Declarations Module
This module contains three declarations:
1.
Chief Executive Officer (CEO)
Certification
2.
Independent Auditor
Statement for Financial Data (IAS–FD)
3.
Independent
Auditor Statement for Federal Funding Allocation Data (IAS–FFA).
Declarations
The National Transit Database (NTD) program was created to
provide a comprehensive public transit database. To meet a high standard of
data quality, the Federal Transit Administration (FTA) requires each transit
agency to complete declarations stating the validity of the data being
reported.
Reporting Requirements and Thresholds
All required declarations must be completed with the
original NTD report submission. A transit agency must file a complete NTD
Annual report by the report due date. See Exhibit 3 in the Introduction section
of this manual for NTD Annual report due dates.
Requirements for submission of the declarations are as
follows:
·
The CEO Certification form (D-10) is submitted with the other NTD
reporting forms.
·
The IAS – FD must be sent via the e-File. The scanned
document must display the letterhead, signature and date signed.
·
The IAS – FFA is not submitted but must be kept on file at the
transit agency for FTA’s Triennial Review. If there are compelling
circumstances why the Statement cannot be completed on time, the NTD Annual
report must be filed by the due date and the chief executive officer (CEO) must indicate
in Part 4d of the D-10 the reason why the Statement is late and when it will be
completed. The IAS–FFA should be completed no later than the last date to
receive report revisions, as listed in Exhibit 3, or your agency may be Closed
Out Failure to Report. As this audit statement is a requirement for
reporting, failure to complete the IAS–FFA data in a timely manner may result
in the agency not qualifying for apportionment.
For further information, you should refer to e-File:
Sending Declarations, Waivers, and General Correspondence to NTD and Viewing
Report Submission Stages in the Internet Reporting section of this manual.
The exhibit below is a summary of required declarations
describing who must make the declaration and follow-up actions.
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Exhibit 23 — Annual Declaration Requirements
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Declaration Performed
By Reporter Actions Required
Chief Executive Officer (CEO) Certification Chief
Executive Officer Annual requirement – D-10 form
Independent
Auditor Statement for
Financial
Data (IAS – FD) Independent Auditor Review
to confirm use of accrual accounting and Uniform System of Accounts (USOA),
or a directly translatable method. Approval is granted in writing from FTA.
Thereafter, the CEO annually certifies financial data in the CEO
Certification. It is valid until the accounting method changes or significant
issues arise.
The
scanned copy of the IAS – FD is submitted via the e-File.
Independent
Auditor Statement for Federal
Funding
Allocation Data (IAS–FFA) Independent Auditor Annual
requirement for agencies in urbanized areas (UZAs) ≥ 200,000 population
with 100 or more vehicles operated in annual maximum service (VOMS) across
all modes and types of service (TOS).
The
IAS-FFA is retained at the agency for Triennial Review. Reported in part four
of the D-10 form, as required.
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What Has Changed from Prior Year
Clarification is provided that data for reporters who fail
to complete a required Independent Auditor’s Statement for Federal Funding
Allocation data may not be included in the apportionment for the year in which
the data are used.
Chief Executive Officer Certification (D-10) form
Chief Executive Officer Certification form (D-10)
Each transit agency is required to submit a CEO
Certification with its NTD Annual report. The certification is an NTD form,
approved by the transit agency's CEO that endorses and attests to the accuracy
of the data submitted in the NTD Annual report. A CEO Certification is not
required of transit agencies that are granted a Nine or Fewer Vehicles Waiver for the
report year.
The D-10 should identify the title of the CEO and be
electronically approved. The CEO is the principal executive in charge of, and
responsible for, the transit agency.
The following examples illustrate who is a CEO:
·
Transit authority general manager
·
Transit authority administrator
·
County or city government department head
·
State Department of Transportation division head
·
Council of Governments, commission or transit district executive
director
·
City sponsored demand response (DR) system executive
director
·
Whomever the transit agency board designates to be authorized and
accountable for the NTD Annual report.
Examples of a CEO for purchased transportation (PT) by a private
operator filing a separate report are:
·
Senior operations manager (site specific)
·
Officers (e.g., the president, vice president or controller at
the corporate level would also be acceptable). This includes equivalent
positions at operating subsidiaries.
The CEO is required to complete a certification for each NTD
report year. The certification must:
·
Certify the accuracy of the complete data submitted in the
overall report
·
Certify specifically the accuracy of the Federal funding
allocation data used in the Urbanized Area Formula Program (UAF)
and Capital Program for Fixed Guideway Modernization
apportionments
·
Attest to the independent auditor reviews of both financial
data and Federal funding allocation data, if applicable
·
Describe the procedures used to estimate or collect actual passenger miles traveled (PMT) data
and unlinked passenger trip (UPT) data by mode and type of service (TOS).
The CEO Certification attests that all data contained in the
NTD Annual report are accurate and are collected and reported in accordance
with NTD definitions.
If the transit agency is in or serves an UZA with a
population of 200,000 or more, the CEO Certification attests that:
·
The data items used for the apportionment of UAF Program and
Capital Program for Fixed Guideway Modernization funds are accurate, and
·
There is documentation of procedures and internal controls to
ensure data accuracy.
The IAS-FD is usually a one-time review that determines if
the transit agency’s accounting system meets FTA requirements. If a transit
agency meets the requirements in the prior year and has not changed its
accounting system, FTA waives the requirement for an annual IAS-FD.
The CEO Certification is used to verify whether FTA approved
an IAS-FD for a prior report year, whether a waiver was granted not to have an
IAS-FD for the current year or whether an IAS-FD was done for the current
report year.
This information will be indicated in the D-10 form for the
CEO to review and indicate any changes.
