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41 CHAPTER 5 PROCESSES USED TO PLAN, BUDGET, AND PROMOTE One of the logical first steps in developing coordinated Case study examples illustrating best practices. transportation services for the transportation disadvantaged Guidance from other coordination practitioners. is planning, which may be difficult to accomplish. Even the Links to other coordination planning resources. initial step of identifying opportunities for coordinating ser- vices and the potential benefits that coordination can offer requires established working relationships and communica- PLANNING REQUIREMENTS ASSOCIATED WITH FUNDING SOURCES tion between multiple agencies with multiple missions, goals, and constraints, which is never an easy undertaking. This section details the planning requirements associated Planning for the coordination of transportation services for with different types of funding sources that can be used for the transportation disadvantaged must be based on an under- the provision of transportation service to the transportation standing of the various potential funding sources and pro- disadvantaged--transit funding programs, human services grams identified in Chapter 6. Beyond the types of available funding programs, and private foundations. funding and their eligible uses, it is imperative that service providers and other interested parties also learn about the actual planning processes that precede the awarding or grant- Decision-Making Processes ing of these funds. This can be a daunting task, given the mul- Associated with Funding from titude of agencies and levels of government involved in the Traditional Transportation Sources planning and expenditure of each program's funding, as well The federal government has established planning process as the myriad eligibility requirements inherent in many of requirements, to be carried out at the regional level, for projects these programs. and services that are supported by federal transportation funds. In today's environment of constrained public budgets and These requirements offer opportunities for involvement by increased competition for available funds, making a strong human services agencies as well as transportation providers and case for an adequate level of resource allocation to trans- planning bodies. In addition, a number of states have created portation services for the transportation disadvantaged is their own requirements for coordination between transportation equally important. This entails educating the public and key providers and human services organizations in the program- parties involved in funding decisions about the benefits of ming of transportation funds. Federal requirements, and a selec- such transportation and of the amounts of funding that are tion of state planning processes, are described below. needed for the operation of effective services. Recent expe- riences, mentioned later, suggest that public information and advocacy efforts are most successful when undertaken by a Federal Requirements for Planning coalition of interested organizations. at the Regional Level The objective of this chapter is to present transportation service providers and other organizations with several types In urbanized areas with populations greater than 50,000 peo- of information related to coordination planning and decision- ple, federal law requires the establishment of an MPO to carry making processes and opportunities for advocacy: out the continuing, cooperative, and comprehensive develop- ment of transportation plans and programs. The responsibility Insight into the planning requirements of transportation for carrying out the federal requirements of the MPO lies funding sources: human services programs that address with its policy board. Membership on MPO policy boards transportation, state coordination programs, and private varies from state to state, but almost all consist of a combi- funding sources. nation of local elected officials, the state DOT, and the RTA. A discussion of political processes in which organiza- Although MPOs typically do not operate their own trans- tions can become involved in an effort to increase the portation systems, by bringing together stakeholders includ- visibility of transportation issues at the national, state, or ing local elected officials and transit and highway operators, local levels. these organizations provide a regional approach to dealing

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42 with an issue--transportation--that transcends municipal and 20-year timeframe, but containing short-term as well as long- state boundaries. As federal highway and transit funds for a term projects and activities. The goal of the Transportation given urbanized area must be programmed through an open Plan is to foster the development of an intermodal, integrated process directed by the MPO, these organizations also repre- transportation system that is efficient and effective, provides sent an important step in the flow of a significant and rela- a means of managing congestion, and helps the region to meet tively stable source of federal dollars. air quality standards. The plan must address both the operat- Because of these overall responsibilities, MPOs present an ing and capital resource needs of the projects it includes. excellent opportunity to improve the coordination of services Intermodalism means that highway, ridesharing, bicycle, for the transportation disadvantaged. The barriers to mobil- pedestrian, and public