Proposed Changes to the Uniform System of Accounts Webinar Q&A on February 18, 2016

Question:  If an organization only subsidizes a certain portion of its members' fares, would the portion that the organization pays be accounted for in the organization-paid fares and the remaining portion paid by riders via passenger-paid fares?

• Answer:   Yes, that's correct.  The key is if the organization is subsidizing directly to the user, you as a transit agency won’t know. You will be reporting what the organization is paying directly to you, in order to let the members pay a discounted fare separately to you.

Question:   For van pool out-of-pocket costs, if a group is invoiced by the vendor for gas, does that out of pocket cost get reported as payment to the vendor or out-of-pocket expenses?

• Answer:  In the example described, it sounds like the van pool vendor is invoicing the van pool riders.  The important thing is whether the transit agency is paying or the riders are paying.  In this case, if the riders are paying the gas, even if paying it directly to the van pool vendor, then it's a passenger out-of-pocket expense.

Question:  Due to a special, one-time event to provide all attendees with free transit, would this be categorized as special or organization-paid?

• Answer:  With the extraordinary and special items, typically those refer to situations outside of the transit agency's control, such as natural disasters.  In the case of a special event where an organization is hosting the event and paying the fares for their attendees, it would be an organization-paid fare.  Additionally, depending on the details, this type of service may be impacted by FTA’s charter rule.  A more detailed conversation may be needed to determine the appropriate category for this example.

Question:  If our MPO contributes capital assets constructed on our behalf, would that be contributed services?

• Answer:   No.  This would be a voluntary non-exchange transaction, not a contributed service.  When any organization builds a capital asset for you and then transfers that asset to you, it is a voluntary non-exchange transaction.

Question:  If vehicle costs include tires, how are leased tires reported?

• Answer:  Vehicle costs refer to the capital cost per vehicle.  When a vehicle is initially purchased, the cost includes one set of tires and tubes.  Replacement tires and tubes are an operating expense, and reported under tires and tubes on the F-30 form.  The lease payments for tires are also an operating expense reported on the F-30 form.

Question:  In the F-30 form, non-vehicle maintenance previously did not include utilities.  Will facility maintenance now allow utilities?

• Answer:  No, there are no changes to the requirements on how utilities are reported.  Utilities for all of your facilities will remain under general administration, as they are now. Utility costs to propel electric vehicles are under vehicle operation.

Question:  Does slide 47 suggest operators’ paid absences be allocated across VO, VM, FM and GA?  If so, why? 

• Answer:   Currently, paid absences are under fringe benefits and fringe benefits get reported across the four functions.  This method is not a change.  Most likely costs would be tracked and reported by person.  For example, a vehicle operator’s salary would be reported under vehicle operations, as would their paid absences.  An employee who splits time equally between vehicle maintenance and general administration would have both their salary and paid absences split half to each of these functions and reported this way.  FTA’s reporting structure is not able to report costs outside of the four functions.  To get the best number possible, we want to allocate portions, where appropriate, across the four functions.

Question:  Are deferred inflows and outflows from GASB 68 reportable?

• Answer:  We do not have an answer for you are this time.  We will take this for action and provide an answer at a later date.

Question:  Is interest paid on local bonds still reported on the F-40 form?

• Answer:  Yes.

Question:  For APC validation, is there a minimum number of equipped vehicles?  For example, if I have 600 vehicles and 29 equipped with APCs, can I get validated with 15 trips?

• Answer:  In principle, yes.  If you have such a small proportion of your vehicles that are APC equipped, then that's something that we would look at when evaluating your report.  You know, it gets tricky in that situation because you have to make sure that APC equipped vehicles are getting scheduled in all the right trips so that you can get your sample so you can report passenger miles.  So in principle, yes, you can, but in practice that gets -- that gets difficult.  I think in most cases if you have 600 vehicles you have more than 29 that are APC equipped.

Question:  Is the percentage calculated at the aggregated level or at the trip-by-trip level?

