Compliance information

Titles II and III of the Americans with Disabilities Act (1990) provide that no entity shall discriminate against an individual with a disability in connection with the provision of a transportation service. The law sets forth specific requirements for vehicles and facilities accessibility and the provision of service.

• ADA Circular
• RTAP ADA Toolkit
• Title 49 CFR Part 37, Transportation Services for Individuals with Disabilities 
• Title 49 CFR Part 38, Americans with Disabilities Act (ADA) Accessibility Specifications for Transportation Vehicles 
• Title 49 CFR Part 27, Nondiscrimination on the Basis of Disability in Programs or Activities Receiving Federal Financial Assistance 
• MDOT OPT ADA Complaint and Reasonable Modification Policy Template Bus
• MDOT OPT ADA Complaint and Reasonable Modification Policy Template Marine
• MDOT OPT Service Animal Policy Template
• MDOT OPT Oxygen and Respirator Policy Template

FTA grantees are prohibited from using federally funded equipment and vehicles to provide charter service. All formal charter complaints must be filed with the Federal Transit Administration as described in the federal regulations.

• FTA Charter Rule and Guidance
• FTA Charter Service Regulations
• FTA Charter Bus Service Registration
• MDOT OPT Charter Exceptions and Quarterly Reporting Instructions
• MDOT OPT Charter Exceptions Quarterly Report Form
• 49 CFR 604, Charter Service
• Charter Fact Sheet
• FTA Demand Responses vs Charter Service Fact Sheet
• MDOT OPT Charter Guidance

Cost allocation is the assigning of costs that jointly benefit two or more cost objectives (indirect costs). A cost objective is any activity or item for which you want to separately measure costs.

• CAP Guidance Document
• FTA Circular C 5010.1E Appendix F Cost Allocation Plans

Agencies must maintain satisfactory and continuous control over federally funded facilities and equipment and ensure they are used properly in transit service.

• FTA Circular 5010.1E
• FTA Circular 9040.1G
• FTA Circular 9070.1G
• Equipment Disposal Request (Form 3651)
• MDOT OPT Incidental Use Form

MDOT and its subrecipients are prohibited from providing exclusive school bus service unless the service qualifies and is approved by the FTA Administrator under an allowable exemption. Federally funded equipment or vehicles cannot be used to provide exclusive school bus service. School tripper service that operates and looks like all other regular service is allowed. FTA defines tripper service as regularly scheduled transit service that is open to the public and that is designed or modified to accommodate the needs of school students and personnel, using various fare collection and subsidy systems.

• 49 CFR 605
• MDOT OPT School Bus Service Guidance

Title VI of the Civil Rights Act of 1964 prohibits discrimination based on race, color, or national origin in programs and activities receiving Federal financial assistance. Specifically, Title VI provides that “no person in the United States shall, on the ground of race, color, or national origin. Be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance. (42 U.S.C. §2000d). FTA requires that Title VI plans be updated every three years, and agencies must submit their next update in 2020.

• FTA Circular 4702.1B
• FTA Title VI Guidance
• LEP Data Resources and Instruction Guide 
• Promising Practices for Meaningful Public Involvement in Transportation Decision-Making 
• 49 CFR 21, Nondiscrimination in Federally-Assisted Programs of the Department of Transportation – Effectuation of Title VI of the Civil Rights Act of 1964
• "I Speak" Language Identification Flashcard
• 2023 Title VI Policy Agency Template
• Title VI Program Checklist

Transit agencies are required by contract to maintain vehicles throughout their useful life. This maintenance must conform to at least the manufacturer’s minimum recommended service levels.

Agencies are required to submit a written vehicle maintenance plan to MDOT OPT for review and approval. Any subsequent additions or changes must also be approved before they become effective.

The OPT compliance analyst will conduct an onsite review of each transit agency’s vehicle maintenance program on at least a triennial basis. The review consists of a random sampling (20 percent of the fleet or a maximum of 10 vehicles) of vehicle maintenance records for compliance with the approved plan. Maintenance reviews are usually scheduled and completed in conjunction with the triennial FTA compliance review.

• Field Visit Report Vehicle Maintenance Monitoring Program Summary
• Preventive Maintenance Manual
• Vehicle Maintenance Monitoring
• Vehicle Maintenance Review Preparation Guide
• MDOT OPT Sample Vehicle Maintenance Plan Template
• Vehicle Safety Inspection Checklist

• Compliance Review Preparation Guide for Section 5310
• Compliance Review Preparation Guide for Section 5311
• MDOT OPT Compliance Review Report
• FTA FY 2026 Contractor's Manual