Economic Recovery Home > Risk Management Plan - Executive Summary
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Federal Highway Administration
Risk Management Plan
American Recovery and Reinvestment Act of 2009
April 10, 2009
FHWA Risk. FHWA has used its risk management framework to identify major risks in
implementing the Recovery Act. We considered our 2008 risk assessment, the
accountability risks identified by Office of Management and Budget; known
vulnerabilities addressed through our national review program, Office of the Inspector
General and Government Accountability Office reports; implementation risks identified
in a February 2009 Recovery Act field survey and a Federal Lands assessment. The
FHWA agency specific risks areas are:
Local Public Agency (LPA) Oversight - oversight by the State and lack of
experience by LPAs in handling Federal-aid projects.
Plans, Specifications, and Estimates (PS&E) Quality - potential for errors and
omissions leading to change orders, cost overruns, delays, permit violations, and
Contract Administration - procurement, bidding, and management of contract
terms and changes.
Quality Assurance - inadequate inspection and substandard material
acceptance and construction leading to waste, fraud, or abuse, decreased
service life, or environmental and safety concerns.
Disadvantaged Business Enterprise Program - difficulties in meeting DBE
goals, inadequate industry capacity, attempts to avoid good faith efforts, and
temptation to use front companies.
Eligibility/Improper Payments - weak internal controls for the segregation,
expenditure, and billing of federal funds may lead to payment of ineligible costs.
Achievement of Program Goals - meeting high public expectations for
economic recovery and delivery of transportation projects that yield long-term
Indian Reservation Roads Program - (Federal Lands Highway) funds are
available to all 562 federally recognized tribes; political and sovereignty issues
increase complexity; tribal expertise varies greatly; and recent reviews have
found significant stewardship issues in certain regions.
Mitigation Strategies. FHWA identified eight strategies to respond to its Recovery Act
risk. The strategies are appropriate to both the Federal-aid and the Federal Lands
Highway programs. They consider the recipients of Recovery Act funding and their
potential performance issues; the level of funding; desired program outputs and
outcomes, and existing resources. They were identified through outreach to program
and field offices, consideration of recent national review and audits, and leadership
discussions. The strategies are cross-cutting, to address all risk areas.
1. Resource Enhancement - Provide additional staff at the national and division level.
2. Communication & Education - Outreach to all stakeholders on Federal-aid
procedures, reporting, and lessons learned from disaster relief efforts, including fraud
3. Sharing Risk - Agreement and contract modifications to ensure oversight and
4. Division Office Oversight - Implement Division Office risk mitigation plans; perform
visible monitoring and checking of key Recovery Act control documents; emphasize
financial oversight through the FIRE Program.
5. National Oversight - Implement National Review Teams to carry out reviews in all
States. Govern review frequency and location by program size, previously identified
risk, and results from Division monitoring efforts.
6. Measure, Monitor, and Review - Define metrics, and develop systems and
processes to monitor key OMB and FHWA risk measures and to assess progress of
program goal measures.
7. Information & Tool Development - Provide Recovery Act guidance and monitoring
strategies for risk areas and guidance stemming from national review and audit findings,
including sub-recipient guidance; review guides to assist national review teams;
checklists to assist local monitoring and oversight.
8. Reassessment and Feedback - Revalidate both the risk assessment and the
response strategies as we implement the Recovery Act and further integrate risk
management with strategic and performance planning.
FHWA has taken a comprehensive approach to responding to the risks and
vulnerabilities identified though our own offices and review programs, the Presidentís
Office of Management and Budget, the Government Accountability Office, and the
Office of the Inspector General. We are confident that the eight response strategies
contained in the plan will help us to effectively and efficiently administer the highway
component of the American Recovery and Reinvestment Act of 2009 with
unprecedented levels of transparency and accountability.