It is important to note that “accounting system” refers to
the accounting methodology, for example, accrual or cash basis and to the chart
of accounts, i.e. the USOA. "Accounting system" does not refer to the
hardware or software. Therefore, if the accounting system remains the same,
while the hardware or software is upgraded or changed, this does not
necessitate a new IAS–FD.
If the transit agency is in or serves a UZA with a
population of 200,000 or more and operates 100 or more vehicles operated in annual
maximum service (VOMS) across all modes and TOS, the CEO Certification
states that the transit agency's IAS–FFA has been completed, along with:
·
The name of the auditor and date of the completed Independent
Auditor Statement
·
Whether there are any negative findings
·
If there were any negative findings, how the transit agency
addressed the negative findings.
If there are compelling circumstances which prevent the
IAS–FFA to be completed on time, the NTD Annual report must be filed by the due
date and the CEO must indicate in paragraph 4d of the D-10 the reason why the
IAS–FFA is late and when it will be completed. The IAS–FFA is to be completed
no later than the last date to receive report revisions for the transit
agency’s report due date and filed for FTA’s Triennial Review.
Though not
required, FTA strongly encourages each transit agency to attach a copy of their
IAS–FFA to the e-File.
CEO Certification states that either a 100-percent PMT count
was conducted (actual data), or the sampling method used to collect (estimate)
PMT data for each mode by TOS meets FTA requirements. For PT service, sellers
for the same mode may use different sampling methods or choose to do a
100-percent count of PMT data. If this occurs, each method or 100-percent count
must be listed.
It is important that the NTD Annual report be consistent in
stating how PMT data were derived. The CEO Certification, Independent Auditor
Statement for Federal Funding Allocation Data and the Service form (S-10) must
indicate the same information regarding PMT data.
The CEO Certification states that either a 100-percent UPT
count was conducted (actual data), or the sampling method used to collect
(estimate) UPT data for each mode by TOS meets FTA requirements. For PT
service, sellers for the same mode may use different sampling methods or choose
to do a 100-percent count of UPT data. If this occurs, each method or
100-percent count must be listed.
It is important that the NTD Annual report be consistent in
stating how UPT data were derived. The CEO Certification,
IAS–FFA and the S-10 form must indicate the same information regarding UPT
data.
Chief Executive Officer Certification form (D-10)
The form ensures the certification contains the necessary
assurances of data accuracy, data recording and retention procedures, and uniform
reporting requirements. The certification has six parts:
1.
Attests that the data are accurate, truthful and conform in all material
respects with the USOA and Reporting Manuals.
2.
Attests to each item fixed guideway directional route
miles (FG DRM) and age of fixed guideway (FG) segments, actual vehicle revenue miles (VRM),
PMT and operating expense (OE) by mode and TOS used in
the UAF and Capital Program for Fixed Guideway Modernization allocations. The chief executive officer (CEO)
verifies data accuracy, collection, supervision and records retention.
3.
Attests that the transit agency has / has not received FTA approval of
an IAS–FD for a prior report year. If the transit agency does not have
approval, the CEO must state the independent auditor's name and the date that
the IAS–FD was completed for the current report year. For agencies that have
FTA approval, information is customized and pre-filled for each transit agency
in Internet Reporting. The customized information includes the type of
accounting system, the report year, and the date and auditing firm that
reviewed the financial data. In rare cases, FTA may grant a waiver from
completing an IAS-FD for the current year and this is also stated in the CEO
Certification.
4.
Attests that the transit agency does / does not have an IAS–FFA, if
applicable. In addition, the CEO must state the auditor’s name and the date
that the IAS–FFA was completed for the current report year, whether there are
any negative findings, and if so, how the transit agency addressed the negative
findings. If there are compelling circumstances which prevent the IAS–FFA to be
submitted on-time, the NTD Annual report must be filed by the due date and the
chief executive officer must indicate in Part 4d of the D-10 form the reason
why the IAS–FFA is late and when it will be completed. The IAS–FFA is to be
kept on file by the agency for three years after report submission, so that it
is available for FTA’s Triennial Review.
5.
Describes the PMT data (estimate or actual) by mode and TOS.
6.
Describes the UPT data (estimate or actual) by mode and TOS.
During the validation process, the CEO or independent
auditor, as applicable, should document that they concur with revisions to the
transit agency's data, and retain a copy of the revisions in the transit
agency's files. The CEO should update the D-10 form with each report revision.
The independent auditor does not have to redo the IAS - FFA. When
submitting a revised report, Internet Reporting will prompt you to confirm that
the CEO certifies the revisions to the report and, if required, that the
independent auditor has reviewed and concurred with the revisions.
Completing the CEO Certification form (D-10)
Complete one form.
Form Level Help: Click on the Help tab at the
top of the screen for form level help.
Form Note: A form note can be attached to any form.
Use the Add Form Note link for relevant information to a specific field,
to the entire form or to multiple forms. You should click on the Add Form
Note link at the top of the screen and enter your note on the Notes
screen. You can review and / or edit a form note from the Notes tab. You
should not use the Form Notes feature to answer issues generated from
this form. Instead, from the Issues tab, you should use the Add
Comments link next to the specific issue.
Saving or Closing the Form: You should click on the Save
button prior to exiting the form and continuing with the report. You should click
on the Close button at the bottom of the screen to close the form
without saving.
NTD Report Year. This is an auto-generated field and
cannot be edited, review for accuracy. The field displays the current report
year for which the CEO is certifying the NTD data.
Agency Name. This is an auto-generated field and
cannot be edited, review for accuracy. The field displays the current agency
name as stated on the Identification form (B-10).