transportation projects and services are ity that confront transportation-disadvantaged individuals are, all considered. Public transportation projects can include not like MPOs, regional in nature. Federal transit funding, which only fixed-route bus and rail services, but also flex routes, is most likely to be relevant to the improvement of service demand-responsive services, and taxi services, making human coordination, as well as certain federal highway program services agencies relevant participants in the planning process. funds such as the Congestion Mitigation Air Quality (CMAQ) Transportation plans must be developed with the input of program, pass through the MPO and can only be spent after elected officials, public agencies, and citizens, and MPOs being part of approved MPO plans and programs. Addition- are required to make draft plans available for review and ally, the MPO process is an open one, with high minimum comment. standards for public outreach and participation. It is this open access characteristic of MPOs that represents the strongest Job Access Transportation Plan. FTA will consider an argument for human services involvement in the MPO process. application for a grant from its JARC program only if the There are several points in the MPO process at which doc- projects contained in the application are part of the region's uments must be developed and which provide an opportunity Job Access Transportation Plan and have been reviewed and for participation in funding decisions: approved by the MPO as being in accordance with the region's Transportation Plan and included in the TIP. Unified Planning Work Program (UPWP) A coordinated transportation and human services planning Transportation Plan process that includes all interested stakeholders must be used Job Access Transportation Plan to develop the Job Access Transportation Plan. MPOs are normally involved in, if not the lead agency for, the develop- TIP ment of regional Job Access Transportation plans that are required at the federal level, giving agencies that are con- Each of these documents, and the processes by which they cerned with assisting individuals who are preparing to enter are developed, are described below. the workforce another reason to become involved with their MPO. Stakeholders that typically participate in the job access UPWP. The UPWP is a planning document that programs fed- planning process include the following: eral transit and highway planning funds. Most of the planning studies programmed through the UPWP process are recom- Transportation officials mended by the MPO policy board. Public outreach require- Transit agencies and other transportation providers ments provide opportunities for other interested parties to Agencies administering TANF and Welfare-to-Work propose projects. For example, community groups in Boston funds organized around a plan to analyze the merits of the Fair- Workforce development organizations mount Line, an underutilized commuter rail line that cuts Other human services providers through densely populated Boston neighborhoods with a high Community and faith-based organizations proportion of transit-dependent residents. By becoming active Disability groups in the citizens advisory committee of the MPO, the groups Public and assisted housing providers were able to convince board members to allocate federal plan- Child care organizations ning funds to this project. Employers and business organizations Unless the interests of human services providers are already Elected officials represented within the MPO policy board, these organizations Citizens must actively seek to increase their involvement. The limited amount of available federal planning funds, combined with As with the development of the area's UPWP, nontrans- a seemingly limitless list of planning concepts, means that portation agencies can more effectively and meaningfully MPOs are unlikely to dedicate efforts toward bringing more participate in the development of the Job Access Transporta- stakeholders, and therefore planning ideas, into the process. tion Plan by serving on technical or policy committees of the MPO than by attending public meetings. Transportation Plan. MPOs are required to develop a long- The Job Access Transportation Plan must describe the loca- term transportation plan for their region, covering at least a tion of welfare recipients and low-income residents (particu-

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43 larly those with disabilities); employment centers and facili- ments. This new emphasis on environmental justice has been ties for employment-related activities; and public, private, and most significant in how it has shaped planning at the MPO nonprofit transportation services. It must also identify level. In an effort to ensure that transportation plans and pro- transportation gaps that limit the target population's ability grams satisfy Title VI requirements, MPOs have brought to prepare for or find and maintain employment. Projects and a variety of stakeholders to the table. In most cases, these services to address those gaps must not only be proposed, but stakeholders were not previously involved in transportation assigned a priority for funding and implementation. planning. This has typically resulted in stronger links with Job access transportation services are typically funded organizations and advocacy groups that focus on minority or with a combination of federal TANF, Welfare-to-Work, and low-income populations; as well, there