Office of Inspector General

Audit Report

FHWA PROVIDES SUFFICIENT GUIDANCE AND 

ASSISTANCE TO IMPLEMENT THE HIGHWAY 

SAFETY IMPROVEMENT PROGRAM BUT COULD 

DO MORE TO ASSESS PROGRAM RESULTS

Federal Highway Administration

Report Number: MH-2013-055

Date Issued: March 26, 2013
U.S. Department of

Memorandum

Transportation

Office of the Secretary

of Transportation

Office of Inspector General

Subject: ACTION: FHWA Provides Sufficient Guidance 

and Assistance To Implement the Highway Safety 

Improvement Program but Could Do More To 

Assess Program Results

Federal Highway Administration

Report Number MH-2013-055

Date: March 26, 2013

From: Joseph W. Comé

Assistant Inspector General 

 for Highway and Transit Audits

Reply to 

Attn. of: JA-40

To: Federal Highway Administrator

Reducing the number of fatalities and serious injuries on our Nation’s highways 

continues to be a top safety priority for the Department of Transportation (DOT). 

The Federal Highway Administration’s (FHWA) Highway Safety Improvement 

Program (HSIP) is the primary DOT program for reducing fatalities and serious 

injuries on roadways through infrastructure improvements, such as guard rails or 

rumble strips. HSIP has received approximately $8.4 billion in funding from 2006 

through 2011. The current surface transportation authorization, the Moving Ahead 

for Progress in the 21st Century Act (MAP-21),

1 continues HSIP and increases its 

funding to roughly $2.4 billion per year for the next 2 years. Given the major 

contribution HSIP is intended to make to highway safety and the large funding 

levels involved, we initiated this audit to assess whether FHWA (1) provides 

sufficient guidance and assistance to enable the States to effectively implement the 

data-driven, performance-based approach called for in HSIP legislation and 

(2) evaluates HSIP results, which States report to FHWA annually, to determine 

the program’s impact.

To conduct our audit, we reviewed laws, regulations, and guidance pertaining to 

HSIP and interviewed FHWA Office of Safety staff responsible for the program. 

We collected and evaluated the annual reports submitted by each of the 50 States

and the District of Columbia in 2011 to determine how responsive States were to 

HSIP requirements and guidance. Based on this information, we interviewed 

 1 The Moving Ahead for Progress in the 21st Century Act (MAP-21), Pub. L. No. 112-141 (2012).
2

FHWA Division and State transportation officials about program implementation 

from a statistically selected sample of nine of 51 States. We also reviewed 

different methods States used to identify the impact of HSIP-funded projects and 

those the FHWA Office of Safety used to evaluate the impact of HSIP nationally. 

We conducted our work between February 2012 and January 2013 in accordance 

with generally accepted Government auditing standards. Exhibit A provides more 

detail on our audit scope and methodology.

RESULTS IN BRIEF

FHWA provides sufficient guidance and technical assistance to the States to 

implement HSIP in accordance with current requirements that permit substantial 

State flexibility. As required by law, States used safety data to select HSIP 

projects and develop performance-based programs. Overall, our review of States’ 

2011 HSIP reports found that 98 percent of States met program requirements and 

92 percent followed FHWA’s program guidance on reporting. This guidance is 

widely available on the Agency’s website and covers collection and use of 

highway safety data, development of Strategic Highway Safety Plans (SHSP),2

and reporting. FHWA also provides technical assistance and training on program 

implementation through its Division Offices; webinars; and the Roadway Safety 

Peer-to-Peer Program, which connects State transportation agencies seeking best 

practices or technical assistance with experts in other States. As a result, States 

have the guidance and assistance needed to meet basic program requirements 

while retaining the flexibility to implement HSIP to address State-specific 

highway safety needs.

FHWA periodically evaluates HSIP results and other traffic safety information 

reported by the States, but conclusions from these evaluations are limited and 

FHWA does not have an effective way to regularly use program data to report 

HSIP results nationwide. This is largely because States provide varying types and 

quantities of data to FHWA in their annual HSIP reports, even though the States

all met the current legal reporting requirements on what information to include.

