Transportation-Disadvantaged Populations: Some Coordination Efforts Among Programs Providing Transportation Services, but Obstacles Persist
Published: 2003-06-30T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Millions of Americans are unable to provide their own transportation--or even use public transportation--for Medicaid appointments, Head Start classes, job training, or other services. Such "transportation disadvantaged" persons are often disabled, elderly, or low income. Various federal programs are authorized to provide transportation services to them. GAO was asked to (1) identify the federal programs that fund such transportation services and the amount spent on them, (2) assess the extent of coordination among the various programs, and (3) identify any obstacles to coordination and potential ways to overcome such obstacles.
section_title: What GAO Found
paragraphs: Sixty-two federal programs--most of which are administered by the Departments of Health and Human Services, Labor, Education, and Transportation--fund transportation services for the transportation disadvantaged. The full amount these programs spend on transportation is unknown because transportation is not always tracked separately from other spending. However, available information (i.e., estimated or actual outlays or obligations) on 29 of the programs shows that federal agencies spent at least an estimated $2.4 billion on these services in fiscal year 2001. Additional spending by states and localities is also not fully known but is at least in the hundreds of millions of dollars. Efforts to improve services and achieve cost savings through coordination of transportation activities (through sharing resources or information or consolidating services under a single agency) among federal agencies vary. The Coordinating Council on Access and Mobility--a body with representation from the Departments of Transportation and Health and Human Services--has undertaken some activities to improve coordination. However, other agencies that administer a substantial number of programs for the transportation-disadvantaged, such as the Departments of Labor and Education, are not part of the Council. In addition, the Coordinating Council's strategic plan is not linked to its action plan and contains few measurable performance goals. The strategic and annual performance plans of the Departments of Transportation and Health and Human Services contain few references to coordination relating to their subagencies and programs that fund transportation services for the transportation disadvantaged, and the plans of the Departments of Labor and Education do not mention coordinating these services. Obstacles impeding coordination include concern among administrators that their own participants might be negatively affected, program rules that limit use by others, and limited guidance and information on coordination. To mitigate these obstacles, officials and experts suggested making federal standards more consistent, creating a clearinghouse or better Web site to facilitate interagency communication and provide better guidance on coordination, and providing financial incentives or instituting mandates to coordinate.

section_title: Letter
paragraphs: The ability to access personal or public transportation is fundamental for  people to connect with employment opportunities, health and medical  services, educational services, and the community at large. However,  certain populations in the United States lack the ability to provide their  own transportation or have difficulty accessing whatever conventional  public transportation may be available. These “transportation- disadvantaged” persons may have an age-related condition, a disability, or  income constraints. This is potentially a sizeable group. For example,  according to the 2000 U.S. Census, 35.1 million people were over age 65,  44.5 million people were over age 21 and disabled, and 33.9 million people  were living below the poverty line. Many within these populations face  significant problems in accessing transportation.
Many federal programs authorize use of funds to provide transportation  for transportation-disadvantaged people so they can access government  programs. Programs that provide incidental transportation include health  and medical programs, job-training programs, or programs for the aging.  The coordination of these transportation services—through pooling  resources, consolidating trips provided by various agencies under a single  agency, or sharing information between programs—has been found to  improve the quality and cost-effectiveness of service. At the federal level,  the Coordinating Council on Access and Mobility—a body consisting of  representatives from the Departments of Health and Human Services and  Transportation—is charged with coordinating transportation services  provided by federal programs and promoting the maximum feasible  coordination at the state and local levels. In a 1999 report, we found that  these coordination efforts needed strengthening. We have also issued  other reports raising concerns about service coordination.
You asked that we study the extent to which government agencies and  programs are currently providing transportation services to the  transportation-disadvantaged and coordinating the provision of these  transportation services and that we update you on actions taken by the  Coordinating Council since our 1999 report. This report addresses (1) the  federal programs that provide transportation services for transportation- disadvantaged populations and the types of services they provide; (2)  federal, state, and local government spending for transportation services  through these federal programs; (3) the extent of coordination among  state, local, and federal agencies in delivering transportation services for  the transportation-disadvantaged, including actions taken by the  Coordinating Council; and (4) any obstacles that may impede effective  coordination and potential options for overcoming such obstacles.
Our overall approach was to (1) review federal laws and regulations  governing the use of federal funds for services for transportation- disadvantaged populations; (2) analyze spending data where available; (3)  review federal and other governmental activities and the research  literature related to the coordination of transportation services; and (4)  obtain the views of more than 100 officials from federal, state, and local  government agencies, industry and client advocacy groups, and other  experts involved with or affected by the coordination process on the  obstacles and options for improving coordination. Many of these  interviews were part of case studies that we conducted in five states— Arizona, Florida, New York, South Dakota, and Wisconsin—to understand  how these various federal programs were implemented and coordinated at  the state and local level. We chose these states to include a cross section  of characteristics including urban/rural mix, geographic area of the  country, and presence or absence of a state council or other coordinating  body. Appendix I contains more information about our scope and  methodology.
subsections: section_title: Background
paragraphs: Many elderly, disabled, and low-income individuals face significant  challenges in accessing transportation. For example, some of these  challenges are as follows:    Sixteen percent of respondents over age 75 reported not having a driver’s  license in 2001, and 25 percent of the respondents had not driven at least  once in the last month according to an AARP survey. Elderly people are  also more likely to have difficulty accessing traditional public  transportation due to physical ailments.
Thirty percent of respondents with disabilities reported difficulty in  accessing transportation, compared to 10 percent of respondents without  a disability, according to a 2000 survey by the National Organization on  Disabilities.
Low-income households are less likely to own a car than other households  due to the prohibitive cost of purchasing, insuring, and maintaining a car,  and public transportation may not provide sufficient options for their  needs. Over 90 percent of public assistance recipients do not own a car.
The importance of coordinating transportation services for transportation- disadvantaged populations has been evident since the 1970s. In 1977, we  issued a report on transportation coordination, which concluded that the  most significant hindrance to the coordination of transportation services  under these programs was confusion at all levels of government as to how  much coordination federally funded projects could engage in. Since 1986,  responsibility for coordinating transportation programs at the federal level  has rested in the Coordinating Council on Access and Mobility, which was  created under a memorandum of understanding between the Department  of Health and Human Services (HHS) and the Department of  Transportation (DOT). This body is composed of representatives from  program offices within these departments, and employees of the two  departments meet its staffing needs, on a part-time basis.
More recent reviews have continued to identify a need for stronger efforts  in this area. In a 1999 report on transportation coordination, we found  that coordination efforts of the Coordinating Council, DOT, and HHS were  ongoing but still needed strengthening. This report also noted that the  Congress had endorsed increased coordination as evidenced by several  provisions in the Transportation Equity Act for the 21st Century (TEA- 21), and significant financial benefits had been realized through  coordination. In addition, reports by advocacy groups and transportation  researchers have raised concerns over continuing duplication of effort  among federal programs and certain sub-populations still not being served  effectively.
section_title: Sixty-Two Federal Programs Fund Transportation Services to Transportation- Disadvantaged Populations
paragraphs: We identified 62 federal programs that fund transportation services to  populations that are transportation-disadvantaged. As shown in figure 1,  the bulk of these programs are administered by four federal agencies—23  programs in HHS, 15 programs in the Department of Labor (DOL), 8  programs in the Department of Education, and 6 programs in DOT. The  remaining 10 programs are administered by the Departments of Housing  and Urban Development (HUD), Veterans Affairs (VA), Agriculture, and  the Interior. A full listing of programs, their authorizing legislation, typical  uses, types of trips provided, target populations, and spending information  is found in appendix II.
Many of the 62 programs are significantly involved in providing  transportation services to their recipients. These include 16 programs  identified by the Community Transportation Association of America  (CTAA) as being routinely used to provide transportation and an  additional 11 programs that we identified as spending at least $4 million  for transportation services to transportation-disadvantaged populations in  fiscal year 2001 on the basis of funding data or estimates that were  available. The remaining programs also fund transportation services, but  do so minimally, or the extent of transportation services funded is  unknown, according to program officials. Table 1 shows the 16 programs  identified by CTAA and how they provide transportation. These 16  programs are administered by DOT, HHS, Education, and DOL. As the  table shows, transportation is not the primary purpose of most of these  programs. For example, Medicaid provides payments for medical services,  and the Vocational Rehabilitation Grants Program provides training and  employment services to individuals with disabilities.
Table 2 shows the 11 programs we identified as spending at least $4  million on transportation for the transportation-disadvantaged in fiscal  year 2001.
Under most of the federal programs providing transportation services,  funding recipients typically purchase the services from existing sources,  according to program officials. This includes contracting for services with  private transportation providers or providing bus tokens, transit passes,  taxi vouchers, mileage reimbursement to volunteers or program  participants, or some combination of these methods. For example,  recipients of funds from DOL’s Workforce Investment Act Adult Services  Program typically provide bus tokens or mileage reimbursement for  participants to access training, while recipients of HHS’s Grants for  Supportive Services and Senior Centers most often contract with local  transportation providers to provide client transportation. The funding  recipients of several programs, however, typically purchase and operate  vehicles, or modify existing vehicles for use by individuals with  disabilities. These programs include Head Start and the Program for  American Indian, Alaskan Native, and Hawaiian Elders in HHS; the  Vocational Rehabilitation Grants Program in the Department of Education;  and the six programs within DOT.
