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Coordination: It's the Law

Coordination is the efficient and effective use of transportation resources for getting people to important destinations, such as jobs and medical appointments. Coordination means working with transit providers, human service agencies, private institutions, businesses, volunteers and political leaders to broaden transportation options.

Since the 1970s, the benefits of coordinating public transportation with human, workforce and medical services have been well-researched and well-documented. However, coordination between public transportation and human services is not only a good idea, it is a federal requirement for recipients of U.S. Department of Transportation funds. Specifically, federal transit laws (i.e., the Federal Transit Act, codified at Chapter 53 of Title 49 of the United States Code) require coordination between public transportation and human services in statewide and metropolitan transportation planning, in the provision of urban and rural public transportation, and in the provision of specialized transportation services to elderly individuals, persons with disabilities, and persons from low-income households accessing jobs or job-related activities.

Following are citations directly from federal transit laws that spell out the statutory requirements to coordinate public transportation and human services:

49 USC 5303(g)(3): "Under the metropolitan planning process, transportation plans and TIPs shall be developed with due consideration of other related planning activities within the metropolitan area, and the process shall provide for the design and delivery of transportation services within the metropolitan that are provided by--(A) recipients [of Federal transit assistance]; (B) governmental agencies and nonprofit organizations (including representatives of the agencies and organizations) that receive Federal assistance from a source other than the Department of Transportation to provide nonemergency transportation services; and (C) recipients of assistance under section 204 of title 23 [i.e., the Federal Lands Highway Program]."

49 USC 5304(e): "In carrying out [statewide transportation] planning under this section, each State shall consider, at a minimum...coordination of transportation plans, the transportation improvement program, and planning activities with related planning activities being carried out outside of metropolitan planning areas and between States."

49 USC 5307(c)(5): "[Each recipient of a grant under this section shall] ensure that the proposed program of projects provides for the coordination of public transportation services assisted under section 5336 of this title [i.e., formula-based grants for public transportation in urbanized areas] with transportation services assisted from other United States Government sources."

49 USC 5310(d)(2): "[Each] grant recipient under this section shall certify that--(i) the projects selected were derived from a locally developed, coordinated public transit-human services transportation plan; and (ii) the plan was developed through a process that included representatives of public, private and nonprofit transportation and human services providers and participation by the public." 49 USC 5310(e)(2): "A State shall submit annually to the Secretary [of Transportation] for approval a program of projects [to be supported with funds apportioned to the State under this section]. The program shall contain an assurance that the program provides for maximum feasible coordination of transportation services assisted under this section with transportation services assisted by other Government sources."

49 USC 5311(b)(2)(C): "The Secretary [of Transportation] may not approve [a State's] program [of projects to be supported with funds apportioned to the State under this section] unless the Secretary determines that...the program provides the maximum feasible coordination of public transportation service assisted under this section with transportation services assisted by other Federal sources."

49 USC 5316(g): "The Secretary [of Transportation] shall coordinate activities under this section with related activities under programs of other Federal departments and agencies...A recipient of funds under this section shall certify to the Secretary that...the projects selected were derived from a locally developed, coordinated public transit-human services transportation plan...and the plan was developed through a process that included representatives of public, private and nonprofit transportation and human services providers and participation by the public."

49 USC 5317(f): "The Secretary [of Transportation] shall coordinate activities under this section with related activities under programs of other Federal departments and agencies...A recipient of funds under this section shall certify to the Secretary that...the projects selected were derived from a locally developed, coordinated public transit-human services transportation plan...and the plan was developed through a process that included representatives of public, private and nonprofit transportation and human services providers and participation by the public."

Are Non-DOT Programs Required to Coordinate with Public Transportation?
In a word, "no." Although federal spending on transportation in human services, workforce development, and health care is on par with spending through programs of the Federal Transit Administration, none of these non-DOT programs has a statutory mandate to provide transportation. Therefore, it is impossible to point out non-DOT legal language that has as much statutory clarity as the provisions of the Federal Transit Act cited above. 

Nevertheless, in 2003, the U.S. Government Accountability Office (GAO) identified 62 programs outside the DOT that not only were authorized to spend federal funds on transportation, but in fact did spend at least some small portion of their funds on transportation. In almost all these cases, one can identify permissive language in authorizing statutes that allows these funds to be spent on transportation services. In quite a few cases, federal agencies have issued regulations or guidance documents that spell out how program resources can be used for transportation. From a practical perspective, it is close to impossible for these programs to succeed in the transportation aspect of their mission without coordinating services with the activities of state or local transit agencies, but this coordination is not specifically required of non-DOT programs.

Statutory requirements in Federal transit law have the best chance of being successfully implmented when there is genuine cooperation from funding and programmatic partners. Providers, funders, and policy-makers in non-DOT programs have realized for decades that their programs' success depends on working constructively with transit partners. That's why the Federal departments of Transportation, Health and Human Services, Labor, Education and others have been working together since the 1980s in the Interagency Coordinating Council on Access and Mobility, and that's why the Coordinating Council's United We Ride initiative has been promoting partnerships since 2004.

Contact
Chris Zeilinger
Director, National Resource Center for Human Service Transportation Coordination
800.891.0590 x717
202.250.4108