

Report Number: MH-2008-046 

Date Issued: March 25, 2008 
U.S. Department of 

Memorandum

Transportation 

Office of the Secretary 

of Transportation 

Office of Inspector General 

Subject: ACTION: Report on Best Practices for Improving 

Oversight of State Highway Safety Programs 

National Highway Traffic Safety Administration 

Report No. MH-2008-046 

Date: March 25, 2008 

From: Rebecca Anne Batts 

Assistant Inspector General 

 for Highway and Transit Audits 

Reply to 

Attn. of: JA-40 

To: National Highway Traffic Safety Administrator 

This report presents the results of the Office of Inspector General’s (OIG) audit of 

the National Highway Traffic Safety Administration’s (NHTSA) oversight of state 

highway safety programs. This audit was required by the Safe, Accountable, 

Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEALU).1

 Our audit objective was to evaluate NHTSA’s oversight of state highway 

safety programs and identify best practices. 

NHTSA is the lead agency responsible for reducing fatalities, injuries, and 

economic losses resulting from motor vehicle crashes. In keeping with this 

mission, NHTSA’s fiscal year (FY) 

2008 budget provided nearly 

$600 million in formula and incentive 

grants to the states for improving 

highway safety. 

From 2001 through 2006,2 the 

highway fatality rate declined 

6.6 percent, from 1.51 deaths to 

1.41 deaths per 100 million vehicle 

miles traveled.3

 However, as figure 1 

shows, the actual number of fatalities 

increased by 1 percent, from 

Figure 1. Motor Vehicle Fatalities (2001-2006)

42,196

43,005

42,884

42,836

43,443

42,642

40,000 40,500 41,000 41,500 42,000 42,500 43,000 43,500 44,000

2001

2002

2003

2004

2005

2006

Calendar

Year

Fatalities

Source: NHTSA data

 

1

 Section 2008(d), Pub. L. No. 109-59 (2005). 

2

 Throughout this report, unless otherwise indicated, calendar year data are reported. 3

 Fatality rates are computed by dividing the number of fatalities by vehicle miles traveled. 
2

42,196 in 2001 to 42,642 in 2006. NHTSA estimates that motor vehicle crashes 

cost the United States about $230 billion annually. Given these statistics, it is 

crucial that NHTSA provide strong oversight to ensure that limited grant funds are 

used effectively to maximize highway safety. 

We conducted this performance audit in accordance with Generally Accepted 

Government Auditing Standards prescribed by the Comptroller General of the 

United States. Exhibit A contains details on the objective, scope, and 

methodology we used in conducting this audit. 

BACKGROUND 

NHTSA provides highway safety formula and incentive grants to state and local 

governments for conducting highway safety programs, including the promotion of 

seat belt use, the discouragement of alcohol-impaired driving, and a variety of 

other issues. States allocate the grant funds to the government agencies (both state 

and local) and nonprofit organizations that implement behavioral highway safety 

programs. The grants provide funds to identify highway safety problems and to 

implement safety programs. Because Federal regulations hold each state 

responsible for developing individual performance measures, NHTSA cannot 

mandate that states adopt any specific performance measure. 

Each state must submit to NHTSA an annual performance plan and a highway 

safety plan that establish the state’s safety goals and performance measures and 

identify the projects and activities designed to help achieve the safety goals.4

 

Using the performance measures identified in the annual performance plan, states 

are required to submit end-of-year performance reports to NHTSA describing their 

progress in meeting safety goals. NHTSA conducts annual program reviews of 

states’ safety performance plans and highway safety plans to assess whether each 

state has identified measurable safety goals, programmed grant funding for safety 

programs and projects, and made progress in attaining stated performance goals. 