Several of these programs have requirements for grantees to coordinate  their services with other agencies providing similar services, which would  include transportation, among other services. For example, Head Start  grantees are required to make every reasonable effort to coordinate  transportation services they provide with other human service  transportation in their communities. Similarly, DOT’s Capital Assistance  Program for Elderly Persons and Persons with Disabilities, Job Access and  Reverse Commute, and Nonurbanized Area Formula Program have  requirements for grantees to coordinate their transportation services. In  addition, some programs have provisions designed to avoid duplication of  effort and encourage the use of existing community resources. For  example, Workforce Investment Act programs may use funds to support  those who are participating in the program only if those individuals are  unable to obtain services through other programs, according to program  officials. Also, the Veterans’ Workforce Investment Program requires  grantees to provide information on the linkages this program will have  with other providers of services to benefit veterans.
section_title: Extent of Spending on Services for the Transportation- Disadvantaged Is Not Fully Known but Is in the Billions of Dollars
paragraphs: Available information shows that federal programs spent an estimated $2.4  billion on transportation services for transportation-disadvantaged  populations in fiscal year 2001, and additional state and local spending for  these populations was several hundred million dollars more. Complete  spending information is not available because many federal funding  recipients are not required to distinguish transportation from other  spending when reporting spending information to federal agencies.
subsections: section_title: Spending by 29 Federal Programs Is Estimated at $2.4 billion in Fiscal Year 2001
paragraphs: Information on federal spending for transportation is available for 29 of  the 62 programs we identified. These programs spent an estimated $2.4  billion on transportation services in fiscal year 2001. (Appendix II lists  available spending data for each federal program.) Based on available  information, HHS programs as a whole spent the most on transportation  for transportation-disadvantaged populations in 2001—an estimated $1.8  billion. Table 3 shows estimated transportation spending by the eight  federal agencies that fund services for the transportation-disadvantaged.
More than three-quarters of our estimate is based on spending for  transportation in five programs. Of the five, Medicaid and Head Start, both  in HHS, spent the most on transportation in fiscal year 2001—an estimated  $976.2 million and $514.5 million, respectively. The three other programs,  all of which spent more than $100 million on services for the  transportation-disadvantaged in fiscal year 2001, were DOT’s Capital  Assistance Program for Elderly Persons and Persons with Disabilities,   HHS’s Temporary Assistance for Needy Families (TANF), and VA’s  Veterans Medical Care Benefits.
The amount spent on transportation services by the remaining 33 federal  programs is unknown, mainly because the majority of programs do not  require recipients of federal funds to report transportation spending  information to the federal agency.
section_title: State and Local Transportation Spending Is Unknown, but Is Likely Significant
paragraphs: Total state and local spending for transportation services, which  supplements federal spending for such programs, is likely significant—at  least in the hundreds of millions of dollars—although the total is unknown  because most programs do not require grantees to report these data.  Matching requirements, which represent the nonfederal contributions to  the program’s costs that come from state, local, or private funds, provide  some information on state and local spending on transportation for the  transportation-disadvantaged. About half of the 62 programs have  matching requirements that generally require states and localities to  contribute between 5 and 50 percent of total costs. Additionally, limited  information from officials in the five states we visited indicates that total  state and local spending on transportation runs into the hundreds of  millions of dollars. For example:    Nonfederal contributions for Medicaid nonemergency transportation  ranged from 32 to 50 percent of the total spending on this service in the  five states that we visited. In New York, 50 percent, or an estimated  $139.4 million, of the state’s total spending on Medicaid funded  transportation in 2001 was from nonfederal sources. In Florida and  Wisconsin approximately 40 percent of the total amount spent on  nonemergency medical transportation in the state was from nonfederal  sources; state contributions in those states were $28.6 million and $13.4  million, respectively, in 2001. In Arizona and South Dakota, approximately  one-third of the total amount spent on Medicaid transportation was from  nonfederal sources in those states in 2001, approximately $7.0 million and  $490,000, respectively.
In Wisconsin nearly 38 percent, or $922,000, of the funding to provide  transportation services through DOT’s Capital Assistance Program for  Elderly Persons and Persons with Disabilities in 2001 was from nonfederal  sources. The program requires grantees to provide 20 percent of total  program funding.
In New York, about 30 percent of the spending on transportation under the  Department of Education’s Vocational Rehabilitation Program in 2002, or  $2.6 million, was from nonfederal sources. Similarly, about 27 percent or  $673,000 of Florida’s funding was from nonfederal sources in 2001. The  program requires states to contribute 21.3 percent of total costs.
Although some states and localities currently spend a significant amount  for transportation through federal programs, many now face budget  deficits that could diminish their future contribution to these programs. In  a 2003 survey by the National Conference of State Legislatures, 36 states  reported budget deficits midway through their fiscal year. Fifteen of these  states reported deficits in excess of 5 percent of the state budget, and four  states are facing deficits greater than 10 percent of the state budget.  Because 49 states have balanced budget requirements, such large deficits  could lead to a decrease in the amount of funds available to states for  programmatic spending, including transportation programs. For example,  according to the National Conference of State Legislatures report, 29  states have imposed across-the-board cuts in response to budget deficits.
State budget deficits have affected state transportation spending  differently in the five states that we visited. For example:    Two of the states have cut their state programs that local grantees used to  fund services for the transportation-disadvantaged, according to  transportation officials in those states. In one state, the state legislature  eliminated the state’s transportation assistance program to help deal with  the state’s budget deficit; as a result, the state official and the director of a  senior center in the state said that some of the projects funded through the  program will likely be discontinued because grantees cannot find  replacement funds. In the other state, the state legislature cut a state fund  that grantees used to supplement federal transportation funding.  According to an official, the loss of this fund, combined with the  increasing costs of fuel and insurance, may lead providers to cut service to  transportation-disadvantaged populations by as much as 40 percent.
In another state, the Governor’s plan for closing the state’s budget gap  includes reducing spending on Medicaid nonemergency medical  transportation by $5 million, or 7.6 percent; however, the state’s fund  dedicated to providing other services for the transportation-disadvantaged  was not recommended for cuts.
Transportation officials in two states told us that they had not yet  experienced cuts in state funding for services for the transportation- disadvantaged. In one of the states, local grantees rely on a state  transportation fund and a large set-aside of TANF funds to provide  services to transportation-disadvantaged populations. Without these two  funds, local grantees would have difficulty financing services for the  transportation-disadvantaged, according to an official. The other state is  not currently anticipating cuts in state funding for services for  transportation-disadvantaged populations, however, according to an  official, the full impact of the fiscal situation in that state will not be  known until local governments develop program budgets for 2004 because  the local governments—which are also facing budget constraints—play a  key role in determining what services will be provided.
While some states are not currently experiencing reductions in their  transportation programs, many states are anticipating that budget deficits  will continue into 2004. According to the National Conference of State  Legislatures report, 36 states are anticipating budget gaps for 2004; nearly  all of these states anticipate gaps greater than 5 percent of their state  budget and half of these states expect gaps greater than 10 percent.
section_title: Coordination Efforts Vary, but Some Successful Efforts Show Promising Results
paragraphs: Efforts to improve services and achieve cost savings through coordination  of transportation activities among agencies at all levels of government  vary. At the state and local levels, the extent and the type of coordination  activities differ, ranging from one state body providing guidance and  overseeing coordination efforts for most of its programs to two local  agencies sharing vehicles. In some areas within the five states we visited,  coordination among providers has resulted in significant benefits, such as  improved customer service and lower unit costs. However, we also found  some examples of overlapping, fragmented, or confusing services resulting  from a lack of coordination. At the federal level, DOT, HHS, and—to some  extent—DOL have undertaken some activities aimed at improving  coordination among their programs. DOT and HHS implement many of  their activities through the Coordinating Council on Access and Mobility.  However, DOT and HHS make only a few mentions of coordinating  services for the transportation-disadvantaged in their strategic and annual  performance plans, and other agencies do not mention such activities at  all. Also, several federal agencies that provide services to the  transportation-disadvantaged are not involved in coordination efforts at  the national level.
subsections: section_title: Extent of State and Local Transportation Coordination Varies
paragraphs: While agencies within each state we visited were involved in some form of  coordination, the extent of coordination of transportation services varies  widely. For example, Florida has a state organization that oversees the  coordination of most of the transportation services for the transportation- disadvantaged, while some other states we visited had no statewide  coordination body. Even in states without such a coordinating body,  however, some state and local agencies are engaged in coordination  efforts. This variation also occurred in the nation as a whole, according to  data from a preliminary report by the National Academy of Sciences’  Transportation Research Board, which found that roughly half of U.S.  states have a state transportation coordinating body.  (See appendix III  for information on the type of coordination in the five states we visited  and the state agencies involved.)
Within each state, local efforts also varied. Examples of coordination  activities include the following:  Coordinated planning: In this type of coordination, some combination of  human service and transportation agencies and providers work together to  plan transportation services for their clients. For example, in northwestern  Wisconsin, at the initiative of staff from a center for independent living,  the Area Consortium on Transportation was formed in 2001 to improve the  planning and provision of transportation for the disabled and others who  are transit-dependent. The council—which consists of consumers, transit  providers, county and city officials, disability organizations, and aging  groups—is instituting several pilot programs to test various methods of  coordination.
Brokerage:  In this type of coordination, one agency or provider serves as  the central point of contact for providing ride and eligibility information or  actually arranging transportation services for clients of multiple programs.  For example, officials in several New York counties wanted to maximize  residents’ mobility by coordinating transportation services offered by  various federal and state programs, but lacked the expertise or start-up  costs to do so. With a grant from the state Departments of Transportation  and Health, the counties instituted a coordination demonstration project  whereby one agency arranges an average of 2,500 daily trips for clients  from a number of populations—such as the disabled, senior citizens,  former welfare recipients, and others—served by different federal and  state programs.