NTD ID. This is an auto-generated field and cannot be
edited, review for accuracy. The field displays the NTD identification number
assigned by FTA.
CEO Name. Enter the name of the CEO for your transit agency.
CEO Title. Enter the title of the CEO for your agency.
Certification Completion Date. This is an auto-generated
field and cannot be edited, review for accuracy. This is the date of the 2008
NTD report at each submission.
Line 01: Overall Data Accuracy. If the CEO certifies to the overall accuracy of the data in the NTD report, select “yes”. If “no” is
selected for each statement:
·
The financial and non-financial operating data in this submission
are accurate and truthful records of the financial transactions and operations
·
The financial and non-financial operating data in this submission
conform in all material respects with the accounting and definitional
requirements of FTA Reporting Manuals and the USOA.
Internet Reporting will display a box for you to explain why
the CEO will not certify the data. An explanation is required.
Line 02: Part 2 Federal Funding Allocation form (FFA-10)
Data for Agencies Serving UZAs over 200,000 Population. If the CEO agrees with each of the following verifications, select “yes” for each mode and TOS. If “no”
is selected, Internet Reporting will display a box for you to explain, by mode
/ type of service and data item (vehicle revenue miles,
PMT, operating costs and FG DRM), which of the
verifications cannot be met and why. An explanation is required. The CEO is asked to verify the following statements:
·
A system is in place for recording these data in accordance with
FTA definitions. The system records complete data without systematic errors in
data definitions or comprehensive coverage.
·
Data gathering is an ongoing effort and is collected on a
continuing basis throughout the year.
·
Source documents are available to support the reported data and
will be maintained for at least three years. The source documents are reviewed
and signed by a supervisor, as required.
·
A system of internal controls is in place to ensure the accuracy
of the data collected and reported to the NTD. Documents are reviewed and
signed by a supervisor, as required.
·
Data collection methods for these data are those suggested by FTA
or equivalent.
·
FTA standards for precision and accuracy in these data have been
satisfied. The sampling technique for PMT has either been approved by FTA, or
has been determined to conform to FTA requirements by a qualified statistician.
The approved sampling technique for PMT was followed as documented.
·
These data are consistent with prior reporting periods, and other
facts known about transit agency operations.
Line 03: Part 3 Financial Data.
Select Yes, No or Waiver as follows:
·
3a and 3b: If FTA approved your IAS-FD for a prior report year
and you are not submitting a new IAS-FD, select “yes”. If yes, Paragraph 3a or
3b will appear.
·
3a or 3b are pre-filled and cannot be edited, review for
accuracy. The data provide the
·
Accounting system.
·
Name of the Independent Auditor who performed the financial
review,
·
Date of the financial review.
·
Report year for which the financial review was performed.
·
3c: If your transit agency does not have a prior year approval by
FTA of your IAS-FD review or the accounting system has changed, and you are
submitting an IAS-FD for the current report year, select “no” and complete 3c.
·
Name of the Independent Auditor who performed the financial
review.
·
Date of the financial review.
·
Submit the IAS-FD using the e-File tab.
·
Retain a copy of the review in agency files.
Waiver: If your agency does not have a prior year approval
of your IAS-FD review and FTA granted a waiver for an IAS-FD review for the
current report year, you should select “waiver”. If this is done, 3a, 3b, or 3c
will not appear.
Line 04: FFA-10 Data for Agencies Serving UZAs over 200,000
Population and Operating 100 or more VOMS.
·
4a: You should indicate whether the auditor review of the FFA-10
data has been completed, by selecting “yes” or “no”. If no, go to part 4d. If yes:
·
Name of the Independent Auditor who performed the review.
·
Date of the data review.
·
Retain the review in agency files.
·
Note: Suggested review procedures are provided in Exhibit 25.
·
4b: You should indicate whether the auditor had any negative
findings as a result of the data review by selecting “yes” or “no”.
·
4c: If there were negative findings indicated in 4b, then
Internet Reporting will display a box for you to explain each negative finding
and how your agency addressed each finding.
·
4d: If the independent auditor has not completed the data review
by the report due date, you should provide:
·
Reason why the review was not completed.
·
Anticipated completion date.
Line 05: PMT Data Collection: For each mode / type of
service you should describe how PMT data were collected or estimated for the
current report year (year is pre-filled and cannot be edited) using 5a,
5b, 5c, 5d or 5e. For purchased transportation (PT) or PT
reported as directly operated (DO), the contractor name is auto-filled.
If there are multiple providers and they use different methods, select all that
are used. Note that contractors for purchased transportation reported as
directly operated applies to only a few reporters. Usually contracted service
in an agency’s NTD report is reported as purchased transportation type of
service.
·
5a: FTA Circular (select circular 2710.1a or 2710.2a)
(estimated data)
·
5b: 100% count of PMT data (actual data)
·
5c: Alternative sampling procedure: Note that the procedure
must meet 95% confidence and ±10%
precision levels as determined by a qualified statistician (estimated data).
·
5d: Collected and estimated using the trip length from the last
mandatory year multiplied by the unlinked
passenger trip (UPT) number from this year (estimated data). The last
mandatory year PMT data were collected and estimated (select from the following
using the drop down box):
5d.1 Using
FTA Circular (select circular2710.1a or 2710.2a) (estimate)
5d.2 Using
a 100% count of PMT data (actual)
5d.3 Using
an alternative sampling procedure determined to meet 95% confidence and ±10% precision levels by a qualified
statistician (estimate).
·
5e: None of the above. Internet Reporting will display a box for
you to describe.
Line 06: Unlinked Passenger Trip Data Collection: For each
mode / type of service you should describe how unlinked passenger trips were
collected or estimated for the current report year (year is pre-filled
and cannot be edited) using 6a, 6b, 6c or 6d. For purchased transportation or
purchased transportation reported as directly operated the contractor name is auto-filled.
