GAO 

United States Government Accountability Office

Report to Congressional Requesters

FEDERAL-AID 

HIGHWAYS 

FHWA Has Improved 

Its Risk Management 

Approach, but Needs 

to Improve Its 

Oversight of Project 

Costs 

July 2009 

GAO-09-751 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

July 2009

FEDERAL-AID HIGHWAYS

FHWA Has Improved Its Risk Management Approach, 

but Needs to Improve Its Oversight of Project Costs

Highlights of GAO-09-751, a report to 

congressional requesters 

The federal-aid highway program 

provides about $33 billion a year to 

states for highway projects. The 

federal government provides 

funding for and oversees this 

program, while states largely 

choose and manage the projects. 

As requested, GAO reviewed the 

Federal Highway Administration’s 

(FHWA) implementation of several 

requirements in the Safe, 

Accountable, Flexible, Efficient 

Transportation Equity Act: A 

Legacy for Users (SAFETEA-LU): 

(1) oversight of states using a risk 

management approach; (2) efforts 

to develop minimum standards for 

estimating project costs, and 

periodically evaluate states’ cost 

estimating practices; and 

(3) reviews of states’ financial 

management systems. GAO also 

reviewed FHWA’s policy on 

presenting an estimate of financing 

costs in financial plans for major 

projects (i.e., projects estimated to 

cost over $500 million). GAO 

reviewed FHWA plans, risk 

assessments, reviews, and other 

documents; visited five FHWA field 

offices and reviewed financial 

management reviews in an 

additional five field offices; and 

interviewed FHWA officials. 

What GAO Recommends

GAO is making recommendations 

to improve FHWA’s tracking of 

risks and its oversight of states’ 

estimates of project costs, financial 

management systems, and financial 

plans for major projects. The 

Department of Transportation 

stated it would consider the 

report's recommendations. 

FHWA has improved its approach to managing risks to the federal-aid 

highway program by requiring field offices to identify risks, assess them on 

the basis of the potential impact and the likelihood they will occur, and 

develop response strategies for key risks in their planned oversight activities. 

For fiscal years 2007 through 2009, most of the field offices GAO visited had 

oversight activities to address a majority of the key risks. However, most of 

the field offices that GAO visited were not fully tracking risk mitigation 

activities, thereby limiting the effectiveness of FHWA’s efforts to mitigate 

risks to the federal-aid highway program. 

FHWA has made limited progress in meeting SAFETEA-LU’s requirement to 

develop minimum standards that states must follow when estimating project 

costs. GAO has reported that project cost estimates typically have not been 

reliable predictors of project costs or financing needs. While FHWA has 

efforts under way, it is unlikely to issue standards until 2011, at the earliest. In 

addition, FHWA has not established a process to periodically evaluate states’ 

cost estimating practices, and four of the five field offices GAO visited were 

doing little in this regard. However, for major projects, FHWA has established 

a process for evaluating the credibility of states’ cost estimates. Establishing 

standards for cost estimates and periodically evaluating states’ cost estimating 

practices could help to ensure that highway projects are effectively and 

efficiently managed. 

FHWA’s guidance and documentation for reviews of state departments of 

transportation’s financial management systems and practices generally meet 

key federal standards and principles, but they lack specific steps and 

documentation in some key areas. For example, FHWA’s guidance does not 

require reviewers to provide certain specific information on improper 

payments. In addition, while the 10 field offices that GAO reviewed generally 

covered the required areas in their financial management reviews in 2008, 

their documentation sometimes lacked information on the specific procedures 

performed or issues identified by reviewers. Without this information, it is 

difficult for FHWA to monitor and follow up on field offices’ and states’ 

progress in correcting deficiencies. 

FHWA does not require states’ financial plans for major projects to present an 

estimate of the projects’ financing costs. According to a senior FHWA official, 

this is partly because it is difficult to develop accurate estimates. While 

uncertainty about a major project’s financing cost can exist, and presenting 

estimates of financing costs for all projects could be impractical, financing 

costs on major projects can represent a significant cost to a state, and can, 

when combined with payments on the principal portion of the debt, tie up 

large shares of future federal transportation funding. Presenting an estimate 

of a project’s financing costs would help ensure that decision makers who 

approve funding for these projects have key information that is relevant to 

such decisions. 

View GAO-09-751 or key components.

For more information, contact Phillip Herr at 

(202) 512-2834 or herrp@gao.gov. 
Page i GAO-09-751 

Contents 

Letter 1

Background 4 

FHWA Has Improved Its Risk Management Approach but Is Not 

Fully Tracking Risk Mitigation Activities 8 

FHWA Has Made Limited Progress in Meeting SAFETEA-LU’s 

Requirements for Cost Estimating 12 

FHWA’s Guidance and Documentation for Reviews of State DOTs’ 

Financial Management Systems and Practices Generally Meet 

Key Standards and Principles, but Lack Some Important Details 15 

Financial Plans for Major Highway Projects Lack Information on 

Financing Costs 17 

Conclusions 18 

Recommendations for Executive Action 19 

Agency Comments 20 

Appendix I Scope and Methodology 21 

Appendix II GAO Contact and Staff Acknowledgments 23 

Table 

Table 1: Types of Projects Receiving FHWA Oversight Versus State 

Oversight 7 

Figure 

Figure 1: Stages of a Highway or Bridge Project and State and 

FHWA Roles and Approval Actions 6 

 FHWA Oversight 
Abbreviations 

AASHTO American Association of State Highway and 

 Transportation Officials 

DBE Disadvantaged Business Enterprise 

DOT Department of Transportation 

FHWA Federal Highway Administration 

OMB Office of Management and Budget 

SAFETEA-LU The Safe, Accountable, Flexible, Efficient 

 Transportation Equity Act: A Legacy for Users 

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Page ii GAO-09-751 FHWA Oversight
Page 1 GAO-09-751 

 

United States Government Accountability Office

Washington, DC 20548 

 

