Federal Transit Administration: Progress Made in Implementing Changes to the Job Access Program, but Evaluation and Oversight Processes Need Improvement
Published: 2006-11-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Begun in 1998, the Job Access and Reverse Commute (JARC) program provides grants to states and localities for improving the mobility of low-income persons seeking work. The Federal Transit Administration (FTA) administers this program. In 2005, the Safe, Accountable, Flexible, Efficient Transportation Equity Act--A Legacy for Users (SAFETEA-LU) authorized $727 million for JARC for fiscal years 2005 through 2009, changed how these funds were to be awarded after fiscal year 2005, and required FTA to evaluate the program by August 2008. GAO examined (1) SAFETEA-LU's changes to JARC, (2) FTA's progress in implementing these changes, (3) states' and localities' efforts to respond and challenges they have encountered, and (4) FTA's proposed strategy for evaluation and oversight. GAO's work included analyzing program guidance as well as interviewing officials from FTA, industry groups, and more than 30 state and local agencies.
section_title: What GAO Found
paragraphs: SAFETEA-LU created a formula for distributing JARC funds starting in fiscal year 2006, substantially altering funding allocations provided under earlier grants. Funding in some states increased, with 2 states receiving increases of more than 1,200 percent between fiscal years 2005 and 2006. Funding in other states decreased as much as 80 percent, while 18 other states received funds that had not received them in fiscal year 2005. To receive funds, SAFETEA-LU required that states and localities designate a recipient agency to administer JARC funds, award grants on a competitive basis, and certify that projects were derived from a coordinated public transit-human services transportation plan. In March 2006, FTA issued interim guidance and proposed strategies for implementing these new requirements, but delays in issuing final guidance have reduced the window of opportunity for states and localities to obligate fiscal year 2006 funding. As required by SAFETEA-LU, FTA requested public comment on its interim guidance and proposed strategies, and responding to the more than 200 comments took more time than FTA had initially planned. FTA has specified in its guidance that states and localities have until the end of fiscal year 2008 to obligate fiscal year 2006 funds, so their ability to use the funds is not imminently jeopardized. FTA also encouraged states and localities to implement their programs on the basis of the interim guidance. However, given that officials in a number of areas we interviewed planned to wait for final guidance before moving forward, these areas will have less time available to obligate fiscal year 2006 funds. Most states and localities are in the process of trying to meet these new requirements, and although they have encountered challenges in doing so, FTA is taking steps to alleviate most of these challenges. As of the end of fiscal year 2006, about 4 percent of fiscal year 2006 funding apportioned to states and localities had been obligated. States and localities have raised a number of questions or concerns about the new requirements, such as whether an agency serving as the designated recipient would also be eligible to receive funds. In response, FTA proposed several actions that localities could take to reduce the potential conflict of interest in such situations. FTA is continuing to develop and refine its strategies for evaluation and oversight of JARC. FTA, which has had difficulty assessing this program in the past, proposed a new approach, but states and localities found problems with it. FTA is revising its approach and gathering baseline data for its required evaluation of the JARC program. Even if FTA resolves the concerns that have been raised, gaps in monitoring may still limit its ability to evaluate and oversee the program. FTA plans to use existing oversight processes for monitoring JARC recipients; however, FTA officials noted that SAFETEA-LU did not provide specific program management oversight funds for the JARC program and said that they are looking for alternate sources of funding.

section_title: Letter
paragraphs: Access to adequate transportation is an important factor in the ability of  low-income individuals—including those who receive government help to  become self-sufficient—to find and retain employment. However, existing  public transportation systems—originally established to allow city  residents to travel within the city and bring suburban residents to central- city work locations—cannot always bridge the gap between where these  individuals live and where many jobs for which they would qualify are  located. Our previous work has noted that a majority of the entry-level jobs  that low-income individuals would be likely to fill are located in suburbs  that have limited or no accessibility through existing public transportation  systems. Furthermore, many entry-level jobs require shift work in the  evenings or on weekends, when public transit services are either  unavailable or limited.
To increase collaboration among transit agencies, local human service  agencies, nonprofit organizations, and others, and thereby improve the  mobility of low-income individuals seeking work, the Job Access and  Reverse Commute (JARC) program was first authorized under the  Transportation Equity Act for the 21st Century (TEA-21) in 1998.
Administered by the Federal Transit Administration (FTA), this program  provides grants for such purposes as expanding public transit routes,  lengthening service hours, or providing other transportation options.  However, our previous reviews of the JARC program found a number of  challenges that arose in the program, such as difficulties in awarding grants  competitively and inconsistencies with statutory requirements of other FTA  grant programs, making implementation difficult. FTA also experienced  difficulties in evaluating the program, as TEA-21 required.
In 2005, the Safe, Accountable, Flexible, Efficient Transportation Equity  Act – A Legacy for Users (SAFETEA-LU) authorized $727 million for the  JARC program from fiscal years 2005 through 2009. SAFETEA-LU also  made a number of changes that, beginning with fiscal year 2006 funding,  will affect FTA, states, and urbanized areas as they administer the program.  For example, FTA will now provide grant monies through a formula to  states—for distribution to small urbanized and rural areas—and to large  urbanized areas. In addition, SAFETEA-LU requires the Department of  Transportation (DOT) to evaluate the effectiveness of the JARC program  and report the results to Congress by August 2008.
SAFETEA-LU also requires us to study the JARC program, beginning 1 year  after the legislation takes effect and every 2 years thereafter. This report,  our first in compliance with this mandate, analyzes what has happened to  date in implementing program changes and installing a framework for FTA’s  evaluation of program results in 2008. Our specific reporting objectives  were as follows:   identify changes made to the JARC program as a result of SAFETEA-LU;   assess the progress FTA has made in implementing these changes;   describe the extent to which states and urbanized areas have  implemented changes to the JARC program, and challenges they have  encountered; and   determine the extent to which FTA’s proposed strategy for evaluation  and oversight of the JARC program will allow the agency to assess  whether the program is meeting its stated goals.
Our work was based in part on our analysis of program documentation,  relevant legislation, Office of Management and Budget circulars, previous  GAO reports and guidance on the JARC program and on program  evaluation and performance measurement, and over 200 comments posted  to the DOT’s online docket in response to FTA’s March 2006 interim  guidance and proposed strategies for the JARC program. We determined  that the data that FTA provided were sufficiently reliable for the purposes  of this report. We also interviewed officials from FTA and industry  associations as well as representatives from 12 state departments of  transportation, 8 metropolitan planning organizations, and 9 local  transportation agencies in 12 large urbanized areas; a transportation  agency in 1 small urbanized area; and 1 nonprofit organization that works  with rural transit providers. These agencies were selected on the basis of  several factors, including changes in JARC funding from fiscal years 2005  to 2006, whether the areas had formally designated a recipient for JARC  funds, and whether the agency was recommended to us by FTA or an  industry association. The agencies were selected to provide a distribution  of the various factors; however, we did not select them in such a way that  we may project the results as representative of the entire country.  Appendix I contains a detailed discussion of our objectives, scope, and  methodology, including more information on how we selected the state and  local agencies we contacted. We conducted our work between May and  October 2006 in accordance with generally accepted government auditing  standards.
subsections: section_title: Background
paragraphs: The enactment of the Personal Responsibility and Work Opportunity  Reconciliation Act of 1996 dramatically altered the nation’s system to  provide assistance to low-income families with children. The act replaced  the existing entitlement program with fixed block grants to the states to  provide Temporary Assistance for Needy Families (TANF). TANF provides  about $16.5 billion annually for the states to use for families to become self- sufficient, imposes work requirements for adults, and establishes time  limits on the receipt of federal assistance. Without adequate transportation,  however, TANF recipients and other low-income individuals face  significant barriers in finding and keeping jobs. Evidence from  metropolitan areas, such as Atlanta, Boston, and Cleveland, shows that  TANF recipients disproportionately live in inner-city neighborhoods, far  from entry-level employment opportunities located in the suburbs.  Although poverty has declined in central cities, urban poverty rates were  still twice as high as suburban poverty rates in 1999 (approximately 16  percent versus 8 percent). In addition, available jobs may not be located  near central cities. For instance, one study in 2001 found that in Atlanta,  Chicago, Detroit, and a number of other metropolitan areas, more than 60  percent of the regional employment was located more than 10 miles from  the city center. Similarly, the TEA-21 legislation noted that even in  metropolitan areas with excellent public transportation systems, less than  one-half of the jobs were accessible by transit. This spatial mismatch  between low-income individuals and the locations of jobs or other  employment-related services may hinder those individuals’ ability to both  find and keep jobs.
These challenges are especially acute for low-income individuals who do  not own cars and for those who generally drive long distances in poorly  maintained cars. Data from the 2001 National Household Travel Survey  indicated that 26.5 percent of households that earn less than $20,000 do not  own a car, as compared with 1.2 percent of households with incomes over  $75,000. Lack of adequate modes of transportation makes it difficult to  make multiple trips each day to accommodate child care and other  domestic responsibilities and employment-related services. As we reported  in 2004, many rural TANF recipients also cannot afford to own and operate  a reliable private vehicle, and public transportation to get to and from  training, services, and work is often not available. In addition, several  caseworkers and service providers in rural areas identified the lack of valid  driver’s licenses as a problem for many of their clients. A study from the  Journal of the Transportation Research Board has shown that access to  jobs and job-related opportunities, on the other hand, increases the  employment and earnings of TANF recipients and reduces TANF-use  rates.