For example, some States report crash data for every location receiving HSIP 

funds while others report aggregated crash data for all locations. The Safe, 

Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users 

(SAFETEA-LU)

3 made these data reporting requirements less prescriptive in 2005

than the prior law,

4

 2 Each State is required to develop a SHSP to identify highway safety performance goals and a project selection 

process. 

and they were not altered by MAP-21. Also, the effect of 

specific HSIP-funded infrastructure improvements is difficult to isolate from other 

3 The Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU), Pub. L. 

No. 109-59 (2005). 4 The Transportation Equity Act for the 21st Century (TEA-21), Pub. L. No. 105-178 (1998). 
3

infrastructure and behavioral factors that also contribute to crashes, fatalities, and 

serious injuries with the modeling tools currently available. FHWA has efforts 

underway to address data inconsistencies, such as an optional online reporting tool 

launched in 2011 to standardize how annual HSIP reports are collected from the 

States. However, State officials have cited problems with using and accessing the 

tool. Moving forward, MAP-21 will eventually require more consistency in safety 

data collection outside of HSIP to assess progress toward new national safety 

goals and related performance measures. FHWA could use this data, in 

combination with information on HSIP projects and obligations, to improve 

evaluations of HSIP’s national results. 

We are making recommendations to further enhance FHWA’s ability to (1) collect 

consistent, useful information with the online reporting tool and (2) more 

accurately assess HSIP’s national impact.

BACKGROUND 

States administer HSIP, with oversight from the FHWA Division Offices. Program 

rules and guidance are provided by the FHWA Office of Safety, which also 

coordinates technical assistance. Each State has developed a SHSP to describe a 

program of strategies to reduce or eliminate safety hazards. States annually submit 

HSIP reports to FHWA Division Offices, detailing their progress toward meeting 

safety goals and strategic areas, which are finally submitted to the FHWA Office 

of Safety. A variety of public roadway safety improvement projects are eligible for 

HSIP funding and may be federally funded at either 90 percent or 100 percent. For 

example, a State could use HSIP funds to reduce horizontal curve crashes by 

implementing warning signs, median barriers, or guard rails. FHWA also helps

States focus on improved data collection, using data to identify problems, and 

analytical tools and processes to identify and prioritize safety projects. 

SAFETEA-LU mandated that States improve the accuracy, completeness, 

uniformity, and accessibility of crash data needed to identify safety priorities for 

all public roads. States were required to develop performance goals (e.g., decrease 

impaired driving by 5 percent) and implement a crash data system but were no 

longer required to do project assessments for HSIP.

5

 5 Law pertaining to the Highway Safety Improvement Program is codified at 23 U.S.C. §148 (2005).

The structure of HSIP was 

not significantly altered by MAP-21. FHWA guidance still includes best practices 

for project assessments—including how many years of data should be reviewed 

before and after an improvement is made to look for impacts on crashes, fatalities, 

and serious injuries.
4

FHWA PROVIDES SUFFICIENT GUIDANCE AND ASSISTANCE TO 

THE STATES TO IMPLEMENT HSIP 

The FHWA Office of Safety provides sufficient guidance and technical assistance 

to the States to implement HSIP in accordance with current requirements that 

permit substantial State flexibility. The effectiveness of this guidance and 

assistance is reflected by the high level of compliance with requirements that we 

found among annual reports prepared by the States.

FHWA Provides States with Substantial HSIP Guidance and Support 

To Implement HSIP 

FHWA provides extensive written guidance on use of highway safety data, 

development of SHSPs, and reporting that is widely available on its website and 

routinely used by the States in key areas of HSIP implementation. Exhibit B 

provides more examples of FHWA’s guidance. The guidance is oriented to 

meeting legal requirements and promoting best practices. For example, FHWA’s 

HSIP reporting guidance describes required elements and suggests effective data 

reporting formats. The reporting guidance also suggests four sections the States 

should include in their annual reports: (1) HSIP program structure, (2) progress in 

implementing HSIP projects, (3) assessment of the effectiveness of the 

improvements, and (4) information on the High Risk Rural Roads program. This 

integrated approach to information about reporting, as well as other topics covered 

by FHWA’s HSIP guidance, allows for an organized but accessible collection of 

centralized, written guidance that States may use.

