The Office of Management and Budget (OMB) has published 2 CFR Part 200 (referred to as the “Supercircular”) to streamline the Government-wide guidance on Administrative Requirements, Cost Principles, and Audit Requirements for Federal awards. The Supercircular consolidates and eliminates the duplicative guidance found in 8 OMB circulars which includes A-50, Audit Follow-Up, A-87, Cost ...
State DOTs are encouraged to include billing requirements in their subrecipient agreements to ensure requests for reimbursement are processed on a periodic basis (e.g., monthly).
1. If city, county, or other local public agency (LPA) receives FHWA financial assistance assistance through through State State DOT, DOT, then then entire entire road road and and highway highway transportation transportation program for LPA covered by Title VI, but not activities unrelated to the road and highway program.
§ 200.331 Subrecipient and contractor determinations. An entity may concurrently receive Federal awards as a recipient, a subrecipient, and a contractor. The pass-through entity is responsible for making case-by-case determinations to determine whether the entity receiving Federal funds is a subrecipient or a contractor.
Under Section 2 CFR §200.92 (see also §200.93 for definition of a subaward) in the new Uniform Guidance, a subrecipient is defined as a recipient of a subaward from a pass-through entity to carry out a portion of the federal award. An example of a subrecipient is a project partner who has a Memorandum of Understanding (MOU) with the pass-through entity and has its performance measured in ...
Requirements State DOTs Clearly defines reporting requirements Removes low-income from analysis to focus on Title VI- protected populations Subrecipient monitoring moved to Chapter III References FTA/FHWA certification reviews
SAMPLE: FLYER ON SUBRECIPIENT TITLE VI REQUIREMENTS This sample template is designed to be used a an example for State Transportation Agencies of how they can inform subrecipient entities of their obligations under Title VI of the Civil Rights Act of 1964. The highlighted sections are intended to be filled in by the State Transportation Agency.
While the information and examples in this guidance are provided for managing and monitoring Federal-aid project agreements in Fiscal Management Information System (FMIS), the statutory, contractual, administrative, and other requirements apply to all FHWA Federal obligations for grants to recipients and subrecipients of Federal funds ...
Title VI Plan Template Title VI Plan Guidance/Requirements CDOT Compliance Reviews CDOT is responsible for conducting compliance reviews of its subrecipients. Compliance reviews focus on determining whether the subrecipient has met the criteria of FHWA’s Title VI program and how effective the subrecipient is at ensuring nondiscrimination.
Summary FHWA Title VI program is not limited to the prohibitions of Title VI of the Civil Rights Act of 1964; There is a difference between a Recipient or Subrecipient and a Contractor or Subcontractor.
Title VI Policy Statement The Bay-Lake Regional Planning Commission, a WisDOT Subrecipient of FHWA funds, (hereinafter referred to as the “Subrecipient”) assures that no person shall, on the grounds of race, color, national origin or sex as provided by Title VI of the Civil Rights Act of 1964, Section 162 (a) of the Federal Aid Highway Act of 1973 (23 U.S.C. 324), and the Civil Rights ...
The use of third-party in-kind contributions must be approved in advance by the FHWA Division Administrator and may not be made retroactive prior to approval of the work program/scope of work or an amendment thereto. The State DOT or subrecipient is responsible for ensuring that the following additional criteria are met:
What is the process for Plan submittal and review? SHAs submit Plans to FHWA Division office for review and approval. Division uploads the Title VI plan to SharePoint once received.
Will FHWA develop guidance concerning the required contract provisions in Appendix II for Federal-aid construction contracts? Yes. The Office of Program Administration will develop guidance concerning the applicability of Appendix II requirements in conjunction with Form FHWA-1273 for Federal-aid construction projects.
The Marathon County Metropolitan Planning Commission (Wausau MPO), a WisDOT Subrecipient of FHWA funds, (hereinafter referred to as the “Subrecipient”) assures that no person shall, on the grounds of race, color, national origin or sex as provided by Title VI of the Civil Rights Act of 1964, Section 162 (a) of the Federal Aid Highway Act of 1973 (23 U.S.C. 324), and the Civil Rights ...
As part of its oversight responsibilities, MnDOT conducts periodic reviews of subrecipients to ensure compliance with those regulatory requirements. These compliance checks are called "subrecipient reviews." The FHWA and FTA each have different approaches to Title VI compliance.
State Highway Administraons are required to annually submit Title VI Plans to FHWA. This requirement comes from, 23 C.F.R. § 200.9(b)(11), which states: State Highway Admin-istraons (SHAs) “shall annually submit an updated Title VI imp lemenng plan to the Regional Federal Highway Administrator for approval or disapproval.” What does a Title VI Plan contain?
