Compliance
Audit and Oversight
FTA Clauses and Requirements
FTA Compliance Reviews
Documentation and Recordkeeping
200

Under 2 CFR 200, recipients are required to monitor this regularly to avoid overspending or underutilization of federal awards.

What is budget versus actual expenditures?

200

FTA requires grantees to maintain written procedures for this process, which involves ensuring contractors perform in accordance with the terms, conditions, and specifications of their contracts.

What is contract administration?

200

Required contract clauses for FTA-funded procurements include this clause to ensure compliance with federal wage rates.

What is "Davis-Bacon Act clause"?

200

FTA reviews procurement practices during these formal assessments to ensure compliance with federal procurement regulations.

What are Triennial Reviews?

200

The minimum period procurement records must be retained after the final expenditure report under FTA rules.

What is three years?

400

Under 2 CFR 200.303, recipients must maintain this to provide reasonable assurance that they can manage the award in compliance with Federal statutes, regulations, and award requirements.

What is internal control?

400

To guard against fraud, waste, and abuse, recipients must maintain written standards of conduct covering conflicts of interest and this type of concern, where employees might benefit personally from contract awards.

What is an organizational conflict of interest?

400

FTA procurement contracts must include this clause, prohibiting certain lobbying activities.

What is the Lobbying Certification Clause?

400

During FTA reviews, documentation must demonstrate compliance with this foundational procurement standard.

What is competitive procurement?

400

This document details the specific requirements, evaluation criteria, and instructions provided to potential bidders.

What is a solicitation?

600

This method, also known as formal advertising, is preferred for construction projects and is used when sealed bids are publicly solicited, with a firm fixed-price contract awarded to the lowest responsive and responsible bidder.

What is sealed bidding?

600

Grantees must avoid this practice, in which contract specifications are written to favor a particular brand, contractor, or product, as it undermines full and open competition.

What is restrictive of competition (or “restricting competition”)?

600

This clause is required to ensure products procured are manufactured primarily in the United States.

What is the Buy America Clause?

600

This specific FTA review focuses solely on procurement systems and procedures for transit agencies.

What is a Procurement System Review (PSR)?

600

Agencies must maintain this written justification whenever non-competitive procurement methods are used.

What is a sole source justification?

800

When conditions are not appropriate for sealed bids, this method allows for evaluation based on technical qualifications as well as cost, often leading to negotiation before award.

What is competitive proposals?

800

FTA requires recipients to maintain independent documentation demonstrating that the recipient, not the contractor, made this critical determination about the method of procurement, contractor selection, and contract type.

What is responsibility for procurement decisions?

800

FTA-funded contracts exceeding $100,000 must include this clause protecting against contract disputes or breaches.

What is the Termination for Cause and Convenience clause?

800

The outcome of an FTA procurement compliance review that identifies areas requiring corrective actions.

What is a finding?

800

This document must be completed and maintained to demonstrate the rationale behind selecting a specific contractor.

What is an evaluation matrix or evaluation summary?

1000

This subsection of 2 CFR 200 requires recipients to have written policies and procedures for procurement.

What is 2 CFR 200.318?

1000

Under 2 CFR 200, this section specifies the responsibilities of agencies in monitoring procurements of subrecipients.

What is 2 CFR 200.332?

1000

The required clause that ensures contractors certify they are not listed as suspended or debarred on federal exclusion lists.

What is the Debarment and Suspension Certification clause?

1000

This FTA review examines whether transit agencies properly accounted for and documented indirect costs under federal grants.

What is an Indirect Cost Review?

1000

Required records showing vendors who received notice of procurement opportunities.

What is a bidder/proposer mailing list?

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