Federal spending on Medicaid will continue at the higher rates established under the American Recovery and Reinvestment Act (ARRA, or the "stimulus bill"), under legislation passed by the Senate on August 5, which the House is expected to endorse on August 10.
This temporary increase in the Federal Medical Assistance Percentage (FMAP), which is the rate at which the federal government reimburses states for their medical expenses under Medicaid, has been slated to expire December 31, 2010. However, the budgets in almost every state are such that they simply cannot absorb Medicaid expenses at the lower, pre-ARRA, reimbursement rates. The Senate's legislation extends that FMAP increase for 6 months, to June 30, 2011.
Inasmuch as 37 states and the District of Columbia all provide non-emergency medical transportation service to their Medicaid enrollees as a medical expense, reimbursed at the FMAP rate, this legislation will be likely to have a major positive effect on the continued transportation access to health care services for Medicaid enrollees.
Three side issues are of note with regard to this legislation: (1) ARRA also created a program of supplemental "emergency" funding for states' Temporary Assistance for Needy Families (TANF) programs, which continues to be slated for expiration this year; (2) ARRA increased the allowable dollar amount of employees' tax-free transit benefits to $230 per month, but that increase is slated to expire on December 31, 2010; and (3) social media fans have noted that the first announcement calling the House back into session for its August 10 vote on this bill came as a "tweet" from House Speaker Nancy Pelosi, which is the first time that Twitter was used to conduct official business of the House of Representatives.
Friday, August 6, 2010
Tuesday, July 27, 2010
On ADA's 20th Anniversary, New Guidelines Proposed for Transit Accessibility
On July 26, 2010 - the 20th anniversary of the signing into law of the Americans with Disabilities Act - the US Architectural and Transportation Barriers Compliance Board ("Access Board") published proposed guidelines that - if implemented - would make sweeping changes to the specifications for accessible transit vehicles in the US.
These are proposed guidelines. Nothing is final. Comments are being collected by the Access Board through November 23, 2010.
Transit professionals, disability community advocates, and manufacturers of transit vehicles and accessibility features are aware that these proposed guidelines are the latest iteration in a series of proposals the Access Board circulated in spring of 2007 and autumn of 2008. Based on comments received on those proposals, the Access Board has refined its draft guidelines in this latest publication; evidence suggest that these guidelines are close to what is intended as a final rule. If so, look to such a document being published in the spring or early summer of 2011.
The current proposal, along with a wealth of background information, is found at the Access Board's website, www.access-board.gov, or can be retrieved as a 43-page PDF from the Federal Register (July 26, 2010, Federal Register, page 43747 et seq.). In this proposal, the Access Board has 21 leading questions to which they specifically are requesting informed comments, but they are welcoming public comment on all aspects of the rule.
Technical experts and concerned stakeholders should comb this proposal closely, and prepare their comments for submission.
There seem to be a few truly significant aspects to the proposal, including all-new dimensions and rules of definition concerning wheelchair securement positions on transit vehicles, all-new language to define the accessibility of ramps for low-floor transit vehicles, new requirements for automated stop announcements on many buses (specifically, all buses of 22 feet or more in length that are used by transit agencies with 100 or more buses in service for fixed-route transit), and new guidelines concerning accessibility of bus rapid transit (BRT) services.
Although little about this proposal addresses wheelchair lifts (perhaps that's a sign of evolving technologies in accessible public transit?), it's interesting to note that the earlier idea of increasing the maximum weight to 660 lbs has been dropped, and these accessibility guidelines continue to speak to the requirement of a maximum of 600 lbs that lifts and other accessibility features must be designed to accommodate.
Finally, it's good to recall that any guidelines, once finalized, would affect only future acquisitions of transit vehicles (including buses, over-the-road coaches, and vans that are used for public transit). Just as was the case when the current guidelines were issued in 1991, nothing about these rules would require any retrofitting of any transit vehicles in current use.
If you have concerns or expertise, it is vital that you submit comments on this proposal. Repeatedly, the Access Board's proposal notes items in which they have received contradictory or incomplete information from the field to inform their final guidelines, so they may really need to hear from you this time around.
These are proposed guidelines. Nothing is final. Comments are being collected by the Access Board through November 23, 2010.