The JARC program was created in 1998 to support the nation’s welfare  reform goals by filling gaps in transportation services. JARC funds can be  used to expand existing public transit routes or service hours, among other  things (see sidebars). However, JARC projects are not limited to mass  transit services; some JARC projects include ridesharing activities and the  promotion of transit voucher programs. DOT’s two major goals for the  JARC program are to (1) provide transportation and related services to  urban, suburban, and rural areas to assist low-income individuals,  including welfare recipients, with access to employment and related  services, such as child care and training, and (2) increase collaboration  among transportation providers, human service agencies, employers, and  others in planning, funding, and delivering those services.
Citibus us JARC fnd to subsidize it  fixed-rote bus ervice nd evening ervice  in the city of Lubbock. According to Citibus,  the evening ervice i  demnd-repone,  red ride, c-to-c ervice for the  generl public etween 6:40 p.m. nd 10:20 p.m., Mondy throgh Sardy. The  fre i $4 per trip or $75 for  25-ride pass.  The evening ervice i deigned to meet the  need of passenger who re trit  dependent nd who wold hve no other  me of trporttion in the evening if  the evening ervice were not provided.  Citibus o note thjority of evening  ervice passenger work t night nd use  the ervice for trporttion to nd from jo  ite. done for JARC. Also, the statutory matching requirement for JARC was  inconsistent with other FTA programs because JARC projects could  receive grants for up to 50 percent of the project’s capital expenses, rather  than 80 percent. While we have reported that FTA had met its JARC  program goal of improving collaboration between grantees and  stakeholders, we also have reported that more collaboration is needed at  the federal level to enable grantees to obtain federal funding for JARC  projects. TEA-21 required FTA to report to Congress on the results of an  evaluation of JARC; however, FTA has struggled to develop comprehensive  performance measures that assess a national program when individual  programs, operations, and features vary.
section_title: SAFETEA-LU Created a Formula for Distributing JARC Funds and Amended Other Aspects of the Program
paragraphs: SAFETEA-LU made a number of changes to the JARC program, the most  notable of which was the creation of a formula to distribute JARC funds  beginning with fiscal year 2006. Whereas in recent years, JARC projects  were competitively selected by FTA or congressionally designated for  funding, SAFETEA-LU created a formula to distribute funds to states and  large urbanized areas. This change is significant because some states and  large urbanized areas will receive substantially more funds than under the  discretionary program, while others will receive substantially less. In  addition, the formula program will result in some areas receiving JARC  funds that had not received them in the past. Other JARC changes resulting  from SAFETEA-LU include (1) the need for states and large urbanized  areas to designate a recipient for JARC funds, competitively select projects  for funding, and certify that selected projects came from a locally  developed coordinated plan and (2) the ability to use a portion of JARC  funds for planning activities. Table 1 compares key JARC provisions under  SAFETEA-LU and TEA-21.
subsections: section_title: JARC Became a Formula Program
paragraphs: A key SAFETEA-LU change to the JARC program was the creation of a  formula to distribute JARC funds. Under TEA-21, JARC was a discretionary  grant program for which FTA competitively selected JARC projects and,  more recently, awarded funds for congressionally designated projects.  Under SAFETEA-LU, states and large urbanized areas have been  apportioned funding for JARC projects through a formula that is based on  the relative number of low-income individuals and welfare recipients in each area. Forty percent of JARC funds each year is required to be  apportioned among states for projects in small urbanized and other-than- urbanized areas, and the remaining 60 percent is required to be  apportioned among urbanized areas with a population of 200,000 or more.  For fiscal year 2006, the allocation was as follows:  nonurbanized areas - $27.3 million,  small urbanized areas - $27.3 million, and  large urbanized areas - $82.0 million.
The change to a formula program is significant because some states and  urbanized areas will receive substantially more funds than they received  under the discretionary program, while others will receive substantially  less (see fig. 1). In 22 states, the total amount of JARC funding available  decreased from fiscal years 2005 to 2006, when the formula-based program  began. The percentage decrease in funding for these 22 states ranged from  33 percent to 88 percent. For example:  Alaska’s funding decreased approximately 88 percent, from $1.7 million  in fiscal year 2005 to $207,503 in fiscal year 2006.
Vermont also saw its JARC apportionments decrease more than 80  percent, from $991,182 to $186,885.
The total amount of JARC funding available for 2 states (Michigan and West  Virginia) remained approximately the same over the 2 fiscal years, while in  13 states, the total funding increased. The percentage increase for these 13  states ranged from 17 percent to 2,931 percent.
Florida, for instance, had its JARC funds increased by more than 1,200  percent, from $594,708 in fiscal year 2005 to $8.3 million in fiscal year  2006.
Virginia experienced the greatest percentage increase—more than 2,900  percent—from $84,249 in fiscal year 2005 to $2.5 million in fiscal year  2006.
Eighteen states were allocated fiscal year 2006 JARC funds that had not  received JARC funds for fiscal year 2005. These states represent  approximately 16 percent of the total JARC funding for fiscal year 2006.  (App. II lists the dollar amount of the fiscal year 2006 apportionments for  all of the states and large urbanized areas.)
Large urbanized areas also saw substantial changes to their JARC funding  as a result of formularization. Of the 11 large urbanized areas we  interviewed that had received prior JARC grants, 1 saw its JARC funding  increase 64 percent between fiscal years 2005 and 2006, 5 had their funds  decrease from 3 percent to 88 percent between fiscal years 2005 and 2006,  and 5 had received JARC grants in the past but not in fiscal year 2005.
For example, Tampa/St. Petersburg was apportioned $978,029 in fiscal  year 2006, a 64 percent increase from its two fiscal year 2005 grants that  totaled $594,708.
By contrast, Jefferson County in the Birmingham, Alabama, area had  received a JARC grant for almost $3 million in fiscal year 2005, whereas  the urbanized area was apportioned $356,107 for fiscal year 2006, a  decrease of 88 percent.
In addition, the formula program will result in some states and areas  receiving JARC funds that had not received them in the past. Eighteen  states received JARC funds in fiscal year 2006 that did not receive them in  fiscal year 2005. For example, Wyoming, which has not received JARC  funds before, was apportioned $202,360 for fiscal year 2006 as a result of  the formula. An official from the Wyoming Department of Transportation  told us that the state will be able to use the funding to provide vanpool and  bus services to the new employment opportunities created by the state’s  natural gas and mining operations, many of which are located in areas  without public transportation. Puerto Rico, also new to JARC, was  apportioned $6.6 million under the formula. Many large urbanized areas,  such as Fresno, California, will also be receiving JARC apportionments for  the first time.
Officials from the industry associations and the 29 state and local agencies  that we interviewed had mixed reactions to this change. Some of these  state and local agencies said the change from a discretionary to a formula  program would result in a more equitable distribution of funds or that  formula funding would provide a more consistent source of funding than  congressional designation. Some of the 29 agencies said that they would  likely add or expand transportation services in their area, and a few  thought that formularization would result in improved coordination among  transportation and human service agencies. By contrast, some of the state  and local agencies we interviewed said that the change to a formula  program and the associated program requirements they would need to  fulfill would increase the administrative burden on their agency, with 3 of  these agencies noting that the additional burden might outweigh the  benefits of the program. Other agencies said that the change to a formula  program would result in a loss of funds to their state or area, while 1  agency and 1 industry association said the change would spread an already  small amount of money even thinner. Several agencies also said that they  might have to reduce or eliminate services as a result. Still other agencies  said that the change to a formula program would have little or no impact on  transportation services in their area. Some indicated that the impact would  vary by location, while a few other agencies and 1 industry association  noted that it is too soon to know the impact.
section_title: SAFETEA-LU Introduced Three Key Requirements for Receiving JARC Funding and Made Other Changes
paragraphs: In addition to creating a formula for distributing JARC funds, SAFETEA-LU  also requires states and large urbanized areas to fulfill the following three  key requirements before applying to FTA to receive their apportioned JARC  funding:  (1) identify a designated recipient for JARC funds, (2) conduct a  competitive process to select projects for funding, and (3) certify that  JARC projects were derived from a coordinated public transit-human  services transportation plan (see fig. 2).
Under SAFETEA-LU, the governor of each state must designate a recipient  for JARC funds at the state level to competitively select and award funds  for projects in small urban and other-than-urbanized areas within the state.  In large urbanized areas, the recipient must be jointly designated by the  governor, local officials, and publicly owned operators of public  transportation. These designated recipients will then solicit applications  and develop and conduct a competitive process for selecting projects for  funding. SAFETEA-LU also extended a JARC coordinated planning  requirement to additional FTA programs. In the past, JARC projects were  required to be part of a coordinated public transit-human services  transportation plan; a similar requirement is included in SAFETEA-LU.  However, this requirement will apply in fiscal year 2007 to two other FTA  programs that provide funding for transportation-disadvantaged  populations. In addition, recipients in states and urbanized areas that  select JARC projects must now certify that their selections were based on  this plan.