Shared use of vehicles among multiple programs: In this type of  coordination, one agency may provide transportation for clients of  multiple programs, or each program may own its own vehicles but allow  them to be used by other programs. For example, in Arizona, vans from  one county’s vocational rehabilitation center travel to a neighboring  county to pick up program clients. While there, they also transport clients  of Jobs Administration programs. The two programs split the cost of  transportation equally.
Appendix IV contains a list of some informational resources available for  agencies interested in coordinating.
section_title: Coordination Has Led to Improvements, While Lack of Coordination Can Result in Overlap
paragraphs: In some areas we visited, coordination among providers—through sharing  vehicles, consolidating services under a single agency, or sharing  information about available services—has resulted in significant benefits,  such as improved customer service and lower unit costs. State and local  agencies providing transportation under the 62 federal programs often  serve similar client groups, provide similar services, and operate in similar  geographic areas, so there can be duplication of effort and inefficiency in  providing transportation when those agencies do not coordinate. In our  site visits, we found several examples of overlapping, fragmented, or  confusing services in places where agencies were not coordinating.
subsections: section_title: Benefits of Coordination
paragraphs: Through coordination, some local agencies have realized both improved  levels of service and financial benefits, such as reduced costs of providing  each trip, as follows:    A coordinated system in central Florida provides transportation for  Medicaid, vocational rehabilitation, and other programs. According to  local officials, vans used to show up late, if at all, and clients had difficulty  finding out the status of their ride. Since consolidating services under a  single provider and bringing scheduling and dispatch services in-house,  officials report service improvement.
Through collaboration, information-sharing, and cost-sharing among  county agencies, the Clinton County transit system in New York serves  both Medicaid and elderly populations, making it easier for those  populations to access medical and community services because they only  have to be familiar with one system.
A federal regional official said that coordination could remove the stigma  of specialized transportation because all recipients use the same service  and are treated equally.
Three New York counties joined in a transportation brokering service that  saved an estimated $92,000 in 2001 by identifying a lower-cost alternative  means of transportation, that is, moving groups of clients in buses rather  than transporting individual clients in taxis. This brokerage service  provides transportation to Medicaid patients, the disabled, veterans, and  other client groups.
In Aberdeen, South Dakota, the local transit agency consolidated the  transportation services previously provided by both senior and medical  centers as well as other federal, state, and local programs. This  consolidation allowed the agency to increase the number of trips provided  while reducing the average cost of providing each trip by about 20  percent—from about $5 to $4. The agency has also improved its services  by coordinating with local taxi companies to provide night and weekend  trips.
section_title: Effects of a Lack of Coordination
paragraphs: Although the various programs we reviewed target specific populations,  some populations are eligible to receive transportation services from  multiple programs, resulting in duplication and inefficiency in some cases.  In our visits with state and local transportation and human service  agencies and providers, officials we interviewed identified several  examples of overlapping services in areas or programs that were not  coordinating. A for-profit transportation provider in one state told us that  he often has two vehicles overlap on the same route at the same time, one  for medical trips and one for paratransit, because it is too difficult to mix  clients due to complicated fee structures and paperwork requirements  imposed by the state for the two programs. An official from a workforce  development program in another state told us that many programs in his  county use their own vans to deliver clients to the job center, but because  the programs do not coordinate, only a few people ride in each van. In  another locality that state and local officials said has had difficulty  coordinating, several human service providers hired a consultant to study  the extent to which various agencies provide similar transportation  services within a geographic region. This research showed substantial  overlap in local services for the transportation-disadvantaged, as shown in  figure 2. The consultant identified ways in which the number of routes  could be substantially reduced through better coordination, which are  being considered by the agencies involved.
State and local officials also provided examples of fragmented services  and confusion in localities without coordinated programs. One official in  an uncoordinated area said that a lack of coordination results in  fragmented services, placing a burden on people who receive  transportation through many different programs, depending on trip  purpose, because they must be familiar with multiple systems, rules, and  requirements. Fragmentation also occurs when adjoining counties do not  coordinate their public transportation routes, leaving riders stranded due  to unconnected transit systems. In one state, local officials told us that  paratransit services do not extend beyond county lines, so people have to  schedule two separate trips to get from their homes in one county to  medical services in an adjoining county. When the first paratransit ride is  behind schedule, a passenger sometimes has to wait for hours for the  connecting ride. A provider in another state has contracts to provide  transportation services for clients in multiple human service programs.  Because of a lack of coordination among those programs, the  transportation provider said that his company has to maintain two  separate dispatching and reservation systems for its vehicles to comply  with differing reporting and eligibility requirements. Vehicles can only  operate under one dispatching system at a time, so the drivers cannot  provide rides to more than one type of client at a time. The provider also  said that clients who call for rides are confused by the sheer number of  programs, and the agents who make their reservations do not know for  which programs the clients are eligible.
section_title: Federal Progress toward Improved Coordination Varies
paragraphs: Although the Coordinating Council on Access and Mobility and various  federal agencies have taken a number of steps to improve coordination,  these efforts have had mixed results.
subsections: section_title: Some Prior Recommendations to the Coordinating Council Have Been Implemented
paragraphs: As shown in table 4, the Coordinating Council on Access and Mobility—a  body consisting of representatives from DOT and HHS—has responded to  three of the recommendations we made in our 1999 report by adopting a  strategic plan, developing an action plan, and helping to ensure that  planned coordination efforts reinforce one another by issuing guidelines  for coordinating transportation services. Goals and objectives in the  strategic plan include such things as promoting interdepartmental  collaboration at the federal level through the development of a joint  agenda for transportation research that is of common use to multiple  federal departments. According to the most recent action plan, the Council  has completed some activities, such as producing a series of “how to”  publications on using intelligent transportation systems to assist in the  coordination of HHS programs with local transit agencies.
The Council’s responses to the other three recommendations are still  ongoing. For example, Council representatives told us that they plan to  issue their first annual report on coordination achievements in June 2003,  although this report was originally due to be issued in October 2000,  according to the Council’s strategic plan. With regard to the  recommendation on regional working groups, the 10 DOT and HHS  regional offices have been convening workshops with state transportation  officials during 2003 to discuss obstacles to coordination and other issues.
Finally, the Council’s efforts to strengthen its Web site have had mixed  results. One of the tasks listed in the Council’s strategic plan is to develop  and maintain a Web site that would, among other things, enhance the  exchange of coordination ideas, issues, and concerns. The Council has  developed a Web site—operated by DOT in conjunction with CTAA—that  is reachable through a link on the Federal Transit Administration’s section  of DOT’s Web site. However, there is no similar link from HHS’s Web site  (or the Web sites of other federal agencies that fund transportation  services for the transportation-disadvantaged), possibly making it more  difficult for human service and other agencies to be aware of and access  the site. In addition, the site does not yet contain specific information on  obstacles to coordination or strategies for overcoming them, which we  recommended in 1999, though it does contain links to some reports on the  subject. There is also a page from which viewers can E-mail the Council  with questions or suggestions. The Council is working with CTAA to  further strengthen the site.
section_title: DOT and HHS Have Sponsored Other Coordination Activities
paragraphs: Through the Council, DOT and HHS have sponsored a number of other  efforts to enhance coordination. For example, as part of an item in the  Council’s action plan, DOT and HHS helped initiate a consortium of  national professional organizations and interest groups to conduct  research and provide educational activities related to coordinating  services for the transportation-disadvantaged. Among other tasks, the  consortium has been asked to pursue several items from the Council’s  action plan, such as identifying promising practices and obstacles in  transportation coordination and developing strategies for addressing the  obstacles. Officials from the Council said that working with the  consortium provides a depth of knowledge and experience because  consortium members represent local as well as national interests so that  issues are pursued “from both ends.”
As part of the upcoming regional workshops sponsored by the DOT and  HHS regional offices, participants will discuss expanded opportunities for  achieving more coordinated delivery of transportation services in medical,  aging, and other assistance programs, and technical assistance resources  will be shared with participants. Intended audiences include state  transportation coordinating councils; state agencies that administer  medical, aging, and other assistance programs; and agencies serving  individuals with disabilities. According to DOT and HHS, participants will  be asked to develop state transportation coordination action plans for  their home state, and resources will be made available to assist states in  implementing their plans following the workshop. (See appendix III for  more information on federal coordination activities.)
section_title: Coordination Remains Largely Unaddressed in Strategic Planning Efforts
paragraphs: Because it is not a federal executive branch agency, the Coordinating  Council is not subject to the requirements of the Government Performance  and Results Act (GPRA) of 1993 and, therefore, does not have to follow  the act’s guidance for producing strategic plans, annual performance  plans, and annual reports. However, there are several best practices in  strategic planning that could be useful guides for improving the Council’s  strategic plan when it is updated at the end of 2003 and the action plan  when it is next updated. For example, the current strategic plan does not  contain an overall mission statement for the Council or performance  measures that clearly relate to its long-term goals and objectives, both of  which are considered best practices in strategic planning. In addition,  there are no explicit links between the stated goals and objectives in the  strategic plan and the activities in the action plan. For example, the  current action plan includes seven tasks related to the use of information  technology systems, but those tasks are not clearly linked to any of the  Council’s long-term goals or objectives.