In addition to annual program reviews, SAFETEA-LU requires that NHTSA 

conduct triennial management reviews of each state’s highway safety program.5

 

Based on the management reviews, NHTSA recommends improvements for the 

management and oversight of Federal grant funds. A management review focuses 

on a state’s organization and staffing, financial management, and program 

management practices. NHTSA conducted its first triennial management reviews 

in FY 2005. It also conducts special management reviews when a state 

 

4

 23 C.F.R. § 1200.10 (2007). 

5

 Prior to implementing its management reviews in FY 2005, NHTSA performed similar triennial reviews, known as 

“460-1” reviews. This review process started in 1970 and was revised in 1980 and 1989. In 1996, with the change 

to a performance-based process, the 460-1 review became an optional service provided upon a state’s request. 
3

demonstrates substandard performance and lack of progress in meeting 

performance goals for seatbelt or alcohol-impaired driving programs. 

RESULTS IN BRIEF 

NHTSA has developed detailed guidelines and procedures for oversight reviews of 

state highway safety programs. Although NHTSA’s management reviews 

assessed the program elements required by its guidance, we identified weaknesses 

in NHTSA’s annual program reviews that made it difficult for NHTSA to 

comprehensively assess whether states were on course to meet their safety goals. 

Specifically, NHTSA’s program reviews did not sufficiently (1) ensure that states 

consistently measured performance, (2) assess states’ reporting of performance 

trends, and (3) analyze states’ long-term progress in meeting safety goals. 

NHTSA’s annual program reviews did not sufficiently assess states’ safety 

performance. To ensure that states use grant funds wisely, NHTSA must 

determine which safety programs are most effective in enhancing highway safety. 

NHTSA regularly updates a guide6

 for states that provides science-based traffic 

safety countermeasures. However, NHTSA’s annual program reviews could not 

effectively monitor states’ safety performance because state performance plans 

and reports did not provide comprehensive data and analysis. As a result, NHTSA 

did not: 

• Ensure that states consistently measured performance. Over 56 percent of 

the performance measures we reviewed in state performance plans either 

did not match those in corresponding performance reports or had targets 

that were not measurable. For example, a state’s performance plan 

measured the number of alcohol-related fatal crashes but its corresponding 

performance report measured the alcohol-impaired fatality rate. The lack of 

consistent measures made it difficult for NHTSA to monitor the state’s 

progress in reaching its goal. 

• Assess states’ reporting of performance trends. States provided trend data 

for performance measures, but did not project current trend lines to 

upcoming target milestones. For example, one state set a goal to reduce the 

percentage increase in fatalities by 2008. The state reported fatality trend 

data through 2004, but did not project the trend line through 2008 to show 

whether it could meet the goal. Our analysis showed that the state was not 

on track to meet its goal. Without trend projections, NHTSA’s ability to 

assess states’ performance was limited. 

 

6 Countermeasures That Work: A Highway Safety Countermeasure Guide for State Highway Safety Offices.
4

• Analyze states’ overall progress in meeting safety goals. NHTSA’s 

program review letters to the states commented on 1-year changes in 

overall fatalities, alcohol-related fatalities, and seatbelt use. By focusing on 

1-year changes and excluding longer range trends, NHTSA missed an 

opportunity to comprehensively evaluate long-term performance progress. 

It is essential that states provide NHTSA with comprehensive data and analysis in 

order for NHTSA to assess states’ progress in meeting safety goals. Although 

states have the autonomy to formulate performance measures and plans tailored to 

their specific needs, NHTSA must ensure that state performance is effectively 

reported. 

NHTSA should adopt best practices to improve its grant oversight. NHTSA 

must ensure that Federal grant funds are targeted to programs and projects that are 

most likely to improve highway safety. We identified opportunities for NHTSA to 

better measure the results of its grant programs and enhance the accountability for 

grant funds. Specifically, NHTSA should: 

• Encourage states to adopt consistent performance measures. NHTSA, in 

collaboration with the Governors Highway Safety Association (GHSA), 

identified a set of measures to foster uniformity in planning and measuring 

performance, but states have not consistently adopted them. With consistent 

performance measures, NHTSA could better monitor states’ progress in 

implementing federally funded highway safety programs. 