SAFETEA-LU made a number of other changes to the JARC program,  several of which address issues that we have raised in past reports on JARC  and the coordination of transportation services for transportation- disadvantaged populations. One such change is the ability of a recipient to  use up to 10 percent of its JARC allocation for administration, planning,  and technical assistance. SAFETEA-LU also expanded the definition of  eligible activities to include planning as well as capital and operating  activities. In 2004, we reported that a majority of the JARC grantees we  interviewed supported this proposed change because planning activities  could increase coordination with potential partners. We also reported in  2003 that the overall costs of coordination, which can include additional  staff members and staff time needed for maintaining and overseeing  coordination efforts, can be significant. According to FTA, the 10 percent  of JARC funds that will now be available for administration, planning, and  technical assistance can be used for coordination activities, which can help  state and local agencies improve services and achieve cost savings.
SAFETEA-LU also increased the federal government’s share of capital  costs and removed a restriction on the amount of funding available for  reverse commute projects to help individuals gain access to suburban  employment opportunities. In 2004, we reported that the change in the  matching fund requirement for JARC would make that program consistent  with the matching requirements for other FTA programs. Under TEA-21,  projects could receive a grant for up to 50 percent of the project’s capital  expenses, which are used to purchase capital equipment such as buses.  Grantees will now be able to receive a grant for up to 80 percent of the  project’s capital expenses. FTA officials had told us that this change  would lessen any confusion about matching requirements among grant  recipients who participate in multiple FTA programs.
section_title: FTA Has Developed Proposed Final Guidance for JARC, but Delays in Issuing the Final Guidance May Reduce the Time Available to Obligate JARC Funding
paragraphs: FTA has been developing guidance to help JARC recipients implement  changes to the program resulting from the enactment of SAFETEA-LU, but  delays in releasing final guidance will reduce the window of availability of  fiscal year 2006 funding. To formulate JARC guidance, FTA has been using  an extensive public participation process, including notices, commenting  periods, listening sessions, and focus groups. This strategy has provided  FTA with an abundance of feedback, and the agency has incorporated these  comments into its September proposed final guidance. However, an  extension of the public comment period and the volume of public input  have also contributed to delays in issuing guidance, which meant that FTA  was not able to release final program guidance prior to the beginning of  fiscal year 2007. Given that FTA allows 3 years to obligate fiscal year 2006  funds, this delay results in 1 less year for states and urbanized areas to  obligate JARC funding.
subsections: section_title: FTA Has Engaged in Extensive Public Outreach to Formulate JARC Guidance
paragraphs: As required by SAFETEA-LU, FTA has used an extensive notice and  comment process to gain public input to formulate guidance for the JARC  program. In November 2005, FTA published a notice of changes to JARC  and other relevant programs. This notice provided information on  changes to the JARC program and solicited public comment on aspects of  the program, such as technical assistance needs and the coordinated  planning requirements. In addition, FTA held five public listening sessions  across the country on a number of programs, including JARC, to obtain  comments and input on the issues that should be addressed in future  guidance. The agency also convened a focus group to discuss possible  changes to the implementation of JARC. In March 2006, drawing on  information received in comments and the listening sessions, FTA released  interim JARC guidance for fiscal year 2006 and requested comments on its  proposed implementation strategies.
When the interim guidance and proposed strategies was released, it  generated many questions and concerns among stakeholders. FTA received  more than 200 comments on its March interim guidance and proposed  strategies from state and local departments of transportation, metropolitan  planning organizations, private transportation service providers, interest  groups, and other JARC stakeholders. FTA officials reviewed this feedback  and addressed many of the stakeholders’ issues in the proposed final  guidance for JARC, which was released in September. We will discuss these  comments in more detail later in this report, and appendix III provides a  summary of these comments.
section_title: FTA’s Formulation of Guidance Has Been Delayed Due to Extensive Public Comments on JARC Changes
paragraphs: FTA has been incorporating stakeholder concerns into its formulation of  guidance, but the volume of this input has contributed to delays. FTA  officials originally stated that they planned to issue proposed final guidance  in the early summer of 2006. However, FTA extended the comment period  for the March 2006 interim guidance and proposed strategies from April 21  to May 22 to accommodate additional comments, and more than 100  comments were submitted on or after the last day of the comment period.  Because of these additional comments, FTA officials later told us that they  expected to issue the proposed final guidance in late July or early August.  FTA ultimately issued the proposed final guidance on September 6, 2006  (see fig. 3). Public comments were accepted for 60 days following the  release of the September proposed final guidance, after which FTA began  reviewing the comments to inform its final guidance. Consequently, FTA  was not able to release its final guidance prior to the start of the 2007 fiscal  year in October. FTA officials said that they currently plan to release final  program guidance in March 2007.
section_title: Delays in Issuing Final Guidance May Reduce the Time Available to Obligate Fiscal Year 2006 JARC Funding
paragraphs: FTA’s issuance of final guidance for JARC has been delayed, and this may  reduce the time available to projects to access fiscal year 2006 funding. FTA  officials noted that although the notice and comment process has affected  the timeliness of the program guidance, they feel that it has enriched the  development of guidance. However, the delays associated with taking this  approach have reduced the time between issuing the final guidance on how  to apply for fiscal year 2006 funds and the deadline for obligating these  funds by the end of fiscal year 2008.
A number of states and large urbanized areas have proceeded to implement  JARC’s requirements using the interim guidance and proposed strategies.  Nineteen of the 29 state and local agencies we interviewed in the summer  of 2006 were proceeding with the implementation of JARC in the absence  of proposed final guidance. Many of these agencies are required to comply  with local and state planning and budget schedules, which have compelled  them to move ahead with JARC implementation. FTA officials told us that  they encouraged states and urbanized areas to begin implementing changes  to the JARC program on the basis of the March interim guidance and  proposed strategies, and that FTA is accepting applications for funding  prior to issuance of final guidance. In addition, FTA’s March 2006 interim  guidance and proposed strategies included a “hold harmless” provision  stating that the final guidance requirements would not apply retroactively  to grants awarded prior to the issuance of the final guidance. FTA later  extended this “hold harmless” provision to grant applications submitted in  fiscal year 2007 on the basis of coordinated planning or competitive  selection processes that were substantially complete before the issuance of  final guidance.
Even if the delay in issuing the final guidance does not affect the efforts  already under way, states and large urbanized areas will need to keep the  remaining window of time in mind, or their ability to secure fiscal year 2006  funding allocated to them could be affected. Through the guidance, FTA  implemented a 3-year period to obligate JARC funds for a given fiscal year  (the fiscal year of apportionment plus an additional 2 years). Under this  view, the availability of fiscal year 2006 funding would expire at the end of  fiscal year 2008, and those agencies that chose to wait for the final  guidance to be released before applying for fiscal year 2006 JARC funds would have only 2 years in which to obligate those funds. A number of state  and local agencies we interviewed indicated that they are waiting on FTA’s  final program guidance before moving forward to program implementation.  While these areas will benefit from having the final guidance before they  submit their JARC applications, given that the guidance was not available  by the beginning of fiscal year 2007, they will have less time available to  obligate fiscal year 2006 funds.
section_title: States and Large Urbanized Areas Have Begun to Implement JARC Requirements, and FTA Has Taken Steps to Alleviate Implementation Challenges
paragraphs: States and large urbanized areas that were apportioned JARC funds have  generally begun to implement requirements to receive this funding. As they  have done so, they have encountered challenges, most of which FTA has  taken steps to alleviate. To date, few states and large urbanized areas have  fulfilled the necessary SAFETEA-LU requirements to receive fiscal year  2006 JARC funds, but most states and large urbanized areas we contacted  reported that they are in the process of fulfilling these requirements.  Officials we interviewed as well as other program stakeholders have  encountered several challenges in program implementation, such as  questions regarding the selection of the designated recipient in large  urbanized areas. FTA responded to most of these issues in its September  2006 proposed final guidance.
subsections: section_title: Few States and Large Urbanized Areas Have Received Fiscal Year 2006 JARC Funds, Although Most We Interviewed Are in the Process of Fulfilling Funding Requirements
paragraphs: As we previously noted, states and large urbanized areas must fulfill three  SAFETEA-LU requirements prior to applying to FTA to receive JARC funds  to award for projects: identify a designated recipient for JARC funds,  conduct a competitive selection process, and certify that JARC projects  were derived from a coordinated public transit-human services  transportation plan. To date, few states and urbanized areas have fulfilled  these requirements and received fiscal year 2006 JARC funding.  Nationwide, 3 states and 9 of the 152 large urbanized areas that were  apportioned JARC funding had received fiscal year 2006 funds as of the end of fiscal year 2006. These obligated funds constitute less than 4 percent  of the total fiscal year 2006 JARC funding apportioned to states and large  urbanized areas.
