MANAGEMENT REVIEW ELEMENTS – HIGHWAY SAFETY PROGRAM State Management Review in FY 2017 ONLY- Self Assessment Checklist Note: Some Findings and Management Considerations are referenced as “Fiscal year (FY) 17” or as “FY15 & 16”. These references are needed to distinguish between Elements that are applicable to 23 CFR Part 1300 which went into effect in FY17 and Elements applicable to 23 CFR Part 1200 which was effective in FYs 15 & 16. The FY refers to the FY in which the funds related to the finding were expended, NOT the FY in which the funds were awarded. State of: Projected Review Dates: SHSO Reviewer: I. ORGANIZATION AND STAFFING Responsible SHSO Staff Member: I – A: Authority and Functions MR Element (F) Required Action (RA) Recommended Action Resources/Commendations Criteria Met? SHSO Response and Timeline Legislation or Executive Order Maintain copy of State enabling legislation or Executive Order (EO) on hand that establishes the authority, organization, placement and functions required of the SHSO. Make available any applicable State regulations and SHSO Policies and Procedures. Resources: State Law/EO: XXXX Yes No 1. Policy F: Ensure that legislation or EO states Governor is responsible for SHSO program administration and have copy of document on hand. Demonstrate that the SHSO has been provided adequate powers, is suitably equipped and is organized to carry out the program. Resources: 23 USC Chapter 4, Section 402 (b)(1)(A) State Law/EO: XXXX Yes No 2. Authority F: Ensure SHSO has authority to develop and implement the Highway Safety Plan (HSP), collect data, maintain or access traffic records systems, review and comment to Yes No
the Governor, award grants, provide technical and financial assistance and adequately staff the SHSO. Resources: FYs 15 & 16: FY17: 23 CFR § 1300.4(b)(1-7) 3. Functions F: Ensure SHSO conducts the required functions Resources: : FYs 15 & 16: FY17: , Yes No RA: Define the role of the law enforcement liaisons (LELs), establish specific performance goals/milestones and provide for periodic performance evaluations Commendations: , LEL Program organization Yes No N/A NHTSA TIP: Review current staffing level for adequacy to carry out functions; address each program area; meet deadlines; conduct data analysis for problem identification, target setting and evaluation; and, conduct monitoring. RA: Determine that there are staff assignments for each program area Yes No N/A RA: Ensure that an individual or entity with relevant training is assigned the function of data analysis for the stated tasks Yes No N/A RA: Ensure that the task of conducting monitoring has been adequately staffed to ensure completion of all planned monitoring Yes No N/A Basis for making program coordinator assignments RA: Be able to describe the rationale and basis for division of program staff assignments to ensure efficiency – program, geographic areas, other? Yes No N/A I – B: Organization and Staffing MR Element (F) Required Action (RA) Recommended Action Resources/Commendations Criteria Met? SHSO Response and Timeline
(i) SHSO Organization Maintain an accurate, current copy of the SHSO organization chart Yes No Not Applicable (N/A) RA: Hire a law enforcement liaison (LEL) position to assist with increasing active participation by law enforcement agencies in SHSO enforcement activities and initiatives Yes No N/A (ii) Placement of SHSO within agency RA: Identify placement of the SHSO on the host State agency’s organization chart Yes No N/A (iii) Content of SHSO organization RA: Confirm that all current organizational and the names of each current staff member are included Yes No N/A RA: Ensure that staff position descriptions are kept current and agree with organization chart information Yes No N/A 1. Appointment of the GR F: Ensure that the SHSO can document the appointment of the current GR by the Governor Resources: FYs 15 & 16: FY17: Yes No N/A 2. Name and title of SHSO Director if not the GR and their access to GR RA: Self explanatory Yes No I – C: Policies and Procedures MR Element (F) Required Action (RA) Recommended Action Resources/Commendations Criteria Met? SHSO Response and Timeline (i)SHSO Policies and Procedures (P&P) Manual RA: Establish a P&P Manual specific to the federally funded highway safety program which encompasses the major functions listed using GHSA and other State manuals as models Resources: Commendations: Alaska, Nebraska, Oklahoma Yes No N/A