If there are multiple providers and they use different methods, you should select
all that are used. Note that contractors for purchased transportation reported
as directly operated applies to only a few reporters. Usually contracted
service in an agency’s NTD report is reported as purchased transportation type
of service.
·
6a: FTA Circular 2710.1A (estimated data).
·
6b: 100% count of UPT data (actual data).
·
6c: Alternative sampling procedure determined to meet 95%
confidence and ±10% precision levels by
a qualified statistician (estimated data).
·
6d: None of the above. Internet Reporting will display a box for
you to describe.
Each transit agency is required to file an IAS – FD with
their NTD Annual report. This is usually a one-time submission that must be
reviewed and approved by FTA. An audit conducted for the OMB Circular A-133
Single Audit Act is not a substitute.
The independent auditor must review all financial
forms to ensure that the transit agency's accounting system follows the Uniform System of Accounts (USOA), that accrual accounting or a directly translatable
method is used, and that all data are in accordance with NTD requirements. The
review must state whether any of the reported data do not conform to NTD
requirements and describe the discrepancies.
If FTA approves the IAS–FD, the Chief Executive Officer (CEO)
Certification may be used in subsequent years in lieu of the IAS–FD. The chief executive officer (CEO) must certify
the overall accuracy of the data in the NTD Annual report.
If there is a change in the transit agency's accounting
system, another review must be performed (a new IAS–FD) and submitted to FTA.
FTA may require a new review if there are substantial changes in financial data
reporting.
The criteria for retaining FTA approval are:
·
The transit agency has adopted the USOA, and has previously submitted
an NTD Annual report that was compiled using the USOA and was reviewed by an
independent auditor, or
·
The transit agency:
·
Uses an internal accounting system other than the accounting
system prescribed by the USOA
·
Uses the accrual method of accounting
·
Directly translates the system and accounting categories, using a
clear audit trail, to the accounting treatment and categories specified by the
USOA, and
·
Has previously submitted an NTD Annual report that was compiled
using the same internal accounting system and translation to the USOA, and was
reviewed by an independent auditor.
If the above criteria are met, the CEO Certification must
verify that the financial data continues to meet one of the above conditions.
The transit agency must submit the IAS–FD as applicable. FTA
provides suggested formats in Internet Reporting on the Reports tab
(Example 31). It is not a requirement that a transit agency use these formats;
however, the IAS–FD must still address each of the items outlined in the
suggested format.
The suggested format ensures the financial reporting forms
conform in all material respects with the accounting requirements in the USOA
and NTD reporting requirements. Usually, a transit agency has the financial
data review done only once and sends the IAS–FD to FTA. If the transit agency
is in conformance, FTA grants approval. This approval remains in effect until
the accounting system or method changes, or if significant issues arise.
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Example 29 — Independent
Auditor Statement for Financial Data — Suggested Format
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The Board of Trustees
Transit Agency Name
In connection with our regular examination of the financial
statements of [agency name], for the fiscal year ended [date],
on which we have reported separately under [date of auditor’s statement],
we have also reviewed the reporting forms listed below and included in the
report for the fiscal year ended [date], required under Title 49
U.S.C. 5335 (a), for conformity in all material respects with the
requirements of the Federal Transit Administration (FTA) as set forth in its
applicable National Transit Database (NTD) Uniform System of Accounts (USOA).
Our review for this purpose included such tests of the accounting records and
such other auditing procedures, as we considered necessary in the
circumstances. We did not make a detailed examination such as would be
required to determine that each transaction has been recorded in accordance
with the USOA.
Select 1 of the following 2 paragraphs for inclusion in your
Statement:
The accounting system from which this NTD report is derived
follows the accounting system prescribed by the USOA. The same accounting
system has been adopted and was used to compile this NTD report.
or
The accounting system from which this NTD report is derived is
other than the accounting system prescribed by the USOA, but uses the accrual
basis of accounting and is directly translated, using a clear audit trail, to
the accounting treatment and categories specified by the USOA. The same
internal accounting system has been adopted and was used to compile this NTD
report.
Submit a list of the specific financial forms being reported
upon:
· Sources
of Funds — Funds Earned and Funds Expended form (F-10)
· Uses
of Capital form (F-20)
· Operating
Expenses forms (F-30 and F-40)
Based on our review, in our opinion the accompanying
reporting forms identified above conform in all material respects with the
accounting requirements of the FTA as set forth in its applicable USOA.
Signed: Date:
Title:
City
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Transit agencies that are in or serve urbanized areas
(UZA) with populations of 200,000 or more, and whose report covers 100 or more vehicles operated in annual
maximum service (VOMS) across all modes and types of service (TOS), are required to have
an independent auditor review all NTD data used in the Urbanized Area Formula Program (UAF)
and the Capital Program for Fixed Guideway Modernization
allocations. This is an annual requirement. Transit agencies other than those
stated above would only submit this statement if requested by FTA.
When a transit agency reaches the 100-vehicle threshold, it
must submit an IAS – FFA. This is required for the report year in which the
transit agency reaches the threshold.
The IAS–FFA is required by the transit agency’s due date
(refer to the Introduction section of this manual for the NTD Reporting
Timeline) or your agency may receive a Close Out Failure to Report. The
transit agency should keep the Statement on file for FTA’s Triennial Review. As
this audit statement is a requirement for reporting, failure to complete the
IAS – FFA in a timely manner may result in the agency not qualifying for
apportionment.
Though not
required, FTA strongly encourages each transit agency to attach a copy of their
IAS–FFA to the e-File.