FHWA provides technical assistance and best practices for implementing HSIP to 

the States through its Division Offices, the Roadway Safety Peer-to-Peer 

Program,

6

 6 The Roadway Safety Peer-to-Peer Program is a component of HSIP managed by the FHWA Office of Safety. The 

program is used to facilitate communication between States to share best practices, examine specific problems, or 

conduct peer reviews of State HSIPs.

and FHWA Office of Safety web-based training courses. State officials 

we interviewed used these resources and found them useful. Specifically, these 

officials reported that they routinely received assistance from Division Offices in 

interpreting requirements or FHWA guidance and also had positive experiences 

with the Peer-to-Peer Program as either providers or recipients of information 

about best practices. For example, one State developed a robust highway safety 

data trend analysis process, which it provided to several States through this 

program. The FHWA Office of Safety also shared technical assistance with the 

States by creating and posting a series of webinars on the program website. 
5

States’ Annual Reports Reflect Overall Compliance With FHWA’s 

HSIP Requirements 

The effectiveness of FHWA’s guidance and assistance is reflected by States’ high 

level of compliance with requirements. All annual reports that States and the 

District of Columbia submitted in 2011 met statutory requirements,

7 and reports 

from 50 of 51 States8 (98 percent) met the more detailed requirements issued by 

the agency.

9 Reports from 47 of 51 States10

Consistent with HSIP program requirements, the States were collecting required 

data on crashes, fatalities, and injuries and using it to select HSIP projects in a 

data-driven manner. All States reported highway safety trends, and 27 States

provided additional information on project assessments that was not required. For 

example, 

(92 percent) were consistent with 

FHWA’s reporting guidance. 

• Wisconsin provided a summary of the results of evaluations, which used the 

data-driven practices provided by FHWA guidance, for its HSIP projects 

completed in fiscal year 2008. Each project had a benefit-cost analysis within a 

defined period. Projects were broken down by project type, and the State used

crash data from the before and after project periods to develop benefit-cost 

ratios. These evaluations were also aggregated by safety improvement type to 

help provide an overall summary of progress. All crashes in the before and 

after periods were categorized by crash severity, injury severity, and type of 

collision.

• Iowa conducted and provided FHWA with the results of a HSIP effectiveness 

assessment. The assessment provided crash data for projects that were

evaluated based on 7 fiscal years (2001 to 2007) for sites modified by 43 HSIP 

projects. The State compared injury and crash data for these specific locations 

3 to 5 years before and after the HSIP project was completed. Information on 

road type, improvement type, fatalities, serious injuries, minor injuries, 

possible/unknown injuries, and property damage was also provided, and the 

State used this information with project cost information to calculate benefit 

cost ratios.

 7 23 U.S.C. §148 (2005). 8 Wyoming did not meet a CFR requirement to include information on the High Risk Rural Road Program in its 

annual HSIP report. 9 23 C.F.R. Part 924. 10 Maine, Oregon, Texas, and Wyoming did not follow all elements of FHWA’s guidance for annual reports.
6

FHWA CONDUCTS LIMITED EVALUATIONS OF STATE 

REPORTED HSIP DATA TO REPORT ON THE PROGRAM’S 

IMPACT

FHWA uses information provided by the States in their annual reports to 

periodically evaluate aspects of HSIP, but the results are limited and FHWA does 

not regularly report on the program’s national impact. This is largely because the 

information FHWA receives in States’ annual HSIP reports varies from State to 

State even though it meets program requirements. In addition, it is difficult to 

isolate the effect of specific HSIP-funded projects on improving traffic safety. 

FHWA has efforts underway to address data inconsistencies, which will be 

important given broader requirements beyond HSIP in the new highway 

reauthorization, MAP-21. 

FHWA’s Evaluations of HSIP Are Limited Due to Inconsistent Data 

from the States and the Difficulty of Isolating HSIP’s Safety Impact 

The information FHWA receives in the annual HSIP reports meets program 

requirements, but each State varies in the type and amount of data it includes. 

Specifically, the States vary in their crash and safety data collected, performance 

metrics, and methods used for project selection, evaluation of results, and data 

analysis. With inconsistent information, FHWA periodically uses States’ annual 

reports to identify best practices and challenges, such as States using more robust 

data analysis methods. However, FHWA does not regularly compile and report 

HSIP data such as number, type, and cost of projects that could be used to show 

the national results of the program to stakeholders, Congress, or the public. For 

example, in fiscal year 2011, States obligated $1.5 billion to 4,402 projects 

through HSIP, but FHWA does not report State-specific information on project 

categories or costs.