While few states and large urbanized areas have fulfilled the requirements  to receive JARC funds, officials in most of the 12 states and 12 large  urbanized areas we contacted in June, July, and August 2006 reported that  they have begun to implement these requirements to receive funding.  Specifically:  Identifying the JARC designated recipient. Officials in each of the 12  states we contacted reported that the state had determined its  designated recipient for JARC. In 7 of these states, officials reported  that the governor had signed a letter to formally designate the recipient,  as required by SAFETEA-LU, although not all of these states had  submitted the letter to FTA. The other 5 states reported that their formal  designation was in-progress. Officials in 9 of the 12 large urbanized  areas we contacted also reported that the area had determined which  agency would serve as the designated recipient for JARC funds,  although none had submitted a designation letter to FTA at the time of  our interviews. There is some variety in the agencies that will serve as  the designated recipient in the large urbanized areas we contacted. A  metropolitan planning organization will be the designated recipient in 4  of the areas we contacted, while a transit agency will be the designated  recipient in the other 5 areas. The other 3 areas had not yet decided on  the likely designated recipient.
Developing coordinated plans. Almost all of the states and large  urbanized areas we contacted had taken actions related to the  establishment of locally developed coordinated public transit-human  services transportation plans. SAFETEA-LU requires states and  urbanized areas to certify that they derived JARC projects from these  plans. In 11 of the 12 large urbanized areas we contacted, officials  reported that they either had determined their strategy for meeting the  coordinated plan requirement or had initiated a coordinated planning  process. In addition, officials in all 12 states we contacted reported that  the state will be involved in coordinated planning for the JARC program,  although the extent of their participation varied. For example, one state  official we interviewed reported that his agency will lead the  coordinated planning process for small urbanized and rural areas within  the state, while another state official reported that rural areas will be  responsible for developing plans while the state provides assistance on  a case-by-case basis. In a majority of the states and large urbanized  areas we contacted, officials anticipated completing these plans in early-  to mid-2007. While FTA has allowed states and large urbanized areas to  apply for up to 10 percent of their apportionment for administration,  planning, and technical assistance prior to applying for funding for  project implementation, only 1 of the states and 1 large urbanized area  we contacted had received this funding, and another large urbanized  area we contacted was in the process of applying for the funding.  Reasons that officials we interviewed cited for not applying for this  funding included the intention to wait until fiscal year 2007 to use the  funding, and the use of other funding sources for these activities.
Conducting a competitive selection process. Few states and large  urbanized areas we contacted had conducted a competitive selection  process to award fiscal year 2006 JARC funds. Officials in 2 large  urbanized areas reported that they had conducted a competitive  selection process to award fiscal year 2006 funds. In addition, 3 states  we contacted had competitively selected JARC projects, but at the time  of our interviews, none had yet applied to FTA for the state’s fiscal year  2006 funding to award for project implementation. Officials in a majority  of the remaining states and large urbanized areas anticipated  competitively selecting projects in early- to mid-2007. More than half of  the states and large urbanized areas we contacted reported that they  considered or may consider a project’s prior receipt of JARC funding to  some extent in selecting projects for funding. For example, officials  from 2 metropolitan planning organizations we interviewed noted that  they would consider a project’s prior receipt of JARC funds to continue  successful projects. Other criteria that officials anticipated they would  consider in selecting projects included the capacity of the organization  to administer the funds, whether the project had matching funds, and  how the project would address the needs of the community.
section_title: States and Large Urbanized Areas Have Encountered Several Implementation Challenges, Most of Which FTA Has Responded to in Its Proposed Final Guidance
paragraphs: In comments submitted on FTA’s March interim guidance and proposed  strategies and in interviews with selected state and local officials, program  stakeholders expressed several implementation challenges they had  encountered or concerns they had as the program moves forward. These  issues included questions regarding the designated recipient in large  urbanized areas, and challenges in ensuring stakeholder participation and  adequate resources for the development of coordinated public transit- human services transportation plans. FTA responded to many of these  issues in its proposed final guidance, which it issued in September 2006.  Table 2 below summarizes stakeholders’ key implementation challenges  and concerns and FTA’s actions to respond to these issues.
Selected urbanized area officials we interviewed and stakeholder  comments on FTA’s interim JARC guidance raised several questions and  issues regarding the designated recipient in large urbanized areas. For  example, transit agency officials we interviewed in 2 large urbanized areas  were under the impression that their agency’s status as the designated  recipient for FTA’s Urbanized Area Formula program (Section 5307  program) automatically made the agency the JARC designated recipient. In  addition, two comments on FTA’s March 2006 interim guidance and  proposed strategies noted the stakeholders’ belief that SAFETEA-LU  identified existing Section 5307 designated recipients as the intended JARC  designated recipients. FTA officials acknowledged that on the basis of the  interim guidance and proposed strategies, there was some confusion about  the process to designate the JARC recipient. To clarify this issue, the  preamble of the September proposed final guidance notes that in large  urbanized areas, a new designation letter shall be issued for the JARC  program, regardless of whether the designated recipient is the same or  different than the Section 5307 designated recipient.
Officials we interviewed in large urbanized areas and several stakeholder  comments on FTA’s interim guidance and proposed strategies also raised  the issue of a potential conflict of interest with respect to the designated  recipient in large urbanized areas, and noted uncertainty about the ability  of designated recipients to allow other organizations to conduct the  competitive selection process. In its March interim guidance and proposed  strategies, FTA noted that many comments on its November 2005 Notice of  Program Changes expressed concern that a conflict of interest could exist  in large urbanized areas when the designated recipient, specifically a  provider of transportation services, conducts the competitive selection  process and is eligible for funding. In addition, officials at 12 of the 17  agencies we contacted in large urbanized areas and 18 stakeholder  comments on FTA’s March 2006 interim guidance and proposed strategies  believed there would be a potential conflict of interest or the appearance of  a conflict of interest in this arrangement. Eight other stakeholder  comments stated that a transparent competitive selection process or the  involvement of metropolitan planning organizations in the selection  process would ameliorate any conflict-of-interest concerns. While officials  we interviewed in 2 large urbanized areas raised the possibility of the  designated recipients allowing another organization to conduct the  competitive selection process to avoid potential conflict-of-interest issues,  officials in 1 of these areas said that prior to the release of FTA’s proposed  final guidance, they received inconsistent information from FTA staff  regarding this issue.
The ability of designated recipients to both conduct the competitive  selection process and compete for funds through this process does present  potential conflict-of-interest concerns. However, FTA outlined a number of  strategies and controls in its JARC guidance that, if adhered to by  designated recipients, should address many of these potential conflict-of- interest concerns and minimize perceptions of unfairness in the  competitive selection process. These controls relate to GAO’s internal  control standards for the federal government, one of which addresses the  policies and procedures in place within an agency to ensure proper  stewardship and accountability for government resources. These  strategies and controls were as follows:  Selection of the designated recipient. To address stakeholders’  concerns of a potential conflict of interest, FTA recommended in its  March interim guidance and proposed strategies that the designated  recipient not be a provider of transportation services. FTA noted that it  received a wide range of comments on this proposal, and, in response,  the September proposed final guidance stated that the designated  recipient may be the same as the area’s existing Section 5307 program  designated recipient or that another agency may be a preferred choice  that is based on local circumstances.
Strategies for a transparent competitive selection process. FTA’s  interim guidance and proposed strategies and proposed final guidance  advised that the designated recipient follow a simple and  straightforward selection process that is transparent, and provided  several potential strategies for areas to consider when implementing a  competitive selection process. These strategies include ensuring greater  inclusion at the onset of the coordinated planning process to alleviate  concerns about a level playing field, and ranking projects using methods  such as third-party review, peer review, or review by a panel of planning  partners.
Allowing other organizations to conduct the competitive selection  process. While officials we interviewed in 1 large urbanized area said  that FTA officials had previously provided conflicting information about  the ability of designated recipients to allow other organizations to  conduct the competitive selection process, FTA’s September proposed  final guidance affirms that designated recipients can work with other  organizations to conduct the competitive selection process to alleviate  conflict-of-interest concerns. FTA’s proposed final guidance also notes  that the SAFETEA-LU requirement for designated recipients to conduct  the competitive selection process in cooperation with the metropolitan  planning organization in large urbanized areas should mitigate this  potential conflict-of-interest concern.
FTA oversight of the competitive selection process. Once designated  recipients select projects and submit applications to FTA for funding for  project implementation, FTA officials reported that they will review the  applications to ensure that areas used a competitive process to select  projects. In addition, at the time of submitting an application for  funding, designated recipients are required to certify that they  distributed funds on a fair and equitable basis, and FTA has advised that  a transparent and inclusive competitive selection process should serve  as the basis for this certification.
subsections: section_title: Development of Coordinated Public Transit-Human Services Transportation Plans
paragraphs: State and local officials we interviewed and stakeholder comments on  FTA’s interim guidance and proposed strategies also cited several  challenges and concerns related to the development of the coordinated  public transit-human services transportation plans. These issues included  participation in the planning process and the amount of time needed to  develop coordinated plans. For example, officials in 3 large urbanized areas  and 5 states we contacted noted challenges in getting other organizations,  such as human service agencies, to participate in the planning process. One  of these officials noted her concern that organizations that do not want to  receive FTA funding will have no reason to participate in the planning  process. In addition, five comments on FTA’s interim guidance and  proposed strategies suggested that federal agencies that provide other  sources of federal funds for transportation services should require their  grantees to participate in coordinated planning efforts. FTA officials  reported that they have been working with members of the Federal  Interagency Coordinating Council on Access and Mobility to encourage  federal grantees that receive other sources of human service transportation  funding to participate in coordinated transportation planning. Although it  will take time to put coordination provisions in place within each agency,  FTA officials said they were encouraged by this progress.
