A: Yes. FTA Circular 5010.1E provides that such use must not conflict with the approved purposes of the asset and must not interfere with the intended transit uses of the project property. An acceptable incidental use, such as meal or grocery delivery, does not affect a property’s transit capacity. In cases where a recipient has reduced service levels in response to COVID-19, the recipient may utilize FTA funded assets for other emergency response activities as long as such use does not interfere with its remaining limited service.
A: Yes. Recipients may establish new routes that serve critical community needs at any time. If a recipient provides exclusive transportation for schoolchildren to meal sites, and the service is funded by a third-party, such service would be categorized as a charter service. Although normally prohibited under FTA formula funding, charter service is eligible for COVID-19 response for up to 45 days from the beginning of each state of emergency incident period. For charter services lasting longer than 45 days, the recipient should submit a request to the Emergency Relief Docket.
A: CTAA recommends the use of larger vehicles where feasible to allow for greater social (physical) distance between vehicle occupants. CTAA also suggests, reserving a limited collection of vehicles for such trips, thereby limiting potential exposure and necessary additional cleaning and disinfectant procedures.
A: You should contact local and state public health officials, who generally coordinate information with the Centers for Disease Control and Prevention (CDC), to determine under what circumstances service may be denied to any transit rider.
A: CTAA recommends N95 masks (or the Chinese equivalent KN-95). If you are unable to acquire N95 (or the Chinese equivalent KN-95), CTAA recommends the use of masks/face coverings to slow the spread of the virus and help people who may have the virus and do not know it from transmitting it to others.
A: CTAA recommends you check with your state’s public health department and Medicaid agency, regardless of your status as an NEMT provider. The recommendations regarding this question update frequently and are often state or local decisions. Therefore, whatever decision you may choose, it should be made in conjunction with your local public health officials.
A: If you think it is necessary for your system to suspend service, you should connect with your local and state public health officials. If you mutually agree that is the best decision, you must inform the FTA.
A: Yes, if the training costs are explicit in the award document and the recipient cannot renegotiate or obtain a refund of the costs, Section 5311 RTAP funds may be used to pay the fees.

A: The DOT ADA regulations do not explicitly require the use of the securement system; an entity may determine for itself whether or not securement will be mandatory for their systems. You are therefore free to suspend any mandatory securement policy that you may have in place. However, if an individual passenger makes a request for assistance, you must do so.

CTAA has released best practices on wheelchair securement in light of this pandemic.

Regulatory FAQs

A: Yes. The FTA has issued a Notice of Enforcement Discretion stating that, until December 31, 2020, in light of the extraordinary operational challenges presented by the COVID-19 public health emergency, FTA will refrain from taking enforcement action pursuant to 49 U.S.C. § 5329(g) and the FTA Master Agreement (26) (October 1, 2019) against any FTA recipient or subrecipient subject to the PTASP regulation that is unable to certify that it has established an Agency Safety Plan that complies with the regulation. This Notice will remain in effect until Dec. 31, 2020.
A: Yes. Recipients may delay submission by up to 90 days. A recipient’s next report, therefore, would be for the quarter ending June 30, 2020, with the report due on July 30, 2020.
A: Yes, FTA has postponed the remaining fiscal year 2020 program oversight reviews (triennial, state management, etc.) until early in federal fiscal year 2021.
A: You should continue to comply with existing applicable DOT Agency requirements to document why a test was not completed. If training or testing can be conducted later (e.g., supervisor reasonable suspicion training at the next available opportunity, random testing later in the selection period, follow-up testing later in the month), you are to do so in accordance with applicable modal regulations. If you are unable to conduct DOT drug and alcohol testing due to the unavailability of testing resources, the underlying modal regulations continue to apply. For example, without a “negative” pre-employment drug test result, an employer may not permit a prospective or current employee to perform any DOT safety-sensitive functions.
A: Generally, procurement of goods and services by transit agencies must be completed via a competitive procurement. However, the Uniform Guidance at 2 CFR 200.320 permits sole source contracting when the public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation; or the federal awarding agency expressly authorizes noncompetitive proposals in response to a written request from the transit agency. The recipient must document its sole source justification in writing.


A: Funds available under the CARES Act are available for all operating activities (net fare revenues) that occur on or after January 20, 2020 are eligible. The CARES Act funding can be used for administrative leave, such as leave for employees due to reductions in service or leave required for a quarantined worker. Additionally, funding may be used for any purchases made due to necessity by COVID-19. Funding may also be used to make up lost revenue that occurred because of the virus.
A: No. States and designated recipients have flexibility to allocate CARES Act funding through a different process than the one described in a previously approved State Management Plan, without prior FTA approval. States should document any deviations in an attachment to the CARES Act funding application.
A: No. The funds are available until expended.
A: Yes, funding under the CARES Act can be used to reimburse operating costs associated with providing fare-free service.

A: Yes. This may be categorized as an emergency protective measure taken to protect public health and safety. The employee must be in pay status to be an eligible expense.

A: Administrative leave is an administratively authorized absence from duty without loss of pay or reduction in an employee’s available leave. In the context of the COVID-19 public health emergency, administrative leave could include, but is not limited to, leave for an employee who is not required to work due to a reduction in service or leave for a worker who is quarantined after potential exposure to an individual infected with COVID-19.
A: Yes. Purchases necessary to continue operations in the present emergency are allowed. Items such as laptops, remote secure access (RSA) keys, monitors, printers, etc. are eligible regardless of their relation to COVID-19 response when purchased using CARES Act funds for eligible transit purposes. When purchased using previously apportioned Urbanized Area Formula program (Section 5307) or Rural Areas Formula program (Section 5311) funds using expanded eligibilities under FTA’s Emergency Relief program, the recipient must document the relationship of such purchases to COVID-19 response.
A: No, at this time there is no additional supplemental funding available for 5310 recipients.

The Community Transportation Association of America (CTAA) and its members believe that mobility is a basic human right. From work and education to life-sustaining health care and human services programs to shopping and visiting with family and friends, mobility directly impacts quality of life.