The IAS–FFA should discuss, by mode and TOS: fixed guideway directional route
miles (FG DRM), actual vehicle revenue miles (VRM), passenger miles traveled (PMT), operating expenses (OE) and commencement date of
revenue service. The independent auditor should
describe the procedures for determining the following:
·
Assurance that a system exists to record and gather data on a
continuing basis.
·
Assurance that a system exists, and is maintained, for recording
data in accordance with NTD definitions. This means that the correct data are
being measured and that there are no systematic errors.
·
Assurance that source documents are available to support the
reported data and are maintained for FTA review and audit for a minimum of
three years following FTA's receipt of the NTD Annual report. The data must be
fully documented and securely stored.
·
Assurance that there is a system of internal controls to ensure
the accuracy of the data collection process and recording system and that
reported documents are not altered.
·
Assurance that a supervisor reviews and signs documents as
required.
·
Assurance that the data collection methods are those suggested by
FTA; or have been approved by FTA or a qualified statistician as being
equivalent in quality and precision. The collection methods must be documented
and followed.
·
Assurance that the deadhead miles, computed by taking the
difference between the reported total actual vehicle miles data and the
reported total actual VRM data, appear to be accurate.
·
Documentation that reported data have undergone analytic review
to ensure that they are consistent with prior reporting periods and other facts
known about transit agency operations.
·
Documentation of the specific documents reviewed and tests
performed.
·
Documentation of how purchased transportation
(PT) fare revenues and contract expenditures are reported; i.e., PT
fare revenues should include all fare revenues pertaining to the PT service,
and buyer's contract expenditures are reported net of (not
including) the PT fare revenues.
FTA provides a suggested list of procedures to satisfy the
requirements of the IAS – FFA review (Exhibit 26). The procedures are an aid
for an auditor to conduct in its review of data items used in the UAF and the
Capital Program for Fixed Guideway Modernization allocations. These procedures
allow the auditor to make the assurances about data collection, supervision and
records retention specified in the suggested IAS–FFA.
These are suggested procedures for the review of federal
funding allocation data (Exhibit 26). If any suggested procedure is not used,
the auditor has to replace it with an alternative procedure which fully
addresses the intent of the suggested procedure.
There is also an Auditor Help Sheet that provides guidance
about the type of source documents and personnel to assist in undertaking the
suggested procedures. The Auditor Help Sheet is available from www.ntdprogram.gov.
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Exhibit 24 — Federal Funding
Allocation Data Review — Suggested Procedures
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FTA has specified and agreed to a set of procedures for the
independent auditor to perform to satisfy the requirements of the Federal
Funding Allocation data review. Several of the procedures below require the
auditor to select a random sample of documents or data. The procedures do not
specify the number to be selected (i.e., the percentage of the total
documents / data). The auditor should use professional judgment to determine
the percentage that will enable the auditor to make the required assurances.
The source documents and other records (such as data
summaries) may be in the form of computerized data files. The auditor should
ensure that these files are securely stored and that backup procedures are in
place to ensure that source documents are retained by the transit agency for
a minimum of three years.
The procedures, to be applied to each applicable mode and
type of service (TOS) (directly operated (DO) and purchased transportation
(PT)), are:
a.
Obtain and read a copy of written procedures related to the system for
reporting and maintaining data in accordance with the NTD requirements and
definitions set forth in 49 CFR Part 630, Federal Register, January 15, 1993
and as presented in the 2008 Reporting Manual. If procedures are not written,
discuss the procedures with the personnel assigned responsibility of
supervising the NTD data preparation and maintenance.
b.
Discuss the procedures (written or informal) with the personnel
assigned responsibility of supervising the preparation and maintenance of NTD
data to determine:
·
The extent to which the transit agency followed the procedures
on a continuous basis, and
·
Whether they believe such procedures result in accumulation and
reporting of data consistent with the NTD definitions and requirements set
forth in 49 CFR Part 630, Federal Register, January 15, 1993 and as presented
in the 2008 Reporting Manual.
c.
Inquire of same personnel concerning the retention policy that is
followed by the transit agency with respect to source documents supporting
the NTD data reported on the Federal Funding Allocation Statistics form
(FFA-10).
d.
Based on a description of the transit agency's procedures obtained in
items a and b above, identify all the source documents which are to be retained
by the transit agency for a minimum of three years. For each type of source
document, select three months out of the year and determine whether the
document exists for each of these periods.
e.
Discuss the system of internal controls with the person responsible
for supervising and maintaining the NTD data. Inquire whether individuals,
independent of the individuals preparing source documents and posting data
summaries, review the source documents and data summaries for completeness,
accuracy and reasonableness and how often such reviews are performed.
f.
Select a random sample of the source documents and determine whether
supervisors' signatures are present as required by the system of internal
controls. If supervisors' signatures are not required, inquire how the
supervisors' reviews are documented.
g.
Obtain the worksheets utilized by the transit agency to prepare the
final data that are transcribed onto the Federal Funding Allocation
Statistics form. Compare the periodic data included on the worksheets to the
periodic summaries prepared by the transit agency. Test the arithmetical
accuracy of the summarizations.
h.
Discuss the transit agency's procedure for accumulating and recording
passenger miles traveled (PMT) data in accordance with NTD requirements with
transit agency staff. Inquire whether the procedure used is (1) a 100% count
of actual PMT or (2) an estimate of PMT based on statistical sampling meeting
FTA's 95% confidence and ±10%
precision requirements. If the transit agency conducts a statistical sample for
estimating PMT inquire whether the sampling procedure is (1) one of the two
procedures suggested by FTA and described in FTA Circulars 2710.1A or
2710.2A; or (2) an alternative sampling procedure if the transit agency uses
an alternative sampling procedure, inquire whether the procedure has been
approved by FTA or whether a qualified statistician has determined that the
procedure meets FTA's statistical requirements. Note as a negative finding in
the report use of an alternative sampling procedure that has not been
approved in writing by a qualified statistician.
i.