Program stakeholders also expressed concern about their ability to  develop coordinated plans within FTA’s time frames. For JARC, the  requirement to derive projects from a coordinated public transit-human  services transportation plan was in place for fiscal year 2006 and applied to  the New Freedom program and the Elderly Individuals and Individuals with  Disabilities program beginning in fiscal year 2007. Seven stakeholder  comments on FTA’s interim guidance and proposed strategies noted that it  would be difficult to develop a plan within this time frame. Officials in 2  large urbanized areas we contacted shared similar concerns. In its  proposed final guidance, FTA focuses on a phased-in approach to the  development of coordinated plans through fiscal year 2007, with full  implementation of the coordinated planning requirements for projects  funded in fiscal year 2008. FTA officials also said they are encouraging  areas to build on existing planning efforts to fulfill SAFETEA-LU  requirements.
section_title: Competitive Selection of JARC Projects
paragraphs: State and local officials we interviewed cited fewer challenges related to  the competitive selection of JARC projects. The reason could be because  few state and local agencies we contacted had completed a competitive  selection process, and many did not anticipate selecting projects until  early- to mid-2007. However, officials in 1 large urbanized area and 1 state  we contacted noted the difficulty in initiating a competitive selection  process without additional FTA guidance. One of these officials said that  they did not want to have to begin a new process if their actions contradict  any future FTA guidance. Another state official with whom we spoke said  that he would like FTA to clarify questions his agency had about the  competitive selection process, such as what it means to certify that the  state derived projects that were based on a coordinated plan. FTA’s  proposed final guidance provided recipients with additional information on  how to certify that they selected projects that were based on a coordinated  plan.
section_title: Other Implementation Challenges
paragraphs: In addition to challenges related to the designated recipient, coordinated  planning, and competitive selection of JARC projects, state and local  officials we interviewed also cited implementation challenges related to  funding and their communication with FTA. Officials in nearly half of the  states and large urbanized areas we contacted did not believe that the 10  percent of an area’s JARC apportionment available for administration,  planning, and technical assistance would be sufficient for these activities,  although the reasons for these beliefs varied. For example, officials in 1  state and in 1 large urbanized area did not believe these funds would be  sufficient because they will incur higher initial costs to meet the new  program requirements, while officials in 2 other states and 1 large  urbanized area did not believe this funding would be sufficient due to the  costs of developing coordinated plans. FTA received a number of  comments about funding for administration, planning, and technical  assistance, and the September proposed final guidance informs recipients  of other sources of FTA funding that are available for planning activities.  These sources include funding from FTA’s Urbanized and Non-urbanized  Area Formula programs as well as its Metropolitan and Statewide Planning  programs. The proposed final guidance also proposes that recipients may  combine the administrative funding available under the Elderly Individuals  and Individuals with Disabilities (known as Section 5310), JARC, and New  Freedom programs to develop a single coordinated public transit-human  services transportation plan. In addition, the proposed final guidance  notes that the 10 percent of an apportionment available for these activities  is not specific to one year, and that recipients may roll over administrative  funding into a subsequent year for the anticipated future costs of projects.  Lastly, the proposed final guidance notes that planning activities are an  eligible expense for the JARC program, beyond the 10 percent of an  apportionment available for administration, planning, and technical  assistance.
Several officials we interviewed also cited challenges in meeting the JARC  program matching requirements. Under SAFETEA-LU, grantees may use  federal JARC funding for 80 percent of capital expenses and 50 percent of  operating expenses. Matching funds may come from other federal  programs that are not administered by DOT, such as the Temporary  Assistance for Needy Families (TANF) block grant, as well as from noncash  sources, such as in-kind contributions and volunteer services. One state  official we interviewed, whose agency previously received JARC funding,  noted that the agency had struggled in the past to secure matching funds  and, as a result, has yet to spend all of its past federal JARC funding. A  metropolitan planning organization official we interviewed noted that the  ability of smaller nonprofit organizations in her area to secure the required  matching funds was an issue, because these organizations have limited  resources to use for matching funds. In addition, 1 state official and  officials in 1 large urbanized area said that their areas anticipated or had  seen cutbacks in matching funding they had received in the past from  agencies that provided funding from programs such as TANF. As a result,  these officials said they will have less state and local matching funding  available for projects. Although the JARC matching requirements are set in  the SAFETEA-LU legislation, FTA’s proposed final guidance provides  information on potential sources of matching funds for JARC projects.
While several officials we interviewed had positive comments about FTA’s  efforts to solicit public input as it implements changes to JARC and other  programs, some officials also noted challenges they had encountered in  communicating with FTA regarding JARC implementation. Receiving  consistent information from FTA was one challenge cited by officials we  interviewed. As we previously noted, officials from one metropolitan  planning organization reported that they received inconsistent information  from different FTA staff in response to a question about the responsibilities  of the designated recipient. In addition, officials we interviewed in 1 state  said they received different answers regarding the timeline for completing  a coordinated plan. Other officials we interviewed cited challenges in  receiving information to answer implementation questions. Officials in 2  states we contacted noted difficulties in getting specific answers to their  implementation questions, with 1 state official noting that with new  programs, FTA should be prepared to answer specific questions about  program implementation instead of providing general information.
section_title: FTA Changed Its Evaluation and Oversight Strategies but Still Needs to Address Monitoring Issues
paragraphs: Although FTA revised its original JARC evaluation and oversight proposals  to respond to current and past concerns raised by program stakeholders,  gaps in monitoring may limit FTA’s ability to assess whether the program is  meeting its goals. In previous work, we and others have reported that FTA  could better measure and communicate the outcomes of the JARC program  to program stakeholders, including Congress and JARC grantees. To  address these issues, FTA sought public comment on four new  performance measures—one specifically for JARC and three crosscutting  measures—and an existing data collection mechanism to track JARC  performance data, the National Transit Database (NTD). However, several  program stakeholders noted various obstacles to collecting reliable data on  FTA’s proposed measures, and some state and local officials we  interviewed reported that it would be challenging to use the NTD system.  In addition, state and local officials expressed ongoing concerns about the  lack of feedback on their performance after submitting their data to FTA. In  response to these concerns, FTA clarified the performance measures,  introduced a plan to use its existing grant management system for  collecting performance data, and proposed to be more explicit with  grantees about how reported JARC performance data were being used. FTA  officials also reported that they are testing the JARC performance measure  and obtaining baseline data for use in the required evaluation of the JARC  program, which will be submitted to Congress in August 2008. Even if FTA  resolves its performance measurement and reporting issues, gaps in  monitoring may continue to limit FTA’s ability to evaluate and oversee the  JARC program. FTA plans to use existing oversight processes for  monitoring JARC recipients; however, FTA officials also noted that  SAFETEA-LU did not specifically provide project management oversight  funds for the JARC program. As a result, FTA officials are looking for  alternate sources of funding—such as the agency’s administrative  funding—to provide program oversight for JARC.
subsections: section_title: Past Concerns about the JARC Program Have Included Performance Measurement, Reporting, and Evaluation
paragraphs: The need for agencies to measure performance is based upon the  Government Performance and Results Act of 1993 (GPRA),which was  intended to improve federal program effectiveness, accountability, and  service delivery. GPRA helped create a governmentwide focus on results by  establishing a statutory framework for performance management and  accountability, with the necessary infrastructure to generate meaningful  performance information. This act required federal agencies to develop  strategic plans and annual performance plans, link them with outcome- oriented goals, and measure agency performance in achieving these goals.  The Office of Management and Budget also plays a role in GPRA  implementation and reviews agencies’ strategic plans, annual performance  plans, and annual performance reports. Overall, GPRA’s requirements have  laid a solid foundation for results-oriented agency planning, measurement,  and reporting by providing more objective information on achieving goals  and on the relative effectiveness and efficiency of federal programs and  spending.
Past GAO reports on performance measurement and performance  budgeting have noted the importance of using outcome-oriented measures  to assess the extent to which a program achieves its objectives on an  ongoing basis and the importance of linking resources to results.   However, our previous reviews of the JARC program have found that FTA  lacked the data needed to evaluate and report on the program as required  by Congress. For example, in May 1998, we recommended that FTA  establish specific objectives, performance criteria, and measurable goals to  assess how the JARC program would improve mobility for low-income  workers. In response, FTA instituted an evaluation plan and selected  access to employment sites as the sole measure of program success.  However, we later found that this measure did not address key aspects of  the program, such as increasing collaboration between grantees and  stakeholders and establishing transportation-related services that help low- income individuals. We also reported in August 2004 that grantees found it  difficult to obtain the data requested by FTA, such as the number of  potential employers reached by JARC services. Furthermore, the grantee  reports used to evaluate the JARC program contained self-reported  information, which FTA did not verify. As a result, we stated that FTA’s 2003  evaluation of JARC was limited because it lacked consistent, generalizable,  and complete information, thereby making it difficult to use these data to  draw any definitive conclusions about the program as a whole. In  recognition of these concerns, FTA began taking steps to consider ways to  improve its evaluation process, such as revising the JARC performance  measures.
