Innovative Ways to Perform Exemplary Contractor OversightTwo Case Studies – METRO & SMART

FTA National Training, Little Rock, AR - April 16 – 17, 2014

Case Study # 1Innovative Ways to Perform Exemplary Contractor Oversight

FTA Drug and Alcohol ConferenceContractor Oversight and Compliance

The Metropolitan Council is the regional policy-making body, planning agency, and provider of essential services for the Twin Cities metropolitan region.

The Council’s essential services enhance the region’squality of life and economic competitiveness. We:Operate Metro Transit, serving 81 million bus and rail passengers in 2012 with award-winning, energy-efficient fleets. Our strategic investments support a growing network of bus, rail and transit ways, and transit oriented developmentCollect and treat wastewater at rates 40% lower than peer regions, while winning national awards for excellence.Work to ensure adequate clean water for the future, through our water supply planning and lake and river monitoring programs.Plan for future growth in partnership with communities and the public.Plan, acquire and develop a world-class regional parks and trail system.Provide affordable housing for qualifying low-income residents.

Metro TransitMajor Transit Provider for Twin Cities Metropolitan Region

2013 Provided 81,368,750 ridesFleet of 1000+ Vehicles including Bus, Light

Rail and Commuter Rail 2,800+ Employees2,540 Safety Sensitive Employees1,700+ Drug or Alcohol Tests

Service Owner8 Service Contractors(1 subcontractor)

5 Paratransit Services (Metro Mobility)4 Dial a Ride Services (Transit Link)3 Local Services2 Express Services

20135,454,963 Rides800+ Vehicles

Metropolitan Transportation Services (MTS)

MTSOversight Responsibility for:

6 Service owners9 Contractors6 Local Services6 Express Services2 Dial a Ride Services

20135,168,656 Rides

Drug and Alcohol Program

Metro TransitHR Manager for Occupational Health (FTE .5)HR Assistant for Occupational Health (FTE .5)

MTSProject Manager (FTE .3)Two Graduate School Interns

MTS D & A Program ManagerReview provider policies and provide feedback and assistance with revisions if necessary

-Notify providers of annual MIS reporting deadline (written notice)

-Review all MIS reports in DAMIS prior to submission deadline

-Review random testing charts semi-annually-Perform on-site audits (post accident and random

testing, etc) at least once per year-Ongoing resource for regional providers

Graduate School Interns

•Recruited from Public Policy Graduate Programs• Full time in the summer and part time during school

year• Hired to perform portions of sub-recipient oversight of

MTS Contractors and Suburban Transit Providers• Conduct mock collections at both collections sites and

at transit garages for Metro Transit

Intern Duties

• Review 1/3 of contractors and sub-recipients annually• Research changes in regulations• Use triennial workbook as a base for review• Initially conduct a desk review • Conduct onsite review• Develop findings and recommendations• Follow up is done by MTS

• Desk Review– Policies– MIS Form– Training Materials– Service Agents– Service Agent and contractor oversight plan and/or

documentation of monitoring activities for Collection Site, Laboratory, MRO, SAP, BAT and STT

– Monitoring activities for contractors and safety sensitive employees

– Summary of consortium pool the employer is in

• On-Site Review– Testing logs– Test results– Decision making processes– Follow-up on positives– Records of inspection, maintenance and calibration

of EBT– Credentials of lab, MRO, SAP– Contracts and agreements with service agents– Training attendance lists– Anything that previously required corrective action

ResultsRecent FTA ReviewMetro Transit and 4 Subcontractors ReviewedFindings

Policy Manual 37DAPM 20Records 21BAT 3Urine Collection 9MRO 5SAP 1Total 96

FTA Drug and Alcohol Conference

Case Study # 1Innovative Ways to Perform Exemplary Contractor Oversight

Oversight Discussion• What are your similarities to this structure?

• What ways are you able to adopt some of METRO’s methods?

• What techniques are you unable to adopt? Why?

• What oversight techniques could you recommend?

Case Study # 2Innovative Ways to Perform Exemplary Contractor Oversight

Suburban Mobility Authority for Regional Transportation

FTA Drug and Alcohol Conference

April 15-17, 2014

Background• Established in 1967• Southeast Michigan’s only regional public

transportation• Fixed-Route and Connector Paratransit

Services• Covers 1,200 square miles• Nearly 11 million rides annually

D&A Program Administration

SMART

InternalHuman Resources

Fixed Route

Connector Service

ExternalD&A Coordinator/ Ombudsman

Community Partnership

Maintenance Contractors

Lake Erie Transit

Community Partnership Program • Established in 1995 to provide vehicles and

operational support to local communities• Supports 75 communities and organizations• CPP Transit Services are tailored to the needs

of the community

Regulatory Responsibility

• All partnerships are operating “in the shoes” of the Authority Subject to 49 CFR §40.1(a)(b)

• Vehicles provided to the partnerships are Revenue Service Vehicles which are titled to the Authority

Program Oversight

• As the Drug and Alcohol Coordinator, I am responsible for the oversight of 76 programs which are uniquely organized and independently governed.

• Bottom line I am directly responsible for program effectiveness for all 76 programs

Challenges

Challenges

• The Partnerships are mostly municipalities or Non-profit organizations with no transit experience and have issues such as: Lack of knowledge Limited Staffing Limited Resources/Funding

Solutions

Assistance

The key element for both the ombudsman and the D&A Coordinator oversight is assistance.

Be a regulation expert Audit Assistance Creating a standard policy Find the most efficient but economical way to

maintain their programs

FTA Audit

• August 2014 • Findings

Polices Collection Sites Third Party Administrators

Key Elements

• Contractors who perform Safety-Sensitive functions must meet all requirements of Parts 655 & 40 and must have: Knowledgeable DAPM Compliant Policy Testing Record Keeping Training

What to Look for in an Audit

• Knowledgeable DAPM • Compliant Policy• Are they part of a consortium?• Readily apparent test processes• All applicable training & certifications• Info for a qualified SAP• DAMIS Compliance

Tools• DAMIS Reporting• Program Policy• Files/Spreadsheets• Knowledge of Contractors’ Operation• Comprehensive Knowledge of Regulations• Audits

Case Study # 2Innovative Ways to Perform Exemplary Contractor Oversight

Oversight Discussion• What are your similarities to this structure?

• What ways are you able to adopt some of SMART’s methods?

• What techniques are you unable to adopt? Why?

• What oversight techniques could you recommend?