Because the Council has no funding or full-time staff of its own, it is  dependent on support from HHS and DOT. However, neither department  currently highlights the coordination of services for the transportation- disadvantaged as a priority in its long-term strategic plan or annual  performance plan. According to GPRA guidance, agencies are encouraged  to identify programs with common purposes or crosscutting issues in their  strategic plans. In addition, the agencies’ annual performance plans should  identify performance goals that reflect activities being undertaken to  support programs of a crosscutting nature, and show evidence of  coordination among crosscutting programs. DOT’s most recent strategic  plan and performance plan do not explicitly mention the Coordinating  Council, although both briefly discuss coordinating special-needs  transportation with other federal agencies under DOT’s Job Access and  Reverse Commute (JARC) program. However, there is no mention of  coordination of DOT’s Transit Capital Assistance Program for Elderly  Persons and Persons with Disabilities with other programs for elderly or  disabled populations. At the subagency level, the Federal Transit  Administration’s strategic plan includes the Coordinating Council in an  appendix on coordination of crosscutting functions, under the strategic  goal of promoting economic growth and trade, and its performance plan  mentions working with the Council under a different goal—that of  promoting mobility and accessibility.
HHS’s current strategic plan does not discuss coordination of  transportation services with other agencies, but its draft plan for 2003-2008  specifically lists DOT and state and local transportation and human service  agencies as important partners in providing transportation to access  services in distressed communities and for health care and employment  and training programs elsewhere. Education, DOL, HUD, and VA are not  listed, however. The performance plans of individual HHS components  vary widely in their treatment of transportation coordination. For  example, the performance plan of the Centers for Medicare & Medicaid  does not mention transportation at all, while the Administration on Aging’s  performance plan states that the agency works closely with HHS and DOT  officials on the Coordinating Council in pursuit of improved transportation  services.
The strategic and annual performance plans of the other federal agencies  that fund transportation services for the transportation-disadvantaged  generally do not mention coordination of such services.
section_title: Other Federal Agencies Are Involved in Some Coordination Efforts
paragraphs: Other federal agencies are also involved in some coordination efforts  outside the scope of the Council. For example, DOL is working with CTAA  and DOT to implement several rounds of pilot projects testing various  transportation strategies in support of local one-stop employment and  training centers. Officials from DOT and DOL are also in the process of  developing guidelines for using Workforce Investment Act funds (a DOL  program) for Job Access purposes (a DOT program). In addition, some of  DOL’s research studies and technical assistance materials provide  examples of transportation coordination efforts. However, we did not  find examples of involvement in transportation coordination efforts at the  national level at the Departments of Education, HUD, and VA, although  some of these agencies are involved in transportation working groups in  some of the federal regional offices. The membership of the Coordinating  Council only consists of DOT and HHS officials, representing less than half  of the 62 federal programs that can be used to fund services for the  transportation-disadvantaged. Although these two agencies comprise the  majority of funding for transportation that we were able to identify, the  Departments of Labor and Education also have a significant number of  programs—more than one-third of the total—that provide services to the  transportation-disadvantaged. Officials from the Council said that other  agencies had expressed interest in coordination activities and had been  invited to observe Council meetings in the past, but only DOL sent a  representative for a short time period. Council officials said it would be  very beneficial to have other agencies formally involved in their  coordination efforts, which would require a renewal of the Council’s  charter and memorandums of understanding among all agencies involved  as well as other formal mechanisms to ensure that the proper people are  engaged in the effort.
section_title: Officials Cited Numerous Obstacles to Successfully Coordinating Services and Provided Potential Options to Mitigate Them
paragraphs: Although some federal, state, and local agencies encourage the  coordination of services for the transportation-disadvantaged and some  coordination efforts have been established, federal, state, and local  officials, as well as representatives of national advocacy and industry  organizations with whom we spoke, identified numerous obstacles that  impede effective coordination. We clustered the wide range of identified  obstacles into three categories related to (1) sharing vehicles and the low  priority given to funding coordination activities; (2) programmatic  differences; and (3) limited federal, state, and local leadership and  commitment to undertake and sustain coordination efforts. To mitigate  these obstacles, these officials and other experts suggested three potential  options: harmonizing standards and requirements among federal programs  with a transportation component, providing and disseminating additional  guidance and information on coordination, and providing financial  incentives or mandates to coordinate.
subsections: section_title: Officials May Be Reluctant to Share Vehicles and Provide Financial Resources for Coordination
paragraphs: One set of obstacles was related to officials’ reluctance to share vehicles  or their tendency to give low priority to funding coordination activities. In  addition, some areas have limited transportation services available, thus  limiting any opportunities to benefit from coordination.
subsections: section_title: Apprehension about Sharing Vehicles
paragraphs: In interviews in every state we visited, as well as with national advocacy  and industry organizations, the unwillingness or inability to share vehicles  was identified as a major obstacle. Administrators of some federal  programs may be apprehensive about sharing vehicles for coordination  due, in part, to their belief that only they understand their clients’ needs  and can provide the necessary personalized services. For example,  program administrators reported being concerned about a loss of control  over the quality and convenience of transportation services for their  clients and wanted to maintain their discretion over how to serve their  clients and which transportation resources to purchase. Program  administrators also expressed concern over mixing vulnerable  populations, such as the developmentally disabled and children, or frail,  sick, and healthy populations, in one coordinated system. According to a  report on coordinated transportation systems, this reluctance among  providers to cooperate can lead to an underutilization of vehicles.
Likewise, some human service clients may be apprehensive about using  coordinated transportation because they may be uncomfortable mixing  with members of other populations with whom they are unfamiliar or they  may fear a loss of accommodation or convenience, such as having to  switch from door-to-door service to curb-to-curb service or public transit.
section_title: Low Priority Given to Funding Coordination Activities
paragraphs: The overall costs of coordination, which can include additional staff  members and staff time needed for maintaining and overseeing  coordination efforts, can be significant. For example, a transportation  brokerage firm in one state faced substantial added costs when it began  coordinating transportation for human services programs due to  requirements to meet more stringent state and federal safety standards.  However, some officials stated that the low priority given to funding  coordination activities could impede coordination efforts. For example,  according to officials in one state, although recipients of funds from DOT’s  Capital Assistance Program for Elderly Persons and Persons with  Disabilities are required to coordinate with other local transportation  services provided from federal sources, the program’s current allotment  for administrative expenses would not support any staff to work on  coordination activities. In addition, some states invest in coordination,  while others do not allocate funds specifically for coordination, and efforts  to coordinate often become ancillary activities for those involved.
section_title: Limited Transportation Services Available to Realize Benefits from Coordination
paragraphs: Guidelines issued by the Coordinating Council state that coordination will  not solve all transportation problems in all communities. Coordination  may not be an effective strategy in those communities that have limited  transportation services available, particularly in those communities that  are not served by public transportation. For example, in some remote  areas—such as the northwestern part of South Dakota where services  available to many communities are 40 to 60 miles away—there are few  transportation services available to transport individuals to hospitals or  other services. In these areas, coordination may not be a workable or cost- effective option.
section_title: Differing Program Requirements Can Impede Coordination
paragraphs: Coordinating multiple programs administered at various levels of  government is complicated because the programs have different  requirements with respect to eligibility, funding, reporting, and safety; and  they differ in their programmatic goals and missions.
subsections: section_title: Different Eligibility Requirements
paragraphs: Federal program rules that specify the eligible populations that each  program can serve may limit opportunities for collaboration. For example,  DOT officials in one region stated that they were unable to combine DOL  and DOT funds for a DOT transportation program for migrant farm  workers because DOL funds are designated for U.S. citizens, while there is  no such restriction on the use of DOT funds. In addition, some liability  insurance policies specify that a program’s vehicles may serve only a  certain population, thus those programs face additional insurance costs to  transport individuals other than program clients. Such restrictions may  lead to inefficient transportation services within a community. For  example, an official in one state we visited commented that one agency’s  vehicle provided medically related trips three times per week to that  agency’s clients, but would not transport other individuals seeking similar  medical services provided under other federal programs due, in part, to  liability insurance restrictions. Safety requirements may also vary by  program and jurisdiction, thus complicating efforts to transport multiple  client groups. Some programs, such as Head Start, have specific vehicle  standards that are often more stringent than those of other programs,  making it difficult to share vehicles. For instance, different standards for  roof strength, types of seat belts, and driver qualifications pose problems  for schools, human service agencies, and public transit providers  interested in sharing vehicles. Some areas have been able to overcome  specific program rules to share vehicles. For example, a Head Start  grantee in one state we visited was able to transport students using  vehicles supplied by the local public transit provider because these  vehicles met the same safety standards as school buses.
section_title: Varying Funding Streams and Cycles
paragraphs: Funding streams and cycles vary across federal programs, making  coordination more difficult. For example, DOT funds generally flow from  the state to counties or cities, while DOL funds flow through the state to  local designees. In addition, funding for programs such as Head Start flow  directly to grantees rather than through states, making it more difficult for  the states to directly manage the coordination activities of local grantees,  according to an official in one state. There is also complexity in working  with different funding time frames and cycles under multiple federal  programs. For example, although DOT’s JARC program allows grantees to  use other federal funds to provide the local “match” required to obtain  JARC funds, the funding time frames and cycles of these other funding  sources are different, complicating efforts to combine financial resources.