• Enhance accountability for Federal grant funds. Each year, NHTSA awards 

approximately $600 million in grants to the states for highway safety 

programs. NHTSA works with the states to provide grant management and 

oversight, and its management reviews have resulted in recommendations that 

states correct identified deficiencies in monitoring grantees. However, 

stronger internal control reviews and sample testing of grant expenditures by 

the states are needed to protect Federal grant funds. 

• Electronically track recommendations to states. NHTSA’s regional offices 

tracked the states’ implementation of its recommendations through corrective 

action plans, but their efforts were limited by the manual method used to track 

the recommendations. A nationwide electronic tracking system would allow 

NHTSA to more efficiently share findings and recommendations with other 

regional offices, follow up on unresolved recommendations, and enhance 

quality control through automatic reminders of target action dates, custom 

management reports, and periodic status updates. 
5

We made four recommendations that focused on the actions NHTSA needs to take 

now to more effectively manage its grant funds to maximize highway safety. Our 

full recommendations are listed on page 8. 

In its March 6, 2008, written comments to our draft report, NHTSA concurred 

with our four recommendations. NHTSA also provided an action plan to address 

each of the recommendations. NHTSA’s comments and our response are fully 

discussed on pages 9 and 10. NHTSA’s written comments to our 

recommendations are included in an appendix to this report. 

FINDINGS 

NHTSA Complied With Management Review Guidance, but Did 

Not Sufficiently Assess States’ Safety Performance 

In April 2003, the Government Accountability Office (GAO) recommended that 

NHTSA develop guidance on using management reviews to assist states with 

highway safety programs.7

 In response to this recommendation, NHTSA 

developed detailed oversight guidance for conducting management reviews and 

special management reviews of states’ highway safety programs. We verified that 

NHTSA implemented the requirements prescribed by its management review 

guidance and made constructive recommendations to states for improving grant 

administration, financial accountability, and performance management. NHTSA 

also addressed problems in the seatbelt and alcohol-impaired driving programs. 

Exhibit B provides examples of NHTSA’s recommendations to the states. 

Although NHTSA complied with its guidelines for management reviews, its 

annual program reviews did not effectively monitor states’ safety performance 

because state performance plans and reports did not provide comprehensive data 

and analysis. Specifically, NHTSA did not: 

• Ensure that states consistently measured performance. States did not 

effectively match performance measures identified in performance plans 

with those in annual performance reports, as required.8

 We found that over 

56 percent (183 of 326) of the performance plan measures we reviewed for 

22 judgmentally selected states did not match measures in annual reports or 

had targets that were not measurable. 

For example, for one state’s performance plan, none of the 12 measures we 

reviewed carried over to its annual report and 9 measures had no 

 

7

 GAO Report No. GAO-03-474, “Highway Safety – Better Guidance Could Improve Oversight of State Highway 

Safety Programs,” April 21, 2003. 8

 23 C.F.R. §1200.33 requires that states submit to NHTSA annual performance reports that describe their progress in 

meeting safety goals by using performance measures identified in the annual performance plan. 
6

measurable targets. Another state’s plan measured the actual number of 

alcohol-impaired driving fatal crashes, but its annual report measured the 

alcohol-impaired driving fatality rate per 100 million vehicle miles 

traveled. A third state’s plan did not include a performance measure for 

reducing the number of motorcycle fatalities. This state’s annual report 

included a general measure for reducing motorcycle fatalities but the 

measure did not identify a specific target. Measuring performance in this 

area is crucial as motorcycle fatalities have increased annually for several 

years, from 2,897 in 2000 to 4,810 in 2006. 

The measures that states use in performance plans and annual reports must 

be comparable for NHTSA to effectively analyze performance progress. 

Effective analysis would allow NHTSA and the states to adjust funding 

toward safety programs that have proven to be effective. 