has been increased JARC funds. The planning process associated with use of involvement on the part of human services organizations in these funding sources is described later in this chapter. the planning process. The emphasis on Title VI has also affected the type of TIP. The TIP is the document that an MPO uses to program analysis that is conducted as part of the planning process. Title operating and capital funds for expenditure within a 2-year VI requires that the location of low-income and minority pop- period. The TIP includes all federal highway and federal tran- ulations in each region be identified and that the impacts of sit funds to be spent in an urbanized area. Projects selected for projects and services included in the regional Transportation inclusion in the TIP must be in accordance with the region's Plan and Job Access Transportation Plan on those groups be Transportation Plan. Of particular interest to agencies look- evaluated. For example, a Title VI analysis might calculate ing to coordinate service for the transportation disadvantaged the length of time low-income residents without cars would are FTA's Section 5307 (urbanized area formula grants), have to travel to an employment center with entry-level jobs Section 5309 (capital investment grants), Section 5310 (for- by bus as compared to the length of time residents with cars mula grants for elderly and the disabled), Section 5311 (rural would have to travel. Transportation options for the low- and small urban formula grants), and JARC funds. income group to reduce that inequity could then be proposed. FHWA's CMAQ program is also of interest, as transit ser- vice is an eligible use for these funds. Three broad categories Barriers to MPO Involvement. The examples previously of transit programs are eligible for CMAQ funding: cited suggest that planning requirements related to welfare reform and job access programs and recent federal guidelines Service expansion regarding environmental justice and Title VI can contribute Provision of new transit service to an increase in interaction between traditional transporta- Financial incentives to use existing transit services tion agencies and human services agencies. Although these relationships can help to foster an increase in sensitivity to However, as with the UPWP, MPOs already face funding the transportation concerns of transportation-disadvantaged constraints when developing their programs. This reality and individuals on the part of the traditional transportation offi- the requirement that all projects programmed in the TIP be cials and planners, human services agencies may still not be consistent with an MPO's long-range transportation plan pursuing traditional federal transportation funding streams suggest that stakeholders interested in pursuing coordination through the MPO framework. In interviews with MPO rep- efforts through the MPO process get involved not on a project- resentatives, several reasons for this lack of involvement were by-project basis but with a dedicated, long-term participation identified. effort. One reason is that the MPO process is often unfamiliar to The citizen's advisory committee is the most likely point of entities that have not historically been involved. Human ser- entry into the MPO process, although the technical advisory vices agencies, as relative newcomers to the process, may committee and policy boards tend to be closer to the ultimate need more time and experience or outreach and education decision-making process. Involvement at these levels, even if before they are comfortable with the variety of funding pro- it occurs only through attendance at meetings that are open to grams and the strategies for securing this funding for the the public, serves to heighten awareness of the MPO process transportation disadvantaged. Transportation organizations and increases the likelihood that transportation-disadvantaged should be aware that they may need to make a more aggres- interests will become a focus of the MPO. sive effort to involve human services agencies in the trans- portation planning process, by making direct personal con- Environmental Justice as Catalyst. One recent development tact with agency representatives, actively soliciting input on that has helped to foster stronger links between human services agendas and tasks, extending invitations to human services agencies and MPOs is the federal government's emphasis on agencies to sit on MPO committees, holding meetings at con- environmental justice. Title VI of the Civil Rights Act of venient times and in accessible locations, and simplifying 1964 requires transportation planning to be sensitive to past processes for providing input whenever possible. inequities in both the provision of transportation services and A second explanation is that the human services agencies the burden of negative impacts from transportation invest- may choose to convey their needs and priorities through MPO