Transit professionals, disability community advocates, and manufacturers of transit vehicles and accessibility features are aware that these proposed guidelines are the latest iteration in a series of proposals the Access Board circulated in spring of 2007 and autumn of 2008. Based on comments received on those proposals, the Access Board has refined its draft guidelines in this latest publication; evidence suggest that these guidelines are close to what is intended as a final rule. If so, look to such a document being published in the spring or early summer of 2011.
The current proposal, along with a wealth of background information, is found at the Access Board's website, www.access-board.gov, or can be retrieved as a 43-page PDF from the Federal Register (July 26, 2010, Federal Register, page 43747 et seq.). In this proposal, the Access Board has 21 leading questions to which they specifically are requesting informed comments, but they are welcoming public comment on all aspects of the rule.
Technical experts and concerned stakeholders should comb this proposal closely, and prepare their comments for submission.
There seem to be a few truly significant aspects to the proposal, including all-new dimensions and rules of definition concerning wheelchair securement positions on transit vehicles, all-new language to define the accessibility of ramps for low-floor transit vehicles, new requirements for automated stop announcements on many buses (specifically, all buses of 22 feet or more in length that are used by transit agencies with 100 or more buses in service for fixed-route transit), and new guidelines concerning accessibility of bus rapid transit (BRT) services.
Although little about this proposal addresses wheelchair lifts (perhaps that's a sign of evolving technologies in accessible public transit?), it's interesting to note that the earlier idea of increasing the maximum weight to 660 lbs has been dropped, and these accessibility guidelines continue to speak to the requirement of a maximum of 600 lbs that lifts and other accessibility features must be designed to accommodate.
Finally, it's good to recall that any guidelines, once finalized, would affect only future acquisitions of transit vehicles (including buses, over-the-road coaches, and vans that are used for public transit). Just as was the case when the current guidelines were issued in 1991, nothing about these rules would require any retrofitting of any transit vehicles in current use.
If you have concerns or expertise, it is vital that you submit comments on this proposal. Repeatedly, the Access Board's proposal notes items in which they have received contradictory or incomplete information from the field to inform their final guidelines, so they may really need to hear from you this time around.
Monday, July 26, 2010
House to Act Soon on Transportation Spending
Later this week (probably on Wednesday July 28 or Thursday July 29), the House is expected to vote on its version of FY 2011 Transportation-HUD appropriations.
As reported in a prior "Capitol Clips," the House spending bill would increase Federal Transit Administration (FTA) spending by 5 percent over current levels. Almost every dime of the transit increases proposed in the House legislation would go to increases in the FTA formula grant programs. It would appear the House is all but disregarding the Administration's request for funding its livable communities initiative (some funds are identified in the Secretary of Transportation's office budget for this), and is also disregarding the Administration's request for a multi-billion dollar infusion of funds into a national infrastructure bank.
It's harder to tell when the Senate will act on its version of Transportation-HUD appropriations. The Senate's version of this bill was approved by its Appropriations Committee on July 22, but the timing of Senate floor action is hard to predict. Its spending bill would not increase FTA programs by any significant amount. Although the Senate does not go along with the Administration's request for transportation funding of the livable communities program, it would call upon FTA and the Federal Highway Administration to jointly allocate $200 million of their planning capacity building funds to support planning efforts that better links transportation and housing.
In case you're looking to follow these bills more closely, it's good to note the bill numbers currently assigned to House and Senate bills: HR 5850 and S 3644, respectively.
As reported in a prior "Capitol Clips," the House spending bill would increase Federal Transit Administration (FTA) spending by 5 percent over current levels. Almost every dime of the transit increases proposed in the House legislation would go to increases in the FTA formula grant programs. It would appear the House is all but disregarding the Administration's request for funding its livable communities initiative (some funds are identified in the Secretary of Transportation's office budget for this), and is also disregarding the Administration's request for a multi-billion dollar infusion of funds into a national infrastructure bank.
It's harder to tell when the Senate will act on its version of Transportation-HUD appropriations. The Senate's version of this bill was approved by its Appropriations Committee on July 22, but the timing of Senate floor action is hard to predict. Its spending bill would not increase FTA programs by any significant amount. Although the Senate does not go along with the Administration's request for transportation funding of the livable communities program, it would call upon FTA and the Federal Highway Administration to jointly allocate $200 million of their planning capacity building funds to support planning efforts that better links transportation and housing.