• Answer:  If you are talking about the percent difference in passenger trips and passenger miles, it is calculated at the aggregate level.  You add together all your manual data, as well as all your APC data to come up with two numbers. Then, you calculate the percent difference between those two numbers.  For the unbalanced error, it is calculated at the trip by trip level, at first, to calculate the absolute difference at each stop.  Then once calculated at each stop, you would then aggregate all the errors.

Question:  What if the acceptable level of unbalanced error is 5% or 10%?

• Answer:  5% is the current standard.  We welcome your feedback on this standard via the Federal Register.

Question: Would the APC report pertain to fare gate data, which captures both boardings and alightings?

• Answer:  FTA is only requesting data from onboard counting systems for the APC report.

Question:  Since NTD has 2710.1A, will NTD assist small transit agencies with sampling procedures for passenger miles and unlinked passenger trips?

• Answer:  We do have a sampling manual available on the NTD Web site. We encourage you to check it out.  Hopefully it will be helpful.

Question: When will the first IFSR be due?

• Answer:  This hasn’t been specified in the Federal Register.  Please submit your feedback on this via the Federal Register.  We will review the comments and make a determination.

Question:  Are the new procedures for APC proposed or are they in effect now?

• Answer: They are in the proposal phase and not in effect currently.  The previous APC procedure is still in effect and should be used until a final rule on APC certification is issued.

Question:  For APCs, is 5% chosen for any specific statistical reason?  All things being equal, percentage limits are harder for smaller values.  Systems with small ridership have less wiggle room because their ridership is less.  Larger systems will have larger windows.

• Answer:  Please submit this comment to the Federal Register and FTA will review it.  5% was chosen because in conversations with APC vendors it was determined it would be a reasonable standard to meet.  Currently, it is required that your passenger mile sampling be within 10% error with a 95% level of confidence.  5% is more precise.

Question:  Are APC changes effective in 2017?

• Answer:  The effective date will be published in the final rule.  It may take effective immediately or the rule may set a future effective date.  If you have specific feedback, please submit it to the Federal Register.  If you have specific questions regarding timing of APC changes, please submit them to Maggie Schilling or your NTD Analyst.

Question:  The B-30 form currently asks for the passenger fares generated from a contract.  Would this continue or would those be reported on the F-10 as passenger-paid fares?

• Answer:  It will continue. On each B-30 report, you will report the fares generated by that contract and the NTD system will automatically pull in the sum of those numbers across all your contracts on to the F-10 form.

Question:  What if we do not have an APC?  Would our manual sample every three-years remain the same?

• Answer:  Yes.

Question:  What is the rationale for splitting high school fares and university fares?

• Answer:  In the example given during the webinar, the reason high school and university fares are different is not the age of the students. The difference is because, in the case of high school, the students were paying the fare directly into the fare box, whereas in the university scenario the university was paying the transit agency for service.  The difference is not based on the type of student, but the method of collecting and transferring the fare to the transit agency.

Question:  Is a voluntary non-exchange transaction the same as donated?

• Answer:  In the case of the Silver Line in Washington, DC this is a voluntary non-exchange transaction.

Question:  When will the new changes take effect?  And will this be retroactive for activity in reporting year 2016?

• Answer:  The proposed rule says the changes will take effect in 2017.  The USOA will require software changes that are intended to be in place by July 1 to meet the 2017 fiscal year start for most agencies.

Question:  How is the purchase of an administration building with a mortgage reported in NTD?

• Answer:  The purchase of an administration building would be a capital expense, under administrative buildings.  The policy manual provides examples of how to report loans, which are more complicated.

Question:  By moving insurance expenses to administration, will it affect our preventive maintenance reimbursement from FTA?

• Answer:  FTA will look into this question and provide you an answer separately.

Question:  To confirm, we will need to perform the current maintenance samples for years 2016 to 2018. Then we will change to the smaller sample size and triennial frequency in 2019.  Is that correct?

• Answer:  This question references the APC maintenance samples.  If you are already approved you do not need to continue doing the current maintenance samples according to the previous guidance.  When the final rule is issued, the new rules will be in effect and you will not have to complete the maintenance samples again until 2019.

Question:  When will the IAS be due again?  We submitted the last one in 2010.

• Answer:  You will have to redo it for the 2020 fiscal year.