11

Fatality and serious injury data provide an example of inconsistent data collection 

and reporting among the States from the 2011 annual HSIP reports. Among the 

annual reports we reviewed, some States reported fatality and serious injury data 

for every HSIP-funded project, while other States provided aggregate data

Without such information, FHWA cannot conduct multiyear, national comparisons of project types, spending levels, and program results.

12

 11 Among 11 States that reported this information, intersection safety, pavement improvement, and barrier installations

were among the most common project types.

—

limiting FHWA’s ability to compile results, make comparisons, and assess Statewide or highway system-wide improvements. Much of the inconsistencies in 

reported data stem from the less detailed reporting requirements under SAFETEA12 For example, some States reported fatality and serious injury data for every HSIP-funded project, from 2006 to 2010, 

while other States provided aggregate data for assessing State-wide or system-wide improvements.
7

LU, which were retained in MAP-21, and a related Agency rule.

13

For example, prior to SAFETEA-LU, assessments of HSIP-funded projects were 

required, but after the SAFETEA-LU changes were implemented in 2009 by 

FHWA through a 2008 rule, they were made optional. After the 2008 rule, one 

State began conducting fewer project assessments and no longer reports before 

and after assessments of its HSIP projects. By 2011, only 27 States included 

optional information for individual assessments or comparison of costs and 

benefits for HSIP-funded projects. However, even among the reports that included 

project assessment information there was inconsistency in the number of projects 

assessed or in the duration of the before or after period used to conduct the 

assessments. For example, before and after periods ranged from 2.5 months to 

5 years even though FHWA guidance recommends—but does not require—a 

minimum of 3 years of crash data for these types of project assessments. 

States have 

great discretion in implementing HSIP, particularly as to how or even if the State 

evaluates projects and its HSIP program.

Inconsistent types and amounts of data across various time periods cannot be used 

to make useful comparisons of HSIP implementation among States or across the 

years. For example, one State official stated that analyzing HSIP results is possible 

only if States are reporting back on the same data years and performance 

measures. He also observed it would be difficult to normalize data among rural 

and urban States, but that comparison of improvement types across functional 

classes of roads could allow for measurement of aggregate program impact. 

FHWA officials also observed that the inconsistent data and the limited modeling 

tools available make it difficult to isolate the effect of specific HSIP-funded 

infrastructure improvements from other infrastructure and behavioral factors that 

also contribute to crashes, fatalities, and serious injuries. For example, a crash 

could be caused by multiple factors such as a poorly designed intersection, a driver 

who is texting, and a wet road surface. 

FHWA has tried alternative methods of evaluating HSIP results nationwide but 

remains limited to using annual data reported by the States for periodically 

identifying problems or best practices. For example, FHWA compared obligation 

rates from 2006 through 2009 to 3-year averages of fatality rates among the States 

from 2000 through 2008 but found no correlation. FHWA also calculated a 

14:1 return on investment for HSIP and reported this in agency budget documents, 

but the calculation relies on several major assumptions (e.g., the effectiveness of a 

project does not change over time) and is based on data from a small number of 

States. Accordingly, this calculation is not necessarily a reliable indicator of the 

program’s national impact.

 13 “Highway Safety Improvement Program, Final Rule.” Federal Register Vol. 73. No. 248 (December 24, 2008) 

p.78959.
8

FHWA Has Efforts Underway To Address Data Consistency but Can 

Improve Its Online Reporting Tool

FHWA deployed its online reporting tool and associated training in 2011 that 

could lead to more consistency in the types and amount of HSIP data that States 

annually report. Use of this tool is not required, but 16 States14

While the online tool prompts users with identical requests for project evaluation 

data, there are still inconsistencies in what States report. For example, in 2011 one 

State provided data for nine projects while another provided data for only one 

project. Also, when States provide data through the online reporting tool, the 

information is often uploaded in a format (i.e., Adobe PDF) that does not allow the 

data to be easily compiled or manipulated to conduct analysis. These shortcomings 

obscured the information States were attempting to communicate about their 

implementation of HSIP. 

used the tool in 

2011 to submit HSIP reports, and FHWA stated 27 States used the tool in 2012. 

