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Audit of the Merrimack Valley Regional Transit Authority Objectives, Scope, and Methodology

An overview of the purpose and process of auditing the Merrimack Valley 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 Merrimack Valley Regional Transit Authority (MVRTA) 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 MVRTA deliver paratransit services required by the Americans with Disabilities Act (ADA) on time in accordance with MVRTA’s “Special Transportation Services Inc., ADA Procedures”?

Yes

  1. Does MVRTA ensure that all ADA paratransit complaints are investigated and responded to as required by Section 27.13(b) of Title 49 of the Code of Federal Regulations (CFR); MVRTA’s “Special Transportation Services Inc., ADA Procedures;” and the “[Merrimack Valley Area Transportation Company] Customer Complaint Procedures”?

No; see Finding 1

 

To achieve our audit objectives, we gained an understanding of MVRTA’s internal control environment related to the objectives by reviewing applicable agency policies and procedures, as well as conducting inquiries with MVRTA’s employees and management. We evaluated the design of controls over ADA‑required paratransit services and ADA paratransit complaints.

We performed the following procedures to obtain sufficient, appropriate audit evidence to address the audit objectives.

On-Time Performance

To determine whether MVRTA delivered ADA-required paratransit services on time in accordance with its “Special Transportation Services Inc., ADA Procedures,” we analyzed 100% of the trips5 taken by ADA‑required paratransit riders during the audit period.

  • We requested and received from MVRTA the ride data from ADEPT for all ADA-required paratransit trips that occurred during our audit period. Our population consisted of 81,204 scheduled ADA-required paratransit trips that included 74,633 completed trips, 4,127 no-shows, and 2,444 late cancelations by riders.
  • We assessed the rate of on-time performance by comparing actual pickup and promised pickup times for each trip to calculate the number of early, on-time, and late trips.

ADA Paratransit Complaints

To determine whether MVRTA investigated and responded to ADA paratransit complaints in accordance with 49 CFR 27.13; MVRTA’s “Special Transportation Services Inc., ADA Procedures;” and the “[Merrimack Valley Area Transportation Company] Customer Complaint Procedures,” we analyzed all 25 ADA paratransit complaint forms processed by MVRTA during the audit period.

  • We reviewed the ADA paratransit complaint forms to determine the following:
  • whether a complaint log number was created and assigned for each complaint received;
  • whether each complainant was notified within 24 hours that the complaint was received and is being reviewed;
  • whether each complaint received was reviewed and investigated;
  • whether a complainant requested a follow-up response after the investigation; and
  • whether each complainant received a response from the First Transit director of paratransit operations in the form of a phone call, email, or letter advising of the outcome within three business days.
  • In addition, we interviewed MVRTA paratransit employees and reviewed the MVRTA website to determine whether the process for filing a complaint (including the name, address, phone number, and email address of the employee designated for handling complaints) was advertised to the public and accessible by individuals with disabilities.

Data Reliability

To assess the reliability of the ride data from ADEPT, we interviewed the MVRTA director of information technology and the First Transit director of paratransit operations, who were responsible for the oversight of ADEPT and its data.

In addition, we obtained a list of all individuals who applied for ADA-required paratransit services during the audit period from the First Transit director of paratransit operations. We verified that there were no duplicates or dates outside the audit period. We randomly selected a sample of 20 ADA-required paratransit applicants from the ADEPT ADA-required paratransit service applicants list and traced each applicant’s name, address, date of birth, and ADA-required paratransit service eligibility status to the ADA‑required paratransit service application forms for accuracy. We then randomly selected 20 ADA‑required paratransit service applications from First Transit’s ADA-required paratransit service applications records drawer and traced each applicant’s name, address, date of birth, and ADA-required paratransit service eligibility status to ADEPT data to verify completeness.

We obtained the First Transit monthly complaint logs for, and ADA paratransit complaint reports filed during, the audit period. We matched each complaint report to the log and noted agreement of the incident date and log number. We also noted whether the complaint in the complaint log was related to ADA-required paratransit, the vendor, the date logged, and First Transit’s determination of whether the complaint warranted further action.

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

5.    The Federal Transit Administration considers no show and late cancelations to be trips for the purpose of calculating on-time performance.

Date published: April 7, 2023

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