Question:  When you talk about tracking operators, are you talking about anyone on the operation side or specifically referring to the drivers?

• Answers:  Operators are almost exclusively drivers.  If you have commuter rail it includes conductors.  If you have a ferry boat it includes captains but in a demand-response type agency, then just drivers.

Question:  Our organizations sells monthly passes and value cards to local government agencies, such as the DHHR and Rehabilitation Services.  Those organizations then distribute the passes and value cards to their clients.  Where will we show the revenues when those passes and value cards are used by the clients?  Will they be passenger-paid or organization-paid fares?

• Answer:  Since these are individual fares for individual passes, rather than lump sum payment from the organization, it will be a passenger-paid fare.

Question:  If we are required to restructure our entire chart of accounts, we think 60 days might not be sufficient time.

• Answer:  For clarity, the 60 days refers to the comment period on the Federal Register notice.  After that the new APC guidelines will take effect.  The new USOA system will not come into effect until fiscal year 2017. Since there are not a large number of changes being made, we do not feel you will need to restructure your entire chart of accounts.  If you feel these changes will require a complete restructuring of your chart of accounts and this will be burdensome, please submit a comment to the docket on the proposed timeline for enactment of the changes.  Indicate that in your assessment the current enactment timeline will be insufficient to accomplish the changes prior to fiscal year 2017. 

Question:  When will the NTD require new IAS-FD?

• Answer:  FTA does not have an answer at this time.  The answer will be published after review of any submitted comments.

Question:  Will the USOA be updated and include all existing and updated object class codes in one document and when is it anticipated to be published?

• Answer:  The new USOA will be available on the website as soon as possible.

Question:  When will a new NTD manual be issued?

• Answer:  A new manual is issued for the NTD each year.  The next one is expected to be issued this summer.  Both the USOA and NTD manual guidance are out for comment.  Once the comment period has ended, FTA will review the comments for incorporation in the final product.  They will then be posted on the website as soon as possible.  The timing for posting on the website may be lengthened if there is high number of comments or responding to the comments requires significant changes prior to posting.

Question:  Can the independent financial system review be conducted as part of our regular annual financial audit or will it need to be a separate engagement?

• Answer:  The purpose of the independent financial system review is different than the purpose of your annual audit.  The IFSR is specific to NTD.  It examines whether your chart of accounts is conversant with the USOA chart of accounts.  You can have your auditor review this, but your agency would need to determine if it is outside of the scope of work for your auditor contract. 

Question:  Where can people get more information on the new numbering scheme?

• Answer:  You will be able to see this on the new USOA once published on the website.

Question:  Can you please explain a little bit more about the difference of samplings all of the different bus models for the APC and how that relates to the MAX requirement of 50 samples?  If we have 10 different models of buses with APC, is it 50 samples across the 10 models or 50 for each model?  And how do you determine how many of each model to sample?

• Answer:  In the example given, it would be a total of 50 trips sampled, not 50 per model.  If you have many different models of bus, then it may be that you need more than 50 trips to sample them all, but if you only have ten models of bus then you would just need the 50 samples.  How many of each model to sample, will be left for you to determine.

Question:  Please clarify for non-added revenues, the sale of assets.  Should it be the sale of all assets or the sale of assets bought with FTA funds or FTA grants?  You made a distinction on how to report it if below book value or if over book value.  For grant purposes we dispose of assets after completing useful life, which equals the book value of zero.  Currently, we have to report to FTA any sales over $5,000 after the asset completed the useful life.  So if book value is zero, but sale is over $5,000, where do we report?

• Answer:  It is any asset, not just assets were purchased with FTA grants. If the book value is zero, due to expending its useful life, but you are able to sell it for some value under $5,000, that would go in the new field called other agency revenues.  The sale of assets category is just for the value of the asset.  If the value of the asset is zero, then you do not have to put anything in that line item.

Question:  Who do we work with to certify our APC data?

• Answer:  Please work with your NTD Analyst

Question:  Is the sample size based on fleet or mode?

• Answer:  It is based on the number of APC-equipped vehicles in the mode to be certified.  For example, if it is MB mode and you have 60 buses APC equipped in MB mode, you would need to do 30 trips.