In case you're looking to follow these bills more closely, it's good to note the bill numbers currently assigned to House and Senate bills: HR 5850 and S 3644, respectively.
Friday, July 2, 2010
Spending Bills Take One Step Forward in House
In the current Congressional climate, it's not really clear how next year's federal spending bills will be handled (okay, so most of the pundits, lobbyists, and other observers of the annual appropriations process are predicting that everything will be bundled into one or more catch-all, or "omnibus" appropriations bills after the November elections). Nevertheless, several subcommittees of the House Appropriations Committee did their part this week, right before Congress took off for the Independence Day recess.
This week's "markups" in these panels included FY 2011 appropriations for (i) Agriculture, (ii) Legislative Branch, (iii) State and Foreign Operations, (iv) Commerce, Justice and Science, and (v) Transportation and HUD.
Much can change between now and final enactment of the FY 2011 appropriations, especially in the absence of a SAFETEA-LU transportation reauthorization. However, the House "T-HUD" appropriations draft at least gives an indication of how transit and related programs may fare next year.
Overall, the House panel calls for a 5.4 percent increase in transit spending over this year's levels. That's an interesting figure, given President Obama's call for a "freeze" in domestic discretionary spending.
Here's how the House draft bill addresses aspects of the federal transportation program....
Within the Federal Transit Administration's (FTA) programs, the draft House bill would increase formula grant programs (known to most FTA grantees by their authorizing statutes as Sections 5307, 5310, 5311, 5316 [JARC] and 5317 [New Freedom]), together with funds for fixed guideway modernization and buses and bus facilities by 7.4 percent, to a total of nearly $9.0 billion. FTA's administrative and staff budget would increase $32 million over this year's amount; the Washington (DC) Metrorail system would receive another infusion of $150.0 million and FTA major capital funding for "new starts and small starts" (all of which are rail and fixed guideway projects) would remain at this year's level of $2.0 billion.
The House bill would provide $20 million to the Secretary of Transportation's office for "Livable Communities" investments. The Secretary's office would receive $400 million for more rounds of "TIGER" grants.
Within the rail program, the House bill would provide $1.4 billion for high-speed rail projects, and would provide nearly $1.8 billion to Amtrak for operating, capital and debt service expenses.
It's far to early in the process for anyone to be taking these figures to the bank, but if you want to read more, be sure to visit the House Appropriations Committee's website.
This week's "markups" in these panels included FY 2011 appropriations for (i) Agriculture, (ii) Legislative Branch, (iii) State and Foreign Operations, (iv) Commerce, Justice and Science, and (v) Transportation and HUD.
Much can change between now and final enactment of the FY 2011 appropriations, especially in the absence of a SAFETEA-LU transportation reauthorization. However, the House "T-HUD" appropriations draft at least gives an indication of how transit and related programs may fare next year.
Overall, the House panel calls for a 5.4 percent increase in transit spending over this year's levels. That's an interesting figure, given President Obama's call for a "freeze" in domestic discretionary spending.
Here's how the House draft bill addresses aspects of the federal transportation program....
Within the Federal Transit Administration's (FTA) programs, the draft House bill would increase formula grant programs (known to most FTA grantees by their authorizing statutes as Sections 5307, 5310, 5311, 5316 [JARC] and 5317 [New Freedom]), together with funds for fixed guideway modernization and buses and bus facilities by 7.4 percent, to a total of nearly $9.0 billion. FTA's administrative and staff budget would increase $32 million over this year's amount; the Washington (DC) Metrorail system would receive another infusion of $150.0 million and FTA major capital funding for "new starts and small starts" (all of which are rail and fixed guideway projects) would remain at this year's level of $2.0 billion.
The House bill would provide $20 million to the Secretary of Transportation's office for "Livable Communities" investments. The Secretary's office would receive $400 million for more rounds of "TIGER" grants.
Within the rail program, the House bill would provide $1.4 billion for high-speed rail projects, and would provide nearly $1.8 billion to Amtrak for operating, capital and debt service expenses.
It's far to early in the process for anyone to be taking these figures to the bank, but if you want to read more, be sure to visit the House Appropriations Committee's website.
Thursday, July 1, 2010
Ten More Days to Prepare those TIGER II Pre-Applications
Quick update: If you're interested in applying for the Dept of Transportation's "TIGER II" discretionary grants, you may be relieved to know that the deadline for submitting this program's required "pre-applications" has been extended, to July 26, 2010. The deadline for final applications remains August 23, 2010.