July 24, 2009 

The Honorable James L. Oberstar 

Chairman 

Committee on Transportation and Infrastructure 

House of Representatives 

The Honorable Peter A. DeFazio 

Chairman 

Subcommittee on Highways and Transit 

Committee on Transportation and Infrastructure 

House of Representatives 

The federal-aid highway program provides about $33 billion a year to 

states for highway and bridge projects, often paying 80 percent of these 

projects’ costs. The program is federally financed and state administered—

that is, the federal government provides funding and oversees the 

program, while the states largely choose and manage the projects. These 

projects can take years of planning, environmental review, design, and 

construction. With highway congestion projected to worsen over the next 

20 years and freight traffic expected to double, widespread consensus 

exists on the need to maintain and improve the nation’s surface 

transportation infrastructure. At the same time, revenues to support the 

Highway Trust Fund—the major source of federal highway and transit 

funding—are eroding. Receipts for the fund are derived from motor fuel 

and truck-related taxes. These receipts are declining in purchasing power 

because the federal motor fuel tax rate—which has remained constant at 

18.4 cents per gallon since 1993—has not kept pace with inflation.1

Furthermore, as vehicles become more fuel efficient and increasingly run 

on alternative fuels, fuel taxes may not be a sustainable source of 

transportation financing. As a result, we have designated funding the 

nation’s transportation infrastructure as a high-risk issue.2

 Ensuring that 

states effectively manage and control the cost and schedule performance 

1

GAO, Highway Trust Fund: Improved Solvency Mechanisms and Communication 

Needed to Help Avoid Shortfalls in the Highway Account, GAO-09-316 (Washington, D.C.: 

Feb. 6, 2009). 

2

GAO, High-Risk Series: An Update, GAO-09-271 (Washington, D.C.: January 2009); and 

High-Risk Series: An Update, GAO-07-310 (Washington, D.C.: January 2007). 

 FHWA Oversight 
 

of federally aided projects, and that federal funds are used efficiently and 

effectively, is critically important. 

The Federal Highway Administration (FHWA), under the Department of 

Transportation (DOT), is responsible for overseeing the federal-aid 

highway program. FHWA oversees the program through its headquarters 

in Washington, D.C., and its 52 field offices in the 50 states, the District of 

Columbia, and Puerto Rico. FHWA delegates much decision making and 

program implementation authority to these field offices. FHWA reviews 

and approves the transportation plans and environmental impact 

assessments that states periodically prepare, as well as states’ property 

acquisition activities; it also enforces a variety of requirements, such as 

civil rights laws, that states accept as a condition of federal aid. FHWA 

also oversees the design and construction of federally aided projects, but 

this oversight has evolved over the years and currently focuses on two 

broad areas: (1) for selected projects, direct review and approval of state 

design plans, contract awards, and construction progress and (2) process 

reviews—that is, reviews of state management processes—to ensure that 

the states have adequate controls to effectively manage federally assisted 

projects. FHWA requires its field offices to use a risk management 

approach to allocate oversight resources. Risk management typically 

includes assessments to identify and prioritize risks, and is used in a 

variety of contexts, including the management of government programs. 

For the federal-aid highway program, examples of risks that FHWA has 

identified include inadequate construction practices that could degrade 

the quality of state highway projects, and the risk that projects delegated 

by states to local governments may not meet federal requirements and 

could have cost or schedule overruns. FHWA has additional requirements 

for “major projects”—that is, generally those projects estimated to cost 

over $500 million—such as reviewing and approving annual finance plans 

required by law.3

We and others have raised concerns regarding FHWA’s oversight of the 

federal-aid highway program. For example, in reports that we issued from 

1997 to 2005, we highlighted several problems, including a lack of useful 

project cost estimates, which typically had not been reliable predictors of 

the project costs or financing needs. We also found that the guidance that 

 

3

FHWA’s oversight also applies to projects between $100 million and $500 million. FHWA 

reviews and approves financial plans for major projects. For projects between $100 million 

and $500 million, financial plans have to be prepared, but FHWA does not approve them. 

Page 2 GAO-09-751 FHWA Oversight
 

FHWA provided to states on developing cost estimates was voluntary and 

covered only major projects. In addition, we found that although FHWA 

field offices were assessing risks to the highway programs in their states, 

they were not always using their risk assessments to direct their process 

reviews. In 2005, Congress enacted the Safe, Accountable, Flexible, 

Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU), 

which authorized funding for the federal surface transportation programs 

from fiscal years 2005 through 2009.4

 SAFETEA-LU also established the 

following requirements for FHWA’s oversight of the federal-aid highway 

program: 

• annually review elements of each state Department of Transportation’s 

(DOT) project delivery system;5

• develop minimum standards that state DOTs must follow when estimating 

project costs, and periodically evaluate state DOTs’ practices for 

estimating project costs; and 

• annually review elements of each state DOT’s financial management 

system that affect projects. 

SAFETEA-LU continued an earlier requirement for sponsors of major 

projects to submit a financial plan based on detailed cost estimates to 

complete the project and on reasonable assumptions, as determined by 

FHWA. FHWA evaluates states’ cost estimates for major projects to assess 

the reasonableness of their assumptions. SAFETEA-LU also lowered the 

threshold for a project to be classified as major from $1 billion to $500 

million. 

You asked us to review FHWA’s implementation of several requirements in 

SAFETEA-LU, including its (1) oversight of states’ project delivery 

systems, in particular, its use of a risk management approach to allocate 

their oversight resources; (2) efforts to develop minimum standards for 

states to follow when estimating project costs, and to periodically evaluate 

states’ cost estimating practices; and (3) efforts to review elements of 

states’ financial management systems and practices that affect projects. 

 

4

Pub. L. No. 109-59 (Aug. 10, 2005). 

5

A project delivery system is the process used to move a project from a concept to a 

constructed facility, and the system includes planning, environmental review, design, 

property acquisition, and construction. 

Page 3 GAO-09-751 FHWA Oversight
 

You also asked us to review FHWA’s policy on presenting an estimate of 

financing costs in financial plans for major projects. 

To address these objectives, we reviewed key agency and state documents 

and relevant regulations and legislation. We conducted interviews with 

FHWA and state DOT officials and representatives from the American 

Association of State Highway and Transportation Officials (AASHTO). In 

addition, we observed a risk management training class that is available to 

FHWA staff. We also visited 5 FHWA field offices that oversee states that 

receive a range of federal-aid dollars, several of which were overseeing a 

major project. Because we used a nonprobability sample, information 

obtained from the field offices that we visited cannot be generalized to all 

field offices. Also, we assessed financial management reviews in 5 

additional randomly selected field offices, for a total of 10 field offices. We 

conducted this performance audit from June 2008 through July 2009 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 appendix I for a more complete 

description of our scope and methodology. 