(ii) Current information RA: Develop a system which is documented in a policy to periodically review, update and track changes to the P&P Manual to ensure that is it up to date Resources: Yes No N/A 1. Specific and detailed RA: Ensure that the policies provide clear guidance and contain sufficient details to clarify the various issues related to managing the program Yes No N/A RA: Includes within the P&P Manual any applicable forms or electronic links to the forms to help staff become familiar with their contents Yes No N/A 2. Improvement of processes RA: Conduct periodic reviews of the policies and incorporate necessary modifications to continuously improve the processes Yes No N/A 3. Staff aware of P&P RA: Post the P&P Manual electronically on the intranet (internet) for easy access, notify staff where it is located and periodically remind staff to use the P&P Manual Yes No N/A 4. Staff using P&P RA: Periodically examine files and review key procedures to determine that all staff is consistently following the current policies in the P&P Manual Yes No N/A RA: Provide regular training on sections of the P&P Manual to all staff through staff meetings, electronic updates and/or periodic reminders Yes No N/A 5. SHSO resources RA: Identify and ensure utilize available resources in the development of the policies Resources: , GHSA Policies and Procedures Manual, NHTSA State Traffic Safety Information website Yes No N/A 6. Procedures on allowability and terms and conditions F: Ensure that the SHSO P&P Manual includes written procedures to determine the allowability of costs per the Uniform Guidance and the terms and conditions of the Federal award Yes No N/A
RA: Consider sending to repeat attendance at NHTSA training courses as needed Yes No N/A RA: Develop a formal process, including formalized learning activities and timelines with benchmarks, to train new employees and document the process in the Policies and Procedures Manual Yes No N/A RA: Conduct in-service training for staff on SHSO policies and procedures and the federal grant management manual Yes No N/A 1a. Ensure that appropriate staff attend NHTSA and GHSA courses RA: Assign staff involved with Highway Safety Performance Plan (HSP) development and project oversight, including managers, to attend the NHTSA Program Management and Managing Federal Finances and GTS, Data Analysis and Evaluation or equivalent courses Resources: RITA Transportation Safety Institute Yes No N/A RA: Assign new program staff to attend the applicable NHTSA program management course (Impaired Driving, Occupant Protection, Traffic Records, etc.) within 12 months of hire Yes No N/A RA: Collaborate with NHTSA and other States in hosting and participating in training courses to reduce staff time for travel and address travel restrictions Yes No N/A RA: Send the GR, SHSO Coordinator or Director and other high level managers to the GHSA Executive Seminar when offered Yes No N/A RA: Ensure that applicable staff participate in all GHSA sponsored trainings and webinars Yes No N/A
Resources: FYs 15 & 16: FY17: , See Ch. IV F: Buy America - Ensure that all goods purchased with Federal grant funds are manufactured or assembled in the United States unless under $5,000 in value; or, if $5,000 or more in value: a waiver request has been submitted by the SHSO and approved by the Secretary of Transportation; or, there is a blanket waiver approved for the item for the applicable fiscal year Resources: Yes No N/A F: Ensure that the annual HSP, subrecipient agreements, contracts and MOUs contain the most current and the complete federally required State certifications and assurances statements Resources: Yes No N/A F: Ensure that no federal funds are used to check for motorcycle helmet usage (beginning with FY17) Yes No N/A F: Ensure that all subrecipient agreements and contracts include the required debarment and suspension certification statement and checks the list (annually) before approving a Resources: Yes No N/A RA: Develop and document the specific procedures and timelines for grant suspension and termination and ensure all subrecipients are aware of them Yes No N/A
the system with all applicable State and Federal regulations, policies and business rules RA: Ensure that staff are adequately trained and coached to ensure that all staff fully and consistently utilize the electronic system features Yes No N/A RA: feasible, encourage subrecipients being funded for multiple activities to complete one grant agreement provided all Federal funding sources are appropriately identified and able to be separately tracked by the SHSO Yes No N/A RA: Where feasible, consider allowing a subrecipient to enter into a multi-year agreement and if so, provide for annual review and authorization Yes No N/A RA: Ensure that the grant objectives and deliverables are identified by Federal fiscal year in the grant agreements and contracts Yes No N/A RA: If a subrecipient is unable to purchase equipment valued at $5,000 or more in the first year, ensure that the SHSO repeats their request for prior approval by NHTSA for purchase of the equipment in the second year of multi-year agreement Yes No N/A II – F: Monitoring/Subrecipient Risk Evaluation FY16 & beyond: MR Element (F) Required Action (RA) Recommended Action Resources/Commendations Criteria Met? SHSO Response and Timeline 1. Evidence of SHSO evaluation of subrecipient risk of noncompliance F: Ensure that the SHSO has established a procedure and documents in writing the annual evaluation of every subrecipient ‘s risk of noncompliance for the purpose of determining the appropriate monitoring Resources: Yes No
