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