• Assess states’ reporting of performance trends. State performance plans 

and progress reports provided trend data for several performance measures, 

but 20 of 22 judgmentally selected states did not project trend data to 

upcoming target milestones to demonstrate whether the states are on track 

to meet goals. For example, one state set a goal to limit the percentage 

increase in fatalities to less than the percentage increase in vehicle miles 

traveled and population in 2008. In its annual report, the state provided 

trend data on fatalities through 2004, the latest year for which data were 

available, but did not project the trend line through 2008 to show whether it 

could meet the stated goal. Our analysis found that the state was not on 

track to meet its goal. 

Another state set a goal of no more than 70 fatalities in 2008. In its annual 

report, the state provided trend data on fatalities through 2004, but did not 

project the trend line through 2008. The trend line showed that fatalities 

steadily increased in excess of 80 fatalities during the years 2000 through 

2004, an indication that the state was not on track to meet its 2008 goal of a 

maximum of 70 fatalities. Our analysis shows that a trend projection would 

be an effective tool to show states’ progress toward meeting their safety 

goals. 

• Analyze states’ overall progress in meeting safety goals. NHTSA’s 

program review letters did not discuss the overall progress that states made 

toward meeting safety goals. The letters provided analysis of selected 

performance trends that focused primarily on 1-year increases or 1-year 

decreases in overall fatalities, alcohol-related fatalities, and seatbelt usage. 

NHTSA could provide more effective guidance to the states if the letters 

used long-term trend information to comprehensively evaluate, measure, 

and report on whether states are on track to achieve their safety goals. 
7

NHTSA issued revised guidelines to its regional offices to improve and 

standardize its program reviews, beginning with the FY 2007 reviews. 

Specifically, regional offices are to verify that states: (1) specify 

performance measures for each grant program, (2) link measures in the 

performance plan directly to the annual performance report, and (3) develop 

interim measures to indicate project or program success. These 

improvements in the program reviews should help NHTSA and the states 

make prudent decisions on funding safety programs. 

NHTSA Should Adopt Best Practices To Improve Its Oversight 

of State Highway Safety Programs. 

Through our observations of NHTSA’s programs and through discussion with 

officials from other Federal agencies, we identified opportunities for NHTSA to 

enhance the accountability over grant funds provided to the states and to better 

measure the results of its grant programs. Specifically, NHTSA can: 

• Encourage states to adopt a uniform set of performance measures. 

NHTSA and GHSA designed a set of measures to foster uniformity in 

planning and measuring performance. These measures cover the number 

and rate of overall fatalities and injuries, alcohol-related fatalities, and use 

of seatbelts. However, the 22 states we reviewed collectively adopted only 

52 percent of the suggested measures in their performance plans and only 

73 percent of the measures in their performance reports. By coordinating 

with state and local governments to establish common performance 

measures, NHTSA can ensure that it receives the information it needs to 

oversee state performance. NHTSA could enhance comparability among 

states, better track the states’ progress in implementing the highway safety 

programs funded by Federal grants, and target limited grant funds to safety 

programs that result in measurable success. 

• Enhance protections against potential fraud. To improve accountability 

over approximately $600 million in annual formula and incentive highway 

safety grant funds, NHTSA and the states must improve their oversight to 

prevent and detect fraud, waste, and abuse. In accordance with Federal 

regulations, states must monitor grantees’ program performance to ensure 

compliance with Federal requirements. NHTSA conducts project 

monitoring and management reviews to ensure that grant funds are used for 

eligible program and project activities, and its oversight includes limited 

testing of grantee expenditures. NHTSA has made recommendations for 

states to correct deficiencies in monitoring grantees. 

During the past 5 years, at least three OIG investigations of false claims for 

overtime and embezzlement of grant funds resulted in convictions or 
8

administrative action. For example, an OIG investigation found that four 

police officers submitted false documents to receive payment for work not 

performed. Two other investigations resulted in convictions for 

embezzlement from highway safety grants that resulted in $119,000 in 

recoveries. In our opinion, highway safety grant programs would be less 

vulnerable to fraud, waste, and abuse if NHTSA ensured that states 

comprehensively reviewed sub-grantee internal controls and conducted 

sample tests of grant expenditures. 