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44 forums and committees in which they participate and then to to develop transportation services for transportation- rely on the MPO to advocate for programs to meet these needs. disadvantaged individuals and to seek funding for those In Thurston County, the MPO/Intercity Transit coalition has services. greater access to legislators and decision makers than the MAG, the Phoenix MPO, has its Human Services Com- human services agencies do, so it has made sense for the coali- mittee submit recommendations to the MPO board as to how tion to carry the human services transportation agenda on to spend the funds. These recommendations are the product some state issues. Thurston County planners also suggested of a needs assessment, a public outreach process, and input that because MPOs typically are the keepers of so much data from experts in the areas of programs for older adults, people on transportation and demographics, they are naturally able with disabilities, and low-income individuals. Although the to provide more of the contextual information for certain Human Services Committee has recently made recommen- grant programs. dations that included spending a portion of the SSBG fund- Perhaps the most significant barrier to increased participa- ing on transportation for older adults, most of this block grant tion in MPO activities on the part of the human services money goes toward the core missions of the respective agencies is their own resources. In the Central Massachusetts human services agencies. Regional Planning Commission (CMRPC), not only does the There are examples, however, of greater MAG involve- Environmental Justice Committee represent a very small por- ment in pursuing transportation funds specifically for the tion of participating human services agencies' workload, it transportation disadvantaged. The MAG Human Services also represents a very small piece of the MPO's overall plan- Committee has worked with Maricopa County to try to secure ning and programming efforts. Although the members of the Welfare-to-Work funding for transportation. Although this committee have come together in the past around project- effort did not succeed, MAG has also worked with the county based issues of interest before the MPO, planners in central to pursue FHWA Surface Transportation Program (STP) fund- Massachusetts question whether the amount of time any of ing for an older adult transportation initiative. These efforts the agencies would have to devote to being a full participant included convening a planning group and hosting a national in the MPO would be the best use of their limited resources. conference on the issue. The MAG Human Services Commit- tee also has the responsibility within the MPO for reviewing all grant applications for the FTA Section 5310 funds. In Washington State, coordination is encouraged but not State Requirements for Planning required, resulting in a variety of results and lead agencies. In at the Regional Level Thurston County, the home of the state's capitol in Olympia, the lead agency for coordination efforts has been the MPO, Despite the large amount of federal funding that could be Thurston County Regional Planning Commission, in conjunc- spent on enhanced coordination efforts, a high level of human tion with the RTA, Intercity Transit. Their collaborative effort services participation in the MPO process does not appear to to take the lead on coordination was born of the increased be common. There are, however, some examples of human emphasis on environmental justice in the late 1990s. After services agencies integrating themselves into the MPO struc- realizing that they were not doing all they could to incorpo- ture in order to improve coordination. In Florida, state statutes rate input from segments of their population, they built a coali- mandate each county's coordinating board to advise their tion including the County Health Department and applied for MPO on any issue pertaining to the provision of transporta- a JARC grant. The coalition won the JARC grant and has tion services to the transportation disadvantaged. Although continued to meet on a monthly basis. the coordinating boards are not full voting members of the The funds from this grant went primarily to two initiatives. MPO, they are still able to bring the concerns and needs of The first was a program to provide transportation to a Native the transportation-disadvantaged population to the attention American reservation in the rural southern half of Thurston of the MPO board. County. The service is a fixed-route deviation bus system that In Arizona, human services planning is a mandated func- connects to Intercity Transit's routes. The second initiative tion of the four MPOs and two Councils of Government funded with the JARC grant is called Village Vans. The MPO (COGs). The Arizona Department of Economic Security, the coordinated with the county housing commission to identify state agency that administers aid to low-income families, low-income housing areas and then provided the vans for requires COGs and MPOs to plan for the use of a portion of work trips. Driving was done by WorkFirst (the Washington each region's Social Services Block Grant (SSBG). Cur- welfare system) clients as a job training program. Three of the rently, MPOs receive roughly 24% of their region's SSBG original four drivers now have full-time positions driving for funds, which are signed over to the MPO by the local gov- other companies. The MPO estimates that the Village Vans ernments that receive them. MPOs have staff specifically program has also assisted 70 people find and get to work responsible for overseeing human services planning with between its startup in February 2002 and the end of 2002. In these funds. this project, the coalition found it easier for Intercity Transit Planning efforts in Arizona and Washington offer exam- to take the lead in dealing with the grantor, FTA, as they were ples of transportation planning processes that have been used more familiar with the regulations and process.