section_title: Lack of Uniform Data Collection and Reporting Requirements among Programs
paragraphs: Different reporting requirements among programs can create excessive  paperwork in a coordinated system and may make it difficult for agencies  to determine their true transportation costs and the benefits that may be  realized from coordination. For example, one report commented that a  transit provider was required to give each of several human service  agencies a separate bill for services provided, which reflected the unique  requirements imposed by each of those agencies. Furthermore, according  to officials, Medicaid requires the state Medicaid agency to demonstrate  that individuals receiving transportation under Medicaid are not receiving  transportation from any other source and that the transportation is  medically necessary, complicating the determination of how to fund  transportation services for each Medicaid recipient in a coordinated  system in which costs are shared among agencies. In addition, human  service agencies and providers may not be required or accustomed to  collecting complete and uniform transportation data for their programs. A  recent report concluded that such information was beneficial because it  enabled administrators to re-evaluate how best to provide transportation  services and the savings they could achieve through coordination. For  example, when Florida’s statewide coordination program was established,  state and local agencies in Florida reported their total estimated annual  transportation-related expenditures at $8 million. However, once reporting  requirements were in place for all agencies providing services for the  transportation-disadvantaged, actual expenditures were estimated to total  $224.9 million statewide—much higher than the initial estimate. Such  information has helped agencies in Florida understand the true costs of  providing transportation and has encouraged some agencies to become  more interested in coordination as they realize the potential for cost  savings.
section_title: Distinct Purposes and Goals among Agencies
paragraphs: Unlike transportation agencies, human service agencies provide  transportation as a secondary service so that their clients may access  primary human services. Therefore, while DOT-funded transportation  agencies have specific and relatively uniform federal requirements for  transportation planning, human service agencies do not typically conduct  transportation planning or collect transportation-related data for their  programs, making the planning of coordinated transportation between  transit and human service agencies challenging. In addition, human  service, transportation, medical, and workforce agencies all have distinct  technical languages and cultures, which may inhibit collaboration among  these agencies. In one state we visited, the labor and transportation  departments experienced difficulty collaborating because some common  terms have completely different meanings within each agency. For  example, transportation officials interpreted the term “cost-allocation” as  an accounting methodology to estimate the overall cost of operating  transportation services in order to determine the appropriate rate to  charge for these services, while state labor officials interpreted the term as  a way to determine what proportion of overall costs will be funded by  each agency.
section_title: Program Officials May Not Know How to Coordinate Effectively
paragraphs: Although some federal and state agencies have recognized the potential  offered by coordination and provided some assistance toward this end,  officials we interviewed expressed concerns about the amount and  effectiveness of the guidance they have received on coordination. In  addition, the absence of interagency forums or other mechanisms to  develop and share information about coordination initiatives limits the  support that local providers receive to effectively coordinate.
subsections: section_title: Limited Federal Guidance and Information on Coordination
paragraphs: Officials in some states we visited said that they receive little federal  guidance on potential strategies to coordinate services. As a result, they  develop their own approaches without the benefit of guidance on the most  effective way to coordinate services. We found the following examples of  this in our work:    Officials in one state said that the guidance on how to share costs among  programs for projects funded jointly by DOT’s JARC grants, HHS’s TANF  Program, and DOL’s Welfare-to-Work Program funds did not indicate how  such sharing could or should be done. Instead, the officials had to seek  advice from other states.
While FTA disseminated coordination guidelines for FTA and HHS  programs to transportation officials, some HHS and transportation  officials said these guidelines were not widely disseminated to human  services officials or programs.
According to state Medicaid offices and a national organization of  individuals and agencies concerned with human services, the Centers for  Medicare & Medicaid Services have not provided sufficient guidance on  how to coordinate Medicaid transportation with existing public transit or  other transportation resources.
The Coordinating Council on Access and Mobility has limited visibility for  agencies actually involved in implementing coordination efforts. In several  states, human service program administrators with whom we spoke were  not aware of the Council or its Web site.
section_title: Limited State Guidance and Leadership on Coordination
paragraphs: In the five states we visited—even in those states with a coordinating  body—there was limited state guidance to help local areas implement  coordination, and some officials stated that the lack of leadership and  commitment at the state level was a major obstacle to local coordination.  In addition, while some states have established coordinating councils or  bodies or have designated a lead agency for coordination, nearly half of  the states have no coordinating body, according to one report. Officials in  one state explained that the lack of a coordinating body that requires  various agencies to discuss and resolve transportation issues is the main  obstacle toward a more coordinated system.
section_title: Limited Local Leadership and Commitment to Coordinate
paragraphs: Even in states with a coordinating council or a lead state agency, there  may be a lack of local leadership or commitment to coordination efforts.  For example, one city we visited was unsuccessful in achieving a  coordinated system despite state encouragement to coordinate and some  state-provided technical assistance. Stakeholders there described a lack of  local commitment and leadership in maintaining lines of communication  among those involved in coordination efforts as a factor leading to the  failure. In addition, program administrators may not have data on the  extent of existing transportation services that may be available to their  clients within a geographic region and, therefore, may fail to realize the  extent of overlapping and complementary services within their local area.  Such data can produce improvements. For example, in response to a lack  of data on local services, an agency in one state we visited took the lead in  conducting a study that showed the extent to which various agencies  provide similar transportation services within a geographic region. An  agency official was hopeful that once other agencies saw the extent of  overlap, they would be more willing to coordinate.
section_title: Potential Options to Improve Coordination
paragraphs: Federal, state, and local officials, as well as experts in the area, have  suggested three potential options to improve coordination of  transportation services among federal programs: (1) harmonizing  standards and requirements among federal programs, (2) expanding  interagency forums and providing and disseminating additional guidance  and information on coordination, and (3) providing financial incentives or  coordination mandates.
subsections: section_title: Harmonizing Program Standards and Requirements
paragraphs: Officials and experts expressed a need to harmonize requirements among  federal programs, such as providing more flexible regulatory language that  would allow providers to serve additional client groups, creating  consistent cost accounting methods, and adopting common safety  standards. For example, one official commented that federal program  regulations could include language permitting other client groups to make  use of available transportation options. Also, some officials believed that  adopting standard accounting procedures among all federal human service  programs could provide a consistent measure for comparing services,  allowing administrators to evaluate how best to provide transportation  services and determine the savings they could achieve through  coordination. Likewise, making standards for safety (e.g., types of seat  belts), driver training, and liability insurance provisions uniform among  federal human service programs, as appropriate, may facilitate the shared  use of vehicles and drivers in one coordinated system, according to some  officials. Finally, some officials suggested that federal grant programs that  allow the use of funds from multiple sources should be under the same  funding cycle or time frame so that these funds may be combined more  easily. These officials also commented that harmonizing the time frames  under which federal funding is allocated could possibly aid collaborative  planning. However, differing program standards exist to ensure that the  distinct needs of specific target populations are adequately served and that  agencies maintain accountability for providing these services. Thus, the  benefits from any change in standards or requirements would need to be  balanced against continuing to properly meet client needs and sufficiently  control funds distributed to grantees. In addition, harmonizing program  standards and requirements among 62 federal programs authorized by  more than 20 pieces of legislation would necessitate extensive legislative  changes and could impose additional costs for agencies to meet new  requirements.
section_title: Expanding Interagency Forums and Providing and Disseminating Additional Guidance and Information on Coordination
paragraphs: Some officials advocated expanding the number of agencies involved in  coordination, establishing interagency forums, and improving central  clearinghouses as ways to better develop and disseminate guidance on  coordination. To enhance coordination efforts at the federal level, some  officials suggested expanding the membership of the Coordinating Council  on Access and Mobility to include additional federal agencies, so that a  broader array of agencies that serve the transportation-disadvantaged are  represented. This could include agencies such as DOL and the Department  of Education that we identified as being significant because a large  number of their programs authorize funding of transportation services for  the transportation-disadvantaged. In addition, establishing state-level  forums may also facilitate communication among agencies involved in  coordination and can lead to benefits. For example, one state has  established an interagency task force on transportation coordination,  which has resulted in a number of benefits—including the pooling of  vehicles and the expansion of services—in some areas of the state. Some  officials and experts suggested that federal agencies provide additional  guidance and other information that result from forums or other sources  to clearly define the allowable uses of funds, assist agencies in developing  cost-sharing arrangements for transporting common clientele, and  encourage the establishment and participation in interagency forums. This  additional guidance and information could be better disseminated through  a central clearinghouse, such as the Coordinating Council’s Web site.
section_title: Providing Financial Incentives or Mandates
paragraphs: Some officials and experts believed that incentives or mandates could help  improve coordination, although others expressed concerns that such  actions would have negative effects on the ability of local agencies to  respond to community needs. Officials provided several examples,  including the following:    Federal grant applications could contain provisions giving priority in  funding to those grantees committed to coordination efforts.
With legislative changes, current funds allotted by multiple federal sources  could be combined into one federal, state, or local fund for transportation  services for the transportation-disadvantaged.
Funding opportunities could be tied to federal or state coordination  mandates so that there are financial consequences for a failure to  coordinate.
However, officials pointed out that these options also had some potential  downsides that would need to be carefully considered. For example,  combining funds into a single source could result in some populations  being unfairly overlooked because smaller agencies at the state or local  level would be at a disadvantage in competing for funding with larger  agencies serving more clients. Several officials also raised concerns about  mandates to coordinate. For example, some officials said that mandates  might reduce the flexibility of agencies to design and deliver  transportation services that specifically address their communities’ needs.  In addition, some officials noted that state efforts or mandates might not  guarantee successful local coordination. For example, a city in one state  we visited was unsuccessful in coordinating its multiple transportation  services despite state encouragement to do so and despite losing some  federal funding as a result.
section_title: Conclusions
paragraphs: Successful coordination among programs for the transportation- disadvantaged is not a simple matter. One clear need, given the sheer  number of programs involved, is active and sustained leadership at the  federal level. While the Coordinating Council on Access and Mobility is  positioned to supply that leadership, its efforts are constrained in two  main ways. The first is limited membership: only two departments—DOT  and HHS—are members. While these departments administer nearly 30  programs that can be used for transportation, the Departments of  Education and Labor administer almost as many. The absence of  Education and Labor lessens the ability to muster a collective effort for  greater coordination. The second constraint is a limited ability to translate  a strategic vision into a set of actions. At present, there are no clear links  between the long-term goals in the Council’s strategic plan and the  individual tasks in its action plan. Without such links, the Council risks  judging its progress on the basis of activities undertaken rather than on  the outcomes of those activities and their contribution toward achieving  long-term goals. Linking these goals and actions to the strategic and  annual performance plans of participating departments—because the  Council relies heavily on support from its member agencies—would  provide an additional incentive to pursue coordination activities in the  departments’ activities.