• Implement a system to electronically track NHTSA’s recommendations to 

states. NHTSA’s regional offices monitor states’ implementation of 

management review recommendations through corrective action plans 

agreed upon by the regional offices and the states, but its efforts were 

limited by the manual method used to track the recommendations. 

NHTSA could improve its oversight by implementing a nationwide 

electronic tracking system. By using the system to monitor state corrective 

action plans, NHTSA’s regional offices could: (1) efficiently share 

recommendations with other regional offices to identify solutions for states 

with similar issues, (2) improve accounting for the disposition of 

recommendations to ensure follow-up for unresolved items during 

subsequent reviews, and (3) enhance quality control through automatic 

reminders of target action dates and the development of custom 

management reports and periodic status updates. 

RECOMMENDATIONS 

We recommend that NHTSA: 

1. Promote the development and adoption of consistent performance measures. 

2. Provide guidance to the states to ensure that state performance reports include 

projected trend lines to allow a determination of whether the state is on track to 

meet highway safety goals. 

3. Encourage states to conduct comprehensive on-site reviews of grantee internal 

controls over grant expenditures, substantive testing of grant expenditures, or 

other procedures designed to prevent and detect fraud, waste, and abuse. 

4. Implement an electronic tracking system for monitoring the disposition of 

oversight recommendations to the states in order to efficiently share finding 

information, follow-up on unresolved recommendations, and enhance quality 

control. 
9

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE 

In its March 6, 2008, written comments to our draft report, NHTSA concurred 

with our four recommendations and provided an action plan to address each of the 

recommendations. In its response, NHTSA also requested that we clarify some 

areas in our report. We incorporated NHTSA’s suggested changes, as appropriate. 

NHTSA’s written comments to our recommendations are included as an appendix 

to this report. 

NHTSA concurred with our recommendations and agreed to take the following 

actions. 

• For recommendation 1, NHTSA initiated a project, in conjunction with 

GHSA, to develop consensus traffic safety performance measures. The 

final report is due to NHTSA in August 2008. NHTSA plans to ensure that 

states incorporate the performance measures into their highway safety 

plans, starting with the FY 2010 plans. NHTSA also plans to increase its 

efforts to align states’ annual performance reports with the performance 

measures and projected targets in the highway safety plans. 

• For recommendation 2, NHTSA stated that it will encourage states to use 

trend line projections in highway safety plans, starting with the FY 2010 

plans. Currently, NHTSA offers a data analysis course to both Federal and 

state employees. Offered through the Transportation Safety Institute, the 

course includes training in the use of trend lines. NHTSA will also ask its 

data contractors to assist states in trend line development and analysis. 

• For recommendation 3, NHTSA stated that it will monitor state grantees 

and oversee the states’ monitoring of sub-grantees, including selective 

grantee on-site reviews. In February 2008, NHTSA reinforced this process 

by issuing new regional monitoring guidelines. NHTSA further stated that 

its focus is on program performance and grant compliance, not financial 

auditing practices. 

• For recommendation 4, NHTSA stated that it will search for a reasonablypriced project management tracking system that will meet its needs. Until 

it locates an appropriate system, NHTSA will continue to use Microsoft 

Excel spreadsheets for tracking state-by-state information on findings, 

management considerations, corrective action plans, and performance 

enhancement plans. It plans to post the spreadsheets for all states on its 

Intranet by the end of calendar year 2008. NHTSA believes that the 

spreadsheets will provide a cost-effective method of sharing findings and 

enhancing quality control across all its regional offices. 
10

We consider NHTSA’s planned actions for our four recommendations to be 

responsive; and therefore, consider the recommendations resolved. We will, 

however, continue to monitor the status of NHTSA’s implementation of our 

recommendations, and the recommendations will remain open until NHTSA 

completes its proposed actions. 

We appreciate the courtesies and cooperation of NHTSA representatives during 

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

(202) 366-5630 or Kerry R. Barras, Program Director, at (817) 978-3318. 