Federal funding for highways is provided to the states mostly through a 

series of formula grant programs collectively known as the federal-aid 

highway program. Periodically, Congress enacts multiyear legislation that 

authorizes the nation’s surface transportation programs. In 2005, Congress 

enacted SAFETEA-LU, which authorized $193.2 billion for the federal-aid 

highway program from fiscal years 2005 through 2009. 

Background 

FHWA oversees the federal-aid highway program and distributes most 

funds to the states through annual apportionments established by 

statutory formulas. Once FHWA apportions these funds, they are available 

for states to obligate for construction, reconstruction, and improvement of 

highways and bridges on eligible federal-aid highway routes and for other 

purposes. About 1 million of the nation’s 4 million miles of roads are 

eligible for federal aid—including the 161,000 mile National Highway 

Page 4 GAO-09-751 FHWA Oversight
 

System, of which the 47,000 mile Interstate Highway System is a part.6

While FHWA oversees and funds the program, the responsibility for 

selecting specific highway projects generally rests with state DOTs and 

local planning organizations, which have considerable discretion in 

determining how to allocate available federal funds among various 

projects. The federal-aid highway program is generally referred to as a 

federally assisted, state-administered partnership. 

A highway or bridge construction or repair project usually has four stages: 

planning, environmental review, design and property acquisition, and 

construction. FHWA reviews and approves long-term and short-term state 

transportation plans and programs, environmental documents, and the 

acquisition of property for all highway projects.7

 However, its role in 

overseeing the design and construction of projects varies. On selected 

projects, FHWA exercises what is often considered “full” oversight, 

meaning that FHWA (1) prescribes design and construction standards, 

(2) approves design plans and estimates, (3) approves the selection of the 

contract award, (4) periodically inspects the progress of construction, and 

(5) renders final acceptance on projects when they are completed. 

However, relatively few projects are subject to this full FHWA oversight. 

Under current law, FHWA exercises full oversight of certain high-cost 

interstate system projects, while states oversee design and construction on 

other federal-aid projects. Figure 1 shows the stages of a highway or 

bridge project and the corresponding state role and FHWA approval 

actions. Table 1 shows the types of projects for which FHWA exercises full 

oversight, as compared with state oversight. 

 

6

The 1 million miles of roads eligible for federal aid accounted for about 83 percent of the 

vehicle miles traveled on the nation’s roadways in 2007. The 3 million miles of roads that 

are generally ineligible are functionally classified as local roads or rural minor collectors. 

7

Specifically, FHWA approves state short-range transportation improvement programs and 

reviews state and metropolitan planning processes. 

Page 5 GAO-09-751 FHWA Oversight
 

Figure 1: Stages of a Highway or Bridge Project and State and FHWA Roles and Approval Actions 

Prepare long-range (e.g., 20 

years) plans and short-range 

(e.g., 4 years) transportation 

improvement programs

Approve short-range 

transportation improvement 

programs

Approve environmental

documents

When FHWA

has oversight 

responsibilitya

Approve

property 

acquisition 

and approve

design plans

and

specifications

When state 

has primary 

oversight 

responsibilitya

Approve

property 

acquisition, 

no specific

role in design

plans and

specifications

When FHWA 

has oversight 

responsibilitya

Approve

construction

awards, inspect 

progress, 

and accept 

final product

When state 

has primary 

oversight 

responsibilitya

No specific

role

Prepare environmental

documents identifying and

assessing environmental

alternatives when required

Acquire property and

prepare design plans and

specifications according

to applicable standards

Advertise bids,

award contracts,

and oversee

construction

State’s

role

FHWA’s

role

Stages Design and Construction

property acquisition

Environmental

review

Planning

Source: GAO.

a

The types of projects for which FHWA exercises full oversight, as compared with state oversight, are 

shown in table 1 of this report. 

Page 6 GAO-09-751 FHWA Oversight
 

Table 1: Types of Projects Receiving FHWA Oversight Versus State Oversight 

Type of project Miles of road 

Percentage of federal 

highway funds 

obligated in 2006

Design and 

construction 

oversight Exception 

Interstate System 47,000 8% FHWA oversight Certain types of projects, or projects 

below a certain dollar threshold, in 

which FHWA and state determine that 

state oversight is appropriate 

National Highway System, 

non Interstate routes 

115,000 44 FHWA and state 

agree on which 

entity will provide 

oversight 

State or FHWA determines state 

oversight is not appropriate 

Federal-aid highways off 

the National Highway 

System 

798,000 48 State assumes 

oversight 

State determines that state oversight is 

not appropriate 

Source: GAO analysis of FHWA data. 

Over the past 12 years, we and others have identified problems with 

FHWA’s oversight of the federal-aid highway program. For example: 

• In 1997, we reported that the overall amount of and reasons for cost 

increases on highway and bridge projects could not be determined 

because data were not readily available from FHWA or the states.8

 We 

found on many of the projects for which we could obtain information that 

initial costs estimates—developed in connection with the environmental 

review stage of projects—had increased, sometimes significantly. Several 

factors accounted for the increases, including that these initial cost 

estimates were preliminary and were not designed to be reliable 

predictors of a project’s cost. 

• In our May 2002 testimony, we reported that FHWA had begun to improve 

its oversight by implementing Congress’s finance plan requirements for 

major projects but opportunities existed for improving the quality of cost 

estimating and developing reliable and accurate information on the extent 

and nature of projects’ cost performance to help direct federal oversight 

efforts.9

 

8

GAO, Transportation Infrastructure: Managing the Costs of Large-Dollar Highway 

Projects, GAO/RCED-97-47 (Washington, D.C.: Feb. 27, 1997). 

9

GAO, Transportation Infrastructure: Cost and Oversight Issues on Major Highway and 

Bridge Projects, GAO-02-702T (Washington, D.C.: May 1, 2002). 