This competition is one of the recent flurry of grants and notices related to the DOT-HUD-EPA Partnership for Sustainable Communities and their commitment to promote livable communities. We recently summarized this effort both here and in the NRC's Express Stop blog. Details on the TIGER II program, including notices, FAQs, and more, can be found on the DOT's website at www.dot.gov/recovery/ost/TIGERII.
This competition is one of the recent flurry of grants and notices related to the DOT-HUD-EPA Partnership for Sustainable Communities and their commitment to promote livable communities. We recently summarized this effort both here and in the NRC's Express Stop blog. Details on the TIGER II program, including notices, FAQs, and more, can be found on the DOT's website at www.dot.gov/recovery/ost/TIGERII.
Friday, June 25, 2010
"Livability Money" soon to hit the streets?
All of a sudden, the offices at Dept of Transportation (DOT), Dept of Housing and Urban Development (HUD), and the Environmental Protection Agency (EPA) - the three members of the federal Partnership for Sustainable Communities - have started announcing funding opportunities and other initiatives in support of the federal agenda to support more livable communities.
If you'd like to read some details that seek to decode this latest flurry of activity, check out The Express Stop blog of my NRC staff colleague, Sheryl Gross-Glaser. She's got the answers. And if you're looking for money, act fast! There's a 30-day window for getting mandatory pre-applications submitted, and the clock is ticking. Interested applicants might want to dial in to a June 30 webinar on the topic hosted by our colleagues at PolicyLink.
As if the funds aren't exciting enough, the Federal Highway Administration and HUD just announced contracting flexibility (determined on case-by-case bases) to improve jointly-financed projects, effective right away, all in support of the federal government's livability principles, which are turning out to be a critical set of guideposts for all sorts of federal decision-making these days.
Looking for more information on this livability stuff? Check out the Livability Bookshelf on our National Resource Center website.
If you'd like to read some details that seek to decode this latest flurry of activity, check out The Express Stop blog of my NRC staff colleague, Sheryl Gross-Glaser. She's got the answers. And if you're looking for money, act fast! There's a 30-day window for getting mandatory pre-applications submitted, and the clock is ticking. Interested applicants might want to dial in to a June 30 webinar on the topic hosted by our colleagues at PolicyLink.
As if the funds aren't exciting enough, the Federal Highway Administration and HUD just announced contracting flexibility (determined on case-by-case bases) to improve jointly-financed projects, effective right away, all in support of the federal government's livability principles, which are turning out to be a critical set of guideposts for all sorts of federal decision-making these days.
Looking for more information on this livability stuff? Check out the Livability Bookshelf on our National Resource Center website.
Wednesday, June 16, 2010
On TANF & Transportation
A product of the 1996 "welfare reform," the Temporary Assistance for Needy Families (TANF) program has been around for more than a decade. Transportation plays a key role in this program's success, and TANF is an important financial partner in public transportation, too. Given the current state of states' budgets, and the current state of the national economy, with persistent high rates of unemployment, it's important to give TANF a fresh look.
First a bit of the basics. TANF has an annual appropriation of $16.5 billion, not including a significant expansion under the American Recovery and Reinvestment Act (ARRA). In the federal budget, TANF is mandatory spending, similar to Medicaid, Medicare, Food Stamps, and other so-called "entitlement" programs. The federal agency administering TANF is the Administration for Children and Families (ACF) within the Dept of Health and Human Services. According to ACF data, states currently are spending $400 million a year in their federal TANF funds on transportation, which they match with $44 million in state “maintenance-of-effort” funds for transportation services. ARRA created a one-time "TANF Emergency Fund" of $5 billion, which expires September 30, 2010.
When the 1996 Personal Responsibility and Work Opportunity Reconciliation Act eliminated the previous Aid to Families with Dependent Children (AFDC) program and replaced it with TANF, responsibility for establishing program rules, services and details were left largely in the hands of states. States receive TANF as a block grant, with allocations based primarily on their 1994 levels of AFDC spending. These amounts don't change, even when states' economies plummet and unemployment (and thus the degree of TANF demand) rises.