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45 Decision-Making Processes Associated TANF funds for transportation are often combined with with Funding from Human Services Sources U.S. DOL welfare-to-work funding or FTA JARC funds or both. These three agencies jointly issued guidance in 1998 In addition to support from transportation funding pro- and 2000 regarding the use of funds for transportation ser- grams, providers of transportation service for the transporta- vices (4, 5, 6). Planning often involves an interagency coor- tion disadvantaged often rely on funding from human ser- dinating committee to provide guidance on transportation vices organizations. The processes used to make decisions initiatives, as well as other components of welfare reform about the use of those funds are discussed below. programs. This approach has been taken by nine states: Outside of U.S. DOT, the most significant sources of fed- Alabama, Idaho, Kansas, Minnesota, Mississippi, Montana, eral funding that can be used to support transportation ser- Oklahoma, Pennsylvania, and Wisconsin. New Jersey and vices are located within DHHS and DOL. Three of the most Ohio have ensured coordination between transportation and significant funding programs include Medicaid, Title III of human services agencies through a mandated local job access the Older Americans Act, and TANF. These and other sources planning process. of federal funds are discussed in Chapter 5. The planning In another structural model, programs distribute funds to a requirements that are typically associated with these federal designated state agency and hold the state agency responsi- programs are described below. ble for distributing funds to eligible local recipients and In terms of their structure, federal programs follow a num- ensuring that policy and administrative requirements are met. ber of different models that affect how funds flow from the For example, Title III funds from the federal Administration federal level to states and localities. In most cases, however, on Aging (AoA), which may be used to provide transportation a requirement to submit a plan for the use of the funds to the and other support services for seniors living outside of care federal agency is a condition of receipt, and programs and facilities, are distributed to the agency on aging in each state. services must be developed and implemented in accordance The agency on aging then passes funding along to designated with that plan. Area Agencies on Aging (AAAs). In the case of Title III funds, Some programs make funds available to a designated state a state plan must be approved by the appropriate regional AoA agency, either according to a formula or on a discretionary office, and an area plan must be approved by the state agency basis, to support eligible programs and activities. The Med- on aging before the funding can be used to implement pro- grams and services. icaid program follows this model. The federal Centers for Medicare & Medicaid Services (CMS) allocate federal Med- icaid funds to the designated Medicaid agency in each state, State Coordination Planning Processes by formula, for use in providing health care services for indi- viduals and families who meet certain income and resource Planning for coordination of transportation services for the requirements.1 Each state may design its own Medicaid pro- transportation-disadvantaged population has evolved in a vari- gram, but it must comply with federal guidelines and require- ety of ways across the country. States with formal coordina- ments and be documented in a Medicaid State Plan that is tion programs or policies may require participants to follow approved by CMS. certain planning or decision-making processes or may oversee The TANF program also follows this basic model. Formula planning and budgeting at the state level to ensure that coor- funds are distributed in the form of block grants to the desig- dination guidelines are followed. In Florida, for example, nated welfare agency in each state by the federal Office of coordination legislation requires Local Coordinating Boards Family Assistance (OFA) in the Administration for Children (LCBs), assisted by designated official planning agencies, to and Families (ACF). When the legislation establishing the identify local service needs and prepare annual plans for addressing them. Maine and North Carolina both require local TANF program was passed in 1996, each state was required coordinating bodies to develop periodic plans that identify to submit a TANF plan to the OFA that outlined how the state needs within the area. In Maine, the plans are reviewed by the would implement welfare reform. state DOT when acting on funding requests; in North Carolina, However, the planning process for the use of TANF funds a state-level interagency advisory council is responsible for for transportation can be slightly more complex. From the out- ensuring that state and federal transportation funding is spent set of welfare reform, transportation was seen as a crucial ele- in accordance with the plans developed locally. ment in the process of moving individuals from welfare into The following paragraphs summarize the experience of six the workforce and was included as an eligible use not only for states: Florida, Kentucky, Maine, Michigan, New York, and TANF dollars but also for welfare-to-work grants from the Washington. U.S. DOL and was the purpose of JARC grants from the FTA. Florida 1 In some states, the state Medicaid agency distributes funds to local agencies, such as county departments of social services, for use in providing health care services. State agencies responsible for programs serving individuals with developmental disabilities As described in Chapter 4, the Florida Commission for the or mental retardation may also receive Medicaid funds from the state Medicaid agency. Transportation Disadvantaged designates and oversees LCBs