Page 7 GAO-09-751 FHWA Oversight
 

• In 2003, the DOT Inspector General reported progress in FHWA’s 

stewardship over major projects but identified improvements needed in 

eight areas, including developing more reliable cost estimates, managing 

project schedules better, and refocusing FHWA’s efforts on project 

management and financial oversight.10

• We and others have raised concerns regarding FHWA’s use of risk 

assessments to identify and prioritize risks to the federal-aid highway 

program. In 2004, the DOT Inspector General reported that FHWA’s risk 

assessments did not provide a systematic approach for assessing program 

risks throughout the agency.11 As a result, risk assessment results were not 

reliable or comparable across states. The Inspector General recommended 

that FHWA issue guidance to its field offices to ensure that risk 

assessments are conducted more strategically by identifying major 

programs and program components to be evaluated, correlating the 

assessments with agency priorities, and providing field offices with a 

disciplined methodology for evaluating and classifying program risks. In 

addition, in 2005, we reported that FHWA field offices were not always 

using risk assessments to help guide their reviews of state management 

processes.12

FHWA has improved its risk management approach by requiring field 

offices to identify risks to the federal-aid highway program in their states, 

assess the risks on the basis of the potential impact and the likelihood that 

they will occur, and include response strategies for key risks in the offices’ 

planned oversight activities. FHWA also has improved its use of risk 

assessments to guide oversight activities. However, most of the field 

offices that we visited were not fully tracking risk mitigation activities, 

thereby limiting the effectiveness of FHWA’s efforts to mitigate risks to the 

federal-aid highway program. 

FHWA Has Improved 

Its Risk Management 

Approach but Is Not 

Fully Tracking Risk 

Mitigation Activities 

 

10Statement of the Honorable Kenneth H. Mead, Inspector General, Department of 

Transportation, Management of Cost Drivers on Federal-Aid Highway Projects, 

(May 8, 2003). 

11U.S. Department of Transportation, Office of Inspector General, Managing Risk in the 

Federal-Aid Highway Program, MH-2005-012 (Washington, D.C.: Nov. 19, 2004). 

12GAO, Federal-Aid Highways: FHWA Needs a Comprehensive Approach to Improving 

Project Oversight, GAO-05-173 (Washington, D.C.: Jan. 31, 2005). 

Page 8 GAO-09-751 FHWA Oversight
 

FHWA has improved its risk management approach by establishing a 

process for field offices to identify, assess, and respond to risks to the 

federal-aid highway program. Following the issuance of the 2004 DOT 

Inspector General report, FHWA issued risk management guidance to field 

offices in 2006, 2007, and 2008, and the Inspector General told us that 

FHWA has implemented the recommendation. FHWA has also developed 

risk management training and offers a class through the National Highway 

Institute. According to an FHWA official, senior management from each 

field office received the training in 2007. 

FHWA Has Improved Its 

Risk Management 

Approach and Is Using 

Risk Assessments to Guide 

Oversight 

FHWA’s guidance requires field offices to identify risks to the federal-aid 

highway program (usually on an annual basis), assess the risks on the 

basis of the potential impact and the likelihood that they will occur, 

develop response strategies for key risks (typically, the top 10), and 

include these strategies in the offices’ planned oversight activities. We 

assessed FHWA’s risk management guidance and training against the best 

practices that we developed in the following four areas: strategic planning, 

identifying and assessing risks, implementing and monitoring risk 

mitigation plans, and evaluating and selecting alternatives for responding 

to risks.13 We found that FHWA adequately reflected these best practices 

in the first three areas, but not the fourth. For example, in the area of 

strategic planning, FHWA’s guidance directs staff to develop risk planning 

strategies and identify actions that could mitigate the impact of negative 

events. In addition, in the area of assessing risks, the guidance and training 

provide detailed discussion of considering the likelihood and potential 

impact of risks to help field offices prioritize identified risks. However, in 

the area of evaluating and selecting alternatives for responding to risk, 

FHWA’s guidance and training have limited discussion of evaluating the 

impact of alternative response strategies in terms of their potential to 

reduce risks and their associated costs, or of documenting the basis for 

choosing the selected alternative. 

Since our 2005 report, FHWA has improved its use of risk assessments to 

guide oversight activities. We found that risk assessments were a 

significant factor in determining oversight activities in the field offices that 

we visited for this work. Officials from these five field offices said they 

used risk assessments to inform their planned oversight activities for the 

year. In addition, for fiscal years 2007 through 2009, three of the five field 

offices documented planned oversight activities to address a majority of 

 

13GAO, Risk Management: A GAO Analysts’ Guide. 

Page 9 GAO-09-751 FHWA Oversight
 

the key risks identified during their annual risk assessment process. The 

other two field offices addressed one-half or more of the risks in 2 of the 

3 years. For instance, for fiscal year 2008, one field office identified 10 

risks and documented a planned oversight activity for 9 of these risks in its 

performance plan. For example, to address risks associated with projects 

delegated by the state to local governments or agencies, over 20 percent of 

the field office’s construction inspections in fiscal year 2008 focused on 

local projects. It found deficiencies in some areas, including construction 

documentation and meeting disadvantaged business enterprise goals.14 In 

another field office we visited, staff identified a risk that inadequate 

construction practices could degrade the quality of state highway projects. 

To respond to the risk, the field office initiated a review of the state’s 

practices for addressing discrepancies between the construction materials 

and methods used and the plans and specifications for projects. The 

review found that the state’s process and guidance were adequate, but 

made recommendations to improve the efficiency and consistency of the 

process. 

The American Recovery and Reinvestment Act of 2009 (Recovery Act) 

provides an additional $26.7 billion in highway spending to the states.15

FHWA is taking steps to oversee the increased spending by directing its 

field offices to revise their existing annual plans so that they address risks 

associated with delivering these projects. Field offices were required to 

identify and prioritize their primary risks and submit their plans to 

FHWA’s field office directors by late March 2009. On the basis of these 

efforts, in April 2009, FHWA issued a risk management framework 

identifying eight key risks in implementing the Recovery Act, including 

 

14DOT’s Disadvantaged Business Enterprise (DBE) program is designed to remedy the 

effects of current and past discrimination against small businesses owned and controlled 

by socially and economically disadvantaged individuals and to foster equal opportunity in 

transportation contracting. Federal law generally requires DOT to ensure that at least 

10 percent of the funds authorized for the highway and transit financial assistance 

programs be expended with DBEs. 

