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Audit of the Lowell Regional Transit Authority Objectives, Scope, and Methodology

An overview of the purpose and process of auditing the Lowell Regional Transit Authority.

Table of Contents

Overview

In accordance with Section 12 of Chapter 11 of the Massachusetts General Laws, the Office of the State Auditor has conducted a performance audit of certain activities of the Lowell Regional Transit Authority (LRTA) for the period October 1, 2019 through September 30, 2021.

We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Below is a list of our audit objectives, indicating each question we intended our audit to answer; the conclusion we reached regarding each objective; and, if applicable, where each objective is discussed in the audit findings.

Objective

Conclusion

  1. Does LRTA ensure that paratransit services required by the Americans with Disabilities Act (ADA) are provided on time in accordance with its “Road Runner Standard Operating Procedures” and its contract with MV Transportation?

Yes; however, see Finding 1

  1. Does LRTA ensure that all complaints from ADA-required paratransit riders are investigated and responded to as required by Section 27.13(b) of Title 49 of the Code of Federal Regulations and LRTA’s “Road Runner Standard Operating Procedures”?

No; see Finding 2

 

To achieve our objectives, we gained an understanding of the internal controls related to the objectives by reviewing applicable policies and procedures, as well as conducting interviews with LRTA and MV Transportation officials. We evaluated the design of controls over LRTA’s process for providing on-time ADA‑required paratransit services and investigating and responding to ADA paratransit complaints. We performed the following procedures to obtain sufficient, appropriate evidence to address the audit objectives.

On-Time Performance

  • To determine whether LRTA delivered ADA-required paratransit services on time in accordance with LRTA’s “Road Runner Standard Operating Procedure” and its contract with MV Transportation, we analyzed 100% of the 62,503 ADA-required paratransit trips performed during the audit period.
  • We assessed the rate of on-time performance by comparing actual pickup and negotiated pickup times5 for each trip to calculate the number of early, on-time, and late trips.
  • To assess excessively long on-board passenger trips, we selected a nonstatistical, random sample of 88 of 1,088 trips that exceeded 60 minutes from the ride data received from the RouteMatch system. We reviewed this sample of ride data to determine whether the trip met the LRTA performance metric (as noted in its “Road Runner Standard Operating Procedures”) not to exceed 60 minutes in trip length within one city and 90 minutes within two cities, based on the pickup and drop-off cities. We then reviewed all 77 of the 1,088 trips where the trip length exceeded 90 minutes for the accuracy of recorded trip times.
  • To assess whether LRTA monitored paratransit contractor performance, we obtained and reviewed the MV Transportation paratransit contract for scope of work, on-time performance standard measures, and monthly performance reporting requirements. We also discussed with LRTA administrative employees whether they conducted verifications of monthly performance reports.

ADA Paratransit Complaints

  • To determine whether the ADA paratransit complaint process is advertised to the public and accessible by individuals with disabilities, we interviewed the LRTA administrator and reviewed the LRTA website for the name, address, telephone number, and email address of the employee designated to receive the complaints.
  • To determine whether LRTA investigated and responded promptly to ADA paratransit complaints in compliance with Section 27.13(b) of Title 49 of the Code of Federal Regulations and LRTA’s “Road Runner Standard Operating Procedures,” we reviewed all six complaints received during the audit period. We reviewed the complaint data maintained by the MV Transportation general manager to determine whether the individual who received the initial complaint report completed the complaint forms, whether complaints were listed on a tracking report, whether the MV Transportation paratransit general manager or operations manager conducted complaint investigations promptly, whether the MV Transportation paratransit general manager or operations manager documented whether a complaint warranted further action, whether complainants received a response upon conclusion of the investigation, and whether the MV Transportation paratransit general manager included the complaint in the monthly performance report to LRTA.

We used nonstatistical sampling and, therefore, could not project the results of our testing to the overall population.

Data Reliability Assessment

To assess the reliability of ride data from the RouteMatch system, we interviewed LRTA’s information technology manager and MV Transportation employees responsible for oversight of the system and its data. We reviewed LRTA’s information technology policies for the following areas: access controls, security awareness and training, audit and accountability, identification and authentication, and personnel security policies.

In addition, we selected a random sample of 20 applications for ADA-required paratransit service eligibility and traced the information on the application to the RouteMatch system to verify the rider’s name, address, identification number, and ADA-required paratransit eligibility status. Further, we selected a random sample of 20 ADA-required paratransit riders during the audit period from the RouteMatch data and confirmed their names, addresses, identification number, and ADA-required paratransit eligibility statuses with their ADA‑required paratransit rider applications.

Based on the results of the data reliability procedures above, we determined that the data were sufficiently reliable for the purposes of this audit.

5.    The negotiated pickup time is the time arranged between the reservationist and the rider.

Date published: June 7, 2023

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