States often call their TANF programs by unique, state-specific, names, and set most of their own procedures for how TANF-related services are provided. States are not required to spend any of their TANF funds on transportation. But almost every state does, in some way or another, because the lack of transportation continues to be documented as one of the leading barriers to employment participation, especially among otherwise-unemployed single mothers (not surprisingly, the lack of child care continues to be the other leading barrier to employment participation among this segment of the "at-risk" population). States can provide transportation as part of the direct "assistance" they provide to TANF recipients (typically using vouchers, transit passes or related strategies), in which case TANF funds tend to follow the individual, are tracked closely for eligibility, and have to comply with the time limits and other person-specific requirements of TANF. This practice is especially prevalent at times like our current economy, when TANF-eligible populations are more numerous and demands on TANF resources are peaking. States also have the opportunity to provide TANF-related transportation as "non-assistance," meaning that they are helping to finance transportation networks that serve the needs of the TANF-eligible population, but not in ways that are directly delivered as benefits to individuals. For example, in the late 1990s, many states were using their TANF funds to match Federal Transit Administration "Job Access and Reverse Commute" grants to provide systems of transportation services addressing all low-income populations, not just the populations receiving direct TANF assistance.
The FTA/DOL Joblinks Employment Transportation Initiative, operated by the Community Transportation Association of America, has focused a lot of energy on TANF and created a host of TANF-related documents over its 12 years (and counting) of operation. This post is not meant to recap or replace that wealth of literature, but simply aims to point out a few reminders about TANF and transit programs.
The first reminder, as stated above, is that states have an abundance of flexibility and autonomy to create TANF-funded services in ways that suit their circumstances.
Second, TANF is one of the very few non-DOT grant programs for which federal agencies created guidance directing the relationship between TANF and FTA grants. Although it predates the current SAFETEA-LU authorization, there is a joint guidance document, officially issued by the Federal Transit Administration, the Employment and Training Administration (ETA), and the Administration for Children and Families, that explains, from each of these agencies' perspectives, how their funds - JARC, TANF, and the old Welfare-to-Work grants - can be used together. At the headquarters level, the staff of FTA, ETA and ACF all have said this guidance remains in force. It can be found on the FTA website at http://www.fta.dot.gov/funding/grants/grants_financing_3715.html
Third, SAFETEA-LU makes statutory references to TANF in its authorization for ALL of the Federal Transit Administration's formula grant programs:
Urban transit....
49 USC 5307(e)(4):
Elderly/Disabilities transit....
49 USC 5310(c)(3):
49 USC 5311(g)(4):
Job Access and Reverse Commute.....
49 USC 5316(h)(4):
New Freedom....
49 USC 5317(g)(4):
The above language was inserted in each of those portions of authorizing legislation specifically because Congress did not want there to be an impediment in the use of TANF funds (which is the reference to Section 403 of the Social Security Act) with regard to coordination with FTA funds. This is notable, in that it is the only statutory requirement of "coordination" that imposes a requirement on non-DOT programs; the language specifically addresses TANF as a partner in all FTA grants.
First a bit of the basics. TANF has an annual appropriation of $16.5 billion, not including a significant expansion under the American Recovery and Reinvestment Act (ARRA). In the federal budget, TANF is mandatory spending, similar to Medicaid, Medicare, Food Stamps, and other so-called "entitlement" programs. The federal agency administering TANF is the Administration for Children and Families (ACF) within the Dept of Health and Human Services. According to ACF data, states currently are spending $400 million a year in their federal TANF funds on transportation, which they match with $44 million in state “maintenance-of-effort” funds for transportation services. ARRA created a one-time "TANF Emergency Fund" of $5 billion, which expires September 30, 2010.
When the 1996 Personal Responsibility and Work Opportunity Reconciliation Act eliminated the previous Aid to Families with Dependent Children (AFDC) program and replaced it with TANF, responsibility for establishing program rules, services and details were left largely in the hands of states. States receive TANF as a block grant, with allocations based primarily on their 1994 levels of AFDC spending. These amounts don't change, even when states' economies plummet and unemployment (and thus the degree of TANF demand) rises.