15The Recovery Act directs GAO to conduct bimonthly reviews on the use of funds by 

selected states and localities, among other things. We have recently completed the first 

review, which examined a core group of 16 states, the District of Columbia, and selected 

localities. See GAO, Recovery Act: As Initial Implementation Unfolds in States and 

Localities, Continued Attention to Accountability Issues Is Essential, GAO-09-580

(Washington, D.C.: Apr. 23, 2009) and Recovery Act: States’ and Localities’ Current and 

Planned Uses of Funds While Facing Fiscal Stresses, GAO-09-829 (Washington, D.C.: 

July 8, 2009). We expect to track the activities of these 16 states and the District of 

Columbia over the next few years to provide an ongoing longitudinal analysis of the use of 

Recovery Act funds. 

Page 10 GAO-09-751 FHWA Oversight
 

risks associated with weak internal controls,16 which may lead to the 

payment of ineligible costs, and difficulty in meeting the public’s 

expectations for stimulating economic recovery and delivering 

transportation projects that yield long-term value. The framework also 

includes eight risk mitigation strategies, including reviews of previously 

identified risks in all states and providing guidance on the Recovery Act to 

funding recipients. 

FHWA Is Not Fully 

Tracking Risk Mitigation 

Activities and Associated 

Recommendations 

FHWA’s field offices are not fully tracking risk mitigation activities and 

associated recommendations. FHWA field offices often initiate reviews of 

state or local agency processes in response to identified risks. These 

reviews can result in recommendations. Standards for internal control 

state that agencies should have policies and procedures that help ensure 

that actions are taken to address risks and enforce recommendations.17

Also, monitoring of internal control should include policies and 

procedures for ensuring that the findings of reviews are promptly 

resolved. However, we found that only 1 of the 5 field offices that we 

visited had information about both its own progress in addressing risks 

and its state’s progress in resolving related review recommendations. Also, 

in a 2008 survey of its 52 field offices, FHWA found that of the 29 field 

offices that responded to the survey, 7 did not have a system for tracking 

review recommendations. Of the 22 field offices with tracking systems, 

FHWA found 8 different systems in use, which could make it difficult to 

aggregate review recommendation tracking information at the national 

level. 

To improve the situation, FHWA plans to develop an information system to 

track states’ progress in addressing review recommendations. FHWA has 

not yet decided whether to require all field offices to use the system. Also, 

FHWA has not yet determined whether it will develop an information 

system for its field offices to track their own progress in addressing risks. 

Without complete and consistent tracking information, it is difficult to 

 

16Internal control is an integral component of an organization’s management that provides 

reasonable assurance that the following objectives are being achieved: effectiveness and 

efficiency of operations, reliability of financial reporting, and compliance with applicable 

laws and regulations. Internal control also serves as the first line of defense in safeguarding 

assets and preventing and detecting errors and fraud. 

17GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 

(Washington, D.C.: November 1999). 

Page 11 GAO-09-751 FHWA Oversight
 

aggregate national-level information from the field offices and to ensure 

that risks and related review recommendations have been addressed. 

FHWA has made limited progress in meeting SAFETEA-LU’s requirements 

to develop minimum standards that states must follow when estimating 

project costs, and to periodically evaluate states’ practices for estimating 

project costs. Although FHWA field offices are doing little to periodically 

evaluate states’ cost estimating practices overall, FHWA has established a 

process for evaluating the credibility of states’ cost estimates for major 

projects. 

FHWA Has Made 

Limited Progress in 

Meeting SAFETEALU’s Requirements for 

Cost Estimating 

FHWA Has Made Limited 

Progress in Developing 

Minimum Standards for 

Estimating Project Costs 

FHWA has made limited progress in meeting SAFETEA-LU’s requirement 

to develop minimum standards that states must follow when estimating 

project costs. In 1997, we reported that project cost estimates typically 

had not been reliable predictors of project costs or financing needs.18

Although FHWA has efforts under way, it is unlikely to issue standards 

until 2011, at the earliest. To meet the SAFETEA-LU requirement, the 

agency is participating in AASHTO’s effort to develop cost estimating 

guidance for states. As part of this effort, AASHTO sponsored the 

development of such guidance by the National Cooperative Highway 

Research Program, which was completed in 2007.19 AASHTO is developing 

additional cost estimating guidance; an AASHTO official who is helping to 

coordinate this effort told us that he expects the guidance to be completed 

in the latter half of 2010. FHWA’s Director of Program Administration told 

us that once the guidance is complete, FHWA plans to issue a regulation 

adopting as its minimum standards for cost estimating either the guidance 

developed by NCHRP, the additional guidance being developed by 

AASHTO, or both. This would take more time. For instance, the official 

provided us with an example in which it took about 18 months from the 

time AASHTO issued guidance until FHWA regulation took effect. 

 

18GAO/RCED-97-47. 

19Stuart Anderson, Keith Molenaar, and Cliff Schexnayder, Guidance for Cost Estimation 

and Management for Highway Projects During Planning, Programming, and 

Preconstruction (Washington, D.C.: National Cooperative Highway Research Program, 

2007), prepared for the Transportation Research Board of the National Academies. 

Page 12 GAO-09-751 FHWA Oversight
 

FHWA has not established a process to meet SAFETEA-LU’s requirement 

that it periodically evaluate states’ cost estimating practices. FHWA’s 

Director of Program Administration told us that the agency has not 

established such a process because it has been focused on developing 

minimum cost estimating standards. 

FHWA Has Not 

Established a Process for 

Evaluating States’ Cost 

Estimating Practices 

Four of the five FHWA field offices that we visited were doing little to 

periodically evaluate states’ cost estimating practices. For example, one 

field office has not recently evaluated states’ cost estimating practices 

because, officials stated, most of the state’s cost estimates that they 

evaluate before contracts are awarded for construction are reasonably 

accurate, in that they are close to the lowest bid received from bidders. 

However, estimates that are close to the lowest bid are not always a good 

indicator of sound cost estimating practices. As we reported in 1997, most 

of a project’s cost growth can occur before a project goes to 

construction.20 In addition, cost increases can also occur after a contract is 

awarded. Another field office is working with its state DOT to refine the 

state’s cost estimating guidance, but the field office will not be formally 

evaluating the state’s current practices as part of this effort. In 2008, 

however, one field office evaluated its state DOT’s practices for 

documenting cost estimates, and it is conducting an evaluation of the state 

DOT’s cost estimating practices to determine if they produce accurate and 

reliable estimates. Periodically evaluating states’ cost estimating practices 

could help to enhance the credibility of states’ cost estimates. 

