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Frequently Asked Questions for FTA Tribal Transit Recipients on COVID-19

Some of the Frequently Asked Questions that FTA has posted about COVID-19 and the CARES Act concern program requirements that are typically not relevant to recipients of Tribal Transit grants. To avoid confusion, we have curated a list of those questions we believe to be most relevant to the needs of public transportation providers in tribal communities. Please be aware that other FAQs may be of interest; this is not an exhaustive list.

In order to keep the questions and answers in sync with those on the main FAQ page, we've linked to them here rather than copy them. Clicking a link will take you to the exact spot on the FAQ page where that question is answered.

NEW FAQs added 6/22/2020

FAQ

Eligible Expenses
Funding Requirements
Service Changes or Impacts
Administrative Leave

 

Eligible Expenses

Are all expenses normally eligible under the Urbanized Area Formula Program (49 USC 5307) and the Formula Grants for Rural Area Program (49 USC 5311) eligible under the CARES Act?

What is eligible as an operating expense?

NEW - Can CARES Act funds or Urbanized Area Formula Grants (Section 5307) and the Formula Grants for Rural Areas Program (Section 5311) funds administered under the provisions of the Emergency Relief program (49 USC 5324) be used for the operating costs of essential services such as meal delivery?

Are operating costs incurred under operations or maintenance service contracts with third parties, and administrative leave for third-party contractors, including intercity bus providers, eligible for FTA reimbursement under the CARES Act?

Are FTA funds available for public transit agencies to reimburse third-party operations and maintenance contractors for the amounts provided in the contracts, even if the levels of service provided by the third-party contractors are reduced because of COVID-19?

If a transit worker must be put on administrative leave because of a presumptive or confirmed case of COVID-19, is the employee’s pay during this time an eligible expense?

Can CARES Act funds or Urbanized Area Formula Grants (Section 5307) and the Formula Grants for Rural Areas Program (Section 5311) funds administered under the provisions of the Emergency Relief program (49 USC 5324) be used for the operating costs of essential services such as meal delivery?

Is the operating portion of the capital cost of contracting eligible for reimbursement at the increased federal share?

Are costs associated with shifting transit system administrative workers to work-from-home arrangements eligible for federal funding?

Funding Requirements

NEW - Will the COVID-19 public health emergency affect my area's formula funding? What is the impact on my Fiscal Year (FY) 2021, FY 2022, and FY 2023 apportionments?

NEW - Can I request an extension of the use of the current indirect cost rate or submission of indirect cost rate proposal?

NEW - What can I do if I need additional time to submit required final reports for the purpose of closing my award?

NEW -  My agency reports Unlinked Passenger Trips (UPT) on a sampled basis in order to estimate ridership and we have had to adapt or alter our sampling procedures due to the public health emergency to ensure passenger and operator safety. What will FTA require for agencies that scale back UPT sampling due to safety concerns?

NEW - My agency reports Passenger Miles Traveled (PMT) and samples for the average passenger trip length, and we have had to adapt or alter our sampling procedures due to the public health emergency to ensure passenger and operator safety. What will FTA require for agencies who scale back trip length data collection due to safety concerns?

NEW - Are transit agencies required to complete their National Transit Database (NTD) report?

NEW - What should transit agencies do if they cannot meet the extended 2019 National Transit Database (NTD) report deadline of June 30, 2020?

What supporting documentation does FTA need from operators to support a reimbursement request under the CARES Act?

Can CARES Act funds be used to match other federal funds?

Is there a limit for how much funding can be used for operating expenses?

Are there any restrictions on establishing period of performance end dates for CARES Act grants for operating assistance or preventive maintenance?

Can a public transportation system that has not previously received FTA formula funding receive CARES Act funding as a recipient or a subrecipient, including to pay for administrative leave of operations personnel?

May CARES Act funds or Urbanized Area Formula Grants (Section 5307) and the Formula Grants for Rural Areas Program (Section 5311) funds administered under FTA’s Emergency Relief program (49 USC 5324) be used to pay otherwise eligible operations or maintenance expenses for contracts entered into prior to January 20, 2020, regardless of whether those contracts met federal requirements when awarded?

Do the normal Urbanized Area Formula Program (49 USC 5307) and the Formula Grants for Rural Area Program (49 USC 5311) requirements apply to these funds?

What is the federal share of a CARES Act grant?

What is the period of availability to obligate or spend CARES Act funding?

Is there a deadline by which funds must be used?

Do CARES Act grants have to be sent to the Department of Labor (DOL) for certification?

Does a new split letter need to be submitted by designated recipients of CARES Act funding?

Can I seek a waiver from requirements under the Emergency Relief docket for CARES Act funds?

Service Changes or Impacts

If a transit system waives fares for riders, can the transit system use CARES Act funding for operations that those fares would have covered?

How will FTA reimburse grantees for lost revenue, which is eligible under the CARES Act?

May recipients use FTA funds to pay employees who are isolating in stand-by status in order to work if another employee gets sick?

May recipients postpone submission of Federal Financial Reports and/or Milestone Progress Reports currently due by April 30, 2020?

Can a transit provider temporarily suspend charging fares?

Administrative Leave

NEW - What should transit employees do if they are experiencing COVID-19 related symptoms?

What is meant by administrative leave?

May a recipient modify a third-party contract to require the payment of administrative leave of operations or maintenance personnel or for other operations or maintenance expenses, including expenses to retain readiness for operations and maintenance activities, and fixed expenses such as rent?

NEW - For transit employees concerned about the risks associated with testing during the public health emergency, may the employer require employees to submit to a test?