States often call their TANF programs by unique, state-specific, names, and set most of their own procedures for how TANF-related services are provided. States are not required to spend any of their TANF funds on transportation. But almost every state does, in some way or another, because the lack of transportation continues to be documented as one of the leading barriers to employment participation, especially among otherwise-unemployed single mothers (not surprisingly, the lack of child care continues to be the other leading barrier to employment participation among this segment of the "at-risk" population). States can provide transportation as part of the direct "assistance" they provide to TANF recipients (typically using vouchers, transit passes or related strategies), in which case TANF funds tend to follow the individual, are tracked closely for eligibility, and have to comply with the time limits and other person-specific requirements of TANF. This practice is especially prevalent at times like our current economy, when TANF-eligible populations are more numerous and demands on TANF resources are peaking. States also have the opportunity to provide TANF-related transportation as "non-assistance," meaning that they are helping to finance transportation networks that serve the needs of the TANF-eligible population, but not in ways that are directly delivered as benefits to individuals. For example, in the late 1990s, many states were using their TANF funds to match Federal Transit Administration "Job Access and Reverse Commute" grants to provide systems of transportation services addressing all low-income populations, not just the populations receiving direct TANF assistance.
The FTA/DOL Joblinks Employment Transportation Initiative, operated by the Community Transportation Association of America, has focused a lot of energy on TANF and created a host of TANF-related documents over its 12 years (and counting) of operation. This post is not meant to recap or replace that wealth of literature, but simply aims to point out a few reminders about TANF and transit programs.
The first reminder, as stated above, is that states have an abundance of flexibility and autonomy to create TANF-funded services in ways that suit their circumstances.
Second, TANF is one of the very few non-DOT grant programs for which federal agencies created guidance directing the relationship between TANF and FTA grants. Although it predates the current SAFETEA-LU authorization, there is a joint guidance document, officially issued by the Federal Transit Administration, the Employment and Training Administration (ETA), and the Administration for Children and Families, that explains, from each of these agencies' perspectives, how their funds - JARC, TANF, and the old Welfare-to-Work grants - can be used together. At the headquarters level, the staff of FTA, ETA and ACF all have said this guidance remains in force. It can be found on the FTA website at http://www.fta.dot.gov/
Third, SAFETEA-LU makes statutory references to TANF in its authorization for ALL of the Federal Transit Administration's formula grant programs:
Urban transit....
49 USC 5307(e)(4):
"Use of certain funds. - The prohibitions on the use of funds
for matching requirements under section 403(a)(5)(C)(vii) of
the Social Security Act (42 U.S.C. 603(a)(5)(C)(vii)) shall
not apply to the remainder [ie, the non-FTA share of project costs]"
Elderly/Disabilities transit....
49 USC 5310(c)(3):
"Use of certain funds. - For purposes of paragraph (2)(B)Rural transit....
[defining the non-FTA share of project costs], the prohibitions
on the use of funds for matching requirements under section
403(a)(5)(C)(vii) of the Social Security Act (42 U.S.C.
603(a)(5)(C)(vii)) shall not apply to Federal or State
funds to be used for transportation purposes."
49 USC 5311(g)(4):
"Use of certain funds. - For purposes of paragraph (3)(B)
[defining the non-FTA share of project costs], the prohibitions
on the use of funds for matching requirements under section
403(a)(5)(C)(vii) of the Social Security Act (42 U.S.C.
603(a)(5)(C)(vii)) shall not apply to Federal or State
funds to be used for transportation purposes."
Job Access and Reverse Commute.....
49 USC 5316(h)(4):
"Use of certain funds. - For purposes of paragraph (3)(B)
[defining the non-FTA share of project costs], the prohibitions
on the use of funds for matching requirements under section
403(a)(5)(C)(vii) of the Social Security Act (42 U.S.C.
603(a)(5)(C)(vii)) shall not apply to Federal or State
funds to be used for transportation purposes."
New Freedom....
49 USC 5317(g)(4):
"Use of certain funds. - For purposes of paragraph (3)(B)
[defining the non-FTA share of project costs], the prohibitions
on the use of funds for matching requirements under section
403(a)(5)(C)(vii) of the Social Security Act (42 U.S.C.
603(a)(5)(C)(vii)) shall not apply to Federal or State
funds to be used for transportation purposes."
The above language was inserted in each of those portions of authorizing legislation specifically because Congress did not want there to be an impediment in the use of TANF funds (which is the reference to Section 403 of the Social Security Act) with regard to coordination with FTA funds. This is notable, in that it is the only statutory requirement of "coordination" that imposes a requirement on non-DOT programs; the language specifically addresses TANF as a partner in all FTA grants.
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