FHWA Has Established a 

Process for Evaluating the 

Credibility of States’ Cost 

Estimates on Major 

Projects 

Although FHWA field offices are doing little to periodically evaluate states’ 

cost estimating practices overall, for major projects—those estimated to 

cost over $500 million—FHWA has established a process for evaluating the 

credibility of states’ cost estimates. SAFETEA-LU requires sponsors of 

major projects to submit a financial plan that is based on detailed cost 

estimates to complete the project and on reasonable assumptions, as 

determined by FHWA. To help meet this requirement, FHWA evaluates 

states’ cost estimates for major projects. We assessed FHWA’s evaluations 

of cost estimates for two major projects—an expansion of 21 miles of a 

highway to a four-lane expressway in Wisconsin and an expansion of 

11 miles of an expressway to a six-lane freeway in Colorado. We found 

 

20GAO/RCED-97-47. 

Page 13 GAO-09-751 FHWA Oversight
 

that, consistent with GAO’s best practices for estimating project costs,21

both of the evaluations involved conducting and documenting an analysis 

of risks and uncertainties related to the cost estimate.22 These analyses 

(1) identified the effects on the estimate of changing assumptions about 

key cost drivers; (2) developed a probability distribution of the expected 

cost using a Monte Carlo simulation tool;23 and (3) identified a point 

estimate, along with the probability that the actual cost will not exceed the 

point estimate.24

 

21GAO, GAO Cost Estimating and Assessment Guide: Best Practices for Developing and 

Managing Capital Program Costs, GAO-09-3SP (Washington, D.C.: March 2009). 

22The term risk and uncertainty refers to the fact that because a cost estimate is a forecast, 

there is always a chance that the actual cost will differ from the estimate. Recognizing the 

potential for error and deciding how best to quantify it is the purpose of a risk and 

uncertainty analysis. 

23The term Monte Carlo simulation refers to a computer-based analysis that uses 

probability distributions for key variables, selects random values from each of the 

distributions simultaneously, and repeats the random selection over and over. Rather than 

presenting a single outcome—such as the mostly likely or average scenario—Monte Carlo 

simulations produce a distribution of outcomes that reflect the probability distributions of 

modeled uncertain variables. 

24A point estimate is usually the most likely value for the cost estimate, given the 

underlying data. 

Page 14 GAO-09-751 FHWA Oversight
 

FHWA’s guidance to its field offices on reviewing state DOTs’ financial 

management systems and practices generally follows key federal 

standards and principles, but lacks specific steps and documentation in 

some key areas, such as improper payments, that could help improve 

oversight of state projects.25 The Office of Management and Budget (OMB) 

has established standards and principles related to financial management 

systems in circulars on internal control, improper payments, financial 

systems, and audits of state and local governments.26 To implement these 

circulars, FHWA has established a program in which its field offices 

conduct annual reviews of state DOTs designed to cover the following five 

areas: (1) a key financial process or system (e.g., reviewing states’ 

procedures for recouping costs incurred on federal-aid highway projects), 

(2) improper payments, (3) unobligated balances on inactive projects, 

(4) findings reported pursuant to the Single Audit Act,27 and (5) findings 

reported by the DOT Inspector General and GAO. FHWA’s guidance to its 

field offices on how to conduct the reviews generally follows OMB’s 

standards and principles in the circulars. However, the guidance 

sometimes does not provide enough direction about the specific steps that 

reviewers are supposed to complete to help ensure that the reviewer 

provides sufficient evidence to support the work performed and the 

reviewer’s conclusions as required by generally accepted government 

auditing standards.28 For example, in one of the five areas—improper 

FHWA’s Guidance and 

Documentation for 

Reviews of State 

DOTs’ Financial 

Management Systems 

and Practices 

Generally Meet Key 

Standards and 

Principles, but Lack 

Some Important 

Details 

 

25The Improper Payments Information Act of 2002 defines improper payments as any 

payment that should not have been made or that was made in an incorrect amount 

(including overpayments and underpayments) under statutory, contractual, administrative, 

or other legally applicable requirements. The act includes any payment to an ineligible 

recipient, any payment for an ineligible service, any duplicate payment, payments for 

services not received, and any payment that does not account for credit for applicable 

discounts. 

26OMB, Circular No. A-123 (revised), Management’s Responsibility for Internal Control 

(Washington, D.C.: 2004); Circular No. A-123, Appendix C, Requirements for Effective 

Measurement and Remediation of Improper Payments (Washington, D.C.: Aug. 10, 2006); 

Circular No. A-127 (revised), Financial Management Systems (Washington, D.C.: 

Jan. 9, 2009); and Circular No. A-133 (revised), Audits of States, Local Governments, and 

Non-Profit Organizations (Washington, D.C.: June 27, 2003). 

27See 31 U.S.C. §§ 7501-7507. Nonfederal entities that expend $500,000 or more a year in 

federal awards under more than one federal program are required by the Single Audit Act 

to undergo a single audit. The single audit replaces multiple grant audits with one audit of 

an entity as a whole. Single audits focus on the recipient’s internal controls and its 

compliance with laws and regulations governing federal awards. 

28GAO, Government Auditing Standards, July 2007 Revision, GAO-07-731G (Washington, 

D.C.: July 2007). 

Page 15 GAO-09-751 FHWA Oversight
 

payments—the guidance does not require reviewers to identify the causes 

of improper payments and the actions taken to correct those causes, 

assess related information systems, and determine whether a plan has 

been developed to reduce the outstanding amount. Without requiring this 

information, FHWA is missing an opportunity to improve its oversight of 

state-managed projects. 

The 10 field offices we assessed generally documented coverage of the 

required areas in their financial management reviews in 2008, when 5 of 

the field offices documented coverage of all five areas and 4 of the field 

offices documented coverage of four areas. This represents an 

improvement over 2006, when 7 of the field offices documented coverage 

of three areas, and the other 3 the field offices documented coverage of 

two areas. However, the field offices’ documentation sometimes lacked 

information on the specific procedures performed or any issues identified 

by reviewers, as required by generally accepted government auditing 

standards.29 A reason why the information is lacking is because the 

template that FHWA developed and that the field offices used to report the 

results of their reviews does not call for this information. As a result, it is 

more difficult for headquarters staff to monitor and follow up on field 

offices’ and states’ progress. 