Based on our review, all but one of the reports generated with the online reporting 

tool met requirements and followed guidance. However, FHWA can do more to 

enhance this tool as we found the reports it generated were sometimes difficult to 

read with missing information, poor formatting, and error messages. 

Officials in six States we interviewed noted the positive impact of the online tool’s

consistent reporting template, but they also noted problems that could discourage 

States from abandoning their existing, individualized report processes in favor of 

using the tool. One problem State officials noted is that the tool is not easy to use. 

The tool generated truncated answers to questions that did not flow from one to 

the next and did not print in a readable format. Officials from two States we 

interviewed were also concerned that the tool requires sharing of personal 

information by staff (e.g., photo identification, home address) to set up access, 

which could lead to issues regarding privacy and security of personally 

identifiable information. Another significant criticism of the tool among State 

officials was that the online reporting tool does not facilitate dissemination of 

State HSIP data. One State could not upload data it wanted to include in its annual 

report that was not technically required and did not find that changes to the tool’s 

data fields and codes were explained by FHWA in updated guidance or other 

communications. Another found that answers provided in the pull-down menus for 

some of the fields did not fit the information State officials wanted to report, so 

staff had to choose the response that was the closest to the State’s answer, but not 

necessarily correct. Unless FHWA modifies the online reporting tool to address 

some of these concerns, it may not be widely used.

 14 Sixteen States submitted their reports using the online reporting tool in 2011, but 2 additional States submitted their 

reports both online and in hard copy. Our office received only the hard copies of these reports. 
9

Another FHWA effort to improve data consistency is use of its Model Inventory 

of Roadway Elements (MIRE).

15 MIRE defines the critical inventory and traffic 

data elements needed to analyze safety data using SafetyAnalyst or similar 

programs. In August 2011, FHWA issued HSIP guidance on which MIREs 

(fundamental data elements) should be collected and reported for HSIP. Use of 

these 38 fundamental data elements was not required, but FHWA identified them 

as ways to help States collect more consistent and useful highway safety data (i.e., 

data on crashes, roadways, and traffic). Among the States we interviewed, 1 State 

collected data for significantly more fundamental data elements—31 of the 

38 elements—to identify excess crashes on its roads than the other States. FHWA 

requires States to collect data on 16 of the elements on all Federal-aid highways 

for the Highway Performance Monitoring System.16

FHWA Has an Opportunity To Leverage MAP-21 Data Improvements 

To Regularly Assess HSIP 

Using a uniform set of 

fundamental data elements allows comparison of crashes throughout the United 

States.

MAP-21 requires DOT to establish performance measures that cut across several 

programs, including those focused on safety. HSIP is the primary FHWA program 

that will contribute to the new MAP-21 safety goal to reduce fatalities and serious 

injuries.

17

 15 In 2007, FHWA released a report listing roadway inventory and traffic elements critical to safety management. 

There are now over 200 elements on this comprehensive list which are divided among 3 broad categories: roadway 

segments, roadway alignment, and roadway junctions. These elements include those needed for SafetyAnalyst—a set 

of software tools from AASHTO used by State and local highway agencies to identify safety improvement needs and 

analyze results.

Under MAP-21, DOT is required to define specific performance 

measures and monitor States’ progress toward achieving their targets for these 

measures. MAP-21 also requires States to identify performance targets, collect and 

analyze data, and report progress toward meeting targets as part of the agencywide performance management effort. Preliminary work toward meeting these 

requirements is underway. FHWA’s four related performance measures are the 

number of fatalities, number of serious injuries, fatalities per vehicle miles 

traveled, and serious injuries per vehicle mile traveled. FHWA officials stated that 

they will work closely with the National Highway Traffic Safety Administration to 

define these performance measures. States will set their own targets for these four 

measures, and FHWA is responsible for monitoring States’ progress. 

