FHWA Compliance Assessment Program (CAP) Guidance

Transcription

1 See 2015 updates at FHWA Cmpliance Assessment Prgram (CAP) Guidance Backgrund ed ed The gal f risk-based prject stewardship and versight is t ptimize the successful delivery f prgrams and prjects and help ensure cmpliance with federal requirements. FHWA Risk-Based Prject Stewardship and Oversight invlves three main avenues f prject invlvement: 1) prject apprval actins, 2) data-driven cmpliance assurance, i.e., the Cmpliance Assessment Prgram (CAP), and 3) risk-based stewardship and versight invlvement in Prjects f Divisin Interest (PDI), including Prjects f Crprate Interest (PCI) which are a subset f PDIs (See Figure 1.) Prject Stewardship and Oversight Prject Apprval Actins CAP PDI PCI rs Figure 1. pe Cmpliance Assessment Prgram Su The purpse f the Cmpliance Assessment Prgram (CAP) is t help prvide reasnable assurance that Federal-aid highway prjects cmply with key federal requirements. The CAP helps prvide this assurance by assessing a statistically valid sample f prjects such that the results infrm the FHWA, with an acceptable level f certainty, f the degree f cmpliance. The apprach is bjective, defensible, and will infrm the develpment f Crprate and Unit risk assessments with statistically valid infrmatin and data. The CAP is ne element f prject stewardship and versight and will supplement and strengthen the agency s mvement tward being mre data-driven and risk-based. The CAP will be implemented n a 3-year cycle that includes bth a Natinal-level and a Divisin-level assessment. CAP Implementatin Prject Ppulatin The CAP prgram will be implemented each year fr a pre-determined ppulatin f prjects. T ensure cnsistency, the prject ppulatin will be drawn frm the FHWA Financial Management Infrmatin System (FMIS) fr each Divisin Office (Divisin). The ppulatin culd change frm year t year depending n whether it is a Natinal-level r Divisin-level fcus as described belw. FINAL - March 28, 2014 Page 1

2 Sample Size A prject sample size will be determined frm the prject ppulatin using the established statistical criteria shwn belw. These criteria have been selected in cnsultatin with Agency leadership and in cnsideratin f the tradeff between statistical accuracy and available resurces. All criteria fall within acceptable ranges fr gvernment prgram assessment, industry, and academia. 90% Cnfidence Level the amunt f uncertainty yu can tlerate 10% Margin f Errr the amunt f errr yu can tlerate 50% Respnse Distributin - the expected respnse t the questin Randmly Sampled Prjects Prjects will be randmly sampled frm the prject ppulatin in an amunt equal t the sample size using randmizing sftware. Substitutin f Randmly Sampled Prjects If a randmly sampled prject is nt a gd candidate fr a CAP review, then the Divisin may request a randmly sampled substitute prject frm the Prgram Management Imprvement (PMI) Team. In rder t preserve the statistical integrity f the prcess, it is expected that the issuance f substitute prjects will be rare and will nt be based nly n perceived lw risk. Examples f prjects that culd require a substitutin include: Prjects that shuld nt have been in the prject ppulatin. Fr example, prjects that were mistakenly authrized fr cnstructin. Prjects that were initially authrized fr cnstructin but will nt advance. Fr example, prjects that the state has pulled frm lettings r will nt award. Prjects that are currently in litigatin r under scrutiny by ther versight agencies and where additinal prject review culd interfere with thse prceedings. Standard CAP Guides 1. Cre Questin Guide The Cre Questin Guide includes cmpliance questins fr key regulatry requirements. The guide will be updated annually and questins may change depending upn histrical cmpliance trends r emerging emphasis areas. The Cre Questin Guide will be required t be used by all Divisins n all randmly sampled prjects in each year. 2. Crprate Review Guide A Crprate Review Guide will be develped if FHWA determines that it is necessary t cnduct an Agency-level review f current r ptential risks r key emphasis areas. The review tpic and questins will depend upn the risks r issues being examined, and an Agency-level review may nt be necessary each year. The Crprate Review Guide will be required as utlined in the FINAL - March 28, 2014 Page 2