In previous reports on the JARC program, we and others have also  highlighted issues with FTA’s reporting mechanism and lack of  communication with grantees about their performance. Performance  reporting is a critical element for establishing accountability and evaluating  whether and to what extent program managers are meeting the goals  contained within agency strategic and performance plans. In 2004, we  reported that JARC grantees were required to report quarterly data using a  database that many found to be burdensome. We also noted that specific  information in FTA’s JARC evaluation may not have been consistent  because grantees did not follow a standardized reporting system. Our past  work on data quality has highlighted the importance of ensuring that  reported performance data are sufficiently credible for decision making.   In a 2003 FTA-contracted study of JARC evaluation efforts, some grantees  recommended that FTA allow agencies to report performance data using  existing systems, such as the NTD, and that the reporting structure be  flexible enough to enter qualitative or narrative information to reflect the different types of services provided by JARC programs. Grantees also  stated that they would be interested in receiving feedback from FTA on the  JARC evaluation process and stressed the importance of communicating  program findings to help them assess and improve their performance. We  previously have identified the distribution of information in a form and  time frame that allows managers, staff, and external stakeholders to  perform their duties and to provide them with a basis for focusing their  efforts and improving performance as a critical practice for managing  program results.
section_title: FTA Clarified Its Proposed JARC Performance Measures and Introduced a Different Reporting Mechanism in Response to Concerns Expressed by Program Stakeholders
paragraphs: FTA’s extensive public participation process helped to inform changes  made to the proposed final guidance issued in September, including the  introduction of new performance measures to evaluate the JARC program  as well as a different reporting mechanism for collecting data. In its March  2006 interim guidance and proposed strategies, FTA had proposed using  one JARC-specific measure and three crosscutting measures to assess the  JARC program’s outcomes and impacts:    Cumulative number of jobs accessed (JARC-specific): Cumulative  number of jobs reached through the provision of JARC-related services  for low-income individuals and welfare recipients.
Efficiency of operations (crosscutting measure): Number of  communities and states reporting the use of shared resources between  different agencies and organizations so they can provide more rides for  people with disabilities, older adults, and individuals with lower  incomes at the same or lower cost.
Program effectiveness (crosscutting measure): Number of  communities that have a simple point of entry-coordinated human  service transportation system for people with disabilities, older adults,  and individuals with lower incomes so they have easier access to  transportation services.
Customer satisfaction (crosscutting measure): Level of customer  satisfaction reported in areas related to the availability, affordability,  acceptability, and accessibility of transportation services for people  with disabilities, older adults, and individuals with lower incomes.
According to FTA, the JARC-specific measure was intended to reduce the  numerous JARC data requirements, while the three crosscutting measures  reflected SAFETEA-LU’s emphasis on the coordination of human services  transportation and would apply to the JARC, New Freedom, and Elderly  Individuals and Individuals with Disabilities (Section 5310) programs. In  addition, FTA proposed to address past concerns regarding the burden of  collecting program data on JARC by using existing mechanisms, including  the NTD, which is used to track operational, service, and financial data on  other transit formula programs.
In both the docket comments and in our interviews, program stakeholders  cited potential obstacles to collecting accurate data on the number of jobs  accessed measure, such as a lack of guidance from FTA and limited  resources (see table 3 for a summary of stakeholder concerns regarding the  proposed measures). For example, 7 state and local officials we  interviewed reported that FTA’s definition for the number of jobs accessed  was unclear, or that they did not know how to determine this measure.  Specifically, one metropolitan planning organization official wanted FTA to  clarify whether the jobs accessed measure referred to the number of low- income people using a JARC-funded service to travel to their jobs or to the  total number of jobs available in the area being served by a JARC-funded  service. Three state transportation officials that we contacted were also  concerned that they did not have sufficient staff to conduct the required  data collection. Program stakeholders expressed similar concerns in their  docket comments. For example, 2 stakeholders noted in their written  comments to FTA that collecting data on the proposed performance  measures may be overly burdensome for small agencies.
FTA officials acknowledged that there was confusion among program  stakeholders about the JARC-specific measure and how it should be  measured, and they subsequently clarified the original proposal on the  basis of the comments received. FTA’s proposed final guidance stated that  the JARC-specific measure would assess the following:  Job access:  The increase in access to jobs related to geographic  coverage and/or service times that impact the availability of  transportation services for low-income individuals as a result of the  JARC projects implemented in the current reporting year.
Rides provided:  The number of rides provided for low-income  individuals as a result of the JARC projects implemented in the current  reporting year.
According to FTA, the jobs accessed measure is a measure of “system  coverage,” describing the number of jobs reachable by JARC-funded  services. FTA also clarified that the new measure is not a determination of  an actual number of riders who are getting and going to jobs, which was a  concern raised by some program stakeholders in their docket comments  and in our interviews. FTA also intends to monitor JARC service use by  measuring the number of rides actually provided by the JARC service  annually.
In addition to clarifying the JARC measure, FTA is also taking steps to test  its JARC performance measure and to collect baseline data for its  upcoming evaluation of the program. For example, FTA has hired a  contractor to examine the feasibility of collecting data for the increase in  the jobs accessed measure and is currently analyzing the strategies for  capturing this more precise measure and testing its implementation. FTA  also is soliciting public comments on the revised JARC performance  measures, which will be used to formulate the final JARC guidance. Once  the measures are finalized, FTA will test the JARC-specific performance  measure and plans to obtain baseline data for fiscal year 2006 and beyond using JARC grants active during fiscal year 2005. FTA officials plan to use  these data to conduct the required evaluation of the JARC program, which  must be submitted to Congress in August 2008. FTA’s proposed final  guidance states that it will conduct independent evaluations of the JARC  program focused on specific data elements to better understand the  implementation strategies and related outcomes associated with the  program. This approach is supported by our recent report on grants  management, in which we recommended that performance data should be  tested to make sure they are credible, reliable, and valid. An FTA official  we spoke with told us that FTA hopes to have a formal reporting  methodology targeted to be in place by spring 2007.
Program stakeholders also reported potential difficulties with FTA’s  proposed crosscutting national coordination measures to assess program  performance. (See table 3 for a summary of stakeholder concerns  regarding the proposed performance measures.)  For example, some  program stakeholders stated in their docket comments that the  performance measures would be too prescriptive and would stifle local  creativity, while 13 stakeholders recommended that performance measures  should be developed locally to address local conditions and needs.  Specifically, two commenters noted that FTA’s proposed crosscutting  performance measures did not necessarily acknowledge the differences in  providing JARC services in urbanized areas compared with rural areas,  where the number of transit providers may be limited and the routes  typically serve fewer people at a higher cost. In addition, two local officials  and one state department of transportation official that we interviewed  reported that measuring customer satisfaction would likely require  administering a survey, which could be expensive or labor-intensive.
In recognition of these concerns, FTA did not include the three crosscutting  coordination measures in its proposed final guidance, noting instead that  individual communities will have the option to include evaluation  strategies for their own activities. We have previously observed that  designing results-oriented performance measures for intergovernmental  programs, such as JARC, is complicated by the broad range of objectives  identified for some programs and the discretion states and localities have  in achieving those objectives. According to FTA, the crosscutting measures  were created in response to recommendations stemming from the  Interagency Coordinating Council on Access and Mobility’s United We Ride  initiative to develop a national performance measure for coordination.  After reviewing the comments, however, FTA officials that we interviewed  told us that they realized the difficulty of devising national measures and  determined that measuring coordination should be done at the local level.  FTA also clarified that the intent of the crosscutting measures was to  capture a national picture of JARC-funded services, rather than compare  individual communities or service systems. However, FTA officials  reported that they will encourage grantees to develop additional measures  for evaluating whether their programs are meeting their intended state or  local goals. This proposal is supported by our past work, in which we  reported that performance measures should tell each organizational level  how well it is achieving its goals. In addition, the United We Ride initiative  is developing a tool and plans to provide technical assistance to assist with  these efforts in the future.
Program stakeholders expressed mixed opinions about FTA’s proposal to  use the NTD to streamline data collection. For example, 5 state and local  agencies that we interviewed were generally positive about FTA’s proposal  to use the NTD for JARC reporting, in part because they were familiar with  using this system to collect and report data on other FTA programs.  However, 5 agencies that we interviewed told us that small and rural  agencies may find it difficult to use the NTD for collecting and managing  data. In addition, two agency officials we interviewed reported that NTD  can be cumbersome to use, while two program stakeholders noted in their  docket comments that smaller agencies may need staff training to use the  NTD.
Due in part to the comments received, FTA decided not to use the NTD for  JARC reporting. FTA told us that while the NTD is in place, it is currently  not set up or designed to collect the qualitative measures that are important  for understanding the trends related to human service transportation. FTA  proposed that JARC grantees report their data as an attachment to their  annual report submissions in the Transportation Electronic Award and  Management (TEAM) system, which the agency uses to manage and track  its grants. One FTA official told us that TEAM would be better suited for  collecting JARC data because it can track qualitative information, and that  JARC grantees that receive funding through other FTA programs would be  familiar with how to collect and report data using TEAM.