For the five field offices that we visited, we also assessed the field offices’ 

tracking of states’ progress in responding to recommendations from the 

field offices’ reviews of state DOTs. The five field offices did not use 

consistent approaches to track states’ progress. However, four of the five 

field offices had useful approaches for tracking states’ progress on 

recommendations. For example, one field office conducted a follow-up 

review in 2008, which found that the state had addressed most findings 

from a 2007 review of local projects, and the field office also tracked the 

state’s progress through written correspondence. Three other field offices 

periodically updated tracking sheets with specific information on actions 

that states have taken to address recommendations. In contrast, another 

field office also used a tracking sheet, but for most recommendations that 

had not yet been implemented, the status field in the database said either 

“mostly complete” or “ongoing,” but did not provide any information on 

what steps have been taken to address the recommendations. The 

agencywide tracking system that FHWA plans to develop is partly intended 

to help improve the tracking of these recommendations. 

 

29GAO-07-731G. 

Page 16 GAO-09-751 FHWA Oversight
 

FHWA does not require states’ financial plans for major highway projects 

to present an estimate of the projects’ financing costs. FHWA’s guidance 

on financial plans for major projects states that the plan should reflect the 

project’s cost estimate and revenue sources and amounts and provide 

reasonable assurance that there will be sufficient financial resources 

available to implement and complete the project as planned. FHWA’s 

guidance also states that financial plans are to provide information on 

immediate and long-term financial implications of projects, and to provide 

reasonable assurance that the project’s impact on the state’s 

transportation capital improvement program has been assessed. However, 

FHWA’s guidance does not require, and states’ plans generally do not 

present, an estimate of financing costs. 

Financial Plans for 

Major Highway 

Projects Lack 

Information on 

Financing Costs 

According to FHWA’s Major Projects Team Leader, the agency does not 

require states to include an estimate of financing costs in the project’s 

financial plan, in part because (1) financing costs are already reflected in 

statewide transportation planning documents and (2) accurately 

estimating financing costs for individual projects is difficult because states 

often fund multiple projects from a single bond issuance. However, while 

some uncertainty about a major project’s financing cost is expected, and 

presenting estimates of financing costs for projects of all dollar amounts 

may be impractical, the costs of major projects can represent a significant 

cost to a state. These costs can, when combined with payments on the 

principal portion of the debt, consume large shares of future federal 

transportation funding, potentially impacting a state’s transportation 

capital improvement program. For example, Maryland DOT officials 

provided us the estimated financing costs associated with the Intercounty 

Connector project, which are $1.4 billion, more than half as much as the 

$2.5 billion cost of designing and constructing the project. The financing 

costs are scheduled to be paid over a 34-year period, with annual 

payments on the portion of the debt repayable with future federal-aid 

highway funds scheduled to peak in 2010, requiring 14 percent of the 

federal-aid highway funds that Maryland is expected to receive that year.30

While estimating a project’s financing costs can be complicated due to 

market conditions and other factors that can change over time, without 

presenting an estimate of these costs, a financial plan may not be meeting 

its intended purposes of providing information on immediate and long-

 

30The project is funded by a combination of grant anticipation revenue vehicles (state 

issued bonds or notes repayable with future federal-aid), toll-backed bonds, state funds, 

and federal funds. 

Page 17 GAO-09-751 FHWA Oversight
 

term financial implications of projects, and providing reasonable 

assurance that a project’s impact on the state’s transportation capital 

improvement program has been assessed. 

FHWA has strengthened its oversight of the federal-aid highway program 

by making improvements to its risk management approach, implementing 

a process to evaluate the credibility of major project cost estimates, and 

issuing financial management review guidance to its field offices that 

generally follows OMB’s standards and principles. The agency is targeting 

its resources by systematically analyzing risks that could have a significant 

impact on the federal aid highway program and developing response 

strategies. FHWA’s evaluations of major project cost estimates assess, 

quantify, and document how risks and uncertainties could affect a 

project’s cost. Also, FHWA’s guidance on financial management reviews 

could help ensure that federal funds are used efficiently and effectively. 

Conclusions 

While FWHA has made substantial improvements, further progress in 

tracking risk mitigation activities, overseeing state cost estimates, 

providing guidance and documentation for financial management reviews, 

and including information in financial plans, would enhance its ability to 

ensure that states effectively manage and control the cost and schedule 

performance of federally aided projects. First, while FHWA plans to 

develop a new system for tracking states’ progress in addressing review 

recommendations, it has not yet committed to requiring its field offices to 

use the planned system, nor has it determined whether it will develop an 

information system for its field offices to track its own progress in 

addressing risks. As a result, FHWA may not be able to fully ensure that 

identified risks to the federal-aid highway program are mitigated or detect 

broader trends or concerns across states. Second, because FHWA has 

made limited progress in meeting SAFETEA-LU’s requirement to 

periodically review states’ cost estimating practices, it cannot ensure that 

states’ estimates are credible or that highway projects are effectively and 

efficiently managed. Third, while FHWA’s guidance and documentation for 

reviews of state financial management systems and practices generally 

meet key standards and principles, requiring more information on the 

procedures reviewers should and do perform, such as identifying the 

causes of improper payments and the actions taken to correct those 

causes, would enhance the agency’s ability to oversee these systems and 

practices. Finally, while financial plans for major projects are designed to 

provide reasonable assurance that sufficient financial resources will be 

available to complete a project, requiring states to present an estimate of 

the financing costs of major projects would help decision makers consider 

Page 18 GAO-09-751 FHWA Oversight
 

and make fully informed decisions about whether to approve the 

substantial investment of public funds that major projects require. 

Because FHWA has actions under way to meet SAFETEA-LU’s 

requirement to issue minimum standards that states must follow when 

estimating project costs, we are not making any recommendations in this 

area. However, to have the greatest impact on the quality of states’ cost 

estimates, it will be important for FHWA to issue the standards in a timely 

manner and to ensure that the standards are consistent with our best 

practices for cost estimating. Some best practices, such as conducting and 

documenting an analysis of risks and uncertainties related to the cost 

estimate, could be costly and would not be appropriate for smaller-dollar 

projects if the anticipated benefit of the practice is exceeded by its 

anticipated cost. 