There is great diversity in the specific suggestions we received about how  to overcome obstacles to greater coordination. Two of the three main  options raised by various officials we interviewed—making federal  program standards more uniform and creating some type of requirement  or financial incentive for coordination—would require substantial  statutory or regulatory changes and include potential costs. The third  option, expanding forums and disseminating guidance, can be done in the  context of existing laws, regulations, and procedures, and may, therefore,  be the most expeditious starting point. In this regard, clarification from  federal agencies about how funds can be used for coordination could help  state and local agencies overcome some of the obstacles identified.  Similarly, state and local agencies may be in a better position to  coordinate efforts if they have more knowledge about what has worked  elsewhere. Although the Council has a Web site with information about  coordinating transportation services, some state and local officials were  unaware of it. State and local officials’ point of contact is more likely to be  the Web site of the department administering the program at the federal  level. Establishing better links between the Council’s Web site and the  sites of the departments could help connect grantees with information that  may help them coordinate with other programs, better serve clients, and  use funds more efficiently.
section_title: Recommendations for Executive Action
paragraphs: To increase communication and collaboration among the major agencies  involved in providing transportation services for the transportation- disadvantaged, we recommend that the Secretaries of the Departments of  Labor and Education join the Coordinating Council on Access and  Mobility.
To promote and enhance federal, state, and local transportation  coordination activities, we recommend that the Secretaries of the  Departments of Health and Human Services, Labor, Education, and  Transportation take the following actions:   As member agencies of the Coordinating Council on Access and  Mobility, ensure that the long-term goals in the Council’s strategic plan  have clear links to the individual tasks in its action plan and that these  actions are tied to measurable annual performance goals.
Ensure that strategic and annual performance plans discuss their  departments’ transportation coordination efforts and incorporate long- term goals and performance measures that address the need for  coordination among programs for the transportation-disadvantaged.
Develop and distribute additional guidance to states and other grantees  that encourages coordinated transportation by clearly defining the  allowable uses of funds, explaining how to develop cost-sharing  arrangements for transporting common clientele, and clarifying  whether funds can be used to serve individuals other than the  program’s target population.
Link the Web sites of their agencies involved in providing services for  the transportation-disadvantaged to the Coordinating Council’s Web  site and advertise the site in agency correspondence and during  conferences or other outreach opportunities.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided the Departments of Health and Human Services, Labor,  Education, Transportation, Housing and Urban Development, and  Veterans Affairs with draft copies of this report for their review and  comment. We requested verification of key facts from the Departments of  Agriculture and the Interior, but we did not seek comments from these  departments because they did not administer significant numbers of  programs that benefit the transportation-disadvantaged.
All six departments generally agreed with the findings and conclusions in  the report and provided technical clarifications, which were incorporated  as appropriate. The four departments to whom we made  recommendations—Health and Human Services, Labor, Education, and  Transportation—also generally concurred with those recommendations. In  particular:    The Department of Health and Human Services provided written  comments on the draft of this report which are presented and evaluated in  appendix V. The department noted that it has initiated actions to  implement our recommendations, including (1) strengthening the linkage  between the Coordinating Council’s strategic and action plans, (2)  reviewing the department-wide strategic plan for opportunities to reflect  its transportation coordination efforts, (3) developing coordination  guidance, and (4) linking the Coordinating Council’s Web site to the  Department of Health and Human Services’ Web site. The department also  suggested that we consider incorporating other researchers’ estimates of  transportation spending by health and human service programs. However,  we estimated program expenditures only for those programs where there  was sufficient evidence to support an estimate.
Department of Labor officials stated that the department looks forward to  joining the Coordinating Council on Access and Mobility to improve the  transportation services provided by federal human service programs. In  addition, department officials commented that the reauthorization of some  human service and surface transportation legislation was forthcoming  during the preparation of this report and that these legislative changes  may impact the future directions of the federal programs included in this  report.
The Department of Education provided written comments on the draft of  this report, which are presented in appendix VI. The department said that  it would look favorably on an opportunity to join the Coordinating Council  on Access and Mobility and it would consider developing coordination  guidance for state and other grantees and instituting methods of linking  Web-based information resources about transportation.
Department of Transportation officials said that the Federal Transit  Administration is committed to accomplishing effective transportation  coordination and noted that the list of the agency’s activities and  accomplishments in appendix III of this report demonstrate its  commitment and support for coordination. It also stated that the  administration’s proposal for the reauthorization of surface transportation  legislation, introduced in May 2003, includes provisions that would  encourage further coordination efforts.
We are sending copies of this report to the appropriate congressional  committees and to the Secretaries and other appropriate officials of the  Departments of Transportation, Health and Human Services, Labor,  Education, Housing and Urban Development, Veterans Affairs,  Agriculture, and the Interior. We also will make copies available to others  upon request. In addition, the report will be available at no charge on the  GAO Web site at http://www.gao.gov.
If you have any questions about this report, please contact me at  siggerudk@gao.gov or at (202) 512-2834. Additional GAO contacts and  acknowledgments are listed in appendix VII.
section_title: Appendix I: Scope and Methodology
paragraphs: Our scope of work included federal programs that provide transportation  services to the transportation-disadvantaged. To provide information on  the purposes and types of such federal programs, we first determined the  universe of programs by reviewing an existing inventory produced by the  Community Transportation Association of America and a report prepared  for the Coordinating Council on Access and Mobility. We then  supplemented and modified this inventory of programs on the basis of  interviews with agency officials and searches of the Catalog of Federal  Domestic Assistance. We included only those programs that provide  nonemergency, nonmilitary, surface transportation services of any kind,  targeted to transportation-disadvantaged populations. We interviewed  program administrators to identify the general target population and the  types of transportation services and trips that are typically provided under  each program.
To address the issues related to program funding, effects of coordination,  and coordination obstacles and options, we (1) conducted interviews and  document reviews in the pertinent eight federal agencies that administer  the 62 federal programs that fund transportation services for the  transportation-disadvantaged; (2) conducted five case studies in Arizona,  Florida, New York, South Dakota, and Wisconsin; (3) reviewed the  literature on the challenges encountered in coordinating services for the  transportation-disadvantaged; and (4) interviewed industry  representatives and advocacy groups representing elderly and disabled  populations. We did not verify spending data or estimates received from  federal agencies for accuracy.
At the federal level, we interviewed officials from the headquarters of the  Federal Transit Administration in the Department of Transportation; the  Administration on Aging, the Administration for Children and Families, the  Centers for Medicare & Medicaid Services, the Health Resources Services  Administration, the Office of Intergovernmental Affairs, and the Substance  Abuse and Mental Health Services Administration in the Department of  Health and Human Services; the Employment and Training Administration  in the Department of Labor; the Department of Agriculture; the  Department of Education; the Department of Housing and Urban  Development; the Department of the Interior; and the Department of  Veterans Affairs. We also interviewed federal officials from the 10 regional  offices of the Federal Transit Administration and some regional officials in  the Departments of Health and Human Services and Labor. The federal  officials we met with included representatives of the Coordinating Council  on Access and Mobility from the Federal Transit Administration and the  Department of Health and Human Services.
In conducting our case studies in the five states, we reviewed  documentation and interviewed more than 100 officials from state and  local transportation and human service agencies and service providers, as  well as consumers of transportation services. We judgmentally chose the  states to include three states without a state mandate or state coordinating  body and two states with such conditions. We also chose states on the  basis of relative concentrations of elderly, disabled, and low-income  populations, and for some, geographic dispersion. Within each state, we  spoke with state officials responsible for coordinating transportation  services for the transportation-disadvantaged and/or overseeing funds  from the 62 federal programs we identified. We also asked some of these  state officials for recommendations of local officials and transportation  providers to interview in a range of urban, suburban, and rural areas and  coordinated and uncoordinated programs within the state.