Question:  Our agency receives checks from various state agencies for partial payment of their employees' passes each month, how should these be reported?

• Answer:  Please submit the question with additional detail, so we can get you an answer.  FTA will need more information on whether these passes are available for sale to the general public with a split payment, or is there an arrangement where a special price being changed for the passes applicable to all state employees.

Question:  Shouldn't there be concern that the algorithm is factoring up the sample properly?

• Answer:  We are not clear on the question.  Please submit more detail and we will provide an answer.

Question:  Where would bus pass sales sold to nonprofit agencies be accounted for in organization-paid?

• Answer:  If you are selling individual bus passes, it will be passenger-paid fares.

Question:  Would an agency that purchases tickets or passes for their clients to ride be reported as  organization-paid fares?

• Answer:  If you are selling individual bus passes, it will be passenger-paid fares.

Question:  Referring to F-20, if we purchase cameras for a bus after the purchase of the bus, do we report it under revenue vehicles?

• Answer:  It is a capital expense and you have capitalized the cameras, so it is likely communications and information systems, rather than revenue vehicles.

Question:  Some government employees receive a transit subsidy in the form of a check they bring to us to purchase transit passes.  For example, the government employer may pay $63 and the government employee pays $65.  Is that to be split between organization, which would be assigned $63, and passenger, which would be assigned $65?

• Answer:  No.  This would be combined under passenger-paid fares.

Question:  Are you saying that the next sampling year for all agencies is 2019?

• Answer:  The next year for the maintenance sample for APCs is 2019, not the regular passenger miles sampling.

Question:  Previously maintenance for fare boxes on buses was classified under non-vehicle.  Now that non-vehicle is facilities, do these expenses stay in the same function?

• Answer:  Yes.

Question:  Is there an anticipated date on the final rule for new APC procedures?

• Answer:  The proposal would have the new Uniform System of Accounts take effect for fiscal year 2017.  For many of you, that would be July 1, 2016, for others it would be a different date. Please submit comments on whether this timeline is reasonable, for consideration.  The proposed APC guidance will take effect immediately upon review of the comments and an official announcement of the effective date.  Again, if you feel there should be a longer delay in effective date, please submit comments.

Question:  We have an annual NTD AUP (Agreed upon procedure) done to upload with D-10.  Does this only need to be done at the beginning and then every ten years?

• Answer:  In order to answer the question for your agency, we have to know the specifics of your individual agreed upon procedure.  Please contact Maggie Schilling or your NTD analyst directly or submit more detailed information to the docket and we will provide an answer. If you are a larger agency, with more than 100 vehicles and operate in a UZA with over 200,000 in population, the IAS/FFA review must still be completed annually.  The new 10-year review is a similar certification to what was done by agencies when they became NTD reporters initially.  For many agencies this review has not been done for well over 10 years.  Now you will have this review will be done every 10 years. 

Question:  On the revenue report where fares paid by organizations are listed, are all fares paid by organizations considered to be farebox?  For example, project income?  Right now under certain circumstances some of those can be considered program income or local match.  Does this mean that service contracts can no longer be considered local match?

• Answer:  The proposals do not change match requirements.  They only change NTD reporting.  If it can be used as a local match now, it will not change.  Please submit comments on the local match, so they can be reviewed by the grants management staff to ensure there aren’t unintended consequences to the proposed changes. The key with the organization-paid fares is where an organization is not paid an agreed-upon service contract fee, this goes beyond buying individual publicly available fare media.  It becomes a larger contract. 

Question:  If a van pool program has some fares kept by the agency and some by the provider, how will we designate the fares?

• Answer:  All fares paid by the users of your system need to be reported.  Then if your van pool provider is keeping a portion of those fares, those are considered to be an expense.  This is because those are fares you are foregoing, but would otherwise be entitled to being kept by the provider.  This guidance does not change this.  Please work with your analyst on how to complete the B-30 form for this as it can be confusing and they can assist.

Question:  If the high school district is paying the transit agency directly should this be organization-paid fares?

• Answer:  Yes.  If the high school district is providing a lump sum to allow their students to ride for free it is an organization-paid fare.