track their response to the Single Audit certification requirement to ensure full compliance Commendation: , 1c. Issue a decision of audit findings F: Issue a management decision on audit findings within six months after receipt of the subrecipient’s audit report and ensure that the subrecipient takes appropriate and timely corrective action Resources: FY15:, FY16 & beyond: Yes No RA: Develop an audit finding monitoring system to track all audit findings from Single Audits that relate to NHTSA grant fund activities Yes No N/A RA: Check the Federal Excluded Parties List System or collect a certification from the subrecipient, or add a clause or condition to the covered transaction (2 CFR Section 180.300 – an OMB requirement) Yes No N/A 1d. Adjust pass-through entity’s records F: Determine whether subrecipient audit results, on-site reviews or other monitoring require the adjustment of the pass-through entity’s records Resources: FY15: FY16 & beyond: Yes No N/A 1e. Subrecipients permit access to records F: Ensure that SHSO has a policy that subrecipients are required to permit the SHSO and auditors access to all applicable records and financial statements Resources: FY15: , OMB Circular A-133, Subpart D, Section 400 (d)(7) FY16 & beyond: Yes No N/A
annually in each State grant file designated “local benefit” (not required for direct grants to local agencies) Resources: FY15 & 16: FY17: RA: Ensure required documentation evidencing consent and acceptance is in place before any work is carried out if the State proposes to use the salary and benefits of a State employee toward meeting the local benefit requirement Resources: Yes No N/A 3. Documentation of local benefit for Section 154 and 164 funds if used for SHSO alcohol-impaired driving programs F: Trace local benefit documentation entered into the GTS system by March 31 and full entry by fiscal year close out annually to determine full reconciliation with source documentation to meet the 40% local benefit requirement (pertains to Sections 154AL and 164AL) Resources: , , Yes No III – F: Planning and Administration (P&A) and Program Management (Both terms are defined at beginning of this MR Element. P&A: FY15 & 16: , FY17: . Program Management: : FY15 & 16: , FY17: . MR Element (F) Required Action (RA) Recommended Action Resources/Commendations Criteria Met? SHSO Response and Timeline 1. Verify all P&A and program management expenditures are consistent with sound management practices and documentation supports P&A minimum 50% match (or sliding rate) Section 402 and 410 F: Ensure that the SHSO P&A grant annually documents fully the P&A expenditures and the required match of State or local funds in the amount of 50% (or the applicable sliding scale rate) of the costs claimed for eligible P&A functions. P&A applies to Sections 402, 154 and 164 and SAFETEA-LU 406 and 410. Resources: FY17: . FY15 & 16: , , See Ch. IV Sec. H Yes No
FY17: FY15 & 16: F: Ensure that all related P&A costs, such as travel, equipment, supplies, etc. are charged to P&A and not directly to programs Yes No 6. Salaries and costs charged to program management F: Ensure that only direct and indirect expenses for salaries and other costs that are attributable to the program management functions of the SHSO programs and necessary to carry out its functions are charged to program management and to the specific program area Resources: FY17: . FY15 & 16: Yes No F: Periodically examine the cost data to ensure continued accuracy and amend the data when significant changes occur Yes No F: Determine that only highway safety related time is charged to the highway safety program Yes No III – G. Project Equipment MR Element (F) Required Action (RA) Recommended Action Resources/Commendations Criteria Met? SHSO Response and Timeline 1. System for tracking, managing and disposing of acquired equipment F: Use, manage and dispose of equipment acquired with Federal funds in accordance with the State’s law and procedures (including value threshold) and Federal regulations – this provision applies to the SHSO, subrecipients and contractors Resources: FY17: FY15 & 16: 23 CFR Part 1200.31(c) GHSA Policies and Procedures Manual, See Ch. V, Sec. G, NHTSA Equipment Management Q & A, State Law/Policy: XXXXX Yes No