# 

Attachment
11

EXHIBIT A. OBJECTIVE, SCOPE, AND METHODOLOGY 

Our audit objective was to evaluate NHTSA’s oversight of state highway safety 

programs and identify best practices. We determined whether NHTSA developed 

and followed policies and procedures for conducting management reviews and 

special management reviews. Further, we determined the extent to which 

NHTSA’s annual program reviews addressed states’ safety performance measures. 

We also identified best practices for improving NHTSA’s oversight of state 

highway safety programs. 

This performance audit was conducted from May 2006 through December 2007. 

We conducted our work in accordance with Generally Accepted Government 

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

We performed such tests of internal controls as we considered necessary to detect 

fraud, waste, and abuse. Our review of internal controls included a discussion 

with NHTSA officials and observations of its procedures for assessing states’ 

controls over grant funds and its sample testing of the reliability and integrity of 

states’ expenditures of grant funds. 

To accomplish our audit objective, we: 

• interviewed officials from NHTSA Headquarters in Washington, D.C. and 

NHTSA regional offices in Cambridge, Massachusetts; Baltimore, 

Maryland; Fort Worth, Texas; and San Francisco, California. 

• interviewed the consultant hired by NHTSA regarding efforts to assist the 

development of NHTSA’s oversight procedures and guidelines, train 

NHTSA’s regional office staff on conducting management reviews and 

special management reviews, and ensure that NHTSA’s guidelines were 

consistently applied. 

• interviewed selected state and non-profit organization officials regarding 

NHTSA’s management review process. 

• interviewed officials from GAO and the Departments of Education, Health 

and Human Services, Housing and Urban Development, and Transportation 

regarding best practices for grant oversight reviews. 

• reviewed NHTSA’s Management Review Process Resource Manual to 

identify its policies, procedures, and guidelines for conducting management 

reviews and special management reviews. This manual documented 

20 required elements for management reviews and 6 elements for special 

management reviews, which we used as criteria for determining NHTSA’s 

compliance with its own policies and procedures. 

Exhibit A. Objective, Scope, and Methodology 
12

• accompanied NHTSA teams to observe management reviews in Vermont 

and Louisiana and special management reviews in Idaho and Arkansas. 

• judgmentally selected and reviewed supporting documentation for 11 of 

22 management reviews and 6 of 11 special management reviews NHTSA 

completed as of February 2007 to determine whether NHTSA addressed the 

required management review and special management review program 

elements. We selected the reviews completed by NHTSA region 3 (midAtlantic) and region 6 (south central) because of their geographic proximity 

to OIG Headquarters and field offices. We also selected reviews completed 

by the NHTSA region 9 (western) to provide coverage of western states. 

We reviewed the reports for 22 judgmentally selected management reviews 

and 11 judgmentally selected special management reviews to determine 

whether NHTSA made constructive recommendations for improving safety. 

• reviewed supporting documentation for NHTSA program reviews and 

compared state performance plans and annual performance reports for 

22 judgmentally selected states. We selected states that were in the 

jurisdiction of the NHTSA regions we visited and to provide a cross-section 

of states that received various amounts of highway safety funding. We 

assessed the plans and reports for the effectiveness of performance 

reporting, alignment of performance measures between the performance 

plans and annual reports, evidence that states projected performance trends 

to goal milestones, comprehensive evaluation and reporting of state safety 

performance, and state adoption of GHSA performance measures. 

• consulted with our criminal investigative staff to identify cases of grant 

fraud. We also interviewed NHTSA regional personnel during site visits 

regarding grantee fraud. 

Exhibit A. Objective, Scope, and Methodology 
13

EXHIBIT B. EXAMPLES OF NHTSA’S RECOMMENDATIONS TO 

THE STATES 

NHTSA made constructive recommendations to the states to improve grant 

administration, program management, financial accountability, and the 

administration of the seatbelt and alcohol-impaired driving programs. Selected 

examples of these recommendations follow. 