3 Guide instructins and may nly be applicable t a certain ppulatin f prjects r a certain grup f Divisins depending n the bjective f the assessment. 3. Technical Review Guides The Technical Review Guides will be develped by prgram and technical specialists within FHWA and prvided by the Directrs f Field Services t the Divisin fr use in the CAP prgram. Divisins are encuraged t take advantage f the statistical sample f prjects and strategically use the Technical Guides t assess knwn risks r validate perceived risks. The Technical Guides are ptinal and may be used t supplement the Cre Questin Guide and the Crprate Review Guide. CAP Review Reprting Divisins will cnduct CAP reviews fr prjects that have been randmly sampled frm the applicable prject ppulatin. Divisins may cnduct these reviews in any rder that they determine apprpriate; hwever, they shuld attempt t cnduct reviews thrughut the curse f the year such that there is steady prgress tward cmpletin f all required reviews by the end f the perfrmance year. Divisins will directly validate the answers t each CAP questin with surce dcumentatin. It is nt necessary t retain cpies f surce dcuments in individual prject files; hwever, surce dcumentatin supprting CAP respnses must be readily available at either the Divisin ffice r State DOT ffice(s) and prduced if needed fr audits r quality assurance reviews. The respnses and infrmatin frm the Cre Questin Guide and the Crprate Review Guide (as applicable) will be entered int the CAP SharePint Site ( as reviews are cmpleted. The results will be evaluated and summary reprts will be prvided each year t Agency and Divisin leadership. The results will be used t infrm strategic and unit planning, crprate and unit risk assessment, and stewardship and versight initiatives. Similarly, Divisins are encuraged t evaluate the results frm the Technical Guides t infrm unit planning, risk assessment, and stewardship and versight initiatives. CAP Review Cycle The CAP prject ppulatins will be adjusted n a 3-year cycle fr a Natinal-level assessment in the first year and mre targeted Divisin-level assessments in the subsequent tw years. This 3-year cycle allws time between Natinal-level assessments t implement respnse strategies fr cmpliance findings, and gives flexibility t Divisins t fcus n specific areas f cncern. It als allws the Crprate Review Guide t be used n the Natinal ppulatin during the first year r n a mre targeted ppulatin during the superseding years. FINAL - March 28, 2014 Page 3

4 3-Year Cycle Year 1: Natinal-level Assessment (PY15) Year 2: Divisin-level Assessment (PY16) Year 3: Divisin-level Assessment (PY17) Natinal-level Assessment The Natinal-level assessment will be cnducted in PY 2015 in rder t validate cmpliance with cre regulatry requirements and t assess key Agency-wide emphasis areas as necessary. Prject Ppulatin: The prject ppulatin fr the Natinal-level assessment will include all prjects authrized fr cnstructin r advance cnstructin within the last 12 mnths and will generally be pulled frm FMIS n April 1 st f each year. Table 1 shws CAP sample size with respect t prject ppulatin using the established criteria. Divisin-level Assessment The Divisin-level assessment will be cnducted in Years 2 and Year 3 t validate cmpliance with cre regulatry requirements and t fcus n specific Divisin area f cncern. The Divisin will have the ptin t filter its prject ppulatin t prvide this fcus. If there is a crprate cncern in a particular risk area, a Divisin might be required t sample a specific prject ppulatin as part f their assessment. Fr example, in a State that has an elevated risk related t lcally administered prjects, Divisins might be required t sample a ppulatin f lcally administered prjects and use a specific Crprate Review Guide. Other Divisins wuld have the flexibility t filter their prject ppulatin at their discretin. Prject Ppulatin: The prject ppulatin fr the Divisin-level assessment will include all prjects authrized fr cnstructin r advance cnstructin within the last 12 mnths and will generally be pulled frm FMIS n April 1st f each year. Table 1 shws CAP sample size with respect t prject ppulatin using the established criteria. Filtered Ppulatin (ptinal): Unless there is a specific Agency cncern that requires a specific ppulatin, Divisins will have the ptin t filter the prject ppulatin using any cmbinatin f these standard FMIS fields: 1. Prject lcatin ppulatin targeted t prjects in specific cunties 2. Ttal cst ppulatin filtered fr prjects in a specific range f ttal cst 3. State-administered prjects ppulatin filtered fr prjects that are State administered 4. Lcally-administered prjects ppulatin filtered fr prjects that are lcally administered 5. Prject imprvement type ppulatin filtered fr prjects with specific imprvement types 6. Emergency relief ppulatin filtered fr emergency relief prjects FINAL - March 28, 2014 Page 4

5 Divisins that elect t filter their ppulatin will crdinate with the PMI Team t identify the filtered ppulatin, sample size, and randmly sampled prjects. The cmbinatin f FMIS criteria must nt reduce the sample size t less than 30 prjects. Sample Size Criteria: Cnfidence Level 90% Margin f Errr 10% Respnse Distributin 50% Table 1: CAP Sample Size fr Prject Ppulatin Range Prject Ppulatin Sample Size 1 t 30 census 31 t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t FINAL - March 28, 2014 Page 5

6 Prject Ppulatin Sample Size 455 t t t t t t t t t up 68 FINAL - March 28, 2014 Page 6