Discuss with transit agency staff (the accountant may wish to list the
titles of the persons interviewed) the transit agency's eligibility to
conduct statistical sampling for PMT data every third year. Determine whether
the transit agency meets one of the three criteria that allow transit
agencies to conduct statistical samples for accumulating PMT data every third
year rather than annually. Specifically:
1.
According to the 2000 Census, the public transit agency serves an UZA
of less than 500,000 population.
2.
The public transit agency directly operates fewer than 100 revenue
vehicles in all modes in annual maximum revenue service (VOMS) (in any size
urbanized area).
3.
The service is purchased from a seller operating fewer than 100
revenue vehicles in VOMS, and is included in the transit agency's NTD report.
For transit agencies that meet one of the above
criteria, review the NTD documentation for the most recent mandatory sampling
year (2008) and determine that statistical sampling was conducted and meets
the 95% confidence and +10% precision requirements.
Determine how the transit agency estimated annual PMT
for the current report year.
j.
Obtain a description of the sampling procedure for estimation of PMT
data used by the transit agency. Obtain a copy of the transit agency's
working papers or methodology used to select the actual sample of runs for
recording PMT data. If the average trip length was used, determine that the
universe of runs was used as the sampling frame. Determine that the
methodology to select specific runs from the universe resulted in a random
selection of runs. If a selected sample run was missed, determine that a
replacement sample run was randomly selected. Determine that the transit agency
followed the stated sampling procedure.
k.
Select a random sample of the source documents for accumulating PMT
data and determine that they are complete (all required data are recorded)
and that the computations are accurate. Select a random sample of the
accumulation periods and re-compute the accumulations for each of the
selected periods. List the accumulations periods that were tested. Test the
arithmetical accuracy of the summarization.
l.
Discuss the procedures for systematic exclusion of charter, school
bus, and other ineligible vehicle miles from the calculation of actual
vehicle revenue miles with transit agency staff and determine that stated
procedures are followed. Select a random sample of the source documents used
to record charter and school bus mileage and test the arithmetical accuracy
of the computations.
m.
For actual vehicle revenue mile (VRM) data, document the collection
and recording methodology and determine that deadhead miles are
systematically excluded from the computation. This is accomplished as
follows:
If actual
VRMs are calculated from schedules, document the procedures used to subtract
missed trips. Select a random sample of the days that service is operated and
re-compute the daily total of missed trips and missed VRMs. Test the
arithmetical accuracy of the summarization.
·
If actual VRMs are calculated from hubodometers, document the
procedures used to calculate and subtract deadhead mileage. Select a random
sample of the hubodometer readings and determine that the stated procedures
for hubodometer deadhead mileage adjustments are applied as prescribed. Test
the arithmetical accuracy of the summarization of intermediate accumulations.
·
If actual VRMs are calculated from vehicle logs, select random
samples of the vehicle logs and determine that the deadhead mileage has been
correctly computed in accordance with FTA's definitions.
n.
For rail modes, review the recording and accumulation sheets for
actual VRMs and determine that locomotive miles are not included in the
computation.
o.
If fixed guideway directional route miles (FG DRM) are reported,
interview the person responsible for maintaining and reporting the NTD data
whether the operations meet FTA's definition of fixed guideway (FG) in that
the service is:
·
Rail, trolleybus (TB), ferryboat (FB), or aerial tramway (TR)
or
·
Bus (MB) service operating over exclusive or controlled access
rights-of-way (ROW), and
·
Access is restricted
·
Legitimate need for restricted access is demonstrated by peak
period level of service D or worse on parallel adjacent highway, and
·
Restricted access is enforced for freeways; priority lanes used
by other high occupancy vehicles (HOV) (i.e., vanpools (VP), carpools) must
demonstrate safe operation (see Fixed Guideway Segments form (S-20))
·
High Occupancy / Toll (HO/T) lanes meet FHWA requirements for
traffic flow and use of toll revenues, and that the transit agency has
provided to NTD a copy of the State’s certification to the US Secretary of Transportation that it has established a program for monitoring, assessing and
reporting on the operation of the HOV facility with HO/T lanes.
p.
Discuss the measurement of fixed guideway FG DRM with the person
reporting the NTD data and determine that the mileage is computed in
accordance with FTA's definitions of FG and DRM. Inquire whether there were
service changes during the year that resulted in an increase or decrease in
DRMs. If a service change resulted in a change in overall DRMs, re-compute
the average monthly DRMs, and reconcile the total to the FG DRM reported on
the FFA-10 form.
The auditor
should inquire if any temporary interruptions in transit service occurred
during the report year. If these interruptions were due to maintenance or
rehabilitation improvements to a FG segment(s), the following apply:
·
DRMs for the segment(s) should be reported for the entire
report year if the interruption is less than 12 months in duration. The
months of operation on the S-20 form should be reported as 12. The transit
agency should have completed a Form Note describing the interruption.
·
If the improvements cause a service interruption on the FG-DRMs
lasting more than 12 months, the transit agency should contact their
validation analyst to discuss. FTA will make a determination on how the DRMs
should be reported.
q.
Measure FG-DRM from maps or by retracing route.
r.
Discuss with the person reporting the NTD data whether other public
transit agencies operate service over the same FG as the transit agency. If
yes, determine that the transit agency coordinated with the other transit agency
(ies) such that the DRMs for the segment of FG are reported only once to the
NTD on the FFA-10 form. Each transit agency should report the actual VRM, PMT
and OE for the service operated over the same FG.
s.