16 The Highway Performance Monitoring System is a nationwide inventory system that includes data for all of the 

Nation’s public road mileage as annually certified by the States. The data reflect the extent, condition, performance, 

use, and operating characteristics of the Nation’s highways. 17 MAP-21 established seven national goals: safety, infrastructure condition, congestion reduction, system reliability, 

freight movement and economic vitality, environmental sustainability, and reduced project delivery delays. The law 

requires DOT to establish, with input from States and local agencies, performance measures for these goals through a 

rule within 18 months.
10

HSIP will play an important role in reporting State progress toward meeting the 

targets set for these performance measures. Monitoring States’ progress toward 

FHWA’s four safety measures—and potentially reporting on progress at a national 

level—will require collection and assessment of consistent safety data that the 

Agency currently lacks. Therefore, FHWA faces the challenge of continuing to 

assess and enhance its ongoing efforts to improve HSIP data consistency as they 

will be important to helping it ensure States meet MAP-21 performance targets. 

MAP-21 sets penalties for not meeting safety targets, underscoring the importance 

of making improvements to States’ existing data. If a State does not make 

significant progress toward targets for reducing fatalities or serious injuries within 

a certain period, then that State must dedicate a specific amount of funding to 

safety-related projects, based on its HSIP funding for the prior year, and prepare 

an annual implementation plan.

Performance measures defined through the MAP-21 process could provide a 

common metric to assess HSIP results, though their development is only in the 

early stages. Currently, in their HSIP annual reports, States are required only to 

describe how improvements contribute to safety goals identified individually by 

each State. MAP-21 requires DOT to set performance measures for a national 

safety goal set by Congress. For example, in 2011 most States reported either the 

number of fatalities or number of fatal crashes on the general highway system and 

chose between providing multi-year trend data or a multi-year average ending with 

the most recent year of available data. FHWA officials stated they expect to have 

the opportunity to ensure that States have a common basis for the four national 

safety performance goals because MAP-21 requires DOT to consult with State 

transportation departments, metropolitan planning organizations, and other 

stakeholders to establish performance measures and standards. This requirement 

may also lead to more consistency among the individual performance targets set 

by the States, which could be an important step in facilitating FHWA’s evaluation 

and reporting of nationwide HSIP results. FHWA has an opportunity to leverage

data improvements it makes to meet MAP-21 to better assess and report the 

impact of HSIP. FHWA could use existing financial and performance data on 

HSIP projects, combined with consistent and complete data on performance 

targets and fatalities and serious injuries throughout the United States, to

eventually develop a more complete picture of HSIP’s impact on traffic safety.

CONCLUSION

HSIP has received significant funding increases and is FHWA’s primary means of 

addressing the Department’s national safety goal with infrastructure 

improvements. The data-driven nature of the program is consistent with the 

broader performance management provisions of MAP-21 that require FHWA to 

evaluate State progress toward meeting performance targets on reducing fatalities 

and injuries. As a result, FHWA has an opportunity to enhance its use of the data 
11

that States provide in their annual HSIP reports with new information being 

developed on MAP-21 performance targets. In doing so, FHWA can strengthen its 

efforts to evaluate the impact of billions in Federal funding directed specifically 

toward reducing fatalities and serious injuries through safety-focused HSIP 

infrastructure improvements.

RECOMMENDATIONS

We recommend that the Federal Highway Administrator: 

1. Develop a plan with milestones to increase the use of the online reporting tool, 

improve the tool’s usability, and the readability of the resulting reports.

2. Develop and implement a plan to annually compile and report data, such as 

number, type, and cost of HSIP projects to compare HSIP’s national impact 

across years.

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE

We provided FHWA with our draft report on January 31, 2013. We received 

technical comments from the Agency on February 13, 2013, and a formal response 

on March 22, 2013. FHWA’s complete response is included as an appendix to this 

report. FHWA concurred with both of our recommendations and provided us with 

its plan and milestones, which fully addresses recommendation 1. FHWA also 

provided its plan to annually compile and report data on HSIP’s national outcomes

in response to recommendation 2 and stated that it is currently implementing that 

plan. Before closing this recommendation, we request that FHWA provide us with 

a copy of its report within 10 days after its release.

ACTIONS REQUIRED

FHWA’s completed and planned actions for both recommendations are 

responsive, and we consider recommendation 1 closed. We consider 

recommendation 2 resolved but open pending receipt of FHWA’s report as 

described above. We appreciate the courtesies and cooperation of FHWA 

representatives during this audit. If you have any questions concerning this report, 

please call me at (202) 366-5630 or Wendy Harris, Program Director, at 

(202) 366-2794.

