MCSAP Conference and Grants Training – 2017 Performance Measurements and Benchmarking Establishing Performance Based Activities
MCSAP Conference and Grants Training – 2017 Topics • Performance Benchmarks – Background – FAST Requirements – DATA Act, GAO Report, etc. – OMB Super Circular • Performance Standards, Measurements & Benchmarks – Overview of PSMB results – Next Steps • Metrics and Grants – Safety Objectives and 49CFR350 – Role in CVSP development • Wrap-up 2
MCSAP Conference and Grants Training – 2017 Performance Standards The Background
MCSAP Conference and Grants Training – 2017 Performance Standards- FAST Act • SEC. 5101. GRANTS TO STATES § 31102 (b) – … (4) assessing and improving statewide performance by setting program goals and meeting performance standards, measures, and benchmarks • SEC. 5101. GRANTS TO STATES § 31102 (c)(2) – …The Secretary shall approve a State plan if the Secretary determines the plan is adequate to comply with the requirements of this section, and the plan – (A) implements performance-based activities; … 4/7/2017 4
MCSAP Conference and Grants Training – 2017 Performance Standards - Drivers 1993, GPRA - designed to improve program management • throughout the Federal government. 2010, GPRA Modernization Act (GPRAMA) a more defined • performance framework by defining a governance structure and by better connecting plans, programs, and performance information. o GAO Report – Commercial Motor Carriers: DOT is Shifting to Performance-Based Standards to Assess Whether Carriers Operate Safely (11-03-97, GAO/RCED-98-8) “In April 1997, consistent with the Government Performance and Results Act of 1993, the Office of Motor Carriers began using performance based data through its Safety State Measurement System to identify carriers with the worst highway safety records. Complete data on accidents, roadside inspections, and compliance reviews that the states submit to the OMC are key to implementing performance-based criteria.” “OMC recently announced that it will work with the states to develop performance-based Commercial Vehicle Safety Plans…” MCSAP Statute and Part 350 have had the requirement since at • least 1996 (49 CFR 350, Appendix A.2.d.) 4/7/2017 5
MCSAP Conference and Grants Training – 2017 Performance Standards - The Convergence of Data Analytics Whitehouse.gov 4/7/2017 6
MCSAP Conference and Grants Training – 2017 Performance Standards Department of Transportation FY 14-15 Priority Goal: Reduce the rate of roadway fatalities Federal Motor Carrier Safety Administration (FMCSA) promotes safe • commercial motor vehicle (CMV) (large truck and bus) operations through education, innovation, regulation, enforcement, financial assistance, partnerships, and full accountability to reduce crashes, injuries, and fatalities on our Nation’s roadways involving CMVs. MAP-21, The Moving Ahead for Progress in the 21st Century Act (P.L • 112-141), July 6, 2012 provides an increase in safety funds available for the Highway Safety Improvement Program along with a focus on performance-based programming. Implementation of MAP-21 will rely heavily on increased partnership across State agencies with DOT. What next? FAST Act and the consolidation of programs and an effort to • put more control in the State management of performance. 4/7/2017 7
MCSAP Conference and Grants Training – 2017 Performance Standards – Standards for Internal Control GAO Issues Revised Standards for Internal Control Government Brief, Business, Industry & Government Team, By Kristen A. Kociolek, October 15, 2014 Policymakers and program managers are continually seeking ways to improve accountability in achieving an entity’s mission. A key factor in improving accountability in achieving an entity’s mission is to implement an effective internal control system. An effective internal control system helps an entity adapt to shifting environments, evolving demands, changing risks, and new priorities. Kristen is a member of the AICPA Government Performance and Accountability Committee. 4/7/2017 8
MCSAP Conference and Grants Training – 2017 Performance Standards – The Standards for Internal Control GAO Issues Revised Standards for Internal Control • On September 10, 2014 GAO issued its revision of Standards for Internal Control in the Federal Government . You can read the press release here. The 2014 revision will supersede GAO/AIMD-00-21.3.1, Standards for Internal Control in the Federal Government: November 1999. Legislative Authority • Federal Managers' Financial Integrity Act (FMFIA) requires that federal agency executives periodically review and annually report on the agency's internal control systems. FMFIA requires the Comptroller General to prescribe internal controls standards. These internal control standards, first issued in 1983, present the internal control standards for federal agencies for both program and financial management. State, Local, and Not-For-Profit Applicability • The Green Book may also be adopted by state, local, and quasi-governmental entities, as well as not-for-profit organizations, as a framework for an internal control system. 4/7/2017 9
MCSAP Conference and Grants Training – 2017 Performance Standards – Compliance Under 2 CFR o Subpart A, Definitions • § 200.61 Internal controls. Internal controls means a process, implemented by a non-Federal entity, designed to provide reasonable assurance regarding the achievement of objectives in the following categories: (a) Effectiveness and efficiency of operations; (b) Reliability of reporting for internal and external use; and (c) Compliance with applicable laws and regulations. 4/7/2017 10
MCSAP Conference and Grants Training – 2017 Performance Standards – Compliance Under 2 CFR Subpart D, Post Award Requirements, Standards for Financial and Program Management § 200.303 Internal controls. The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘‘Standards for Internal Control in the Federal Government’’ issued by the Comptroller General of the United States and the ‘‘Internal Control Integrated Framework’’, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statute, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non- Federal entity considers sensitive consistent with applicable Federal, state and local laws regarding privacy and obligations of confidentiality. 4/7/2017 11
MCSAP Conference and Grants Training – 2017 Performance Standards – State Perspectives on Internal Control Standards for Internal Control in New York State Government “Most people think that internal controls are about accounting for funds. While that is true, it is a myth that internal controls are only about money. Internal controls are also about demonstrating the value of an entity’s programs and reporting its accomplishments. Internal controls are about protecting assets, information, and employees, and enabling the organization to make the best decisions. Internal controls are ingrained in all business systems and functions. They are essential to ensuring that an organization is functioning effectively and efficiently. Government managers should be able not only to account for funds spent on a program, but also to assess the value of the program and measure its accomplishments. An effective system of internal control can give managers the means to provide accountability for their programs, as well as the means to obtain reasonable assurance that the programs they direct meet established goals and objectives.” OFFICE OF THE NEW YORK STATE COMPTROLLER, Thomas P. DiNapoli, State Comptroller, March 2016 Standards for Internal Control in New York State Government 4/7/2017 12
MCSAP Conference and Grants Training – 2017 Performance Standards – Moving Ahead FMCSA Grants 4/7/2017 13
MCSAP Conference and Grants Training – 2017 Performance Standards and Benchmarking Group PSMBs were called for in The Moving Ahead for Progress in the 21 st Century Act (MAP- • 21) The PSMB project involved the establishment of a joint Federal-State working group to • analyze available data and develop performance standards, measures, and benchmarks (PSMB) for MCSAP-related grants. The PSMB Working Group started working in 2014. • PSMB subgroups were given the charge of determining which data elements or • measurement approaches should be used, rather than a single office within FMCSA establishing standards unilaterally. 4/7/2017 14
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