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46 in each of the state's 67 counties. The LCB selects a local Its costs were high because of the high number of trips taken Community Transportation Coordinator (CTC) to coordinate by its clients to jobs, interviews, and other work-related des- the provision of transportation for people who are transpor- tinations. As of 2003, DFC gives a fixed amount to each client tation disadvantaged (seniors, people with disabilities, low- for transportation. income individuals, and children at risk). Under Florida law, local and state agencies are required to participate in the coordinated transportation system if they receive local, state, Maine or federal funds for the transportation of transportation- disadvantaged people. A variety of state human services agen- In the 1970s, Maine passed a law requiring the DOT, cies contract directly with each CTC. Department of Human Services, and the former Department Another key feature of the Florida program has been the of Mental Health and Mental Retardation to submit annual involvement of service providers and groups representing the operations plans to coordinate planning of transportation ser- interests of older adults. Despite some difficulties in its start- vices. The latter two agencies were consumers of the vast up phase, providers of services to seniors began to see the majority of purchased transportation in the state. Maine DOT benefits of a coordinated system and the increased purchas- designated Regional Transportation Providers (RTPs) in nine ing power of pooled resources. regions. Some of these are single-county entities, while oth- Each county has a designated CTC that is responsible for ers cover multiple counties. Various funding sources are fun- administering the coordinated transportation. In 2003, 40% neled through the RTPs, although initially only funds for of CTCs are AAAs or other agencies that provide trans- seniors and mental health clients were included. Although the portation and other services to seniors. This makes sense, as structure was initially created for planning purposes, coordi- they bring the largest pool of money to the coordinated sys- nation has begun to occur on the operating side as well. tem. Elderly groups are also part of a very sophisticated polit- RTPs differ not only in geographic scope but also in ical network in the state, which has translated the needs of the function. Some are multipurpose agencies, such as the York transportation disadvantaged into a powerful issue for the County Community Action Corporation. The other RTPs are Florida legislature. (It is not uncommon for legislators to single-purpose agencies that exist solely for the provision of receive 700 e-mails from this network of supporters before transportation, such as the Regional Transportation District in votes affecting service coordination.) More government agen- Portland. In all cases, regional planning agencies are responsi- cies are beginning to take the lead as CTCs. The executive ble for the actual planning. director projects that within 10 years all CTCs will be gov- In the last 10 years, there has been more of an emphasis on ernment agencies. expanding existing programs and moving into new areas. Maine Medicaid changed transportation from an administra- tive service to a medical service in order to obtain a higher Kentucky reimbursement rate from the federal government. Adminis- trative costs require a 50% match from the state, while med- In 1999, Kentucky mandated transportation services to be coordinated through 15 different brokerages that covered all ical costs require a lower match from the state. The RTPs areas of the state. The motivation for coordination was that, were very involved with this policy change. although RTAs were in place statewide to receive 5311 and Medicaid services are coordinated at the RTP level. In 5310 funds, there was evidence that Medicaid and TANF order for RTPs to have Medicaid ID numbers, they must be transportation funds were being abused by both recipients and full-service providers with an agency vehicle, a volunteer providers. The brokerage system was viewed as a means by driver program, and arrangements in place for purchasing which to control costs, which were skyrocketing for the two transportation from taxis. Medicaid is by far the largest pro- programs. gram, funding about 80% of York's annual transportation bud- The Kentucky DOT was selected to lead the effort due to get, for example. There are 30 to 40 funding sources in all. The its experience in managing transportation statewide. It orig- biggest programs after Medicaid are Child Development Ser- inally contracted with two other cabinet-level state depart- vice (Maine preschool program for special needs children), ments, Families and Children (DFC) and Human Services. Mental Health/Mental Retardation, and senior programs. DOT has set the rates for transportation providers in each The Maine Transit Association (to which all RTPs belong) region. These rates differ to reflect the varying size of the provides a forum for all members to share experiences and coordinated transportation market in each region. The broker ask questions. The small size of the state is an asset in coor- can receive only up to the cap rate, which is a fixed dollar dinating service, as the York County CAC coordinator knows amount per population of eligible recipients. The brokers each of her eight colleagues on a first-name basis. Although contract with a variety of providers: nonprofits, taxi compa- MTA does not have any regularly scheduled political con- nies, and even neighbors who volunteer rides. ferences or events, members work together effectively when DFC subsequently opted out of the system because it was there is relevant legislation before the legislature. MTA also unable to pay the cost of transportation for its TANF clients. publishes a directory containing information on programs