#

cc: DOT Audit Liaison, M-1

FHWA Audit Liaison, HAIM-13

NHTSA Audit Liaison, NPO-310
12

Exhibit A. Scope and Methodology

EXHIBIT A. SCOPE AND METHODOLOGY

We conducted our work between February 2012 and January 2013 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.

To assess the level of assistance FHWA provides to States in implementing HSIP, 

we collected and evaluated the policies, procedures, tools and guidance FHWA 

provided to States for execution of the HSIP. We paid particular attention to 

guidance FHWA provided on the quality, consistency, and use of crash data to 

identify performance goals and select HSIP-funded projects. We analyzed pre- and 

post-SAFETEA-LU HSIP requirements and associated agency rules to identify 

differences and the current extent of FHWA authority.

To review States’ implementation of HSIP under FHWA’s guidance, we used a 

consistent methodology to analyze the annual reports each of the States and the 

District of Columbia submitted in 2011. This analysis focused on how closely the 

reports follow program requirements and FHWA’s guidance. We also examined 

the data States reported on their projects, highway safety indicators, and project 

assessments to identify any variation and use of best practices. We interviewed 

and gathered documentation from FHWA officials responsible for implementing 

the HSIP to determine how the information provided annually by the States is used 

to evaluate the impact of the program. We also gathered financial reports from 

FHWA and used them to identify current funding levels and obligation rates.

To verify whether FHWA provided comprehensive guidance and adequate 

technical assistance to the States to effectively implement the HSIP, we 

interviewed State officials and FHWA Division officials from a statistically 

selected sample of 9 of 51 States. As part of these interviews, we gathered 

information on the guidance and tools State officials used when selecting, 

implementing, and evaluating HSIP projects (e.g., the Online Reporting Tool, the 

Peer to Peer Program, or the Self Assessment Tool). We also asked about any gaps 

or weaknesses in FHWA’s program support noted by the States or Divisions. 

To identify methods States use to evaluate the impact of specific HSIP-funded 

projects, we reviewed the project assessment information reported in the 2011 

annual reports of the 27 States that conduct project assessments. We also 

consulted with experts inside OIG to identify existing statistical methods and/or 

best practices for quantifying impact in environments where crash causation 

results from multiple factors and the type of data these methods require.
13

Exhibit B. Examples of FHWA Guidance

EXHIBIT B. EXAMPLES OF FHWA GUIDANCE

Program Implementation

HSIP Funds 10 Percent Flexibility Implementation Guidance (December 2006)

Highway Safety Improvement Program Manual (January 2010)

HSIP Assessment Toolbox Manual (August 2010)

Self Assessment Tool Manual (August 2011)

HSIP Project Eligibility (August 2011)

HSIP MAP-21 Interim Eligibility Guidance (September 2012)

Data

Safety Analyst Software Tools Guidance (July 2010)

Safety Performance Function Development Guidance 

Crash Data Improvement Program Guide (April 2010)

Model Inventory of Roadway Elements Guidance and Manual (October 2010)

Guidance for Roadway Safety Data to Support HSIP (June 2011)

Guidance Memorandum on Fundamental Roadway and Traffic Data Elements to 

Improve HSIP (August 2011)

Reporting

Highway Safety Improvement Program Reporting Guidance (May 2009)

Online Reporting Tool Webinar and Outline

Planning

Strategic Highway Safety Plans: A Champion’s Guide to Saving Lives (April 

2006)

Developing Future Stewardship/Oversight Agreements Memorandum (July 2006)

Peer-to-Peer Exchange

Peer-to-Peer Program Guidelines

Peer-to-Peer Program Technical Assistance including peer referrals and facilitated 

peer exchanges

Training

Topic-specific FHWA Courses including HSIP Program Overview, New 

Approaches to Highway Safety Analysis, SHSP Development
14

Exhibit C. Major Contributors to This Report

EXHIBIT C. MAJOR CONTRIBUTORS TO THIS REPORT

Wendy Harris Program Director

Name Title

Regan Maund Project Manager

Michael English Senior Analyst

Peter Barber Analyst

Doris Kwong Analyst

Michelle Starkey Auditor

Petra Swartzlander Senior Statistician

Megha Joshipura Statistician

Seth Kaufman Senior Counsel

Andrea Nossaman Senior Writer-Editor
15

Appendix. Agency Comments

APPENDIX. AGENCY COMMENTS

Memorandum

U.S. Department

of Transportation

Federal Highway

Administration

Subject: INFORMATION: Federal Highway 

Administration (FHWA) Response to 

Office of Inspector General (OIG) 