Question:  If PT funds are to be reported under the more general directly generated funds, can these funds still be used as local match?

• Answer: The proposals do not change match requirements.  They only change NTD reporting.  If it can be used as a local match now, it will not change.  Please submit comments on the local match, so they can be reviewed by the grants management staff to ensure there aren’t unintended consequences to the proposed changes.

Question:  Do you recommend implementing some of the USOA changes now, such as reporting directly-paid passenger fares versus organization-paid passenger fares?

• Answer:  You will not be able to report the data in NTD in this way at the moment, but you can set up your internal accounts ahead of the final guidance.  In the meantime, please remember these changes are currently proposals and will not take effect until after comments are received and responses given. 

Question:  If some out-of-pocket types of expenses are billed by the agency and some paid directly by passengers, do we have to split the van pool report?

• Answer:  This is all go on one B-30 form.  The expenses paid directly by the passengers will be on the line for passenger out-of-pocket expenses.  The expenses paid by your agency will be under agency subsidy.

Question:  Does the 2017 implementation of USOA start on July 1 of this year for our fiscal year in 2017, July of 2016 to June of 2017?

• Answer:  Yes.  We have proposed a July 1, 2016 start for a 2017 fiscal year.  Again, please provide any comments you have on this proposal through the Federal Register so they can be reviewed.

Question:  Is the proposed chart of accounts listed on the NTD website?

• Answer:  The new USOA will be in the website soon.

Question:  If we provide service and are paid for the contracted services, as well as collect fares, are the contract payments considered fares?

• Answer:  Please submit the specifics of your arrangement, so we can consider all the details.  The basic distinction being made in the proposal is that for individual fare media sold to the public regardless of the purchaser is a passenger-paid fare.  A separate category is being created to recognize cases where an institution, such as a high school or university, pay a bulk amount to fund ridership of their members outside of the usual publicly available fare media.

Question:  Will there be a USOA and IFSR manual?

• Answer:  The new USOA will be published on the website shortly.  The guidance for the IFSR will remain a part of the NTD manual, published annually.

Question:  If the ridecheck software replaces a rejected trip with an errant average trip length, wouldn't the PMT be inaccurate?

• Answer:  Please discuss this directly with your NTD analyst since it is a specific case with a specific software system.

Question:  if you receive capital grant funds to purchase camera equipment, but the individual equipment is below the capitalization threshold, do we report the funding as operating since we are expensing the equipment or do we list both as capital?

• Answer:  Please write up this question and submit it to the Federal Register for review.

Question:  For APC maintenance, is one ridechecker per door a requirement or a recommendation?

• Answer:  It is a recommendation, especially for higher ridership trips.  You want to be able to have your APCs approved, meaning you need the most accurate manual sample possible.  Not having one per door may make this more cumbersome, but if you feel you can obtain this with one per bus it is acceptable.

Question:  If an agency provides vouchers to their clients who use the vouchers for fares, then we collect the vouchers and bill the agency for the fare value, is this an example of passenger-paid fares?

• Answer:  An individual fare being paid at one time would be a passenger-paid fare.

Question:  Do we send specific questions to Maggie or to someone else regarding new changes?

• Answer:  You may reach out to Maggie or your analyst.  We also encourage you to submit questions through regulations.gov to the docket so the answer becomes part of the official record and will benefit all agencies in having the answer.

Question:  Once these changes are in full effect, will there be any additional training Webinars to refresh the reporters on these changes?

• Answer:  Yes, once the changes go into effect we will host additional webinars.

Question:  Is the IFSR a form that I may complete in-house?  Or may we submit the annual audit report?

• Answer:  Please refer to the policy manual for detail on the IFSR.  Currently, this is called the IAS-FD or Independent Auditor Statement for Financial Data.  The name will change, but the requirements will be similar. 

The docket for comments related to this topic is open and will close on April 4 of 2016.  If you wish to submit comments, please do so at www.regulations.gov, and you need to search for the docket number, which is FTA-2016-0009-0001.  All the documentation relevant to today's topic, including the Federal Register notice is available in the NTD website.