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47 and contacts for the benefit of their member organizations are the ultimate decision makers, so a wide variety of services and state legislators. has resulted. One unique characteristic in New York is that the state budget for transit is $1 billion, almost equal to the amount spent on highways. While the overwhelming major- Michigan ity goes to the Metropolitan Transit Authority in the New York City region, the rest of the state sees a greater amount In Michigan, coordination of service has largely occurred of dedicated transit funding than comparable areas in most through Project Zero, the state's Welfare-to-Work program. other states do. Three state-level agencies--Family Independence, Michigan One aspect of service coordination that is handled at the Career Development, and Michigan DOT--work together to state level is employment transportation. The DOT has coordinate transportation services for former welfare recipi- recently signed an MOU with the state's DOL to oversee the ents. Family Independence and Michigan Career Develop- provision of transportation service through the TANF pro- ment utilize a portion of their TANF funds, and the DOT gram. The exception to this MOU is the auto program of matches this contribution. The local partners or departments Labor's TANF program, through which the state assists clients of these three agencies submit an annual plan of service to in financing and purchasing private automobiles. The DOL is the state. still responsible for overseeing the eligibility of their clients. At first, the match provided by Michigan DOT in Project Local agencies have attempted to coordinate Medicaid Zero represented such an increase in resources that the total with other programs. Although these attempts may have cre- program funds were able to cover all requests for client trans- ated savings in Medicaid spending, they may have caused portation services. In recent years, as the two nontransporta- increases to the budgets of other programs. According to the tion agencies have seen a decrease in their TANF budgets, policies have been revised. Rather than hold transportation state's director of mobility services, the biggest weakness spending constant and cut back in other areas, the state agen- with attempts at coordination is that there is no established cies decided to distribute TANF funds to the local agencies method for determining the costs of the Medicaid program. and let them determine what share to spend on transportation In addition, in 2002 the governor signed an initiative that (with the DOT still matching whatever level of spending the increases the pool of eligible recipients of Medicaid in the locals decided upon). One year, the DOT used its federal state. Increased eligibility for Medicaid means increased eli- JARC funds as the match for the TANF funds in 10 regions gibility for Medicaid transportation, so costs are going up and where transit agencies had submitted winning proposals for outpacing any Medicaid-related savings achieved through ser- the JARC funds. vice coordination in counties where it has been attempted. Although coordination is not mandated by the state in Although rural counties in New York have been more inter- Michigan, the DOT does require its transit providers to coor- ested in coordination (some have coordinated service between dinate. In some rural areas of the state where transit service Medicaid, TANF, and veteran services), the state's director of is not provided, other entities have had to step forward to mobility services identified the multitude of varying federal assist in coordinating service. In Ottawa County, for exam- requirements for each program as a disincentive. In an extreme ple, a nonprofit called Life Services System (LSS) has con- example, because of the different federal requirements for eli- tracted with some agencies to purchase rides from human ser- gibility, one county makes use of 15 different color-coded vices providers, taxi companies, and nearby fixed-route tokens to differentiate riders funded by the various programs. transit providers. LSS first became involved in transporta- tion in 1992 after being awarded a Department of Education demonstration grant to provide rides to employment for Washington 3 years. In the years since that grant expired, LSS has con- In Washington, state legislation stops short of mandating tinued to broker transportation service for a variety of agen- coordination. Instead, the legislation refers only to the "intent" cies: Community Mental Health, the DOT (for services for to coordinate services. The ACCT has been undertaking older adults and ADA clients), and Project Zero. A concern efforts, through its biannual report to the legislature, to push voiced by LSS about these sources of transportation funds is that they are not assured from year to year. The DOT funds for more of a mandate for coordination. The ACCT adminis- could be a more stable source, but because the DOT funds trator identified the lack of high-quality data as the biggest can typically be distributed only to transit providers, LSS is challenge that increased support for coordination faces in not able to rely on them as an ongoing funding source. Washington. Without complete and reliable data on ACCT's efforts at coordination, it has been very difficult to demon- strate the program's effectiveness to the legislature. New York In the absence of a legislated mandate, the state's regions have been free to pursue approaches to coordination that best The New York DOT structures its transit programs to suit local realities. In Spokane, human services and trans- encourage coordination at the local level. County governments portation providers have coordinated data collection efforts.