Review the S-20 form. Discuss the commencement date of revenue service
for each FG segment with the person reporting the NTD data and determine that
the date is reported as when revenue service began. This is the opening date
of revenue service, even though the transit agency may not have been the
original operator. Review the form in Internet Reporting and determine that
the information has been properly entered. There should be a date for
segments put into revenue service on or after September 30, 2002. If the
segments opened earlier, the date may be left blank indicating segments older
than seven years. However, if a date was entered in the prior report year, it
should not be removed. Segments are summarized by like characteristics. Note
that for apportionment purposes under the Capital Program for Fixed Guideway
Modernization, the 7-year age requirement for fixed guideway segments is
based on the report year when the segment is first reported by any NTD
transit agency. This pertains to segments reported for the first time in the
current report year. Even if a transit agency can document a revenue service
start date prior to the current NTD report year, FTA will only consider
segments continuously reported to NTD.
t.
Compare operating expenses with audited financial data, after
reconciling items are removed.
u.
If the transit agency purchases transportation services, interview the
personnel reporting the NTD data regarding the amount of PT generated fare
revenues. The PT fare revenues should equal the amount reported on the
Contractual Relationship form (B-30).
v.
If the transit agency's report contains data for PT services and
assurances of the data for those services is not included, obtain a copy of
the AS-FFA data of the PT service. Attach a copy of the statement to the
report. Note as an exception if the transit agency does not have an
Independent Auditor Statement (IAS) for the PT data.
w.
If the transit agency PT services, obtain a copy of the PT contract
and determine that the contract (1) specifies the specific public
transportation services to be provided; (2) specifies the monetary
consideration obligated by the transit agency or governmental unit
contracting for the service; (3) specifies the period covered by the contract
and that this period overlap s the entire or a portion of, period covered by
the transit agency's NTD report; and (4) is signed by representatives of both
parties to the contract. Interview the person responsible for maintaining the
NTD data regarding the retention of the executed contract, and determine that
copies of the contracts are retained for three years.
x.
If the transit agency provides service in more than one UZA, or
between a UZA and a non-UZA, inquire of the person responsible for
maintaining the NTD data regarding the procedures for allocation of
statistics between UZAs and non-UZA. Agencies that operate service in both
within a UZA and outside of a UZA (non-UZA) will report to the 2008 Annual
NTD database. Agencies who operate service only in a non-UZA should report
the 2008 NTD Rural Report. Obtain
and review the FG segment worksheets, route maps and urbanized area
boundaries used for allocating the statistics, and determine that the stated
procedure is followed and that the computations are correct.
y.
Compare the data reported on the FFA-10 form to comparable data for
the prior report year and calculate the percentage change from the prior year
to the current year. For actual VRM, PMT or OE data that have increased or
decreased by more than 10%, or FG DRM data that have increased or decreased
by more than 1%, interview transit agency management regarding the specifics
of operations that led to the increases or decreases in the data relative to
the prior reporting period. The auditor should document the specific
procedures followed, documents reviewed, and tests performed in the work
papers. The work papers should be available for FTA review for a minimum of
three years following the NTD report year. The auditor may perform additional
procedures, which are agreed to by the auditor and the transit agency, if
desired. The auditor should clearly identify the additional procedures
performed in a separate attachment to the statement as procedures that were
agreed to by the transit agency and the auditor, but not by FTA.
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Fixed Guideway
The following provides additional discussion on reporting fixed guideway (FG) segments and covers the
following topics:
·
High occupancy / toll l(HO/T ) lanes
·
New and modified fixed guideway segments
SAFETEA-LU clarifies provisions
governing the use and operation of high occupancy vehicles (HOV), in particular
the use of HOV facilities by high occupancy / toll (HO/T) vehicles. These are
vehicles that are not otherwise exempt to use the HOV facility (e.g., energy
efficient vehicles) if the vehicle pays a toll. HO/T toll lanes allow single occupancy vehicles (SOVs) to gain
access to (HOV) facilities by paying a toll. If a transit agency has stricter
requirements for high occupancy vehicles
facilities than the prohibition of single occupancy vehicles, then those
requirements apply to the HO/T lane.
A State agency with jurisdiction over the operation of a HOV
facility must establish occupancy requirements for HOV lanes and for any
exemptions. The State agency must certify to the US Secretary of Transportation
that they have established a program to monitor, assess, and report on the
operation of the facility and the impact of high occupancy / toll vehicles and
other low emission and energy efficient vehicles. An adequate enforcement
program is also required, and provision made for limiting or discontinuing the
exemptions if the facility becomes seriously degraded.
These provisions and clarifications also require that for
excess toll revenues, priority consideration is to be given to projects for
developing alternatives to single occupancy vehicle travel and for improving
highway safety.
New and Modified Fixed Guideway Segments
You may add new FG segments or modify existing FG segments.
These new segments can be:
·
A segment being reported to NTD for the first time by any transit
agency. If a segment has been added as new it is important to verify that the
segment has never been reported to NTD in prior years. , All data entry fields
will be available
·
A segment being reported to NTD for the first time by this
transit agency. The segment is available to select from the drop-down menu.
Only selected fields can be modified. Refer to the Fixed Guideway Segments form
(S-20).
For new and modified segments, NTD also requires that the
transit agency provide supporting documentation. This includes detailed maps
that clearly show each segment and when revenue service first began on the segment.
For apportionment purposes under the Capital Program for
Fixed Guideway Modernization, the 7-year age requirement for fixed guideway
segments is based on the report year when the segment is first reported by any
NTD transit agency. This pertains to segments reported for the first time in
the current report year. Even if a transit agency can document a revenue
service start date prior to the current NTD report year, FTA will only consider
segments continuously reported to NTD.