Finally, state and local officials that we interviewed also expressed ongoing  concerns about the lack of feedback on their JARC performance after they  report data to FTA, which may limit their ability to manage program  performance. For example, 19 of the 23 states and large urbanized areas  that had received JARC grants in the past commented that FTA had not  provided them with any feedback on their performance data after it was  submitted. Three state and local officials also told us that they would like  to know how the performance data they report is being used by FTA.  Meanwhile, two state transportation officials and two local officials said  that receiving feedback from FTA would be helpful to know how they are  performing and to make improvements or corrections. Previous reports by  GAO and others have found that providing frequent and effective  feedback on performance information can enhance its use for decision  making. According to FTA, the JARC data collected to date have not been  intended to be used to evaluate individual projects, but rather were geared  toward assessing how the program was achieving goals nationally, as  required by GPRA and the Office of Management and Budget. However,  during a recent interview with FTA officials, they said that they would be  more explicit with grantees about how they are using JARC performance  data, and that they are open to exploring the possibility of posting this  information on the FTA Web site in the future.
section_title: Gaps in Monitoring May Limit FTA’s Ability to Evaluate and Oversee the JARC Program
paragraphs: Even if FTA resolves its performance measurement and reporting issues,  gaps in its plan for monitoring JARC recipients may continue to limit FTA’s  ability to evaluate and oversee the program. While FTA has proposed using  existing oversight processes to monitor JARC recipients, these oversight  processes do not explicitly include provisions for oversight of the JARC  program. Furthermore, FTA’s proposed process for oversight of agencies  that do not fall under existing processes could lead to inconsistent  oversight of JARC recipients.
FTA does not have a complete plan for oversight of the JARC program.  Monitoring of policies and procedures to ensure proper stewardship of  government resources is an important aspect of internal control. FTA is  responsible for ensuring that grantees follow federal mandates along with  statutory and administrative requirements. In its March interim guidance  and proposed strategies, FTA stated that it would monitor implementation  of JARC and other programs using pre- and post-award review processes  used for grant applications and grant management, including self- certifications, progress reports, and site visits. FTA’s proposed final  guidance states that FTA will also use existing oversight processes for  other FTA programs to conduct JARC oversight. These processes are as  follows:  State Management Reviews:  These reviews assess states’  implementation and management of the Elderly Individuals and  Individuals with Disabilities program (Section 5310) and the  Nonurbanized Area Formula program (Section 5311).
Triennial Reviews:  These reviews assess grantees receiving Urbanized  Area Formula program (Section 5307) grants. These grantees are  primarily transit agencies and some metropolitan planning  organizations.
FTA has proposed using these processes—which FTA uses for oversight of  programs that award funding to states, transit agencies, and metropolitan  planning organizations—to oversee the JARC program because they should  cover most JARC designated recipients. FTA’s proposed final guidance also  notes that JARC designated recipients that are not a state or a Section 5307  recipient may be subjected to periodic spot reviews of their administration  of the program. However, two issues with FTA’s monitoring proposal may  result in gaps in its oversight of the JARC program.
First, the use of periodic spot reviews of designated recipients that are not  states or Section 5307 recipients may result in inconsistent monitoring of  JARC recipients. For example, while some metropolitan planning  organizations that serve as JARC designated recipients also receive Section  5307 funding and will be subject to FTA oversight through its triennial  review process, other metropolitan planning organizations serving as JARC  designated recipients do not receive Section 5307 funding, and will be  subject to FTA oversight through its proposed periodic spot reviews. It is  not clear from FTA’s proposed final guidance if these periodic reviews will  be more or less frequent than the 3-year cycle of FTA’s triennial reviews and  state management reviews. As a result, JARC designated recipients may be  held to different oversight standards on the basis of what other types of  FTA funding they receive.
Second, FTA’s existing oversight processes currently do not include  provisions for JARC program oversight. For example, FTA’s State  Management Review guidance, which contains information on the Section  5311 program and the Elderly Individuals and Individuals with Disabilities  program, does not include JARC program requirements and information,  such as the requirement to distribute funds on a fair and equitable basis. We  previously noted that this requirement would be important for recipients to  adhere to in order to address potential conflict-of-interest concerns. While  FTA officials said that they have begun to work to incorporate JARC into  their existing oversight processes, they noted that SAFETEA-LU omitted  JARC from the list of programs for which FTA may specifically use  appropriated funds to obtain contractual support for project management  oversight and review of major capital projects. They are presently  researching other sources of funding—such as the agency’s general  administrative funding—that can be used to ask detailed programmatic  questions of JARC recipients and to conduct site visits and project reviews.  FTA officials also said that they currently do not know how much of a  problem this will pose, because they do not yet know which entities will be  the designated recipients for most of the areas receiving JARC funds. As a  result, they are uncertain of how many JARC designated recipients will  already be covered by existing oversight processes because they receive  funds for other FTA programs, such as Section 5307. Given this issue, FTA  officials said that they were still determining the frequency and level of  JARC oversight that could be supported with their current resources. Until  it develops a complete plan for implementing and funding JARC oversight,  FTA’s key oversight processes will not provide assurance that recipients are  meeting program requirements.
section_title: Conclusions
paragraphs: FTA has made progress in implementing changes to the JARC program,  gathering extensive public input to develop program guidance for states  and large urbanized areas. However, FTA lacks an important element of  program accountability and performance measurement for the JARC  program, specifically related to monitoring. FTA officials have proposed to  use the agency’s oversight mechanisms for other FTA programs for JARC  monitoring, but acknowledged that they have not finalized how this will  work. Without the inclusion of JARC program requirements—such as the  fair and equitable distribution of funding—in these existing oversight  processes, FTA will have limited assurances that JARC recipients are  administering the program in accordance with FTA’s requirements and are  meeting program objectives. In addition, FTA has proposed an alternative  oversight process for recipients that are not covered by its existing  Triennial Reviews and State Management Reviews, but FTA has not  specified how often these recipients will be subject to its oversight, which  may result in inconsistent or infrequent oversight of JARC recipients.
section_title: Recommendations for Executive Action
paragraphs: To establish adequate and consistent oversight processes that will enable  FTA to evaluate and oversee JARC projects and determine whether they are  meeting JARC program goals, we recommend that the Secretary of  Transportation direct the Administrator, FTA, to take the following two  actions:   Develop a plan for including the JARC program in Triennial Reviews and  State Management Reviews, and update monitoring guidance and  information accordingly.
Specify in the JARC final guidance how frequently FTA will perform spot  reviews of designated recipients that are not subject to FTA’s Triennial  Reviews and State Management Reviews, and make the interval for  conducting spot reviews consistent with the 3-year cycles for Triennial  Reviews and State Management Reviews, or more frequently if FTA  determines it necessary.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Department of Transportation for  review and comment. Officials from the department and FTA generally  agreed with the report’s findings and said that they would consider the  recommendations as they move forward in implementing the JARC  program. Although FTA officials recognized the need for program oversight  and indicated that they are already taking steps to incorporate the JARC  program into their existing review processes, they reiterated their concerns  that SAFETEA-LU did not provide them with a specific source of oversight  funding for the JARC program. As a result, they are seeking other sources  of funding—such as the agency’s general administrative funds—to carry  out this activity. Finally, FTA officials provided technical clarifications,  which we incorporated in the report as appropriate.
We are sending copies of this report to congressional committees with  responsibility for transit issues; the Secretary of Transportation; the  Administrator, Federal Transit Administration; and the Director, Office of  Management and Budget. We will also 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 regarding this report, please contact me on  (202) 512-2834 or at siggerudk@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff who made major contributions to this report are  listed in appendix IV.
section_title: Objectives, Scope, and Methodology
paragraphs: This report addresses the following four objectives:  (1) changes that were  made to the Job Access and Reverse Commute (JARC) program as a result  of the Safe, Accountable, Flexible, Efficient Transportation Equity Act – A  Legacy for Users (SAFETEA-LU); (2) progress that the Federal Transit  Administration (FTA) has made in implementing these changes; (3) the  extent to which states and large urbanized areas have implemented  changes to the JARC program, and challenges they have encountered; and  (4) whether FTA’s proposed strategy for evaluating and overseeing the  JARC program will allow the agency to assess the extent to which the  program is meeting its stated goals.
To identify the changes that SAFETEA-LU made to the JARC program, we  reviewed the provisions of SAFETEA-LU and of its predecessor, the  Transportation Equity Act for the 21st Century (TEA-21), dealing with the  JARC program. We also reviewed previous GAO reports on JARC and  interviewed officials from FTA’s headquarters and one regional office. To  summarize financial information for JARC for fiscal years 1999 through  2009, we gathered and analyzed data from FTA’s Web site and agency  officials on dollar amounts authorized, appropriated, rescinded, obligated,  and unobligated. To assess the reliability of these data, we interviewed FTA  officials about FTA’s policies and procedures for data collection and  verification. Specifically, we asked them whether their policies and  procedures had changed significantly since we reviewed them for our 2004  report on JARC. FTA officials told us that there were no significant  changes in their data collection and verification procedures for JARC  information. We also compared these data with data published in the  Federal Register and data on FTA’s Web site for obvious errors in  completeness and accuracy. Therefore, we determined that the FTA  information presented was sufficiently reliable for the purposes of this  report.
