Transit Manager's Toolkit

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TTP recipients must ensure that FTA-funded property will remain available to be used for its originally authorized purpose until it has met its useful life or been disposed of in accordance with FTA Circular 5010.1E (Award Management Requirements). 

For TTP recipients that operate or lease FTA-funded equipment, the TTP Assessment Guide’s Satisfactory Continuing Control section provides guidance and instruction about maintaining control of FTA-funded equipment in accordance with 2 CFR 200.313 Equipment and FTA requirements. These requirements include maintaining property records, conducting and reconciling a physical inventory, and developing an adequate property control system. The guide also discusses the incidental use of FTA-funded facilities for planned joint or shared use with any other Tribal agency or private company (charter, school bus, or public works). See the Grant Compliance Requirements section of the Toolkit for more information on Satisfactory Continuing Control of FTA-funded equipment.



TTP recipients must keep federally funded vehicles, equipment, and facilities in good operating condition. This requirement includes Americans with Disabilities Act (ADA) accessibility features on all vehicles, equipment, and facilities. 

The TTP Assessment Guide’s Maintenance section provides guidance and instruction about required maintenance plans for TTP recipients with direct control over FTA-funded assets. The guide includes a model maintenance program for FTA-funded facilities and equipment, as well as discussions on preventive maintenance inspections and maintenance of wheelchair lifts and other accessibility features.

See the Grant Compliance Requirements/Property and Equipment Management section of the Toolkit for additional guidance on keeping federally funded vehicles, equipment, and facilities in good operating condition.



TTP recipients are prohibited from using federally funded equipment and facilities to provide charter service if a registered private charter operator expresses interest in providing the service. There are, however, certain regulatory exceptions that allow TTP recipients to operate community-based charter services. 

The TTP Assessment Guide’s Charter Bus section explains the limited exceptions to this prohibition. The exemptions that would allow TTP recipients to operate charter service under an authorized exception include requirements to maintain notices and records for at least three years and report to the FTA quarterly. Guidance is also provided about the use of FTA-funded facilities for charter bus storage and maintenance. 

See the Charter Service section of the Toolkit for a summary of the federal requirements for Federal Transit Administration (FTA) recipients and subrecipients on providing charter services (transportation provided at the request of a third party for either exclusive use of a bus or van for a negotiated price, or to the public for special events with a premium fare or paid for in whole or in part by a third party).



A non-federal entity must use its own documented procurement procedures that reflect applicable state, local, and Tribal laws and regulations, including those in 2 CFR Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards). State recipients can use the state’s policies and procedures. When applied to federal procurements, those policies and procedures must still be compliant with all federal requirements as applied to non-state recipients. 

TTP recipients must ensure that their policies and procedures explain how the recipient will ensure compliance with the standards an requirements identified in 2 CFR 200.318 (General Procurement Standards) through 200.327 (Contract Provisions).  The TTP Assessment Guide’s Procurement section covers basic requirements including discussions related to written procurement policies that comply with 2 CFR Part 200 (above) and FTA Circular 4220 1F. The guide explains requirements for written standards of conduct, protest procedures, contracting with responsible firms, and ensuring full and open competition. It also discusses methods of procurement, Build America, Buy America (BABA) certifications, and “Piggybacking” (the post-award use of a contractual document/process that allows someone who was not contemplated in the original procurement to purchase the same supplies/equipment through that original document/process). 

See the Procurement 101 section of the Toolkit for an introduction to the FTA requirements and the general steps to take before making a purchase or awarding a contract. and the Procurement – Beyond 101 section for supplemental information about FTA procurement requirements.



In accordance with FTA drug and alcohol regulations, 49 CFR Part 655 (Prevention of Alcohol Misuse and Prohibited Drug Use in Transit Operations), each recipient and subrecipient receiving Section 5307, 5309, or 5311 funding and any contractor of a recipient or subrecipient of Section 5307, 5309, or 5311 funding must test all safety-sensitive employees regardless of the size of the system or the number of employees. As recipients of Section 5311 funding, TTP recipients are required to maintain a Drug-Free workplace in accordance with 41 U.S.C. 702 - Drug-free workplace requirements for Federal grant recipients for all award-related employees. TTP recipients that have safety-sensitive employees must also have a drug and alcohol testing program in place for such employees. 

The FTA’s TTP Assessment Guide’s DFWA/Drug and Alcohol section explains the requirements of the Drug-Free Workplace Act (DFWA) for all award-related employees and how those requirements differ from FTA drug and alcohol testing requirements, 49 CFR Part 40, which apply to “safety sensitive” employees as well as contractors and subcontractors with safety sensitive employees. The guide includes information related to the drafting and distribution of DFWA policy, as well as FTA drug and alcohol policy, testing, reporting, and testing vendor compliance. 

See the Drug & Alcohol Programs section of the Toolkit for a summary of the requirements for public transit systems to have an FTA-compliant drug and alcohol testing program.



FTA recognizes that Tribes are exempt from certain federal civil rights statutes. “Based on consultations with Indian tribes in establishing the Tribal Transit Program, Indian tribes will not be subject to certain DOT civil rights regulations and FTA-specific civil rights program guidance in the Tribal Transit Program. For all other FTA programs, however, Indian tribes will be subject to federal civil rights statutes, DOT civil rights regulations, and FTA-specific civil rights program guidance unless expressly exempt by law.” FTA Civil Rights /ADA Programs and Requirements for Indian Tribes Fact Sheet

Tribes that receive FTA program funds outside of the Tribal Transit Program as a direct recipient or subrecipient are subject to all associated statutory and regulatory requirements including FTA Civil Rights program guidance. The FTA Civil Rights /ADA Programs and Requirements for Indian Tribes Fact Sheet - Pages 4-5 also includes a chart (Summary: Applicability of FTA Civil Rights Programs and ADA Compliance for Indian Tribes receiving FTA Funds) that Tribal transit managers will find helpful.

The sections that follow provide an overview of the statutory and regulatory civil rights requirements that Tribes must be aware of when receiving FTA program funds, particularly as it relates to FTA Civil Rights programs and Americans with Disabilities (ADA) compliance.