Finally, we interviewed representatives of professional, industry, and  advocacy organizations that are part of the National Consortium on the  Coordination of Human Services Transportation, a group that represents a  broad spectrum of stakeholders involved with coordination of  transportation for the disadvantaged. We conducted our work from July  2002 through June 2003 in accordance with generally accepted  government auditing standards.
section_title: Appendix II: Inventory of Federal Programs Providing Transportation Services to the Transportation-Disadvantaged
subsections: section_title: Program Department of Agriculture, Food and Nutrition Service
paragraphs: Food Stamp Act  of 1977, as  amended  7 U.S.C. §  2015(d)(4)(I)(i) (I)
Department of Education, Office of Elementary and Secondary Education  21st-Century  Community Learning  Centers  Department of Education, Office of Innovation and Improvement  20 U.S.C. §  7173(a)(10) $84,600,000  (estimate)
20 U.S.C. §  7225a(a)
Department of Education, Office of Special Education and Rehabilitative Services  Individuals with  Disabilities  Education Act  20 U.S.C. §§  1401(a)(22),  1411(a)(1)
Workforce  Investment Act of  1998  29 U.S.C. §§  796f-4(b)(3)  and 705(18)(xi)
U.S. Code  provisions  authorizing  funds for  transportation  29 U.S.C. §  796k(e)(5)
Workforce  Investment Act of  1998  29 U.S.C. §§  796e-2(1) and  705(18)(xi)
Workforce  Investment Act of  1998  29 U.S.C. §§  795g and  705(36)
Rehabilitation  Act of 1973, as  amended  29 U.S.C. §  723(a)(8)
Persons with  physical or  mental  impairments  $50,700,000  (estimate)
To access  child care  services  $0 (estimate)
U.S. Code  provisions  authorizing  funds for  transportation  42 U.S.C. §§  15002,  15081(2)(D)
Target  population as  defined by  program  officials  Persons with  developmental  disabilities  42 USCA §  9835(a)(3)(C)  (ii)
Fiscal year   2001 federal  spending on  transportation  No actual data or  estimate  available from  the federal  agency  $514,500,000  (estimate)
Refugee Act of  1980, as  amended  8 U.S.C. §§  1522(b)(7)(D),  1522(c)
Refugee Act of  1980, as  amended  8 U.S.C. §§  1522(b)(7)(D),  1522(c)
Refugee Act of  1980, as  amended  8 U.S.C. §§  1522(b)(7)(D),  1522(c)
Refugee Act of  1980, as  amended  8 U.S.C. §§  1522(b)(7)(D),  1522(c)
Social Security  Act, as amended  42 U.S.C. §  1397a(a)(2)(A)
Fiscal year   2001 federal  spending on  transportation  $786,605 (partial  outlay)
Personal  Responsibility  and Work  Opportunity  Reconciliation  Act of 1996, as  amended  42 U.S.C. §§  604(a), (k)
No assistance  is provided to  families  without a minor  child, but  states  determine  specific  eligibility  $160,462,214  (partial outlay)
Older Americans  Act of 1965, as  amended  42 U.S.C. §§  3057,  3030d(a)(2)
Social Security  Act, as amended  42 U.S.C. §§  1396a,  1396n(e)(1)(A)
To access  health care  services  $976,200,000  (estimate)
Medicare,  Medicaid, and  SCHIP Benefits  Improvement  and Protection  Act of 2000  42 U.S.C. §§  1397jj(a)(26),  (27)
Department of Health and Human Services, Health Resources and Services Administration  Public Health  Service Act, as  amended  42 U.S.C. §  254b(b)(1)(A)  (iv)
Public Health  Service Act, as  amended  42 U.S.C. §  256(e)(1)(B)(iii)
To access  health care  services  $4,200,000  (estimate)
Service Act, as  amended  42 U.S.C. §  254c-8(e)(1)
Ryan White  Comprehensive  AIDS Resources  Emergency Act  of 1990  42 U.S.C. §§  300ff-21(a),  23(a)(2)(B)
No actual data or  estimate  available from  the federal  agency  No actual data or  estimate  available from  the federal  agency  $19,500,000  (estimate)
Social Security  Act, as amended  42 U.S.C. §  701(a)(1)(A)
ADAMHA  Reorganization  Act, as amended  42 U.S.C. §  300x-1(b)(1)
ADAMHA  Reorganization  Act, as amended  42 U.S.C. §  300x-32(b)
Department of Housing and Urban Development, Office of Community Planning and Development  Housing and  Community  Development Act  of 1974  42 U.S.C. §  5305(a)(8) $6,761,486   (partial outlay)
42 U.S.C. §  12907(a)(3)
To access  health care  and other  services  $190,252   (partial outlay)
Program must  serve a  majority of low- income  persons  Low-income  persons with  HIV or AIDS  and their  families  Homeless  persons and  families with  children  $14,000,000  (estimate)
Department of Housing and Urban Development, Office of Public and Indian Housing  Housing and  Community  Development Act  of 1992, as  amended  42 U.S.C. §  1437v(l)(3)
Residents of  the severely  distressed  housing and  residents of  the revitalized  units $700,000  (estimate)
Workforce  Investment Act of  1998  29 U.S.C. §§  2801(46),  2912(d)
Workforce  Investment Act of  1998  29 U.S.C. §  2911(d)(2)
Older Americans  Act of 1965  42 U.S.C. §  3056(c)(6)(A)  (iv)
Low-income  persons aged  55 or over  $4,400,000  (estimate)
U.S. Code  provisions  authorizing  funds for  transportation  19 U.S.C. §  2296(b)
Personal  Responsibility  and Work  Opportunity  Reconciliation  Act of 1996  42 U.S.C. §  612(a)(3)(C)
Personal  Responsibility  and Work  Opportunity  Reconciliation  Act of 1996  42 U.S.C. §  603(a)(5)(C)
Investment Act of  1998, as  amended  29 U.S.C. §§  2801(46),  2864(d)(2)
Workforce  Investment Act of  1998, as  amended  29 U.S.C. §§  2801(46),  2864(e)(2)
Workforce  Investment Act of  1998, as  amended  29 U.S.C. §§  2801(46),  2864(e)(2)
U.S. Code  provisions  authorizing  funds for  transportation  29 U.S.C. §§  2801(46),  2854(a)(4)
Workforce  Investment Act of  1998, as  amended  29 U.S.C. §§  2801(46),  2914(b)
Fiscal year   2001 federal  spending on  transportation  No actual data or  estimate  available from  the federal  agency  $415,000  (estimate)
Fiscal year   2001 federal  spending on  transportation  $17,500,000  (estimate)  $0  (partial  obligation)
General public,  although  paratransit  services are  for the special  needs of  persons with  disabilities  $36,949,680  (partial  obligation)
Fiscal year   2001 federal  spending on  transportation  $126,594,591   Grantees report total expenditures and unliquidated obligations made by the state Vocational  Rehabilitation (VR) Agency for transportation services provided to individuals served under the State  VR Services Program for a fiscal year. Total obligations include both federal and nonfederal funds  under the State VR Services Program, the supplemental federal funds awarded to the State VR  Agency for the cost of supported employment services under the Supported Employment Program,  and funds from other rehabilitation sources. The Department of Education does not collect data on  the specific sources of funds used for transportation obligations under the program. However, based  on information available from total annual obligations on a national aggregate basis, a program official  estimated that of the total amount reported for transportation, about 96 percent would be from the  State VR Services Program, and of that amount approximately 76 percent would be federal funds.  Similar estimates could not be made for the Supported Employment Program.
Public Law 102-477 is applied to allow tribal governments to consolidate funding from several federal  programs. These include: the Department of Health and Human Services’s Temporary Assistance for  Needy Families, and Child Care and Development Fund programs; the Department of Labor’s Native  American Employment and Training, and Welfare-to-Work Grants for Federally Recognized Tribes  programs; and the Bureau of Indian Affairs’ Employment Assistance, Indian Social Service and  Welfare Assistance, Adult Basic Education, and Higher Education programs. The Indian Social  Services and Welfare Assistance Program is not used for transportation outside 102-477. The Adult  Basic Education and Higher Education programs do not target transportation-disadvantaged  populations as defined in this study outside of 102-477. The Employment Assistance program and the  HHS and DOL programs provide transportation assistance separately from 102-477.
Program funding from fiscal year 1998 and 1999 may still be spent, but the program no longer  receives funding.
section_title: Appendix III: Federal and State Coordination Efforts
paragraphs: Federal and state efforts to coordinate the services for the transportation- disadvantaged provided through their programs vary widely. This  appendix offers some examples of those efforts.
subsections: section_title: Federal Coordination
paragraphs: In 1999, we reviewed the coordination efforts of the Coordinating Council  on Access and Mobility, a body of representatives from the U.S.  Department of Transportation (DOT) and the U.S. Department of Health  and Human Services (HHS). We made several recommendations for  improving coordination between these two agencies. Table 5 shows the  recommendations and actions taken in response.
As a result of items in the Coordinating Council’s strategic plan and action  plan, FTA and HHS have undertaken multiple efforts to coordinate  transportation services provided through their programs. Other federal  agencies are also involved in coordination activities. Examples of federal  coordination efforts include the following:    The FTA and HHS’s Administration on Aging have entered into a  memorandum of understanding to increase coordination of transportation  for older adults. For example, the agreement says that FTA and the  Administration on Aging will work together to better coordinate the  provision of funding opportunities to the aging services and transportation  networks for the purpose of fostering coordination of transportation  services and developing innovative service delivery models.
FTA and HHS’s Centers for Medicare & Medicaid Services are developing  an action plan between them to address the coordination of Medicaid  funded transportation.
Department of Labor (DOL) and DOT officials are developing guidelines  about using Workforce Investment Act funds for programs funded under  DOT’s Job Access and Reverse Commute Program.
Some federal regional offices have interagency working groups to discuss  transportation and other areas of mutual concern. Four of the 10 regions  have formal working groups that meet regularly to discuss ways to use  federal funds more efficiently, including for transportation services. These  groups include officials from FTA, HHS and, in some regions, the  Departments of Labor, Education, Housing and Urban Development,  Veterans Affairs, and others. In 4 other regions, FTA and some  components of HHS work together informally. One of the regions also has  a formal working group that meets quarterly to discuss Workforce  Investment Act programs.
A study undertaken on behalf of DOT and HHS examined seven specific  planning strategies that can be used as part of a flexible regional planning  process for coordinating transportation services of health and human  service and transit agencies. The report is available on the Coordinating  Council’s Web site.