Draft Report on FHWA’s Highway 

Safety Improvement Program (HSIP)

Date: March 22, 2013

From: Victor M. Mendez In Reply Refer To:

Administrator HCFM-1

To: Calvin L. Scovel III

Inspector General (J-1)

The FHWA’s effective leadership of the HSIP is demonstrated through OIG’s 

finding that 98 percent of States complied with annual program requirements. 

The FHWA provides clear and informative guidance regarding highway safety 

data use, strategic highway safety planning and development, and safety data 

reporting, and will continue this practice through the implementation of the 

Moving Ahead for Progress in the 21st Century Act (MAP-21). This guidance 

helps States meet statutory requirements, promotes shared best practices across 

States, and encourages States to continuously improve safety programs. The 

FHWA appreciates OIG’s acknowledgement of the effectiveness of this 

guidance and the assistance provided by the Agency as reflected by the positive 

feedback State officials offered regarding the broad range of services provided 

by the HSIP.

The FHWA is using all means available to further improve highway safety, and 

HSIP provides important tools to accomplish this goal. Reducing fatalities and 

serious injuries on the Nation’s roadways is a complex multi-faceted challenge 

further complicated by the analytical difficulties in attributing declining 

fatalities to any individual program. We will continue to make the best possible 
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Appendix. Agency Comments

use of available data and coordinate with other Agencies in DOT to ensure that 

HSIP activities complement and support the Department’s other highway safety 

programs as we work toward the common objective of reducing fatalities and 

injuries. The FHWA also provides a broad range of technical assistance 

including Web-based training courses, topic based webcasts, and the Roadway 

Safety Peer-to-Peer (P2P) Program. The P2P Program assists State agencies in 

the development and implementation of effective strategies to tackle a wide 

range of specific issues from pedestrian safety to high risk rural roads. 

The FHWA is continually improving the HSIP and agrees with the OIG draft 

HSIP report recommendations. As discussed with OIG, the Office of Safety was 

in the early stages of conducting a program review when OIG began its 

independent audit. The information from OIG’s analysis will be a valuable 

resource for FHWA’s Office of Safety in conducting its ongoing internal 

program review to evaluate the performance of the HSIP.

OIG Recommendations and FHWA Responses

Recommendation 1: Develop a plan with milestones to increase the use of the 

online reporting tool, improve the tool’s usability, and the readability of the 

resulting reports.

FHWA Response: Concur. The FHWA has developed a formal plan and 

established milestones to improve the readability of reports produced from the 

HSIP online reporting tool and to improve the overall use and usability of the 

tool itself. This plan, which FHWA began implementing in November 2012,

includes strategies for user outreach, such as training and tool marketing, and

strategies for identifying ways to improve the tool. In addition, the plan 

includes an implementation schedule as well as metrics to track progress in 

meeting established milestones. We request that OIG close this 

recommendation upon receipt of this response.

Recommendation 2: Develop and implement a plan to annually compile and 

report data, such as number, type, and cost of HSIP projects to compare HSIP’s 

national impact across years.

FHWA Response: Concur. The FHWA has developed, and began 

implementing in November 2012, a plan to compile and report HSIP program 

data such as number, type, and cost of projects and compare these outputs 

nationally across years. The annual report will be based on information 

provided through States’ annual HSIP reports as well as other supplementary 

information. The first annual report will summarize baseline information and 

subsequent annual reports will compare program outputs across years. We 
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Appendix. Agency Comments

request that OIG close this recommendation upon receipt of this response.

-- -- -- -- --

The FHWA appreciates the opportunity to respond to the draft report. If you 

have any questions or comments regarding this response, please contact 

Elizabeth Alicandri, Director of Office of Safety Programs, Office of Safety, at 

202-366-6409.