Until a segment
is reviewed and accepted by NTD, it appears under a proposed new segments
section on the S-20 form, and the directional route miles (DRM) for
the segment are not included in the summary at the bottom of the form. Once a
new segment is approved, NTD will enter the segment and its directional route
miles into the database and the directional route miles for the new segment
will be u included in the summary.
For new and modified segments, the following should be done:
·
The auditor should review the supporting documentation and S-20
form, and determine with the transit agency the DRM to be reported for the
Federal Funding Allocation Statistics form (FFA-10).
·
In completing the FFA-10 form, you should include the segment in
reporting the DRM and associated statistics for VRM, PMT and OE in the
appropriate UZA / non-UZA column.
NTD requires the IAS – FFA to be completed prior to
submission of the NTD Annual report. The auditor does not have to re-review the
FFA-10 form once NTD approves the new and modified segments if none of the
information on the S-20 form changes.
If the information does change, the auditor must review the
revised FFA-10, but does not have to submit a revised IAS – FFA. When
submitting a revised report, Internet Reporting will prompt you: 1) to confirm
that the CEO certifies the revisions to the report and 2) if required, that the
independent auditor has reviewed and concurred with the revisions.
If the transit agency no longer operates over a segment
reported in the prior year, you must enter the date that transit service was
last operated under Out of Revenue Service Date. The segment will be deleted
and DRM eliminated in the summary at the bottom of the S-20 form.
You should not use the Delete box.
The auditor should confirm the Out of Revenue Service Date,
i.e., the date on which the transit agency stopped operating service.
For further information, you should refer to the S-20 form
for a discussion of the requirements.
The transit agency keeps the Independent
Auditor Statement for Federal Funding Allocation Data (IAS–FFA) on file for
three years after the NTD Annual report is submitted, for FTA’s triennial
review. It does not need to be submitted with the NTD Annual report.
FTA provides suggested formats in Internet Reporting on the Reports
tab (Example 32). It is not a requirement that a transit agency use these
formats; however, the IAS–FFA data must still address each of the items
outlined in the suggested format.
The suggested format ensures that requirements for the data
items used in the Urbanized Area Formula Program (UAF)
and the Capital Program for Fixed Guideway Modernization
allocations meet FTA standards. The format is consistent with the FTA suggested
list of procedures for the independent auditor (Exhibit 26).
During the validation process if revisions are made to the
FFA-10 form, the transit agency should document that both the chief executive officer (CEO) and the
independent auditor concur with revisions to the transit agency's data, and
retain a copy of the revisions in the transit agency's files. The independent
auditor does not have to redo the IAS–FFA. When submitting a revised report,
Internet Reporting will prompt you to confirm that the CEO certifies the
revisions to the report and that the independent auditor has reviewed and
concurred with the revisions.
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Example 30 — Independent
Auditor Statement for Federal Funding Allocation Data — Suggested Format
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The Board of Trustees
Transit Agency Name
FTA has established the following standards with regard to
the data reported to it in the Federal Funding Allocation Statistics form
(FFA-10) of the transit agency's annual National Transit Database (NTD)
report:
·
A system is in place and maintained for recording data in
accordance with NTD definitions. The correct data are being measured and no
systematic errors exist.
·
A system is in place to record data on a continuing basis, and
the data gathering is an ongoing effort.
·
Source documents are available to support the reported data and
are maintained for FTA review and audit for a minimum of three years
following FTA's receipt of the NTD report. The data are fully documented and
securely stored.
·
A system of internal controls is in place to ensure the data
collection process is accurate and that the recording system and reported
comments are not altered. Documents are reviewed and signed by a supervisor,
as required.
·
The data collection methods are those suggested by FTA or
otherwise meet FTA requirements.
·
The deadhead miles, computed as the difference between the
reported total actual vehicle miles data and the reported total actual VRM
data, appear to be accurate.
·
Data are consistent with prior reporting periods and other
facts known about transit agency operations.
We have applied the procedures to the data contained in the
accompanying FFA-10 form for the fiscal year ending [date]. Such
procedures, which were agreed to and specified by FTA in the Declarations
section of the 2008 Reporting Manual and were agreed to by the transit
agency, were applied to assist you in evaluating whether the transit agency
complied with the standards described in the first paragraph of this part and
that the information included in the NTD report FFA-10 form for the fiscal
year ending [date] is presented in conformity with the requirements of
the Uniform System of Accounts (USOA) and Records and Reporting System; Final
Rule, as specified in 49 CFR Part 630, Federal
Register, January 15, 1993 and as presented in the 2008 Reporting Manual.
Additional procedures performed (if any), which are agreed to by the transit
agency but not by FTA, are described in a separate attachment to this report.
This report is intended solely for your information and for FTA and should
not be used by those who did not participate in determining the procedures.
The procedures were applied separately to each of the information systems
used to develop the reported actual VRM, FG DRM, PMT and OE of [transit
agency name] for the fiscal year ending [date] for each of the
following modes:
[List each mode by type of service (TOS) (directly
operated (DO) or purchased transportation (PT)).]
The following information and findings came to our attention
as a result of performing the procedures described in the attachments to this
report:
[Itemize all information and findings. If none, so
state.]
In performing the procedures, except for the information and
findings described above, the information included in the NTD report on the
FFA-10 form for the fiscal year ending [date] is presented fairly, in
all material respects, with the requirements of the USOA and Records and
Reporting System; Final Rule, as specified in 49 CFR Part 630, Federal
Register, January 15, 1993 and as presented in the 2008 Reporting Manual.
Signed: Date:
Title:
City
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