The Community Transportation Association of America (CTAA) is an  organization consisting primarily of rural and small community  transportation providers, and it serves the dual role of transportation  industry representative and mobility advocate. It also has responsibility for  updating and maintaining the Coordinating Council’s Web site. CTAA  sponsored a National Summit on Coordination in May 2003 to encourage  federal, state, and local coordination. The participants—who came from  federal departments, human service agencies, state associations, and  transit providers—discussed, among other things, obstacles to  coordination and strategies for addressing them.
CTAA established a Web site for the National Transit Resource Center, an  information clearinghouse funded by DOT and HHS. The site contains  links to the Coordinating Council as well as to the Community  Transportation Assistance Project (CTAP) and the Rural Transit  Assistance Program (RTAP). CTAP, funded by HHS, provides information  about transportation issues, such as accessibility, coordination, funding  opportunities, training, management, and legislation and regulations.  CTAP also compiled a comprehensive list of federal funding resources for  community transportation providers. The purpose of RTAP, funded by  FTA, is to provide training and technical assistance for rural public  transportation operators, improve professionalism and safety of rural  public transit services, promote efficiency and effectiveness of rural  transit services, and support coordination with human service  transportation.
HHS and CTAA have developed and distributed an Employment  Transportation Toolkit designed to help communities improve access to  transportation for employment purposes.
DOL is working with CTAA and DOT to implement several rounds of pilot  projects testing various transportation strategies in support of local one- stop employment and training centers. According to DOL officials, these  strategies can include referral services, transportation information,  transportation services coordination, mobility management, and other  transportation strategies.
DOL also provides funding to CTAA to convene regional workshops  among workforce development, human services, transportation, and  business communities, and to update a technical assistance toolkit for  employment transportation. The toolkit includes promising practices from  the state and local levels, as well as information on how businesses can be  employment transportation partners.
According to agency officials, DOL’s Employment and Training  Administration sponsored a “Promising Practices” project that includes  transportation coordination efforts.
The National Consortium on the Coordination of Human Services  Transportation—an initiative of FTA and HHS, under the direction of  CTAA—plans to design and conduct a survey of state Medicaid directors  to compile data on the Medicaid transit pass program, brokerages, and  other transportation funding mechanisms within Medicaid; develop a new  brochure outlining the benefits of the Medicaid pass program; develop  case studies of successful brokerage programs and design a brochure  describing them; identify promising practices and obstacles in human  service transportation coordination and develop strategies for addressing  these obstacles; and provide outreach on coordination efforts and  resources.
The federally-funded Transportation Research Board, an arm of the  National Academy of Sciences, has several completed and ongoing  projects on transportation coordination, including the following:  In June 2000 the board issued “Welfare-to-Work: Integration and  Coordination of Transportation and Social Services.” This report  identifies obstacles former welfare recipients face in making the  transition to work and suggests practical strategies to improve access  to job opportunities.
A draft report of TCRP Project B-24, “Toolkit for Rural Community  Coordinated Transportation Services,” is expected in June 2003. The  objective of this research is to develop a practical toolkit for use by  local communities, state agencies, and tribal governments in planning  and implementing coordinated community transportation services in  rural areas.
The final report of TCRP Project H-26, “Economic Benefits of  Coordinating Human Service Transportation and Transit Services,” is  expected in late 2003. The executive summary has been made available  for distribution. In this project, the researchers are examining the  economic benefits associated with various strategies and practices for  coordinating health and human services and transit providers, as well  as additional benefits (beyond costs) that might be obtained through  further coordination efforts.
TCRP Project H-30, “Strategies to Increase Coordination of  Transportation Services for the Transportation Disadvantaged,” has an  expected completion date of January 2004. The objective of this  research project is to develop strategies for initiating or improving  coordination of local and regional publicly funded transportation  services for the transportation-disadvantaged.
section_title: State Coordination
paragraphs: Coordination of transportation services at the state level varies. We visited  two states with formal coordinating bodies, one state with a formal  arrangement between two agencies, and two states with no formal  coordination. Table 6 identifies the states’ coordination arrangements and  the agencies involved in formal coordination efforts.
Arizona does not have formal transportation coordination efforts at the  state level, though some state agencies work together informally, and  some localities have similar arrangements. For example, an official from  the Jobs Administration in the Department of Economic Security said that  the Administration works with the Department of Transportation to try to  avoid duplication of services in rural areas.
Florida has a state coordinating body that oversees local coordination  efforts among most programs. This body is called the Commission for the  Transportation-Disadvantaged and was created in 1989 by the Florida  Legislature to oversee the implementation of coordinated transportation  disadvantaged services. The commission appoints local Community  Transportation Coordinators who are responsible for the arrangement or  delivery of transportation services for transportation-disadvantaged  persons, either by brokering services or by providing transportation  directly. Agencies are required to purchase transportation through the  coordinated system, unless the services offered do not meet the needs of  the client or the agency can find a lower cost alternative that meets the  same safety standards.
New York does not have a formal coordinating body, but some state  agencies work together informally and many local agencies have entered  into brokerage agreements. Officials from the Departments of Labor and  Transportation say they have been working together to identify needs and  initiate transportation projects for employment programs. In addition, five  state agencies review and comment on applications for FTA’s Transit  Capital Assistance Program for Elderly Persons and Persons with  Disabilities.
South Dakota has a state coordination task force that provides guidance to  local coordination efforts, but not all localities or programs have  developed coordinated systems. South Dakota established its  Transportation Planning and Coordinating Task Force in 1998 at the  initiative of the governor’s office. Additionally, the Departments of Human  Services and Transportation require all of their programs or applicants to  coordinate with other resources in the community.
Wisconsin does not have a single body in state government that  coordinates all of Wisconsin’s services for the transportation- disadvantaged, but some state and local programs do coordinate. The state  Departments of Transportation and Workforce Development jointly  administer the Wisconsin Employment Transportation Assistance Program  (WETAP), which uses a combination of federal, state, and local funds to  provide transportation for low-income residents to get to jobs and  employment services. WETAP applicants are required to demonstrate  coordination, and only one grant application is accepted per county. Other  agencies are also working to improve coordination. The Departments of  Transportation and Health and Family Services are trying to coordinate  Medicaid transportation. In addition, the Department of Health and Family  Services convened a conference in August 2002 to discuss ways to  improve coordination of transportation for people with disabilities.
section_title: Appendix IV: Informational Resources on Coordination
subsections: section_title: Web Sites
section_title: Reports
paragraphs: Community Transportation Association of America. 2002. Building  Mobility Partnerships: Opportunities for Federal Investment.  Washington, D.C.: Community Transportation Association of America.
Coordinating Council on Access and Mobility. 2000. Planning Guidelines  for State and Local Coordination. Washington, D.C.: Coordinating Council  on Access and Mobility.
Creative Action, Inc. 2001. Coordinating Transportation Services: Local  Collaboration and Decision-Making. Prepared for Project Action. Akron,  OH: Creative Action, Inc.
National Governor’s Association. 2002. Improving Public Transportation  Services through Effective Statewide Coordination. Washington, D.C.:  U.S. Department of Health and Human Services and U.S. Department of  Transportation.
Volpe National Transportation Systems Center. 2002. Innovative State and  Local Planning for Coordinated Transportation. Washington, D.C.: U.S.  Department of Transportation.
Westat. Economic Benefits of Coordinating Human Service  Transportation and Transit Services. Transit Cooperative Research  Project of the Transportation Research Board. Forthcoming.
Westat. Toolkit for Rural Community Coordinated Transportation  Services. Transit Cooperative Research Project of the Transportation  Research Board. Forthcoming.
National Transportation Consortium of States, Ecosometrics, Inc., and the  American Public Works Association for the Coordinating Council on  Access and Mobility. 2000. Working Together: A Directory of State  Coordination Programs, Policies, and Contacts: 1999-2000. Washington,  D.C.
section_title: Appendix V: Comments from the Department of Health and Human Services
paragraphs: The following are GAO’s comments on HHS’s letter dated May 30, 2003.
subsections: section_title: GAO Comments
paragraphs: 1.  HHS suggested that we consider incorporating other estimates of  transportation spending by health and human service programs,  particularly one estimate that assumed transportation spending  accounted for 5 percent of total program spending. In developing our  estimate of transportation spending, we only included actual or  estimated figures for which the agencies could provide supporting  evidence. For those programs that had actual or estimated spending  information, on average, about 3 percent of total spending for those  programs was devoted to transportation. We do not know whether this  3 percent is an appropriate estimate of transportation spending for  other programs because grantees are generally not required to report  transportation spending information to the federal agency  administering the program. Furthermore, several officials who  administer programs that had no spending data told us that  transportation services probably represented less than 1 percent of  their total program spending.  2.  HHS proposed that we identify the levels, sectors, and affiliations of  officials and others we interviewed. In all agencies and locations we  talked with key human service and transportation officials responsible  for the delivery and coordination of human and transportation  services. We interviewed more than 100 officials in numerous federal,  state, and local transportation and human service agencies as well as  individuals representing service providers, consumers, and  professional and industry advocacy organizations. In our scope and  methodology section (see app. I), we generally describe the  responsibilities and affiliations of those we interviewed.
section_title: Appendix VI: Comments from the Department of Education
section_title: Appendix VII: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: In addition to the individuals above, Christine Bonham, Bradley Hunt, Bert  Japikse, Jessica Lucas-Judy, Sara Ann Moessbauer, Hilary Murrish, Ryan  Petitte, Stanley Stenersen, and Andrew Von Ah made key contributions to  this report.