25.10.2013 Views

FTA Oversight Procedures - Federal Transit Administration - U.S. ...

FTA Oversight Procedures - Federal Transit Administration - U.S. ...

FTA Oversight Procedures - Federal Transit Administration - U.S. ...

SHOW MORE
SHOW LESS

Create successful ePaper yourself

Turn your PDF publications into a flip-book with our unique Google optimized e-Paper software.

(1) If the Sponsor cannot justify the discrepancy, the PMOC should report this finding to<br />

the <strong>FTA</strong> for a ruling.<br />

5.3 Intermediate Audit.<br />

While this audit is not mandatory by <strong>FTA</strong>, it shall be encouraged, since this represents the last<br />

chance to take corrective action before the end of the production process and prior to delivery.<br />

5.3.1 An intermediate audit or review will be conducted in the same manner as a Post-Delivery<br />

Review.<br />

5.3.2 The PMOC should assure that both the Grantee/Sponsor and supplier understand that<br />

failure to meet Buy America can put the Grantee’s/Sponsor’s <strong>FTA</strong> grant in jeopardy.<br />

5.4 Post-Delivery Review.<br />

This section provides specific input that PMOCs can use to evaluate Sponsor’s audit report.<br />

Recommendations for specific questions to ask are provided, along with suggestions for how to<br />

evaluate component/material costs, labor costs, and sub-supplier costs and locations.<br />

5.4.1 Questions for the Post-Delivery Review:<br />

(1) Did the Grantee/Sponsor obtain and retain Pre-Award Buy America certifications<br />

from successful suppliers for purchases of more than $100,000?<br />

• If yes, obtain and compare supplier list from Pre-Award certification results to list<br />

of suppliers in Post-Delivery Review.<br />

• If no, or if the list has changed, mark this as a discrepancy for discussion with<br />

Grantee/Sponsor.<br />

(2) Did the Grantee/Sponsor conduct Pre-Award and Post-Delivery audits for its<br />

purchase of rolling stock over $100,000? Does the Grantee/Sponsor have properly<br />

completed certifications for each review in its contract files?<br />

• If yes, proceed to next question.<br />

• If no, mark this as a discrepancy for discussion with the Grantee/Sponsor.<br />

(3) If the Grantee/Sponsor is purchasing rolling stock with multiple delivery dates, using<br />

options, or multi-year procurements, and, if so, has the Grantee/Sponsor performed<br />

and certified Pre-Award and Post-Award audit for each group of vehicles, before<br />

placing them into revenue service? 10<br />

• If yes, proceed to next question.<br />

10 49 CFR 663.21, 663.31 and <strong>FTA</strong> Dear Colleague Letter of March 18, 1997<br />

OP26A Buy America Review<br />

Revision 0, June 2008<br />

Page 9 of 14

Hooray! Your file is uploaded and ready to be published.

Saved successfully!

Ooh no, something went wrong!