To help ensure effective and efficient management and oversight of the 

federal-aid highway program, we recommend that the Secretary of 

Transportation direct the Administrator, FHWA, to take the following five 

actions: 

Recommendations for 

Executive Action 

• Require all field offices to use the agency’s planned new system for 

tracking states’ progress in addressing FHWA’s review recommendations. 

• Develop the capability for all field offices to uniformly track the status of 

their efforts to mitigate risks to the federal-aid highway program. 

• Develop and implement a process to periodically evaluate states’ cost 

estimating practices. 

• Supplement FHWA’s guidance for reviewing improper payments by 

including information on the specific steps reviewers are supposed to 

complete, such as identifying the causes of improper payments and 

actions taken to correct those causes. In addition, enhance FHWA’s 

reporting template for its reviews of states’ financial management systems 

by requiring reviewers to document the specific procedures performed. 

• For major projects, require states to present an estimate of financing costs 

in the project’s financial plan. 

Page 19 GAO-09-751 FHWA Oversight
 

We provided a draft of this report to DOT for its review and comment. The 

department did not offer overall comments on the draft report, but it 

provided technical comments, which we incorporated as appropriate. DOT 

also stated it would consider the report's recommendations. 

Agency Comments 

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Transportation, the Director of the Office of 

Management and Budget, and other parties. The report will also be 

available at no charge on the GAO Web site at http://www.gao.gov. 

If you or your staffs have any questions about this report, please contact 

me at (202) 512-2834 or herrp@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

Phillip R. Herr 

listed in appendix II. 

Director, Physical Infrastructure Issues 

Page 20 GAO-09-751 FHWA Oversight
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

To assist Congress in the upcoming reauthorization of the federal-aid 

highway program, we examined the Federal Highway Administration’s 

(FHWA) implementation of several requirements in the Safe, Accountable, 

Flexible, Efficient Transportation Equity Act: A Legacy for Users 

(SAFETEA-LU), specifically its (1) oversight of states’ project delivery 

systems, in particular, its use of a risk management approach to allocate 

their oversight resources; (2) efforts to develop minimum standards for 

states to follow when estimating project costs, and to periodically evaluate 

states’ cost estimating practices; and (3) efforts to review elements of 

states’ financial management systems and practices that affect projects. 

We also examined FHWA’s policy on presenting an estimate of financing 

costs in financial plans for major projects. To address these objectives, we 

reviewed key agency and state departments of transportation (DOT) 

documents and relevant regulations and legislation. We conducted 

interviews with FHWA, and state DOT officials and representatives from 

the American Association of State Highway and Transportation Officials 

(AASHTO). In addition, we observed a risk management training class 

available to FHWA staff. We also visited five FHWA field offices—

specifically Colorado, Delaware/Maryland, Pennsylvania, Washington, and 

Wisconsin—which were selected to cover a range of sizes in terms of 

federal-aid dollars and include some offices that were overseeing a major 

project. Because we used a nonprobability sample, information obtained 

from the field offices that we visited cannot be generalized to all field 

offices. In addition, we assessed financial management reviews in five 

randomly selected field offices, specifically Arizona, Arkansas, 

Connecticut, Idaho, and Iowa. 

To evaluate FHWA’s risk-based approach to oversight, we reviewed a 

report from DOT’s Inspector General (IG) on FHWA’s risk management 

approach and interviewed a DOT IG official to obtain information on 

FWHA’s progress in addressing the report’s recommendations. We 

reviewed FHWA’s risk management guidance and training materials and 

compared them with GAO’s internal risk management guide for analysts.1

In addition, we reviewed FHWA field office risk assessments, annual 

performance plans and other related planning documents, and field office 

documentation of risk and recommendation tracking efforts. To evaluate 

FHWA’s efforts related to cost estimating, we assessed FHWA cost 

estimating guidance and its evaluations of states’ cost estimates for two 

major projects against criteria in GAO’s cost estimating and assessment 

 

1

GAO, Risk Management: A GAO Analysts’ Guide. 

Page 21 GAO-09-751 FHWA Oversight 
Appendix I: Scope and Methodology 

guide.2 We also assessed draft cost estimating guidance being developed 

by AASHTO against criteria in GAO’s guide. We also reviewed FHWA field 

office efforts to periodically assess states’ cost estimating practices by 

conducting interviews with FHWA headquarters and field office staff and 

reviewing field office reports related to state DOT cost estimating 

practices. To assess FHWA’s reviews of financial management systems 

and practices, we reviewed FHWA’s guidance and financial management 

work papers from field offices and compared them with relevant federal 

standards and principles established by the Office of Management and 

Budget in circulars on internal control, improper payments, financial 

systems, and audits of state and local governments; and with generally 

accepted government auditing standards. We also assessed whether the 

field offices’ financial management work papers covered all of the areas 

required by FHWA’s guidance and reviewed field offices’ efforts to track 

related recommendations. Finally, to examine FHWA’s policy on 

presenting financing costs in financial plans for major projects, we 

reviewed FHWA’s financial plan guidance and estimates of financing costs 

on a major project. We also interviewed a state official to obtain views on 

presenting estimates of financing costs in major projects’ financial plans. 

We conducted this performance audit from June 2008 through July 2009 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. 

 

2

GAO, GAO Cost Estimating and Assessment Guide: Best Practices for Developing and 

Managing Capital Program Costs, GAO-09-3SP (Washington, D.C.: March 2009). 

Page 22 GAO-09-751 FHWA Oversight
Appendix II: 

A

GAO Contact and Staff 

cknowledgments 

Page 23 GAO-09-751 

Appendix II: GAO Contact and Staff 

Acknowledgments 

Phillip Herr, (202) 512-2834 or herrp@gao.gov 

In addition to the individual named above, Steve Cohen, Assistant 

Director; Daniel Cain; Jennifer Echard; Fred Evans; Colin Fallon; Kathleen 

Gilhooly; David Goldstein; Jason Lee; Flavio Martinez; Amanda Miller; 

Karen Richey; Amanda Seese; Laura Shumway; and Jack Warner made key 

contributions to this report. 

 FHWA Oversight 

GAO Contact 

Staff 

Acknowledgments 

(546019) 
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