To describe the progress FTA has made in implementing changes to JARC,  we interviewed FTA officials and officials from industry associations,  including the American Association of State Highway and Transportation  Officials, the American Public Transportation Association, the Association  of Metropolitan Planning Organizations, the Community Transportation  Association of America, and the National Association of Regional Councils,  to obtain their views on FTA’s progress in implementing the program  changes. We also reviewed FTA’s JARC interim program guidance for fiscal  year 2006 and proposed strategies for fiscal year 2007 (issued in March  2006), and its proposed final guidance for fiscal year 2007 (issued in  September 2006).
To describe the extent to which states and large urbanized areas have  implemented changes to the JARC program and any challenges they have  encountered in doing so, we obtained data from FTA officials on the  number of states and large urbanized areas that had officially designated a  recipient for JARC funds, selected projects and applied for funding, and  obligated funds.
To determine whether FTA’s proposed strategy for evaluating and  overseeing the JARC program will allow the agency to assess whether the  program is meeting its stated goals, we interviewed FTA officials about  their performance measurement and evaluation plans. We reviewed FTA’s  earlier JARC program evaluation, Job Access and Reverse Commute  Program: Report to Congress (May 2003). We also reviewed relevant  legislation, FTA program guidance, Office of Management and Budget  circulars and guidance on performance measurement, prior GAO JARC  reports, and GAO reports and guidance on performance measurement and  program evaluation. We did not evaluate FTA’s proposed performance  measures, because those measures were too preliminary at the time of our  review to allow meaningful comparison with our criteria for successful  performance measures. In addition, FTA had recently hired a contractor to  evaluate the feasibility of collecting data for one of the proposed measures.
To address the third and fourth objectives, we also designed and conducted  semistructured telephone interviews with officials from 24 of the 209 states  and large urbanized areas that were apportioned fiscal year 2006 JARC  funds. The interviews were designed to gain state and local officials’  perspectives on a number of topics, including the effect of changing from a  discretionary program to a formula-based program on JARC services in  their area; the process of selecting a designated recipient, developing a  coordinated public transit-human services transportation plan, and  conducting a competitive selection process for JARC projects; FTA’s  proposed performance measures and program oversight mechanisms for  JARC; and any challenges they may have encountered in implementing  changes to the JARC program. After conducting the interviews with all 24  states and large urbanized areas, we used a content analysis to  systematically determine the state and local officials’ views on key  interview questions and identify common themes in their responses. Two  analysts reached consensus on the coding of the responses, and a third  reviewer was consulted in case of disagreements, to ensure that the codes  were reliable. The interviews included officials from the departments of  transportation of 12 states and from 8 metropolitan planning organizations  and 9 transportation agencies from 12 large urbanized areas. We conducted  the interviews in June, July, and August 2006.
We selected the 12 states to obtain diversity in a range of criteria, as  follows:  Change in JARC funding:  Analyzed the percentage change and  selected 4 states that received an increase in their federal JARC funds  from fiscal years 2005 to 2006, 5 states whose JARC funds decreased  from 2005 to 2006, 1 state that received approximately the same amount  of funding in fiscal years 2005 and 2006, and 2 states that did not receive  JARC funds in 2005.
Comments:  Whether a state department of transportation had  submitted comments to the Department of Transportation’s (DOT)  online docket on FTA’s interim JARC program guidance for fiscal year  2006 and proposed strategies for fiscal year 2007.
Statewide program:  Whether a state was identified in FTA’s fiscal year  2005 grant apportionment notice as having a statewide JARC program,  which meant that the state likely had previous experience in  administering JARC funds.
Designated recipient:  Whether a state had notified FTA of its  designated recipient (as of June 2006) for the JARC funds, from which  we inferred that a state had taken some action to implement the JARC  program.
Planning funds:  Whether a state had applied to FTA for 10 percent of  its apportionment for planning/administration/technical assistance, as  allowed by statute, from which we inferred that a state had taken some  action to implement the JARC program.
Recommendations:  Referral by FTA or industry associations.
Table 4 lists the 12 states that we selected on the basis of these criteria.
To obtain the perspectives of small urbanized areas and rural areas that had  previously received JARC grants directly and would now have to apply to  the state designated recipient for funding, we supplemented the state  interviews with interviews with officials from a transportation agency in  Galveston, Texas—a small urbanized area—and from a nonprofit agency in  Stigler, Oklahoma, that provides transportation in rural areas of the state.
We selected 12 large urbanized areas to obtain diversity in a range of  criteria, as follows:  Prior receipt of JARC funding:  Whether a large urbanized area had  received a JARC grant prior to fiscal year 2006.
Receipt of fiscal year 2006 funding:  Whether a large urbanized area  had successfully applied to FTA for its fiscal year 2006 JARC funding (as  of July 2006).
Comments:  Whether a metropolitan planning organization or local  transportation agency in a large urbanized area had submitted  comments to the DOT’s online docket on FTA’s interim JARC program  guidance for fiscal year 2006 and proposed strategies for fiscal year  2007.
Designated recipient:  Whether a large urbanized area had notified FTA  of its designated recipient (as of July 2006) for the JARC funds, from  which we inferred that the area had taken some action to implement the  JARC program.
Recommendations:  Referral by FTA or industry associations.
Population:  Whether a large urbanized area had a population over 1  million.
Multistate area:  Whether the large urbanized area covers multiple  states, which we assumed could present unique issues for an area in  implementing the JARC program.
Location:  Whether the large urbanized area was in a state that we had  already selected for interviews.
Table 5 lists the 12 large urbanized areas we selected on the basis of these  criteria, and the agencies that we interviewed.
It is important to note that these interviews cannot be generalized to the  entire JARC recipient population because they were selected from a  nonprobability sample.
We supplemented the information obtained from these semistructured  interviews by analyzing the more than 200 public comments submitted to  DOT’s online docket regarding FTA’s interim program guidance for fiscal  year 2006 and proposed guidance for fiscal year 2007. We used a content  analysis to systematically identify common themes in the comments  submitted. Two analysts reached consensus on the coding of the responses,  and a third reviewer was consulted in case of disagreements, to ensure that  the codes were reliable. In summarizing the comments for appendix III, we  only included comments that were made by more than one entity.
We conducted our work from May through October 2006 in accordance  with generally accepted government auditing standards.
section_title: Summary of Stakeholder Comments on FTA’s Interim Guidance and Proposed Strategies for Job Access and Reverse Commute Program
paragraphs: In its March 15, 2006, interim guidance and proposed strategies, FTA  proposed several changes that would affect the operation of the JARC  program. FTA allowed for a 30-day comment period, and after a request for  an extension, the agency allowed approximately 1 month for comments.  FTA received over 200 comments, and program stakeholders that  commented included the following: state transportation agencies, trade  associations, metropolitan planning organizations, public transit providers,  private transit providers, individuals, and advocates. Table 11 summarizes  FTA’s proposed changes to the coordinated planning process, the  designated recipient and competitive selection process, and the  performance measurement and reporting requirements.
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: Other key contributors to this report were John Finedore (Assistant  Director), Vidhya Ananthakrishnan, Lauren Heft, Foster Kerrison, Jessica  Lucas-Judy, Nancy Lueke, Kimanh Nguyen, and Stan Stenersen.
section_title: Related GAO Products
paragraphs: Public Transportation:  Preliminary Information on FTA’s  Implementation of SAFETEA-LU Changes. GAO-06-910T. Washington,  D.C.:  June 27, 2006.
Transportation-Disadvantaged Seniors:  Efforts to Enhance Senior  Mobility Could Benefit from Additional Guidance and  Information. GAO-04-971. Washington, D.C.:  August 30, 2004.
Job Access and Reverse Commute:  Program Status and Potential Effects  of Proposed Legislative Changes. GAO-04-934R. Washington, D.C.:  August  20, 2004.
Transportation-Disadvantaged Populations:  Federal Agencies Are  Taking Steps to Assist States and Local Agencies in Coordinating  Transportation Services. GAO-04-420R. Washington, D.C.:   February 24,  2004.
Transportation-Disadvantaged Populations:  Some Coordination Efforts  Among Programs Providing Transportation Services, but Obstacles  Persist. GAO-03-697.  Washington, D.C.:  June 30, 2003.
Welfare Reform:  Job Access Program Improves Local Service  Coordination, but Evaluation Should Be Completed.   GAO-03-204. Washington, D.C.:  December 6, 2002.
Welfare Reform:  DOT Has Made Progress in Implementing the Job Access  Program but Has Not Evaluated the Impact. GAO-02-640T. Washington,  D.C.:  April 17, 2002.
Welfare Reform:  Competitive Grant Selection Requirement for DOT’s Job  Access Program Was Not Followed. GAO-02-213. Washington, D.C.:   December 7, 2001.
Welfare Reform:  GAO’s Recent and Ongoing Work on DOT’s Access to Jobs  Program. GAO-01-996R. Washington, D.C.:  August 17, 2001.
Welfare Reform:  DOT Is Making Progress in Implementing the Job Access  Program. GAO-01-133. Washington, D.C.:  December 4, 2000.
Welfare Reform: Implementing DOT’s Access to Jobs Program in Its First  Year. GAO/RCED-00-14. Washington, D.C.:  November 26, 1999.