Management Review Recommendations 

• Strengthen controls for equipment purchases to ensure proper accounting and 

inventory. This recommendation was made in 12 of 22 management reviews 

completed as of February 2007. For example, one grant lacked documentary 

support for expenditures on five blood alcohol content machines and software 

valued at approximately $113,000. 

• Improve project monitoring and develop written policies and procedures to 

ensure sub-grantees’ compliance with laws, regulations, and grant agreements. 

This recommendation was made in 18 of 22 management reviews. For 

example, 42 percent of grants reviewed for one state had no evidence that the 

state performed monitoring of the sub-grantees. 

• Promptly spend grant funds in the year received. This recommendation was 

made in 9 of 22 management reviews completed as of February 2007. For 

example, NHTSA found that one state spent only 25 percent of the funds 

received, compared to the normal 75 percent spending rate. 

Special Management Review Recommendations 

• Create an environment conducive for passing a primary seatbelt law by 

communicating the benefits to the public and to the state legislature. 

• Request an assessment of the state’s occupant protection program to identify 

best practices and recommend improvements for increasing seatbelt use. 

• Hire a law enforcement liaison to assist in developing local projects and to 

coordinate with local law enforcement agencies. 

• Focus on concentrated enforcement and publicity for alcohol-impaired driving 

programs, mirror national priorities to curb impaired driving, and actively 

promote the annual crackdown to ensure that at least 65 percent of the 

population is covered by sustained enforcement activities. 

Exhibit B. Examples of NHTSA’s Recommendations to the States 
14

EXHIBIT C. MAJOR CONTRIBUTORS TO THIS REPORT 

THE FOLLOWING INDIVIDUALS CONTRIBUTED TO THIS REPORT. 

Name Title 

Kerry R. Barras Program Director 

Craig A. Owens Senior Analyst 

Alvin B. Schenkelberg Senior Auditor 

Stuart I. Weibel Senior Auditor 

Farrin Tamaddon Analyst 

Harriet E. Lambert Writer-Editor 

Petra Swartzlander Statistician 

Exhibit C. Major Contributors To This Report 
15

APPENDIX. NHTSA COMMENTS 

 Memorandum

U.S. Department 

of Transportation 

National Highway 

Traffic Safety 

Administration 

Subject: Corrective Action to Draft Report Date: on Best Practices For Improving 

 Oversight of State Highway 

 Safety Programs 

 [Signed on March 6, 2008] 

 From: James F. Ports, Jr. Reply to Kerry R. Barras

 Deputy Administrator Attn. Office of the Inspector

 X62775 General 

 (817)978-3318 

 To: Rebecca Anne Batts 

 Assistant Inspector General for 

 Highway and Transit Audits

Attached are the National Highway Traffic Administration (NHTSA) proposed responses and 

corrective actions to address the four recommendations in the Office of the Inspector 

General’s recent Audit of the NHTSA’s Best Practices For Improving Oversight of State 

Highway Safety Programs, forwarded to us on February 7, 2008. 

NHTSA looks forward to continue working with the States to establish programs that will 

decrease fatalities and injuries on the Nations roadways. 

Additionally, we have some proposed changes to the text of the report, which is also attached. If 

you have any questions on this response, please contact Antonyio Johnson, our OIG Liaison at 

X6-1490. 

Attachments 

APPENDIX. NHTSA COMMENTS 
16

NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 

RESPONSE TO OIG DRAFT REPORT 

TITLE: Audit of the National Highway Traffic Safety Administration’s Best 

Practices for Improving Oversight of State Highway Safety Programs. 

PROJECT NUMBER: 06M3002M000. 

NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 

CORRECTIVE ACTIONS 

NHTSA provides highway safety formula and incentive grants to States to 

establish programs that will decrease fatalities and injuries on the Nations 

roadways. As a requirement of receiving funds, States must submit annual 

performance and highway safety plans that discuss annual and long term goals, 

define performance measures and identify projects. At the end of each fiscal year 

an annual report must be submitted to NHTSA that describes progress toward 

meeting the annual goals. To assist States with this process, NHTSA reviews and 

comments on the above documents and conducts monitoring no less than 

quarterly. In addition, management reviews (MR) that look at organization and 

staffing, program management and fiscal management are conducted triennially 

and special management reviews (SMR) are conducted with those States 

demonstrating below average performance. We do not conduct audits. . 

NHTSA generally concurs with the OIG recommendations. However, NHTSA 

works in an environment where we have been criticized for being over 

prescriptive, and therefore we work to strike a balance between guidance that 

ensures compliance with Federal regulations and sound management practices 

while at the same time allowing States the freedom to identify develop, manage, 

and evaluate their own traffic programs. 

Recommendation 1: Promote the development and adoption of consistent 

performance measures. 

Response: Concur. 

Corrective Action 1: NHTSA, in conjunction with the Governors Highway 

Safety Association, has initiated a project to develop consensus traffic safety 

performance measures. The final report is due to NHTSA in August of 2008, and 

then NHTSA will encourage States to incorporate the performance measures into 

their Highway Safety Plans (HSPs), beginning with the FY 2010 plans. We will 

APPENDIX. NHTSA COMMENTS 
17

also redouble our efforts to align States’ annual performance reports with the 

performance measures and projected targets in their HSPs. 

Recommendation 2: Provide guidance to States to ensure that State performance 

reports include projected trend lines to allow a determination of whether the State 

is on track to meet highways safety goals. 

Response: Concur. 

Corrective Action 2: While NHTSA has no statutory authority to compel States 

to use trend line projections, we will encourage States to use trend line projections 

in HSPs starting with their FY 2010 plans. Currently NHTSA offers to both State 

and Federal employees a Data Analysis Course (which includes training in the use 

of trend lines) through the Transportation Safety Institute. NHTSA will also ask its 

data contractors to assist States in trend line development and analysis. 

Recommendation 3: Encourage States to conduct on-site comprehensive reviews 

of grantee internal controls over grant expenditures, substantive testing of grant 

expenditures, or other procedures designed to prevent and detect fraud, waste and 

abuse. 

Response: Concur. 

Corrective Action 3: NHTSA Regional offices currently monitor State grantees 

and monitor how States monitor sub-grantees, including selective on-site reviews. 

This process was just reinforced with the issuance of new Regional Monitoring 

Guidelines in February 2008. However, the agency focus is on program 

performance and grant compliance, not financial auditing practices. 

Recommendation 4: Implement an electronic tracking system for monitoring the 

disposition of oversight recommendations to States in order to efficiently share 

finding information, follow-up on unresolved recommendations and enhance 

quality control. 

Response: Concur 

Corrective Action 4: NHTSA is currently researching project management 

tracking systems and available technologies. We are currently unaware of any 

reasonably-priced system that will meet the agency’s needs, but will continue to 

explore options. As an interim measure, NHTSA will continue to use excel 

spreadsheets for tracking State by State information on findings, management 

considerations, corrective action plans and performance enhancement plans. 

However, the spreadsheets for all States will be posted on our intranet by the end 

APPENDIX. NHTSA COMMENTS 
18

of calendar year 2008, so all employees have access to the information. The 

Agency feels this is a cost effective way to share MR and SMR findings and 

enhance quality control across the Nation. 

APPENDIX. NHTSA COMMENTS 
The following page contains a textual version of the figure found in this document. 

This page was not in the original document but has been added here to 

accommodate assistive technology. 
Best Practices for Improving Oversight of State Highway Safety Programs 

Figure 1: Motor Vehicle Fatalities (2001-2006) 

The figure is a bar chart showing the number of motor vehicle fatalities by 

calendar year from 2001 through 2006. 

2006 42,642 

2005 43,443 

2004 42,836 

2003 42,884 

2002 43,005 

2001 42,196 

Source: NHTSA data.