236.12 Quality Assurance Reviews
236.12.1 Introduction
The Central Office right of way staff members coordinate periodic reviews of district office operating procedures to promote and ensure quality assurance of the acquisition process, realty asset activities and compliance with The Uniform Act.
236.12.2 Organization and Job Functions
236.12.2.1 Authority
The Asst. to the State Design Engineer - Right of Way will approve the Quality Assurance Review (QAR) plan. Consideration should be given to scheduling these routine reviews so all districts are reviewed in at least one functional area. Districts scheduled for review are to be advised in advance of the review.
The Asst. to the State Design Engineer - Right of Way may substitute a QAR with comparable reviews similar to the following:
- Joint Process Review,
- Peer Review,
- Internal Audit or
- External Audit.
If comparable reviews are conducted, the Asst. to the State Design Engineer - Right of Way may waive a QAR at their discretion.
236.12.2.2 QAR Administration
The QAR team is led by a designated right of way liaison within the right of way section of Design Division. The QAR team will coordinate the QAR and be responsible for identifying division/district participants and ensure completion in a timely manner.
The QAR team lead has the overall responsibility for selection, training and supervising the QAR team and shall coordinate the following:
The QAR team will also be responsible for ensuring the QAR recommendations are monitored for implementation.
236.12.3 QAR Process
236.12.3.1 Purpose
To develop policies and methods of continuously evaluating the quality of all right of way functions statewide through a quality assurance process. Also, to develop best practices as processes are reviewed and constantly improved.
236.12.3.2 Background
This article contains the regulations, requirements, and procedural directives governing the operation of the right of way section.
Federal regulations governing right of way acquisition are found in 23 CFR (Code of Federal Regulations) and 49 CFR Part 24 and 7 CSR (Code of State Regulations) Chapter 4 10-4.010-.020. Compliance with these regulations are required for every MoDOT project. The policies and procedures outlined in the above-mentioned manual are written to include all state and federal requirements.
236.12.3.3 Definitions
Critical Requirement: A measurable activity in a departmental process that indicates whether or not the process is being properly carried out and if the quality of the product is being controlled. A critical requirement could reveal significant problems or indicate beneficial results for the department.
Critical Problem Area: An area where critical requirements indicate a process is not in compliance with predetermined criteria.
Outstanding Quality Area: An area of unique superior performance due to magnitude of effort or innovation in concept or application.
Quality Assurance: Conformance to predetermined criteria. Quality assurance refers primarily to process requirements in this procedure.
Quality Assurance Monitoring Plan: A monitoring plan based on critical requirements prepared by the right of way quality assurance administrative team leader to outline the criteria, frequency and methods for conducting QARs.
Quality Assurance Guidelines: Step by step guideline for conducting QARs.
QAR Report: The written report of the results of a Quality Assurance Review.
Recommendations: Significant issues/items that require action.
Source Documents: Document in which data collected for a QAR is first recorded.
236.12.3.4 Procedure
The Asst. to the State Design Engineer - Right of Way will designate a quality assurance administrative team lead by a right of way liaison who will establish and direct QARs of all districts and certain division office units, which implement the MoDOT’s right of way program.
The right of way section through the quality assurance administrative team leader will establish and maintain complete, current and usable directives, and respective guidelines.
The quality assurance administrative team leader will establish and maintain current review plans based on critical requirements identified in each functional area or process.
The quality assurance administrative team leader will select QAR team members, each with expertise in the respective QAR. Members shall not monitor their own district. Team members are to be selected from the appropriate right of way personnel including the FHWA realty officer.
District and division participants in QARs will identify for the quality assurance administrative team, possible need for training; improvements to procedures, guidelines; and problems or innovations of statewide significance.
The quality assurance administrative team will report the final results of QAR to the Asst. to the State Design Engineer - Right of Way.
The right of way section will evaluate the quality assurance results, make improvements to procedures and processes, conduct appropriate training, circulate to all districts applicable outstanding results, record the summary of the results and responses to each review and track problem areas until they are corrected or resolved.
236.12.4 QAR Plan
236.12.4.1 QAR Plan
This document establishes the minimum standard for right of way section’s QAR plan.
236.12.4.2 Schedule
A schedule will show the dates of review by the QAR team.
236.12.4.3 Notice
Prior to the review, a notice shall be sent to the district right of way managers to ensure that all parties are aware of the review. This notice will contain the following:
- Identify team members.
- The anticipated dates the reviews will begin and be completed.
- The functional areas that will be reviewed.
- The desired date for scheduling of the recommendation reviews.
236.12.4.4 Reviews
The purpose of each review is to determine compliance with right of way processes and procedures in each of the functional areas being reviewed.
Each review will be conducted in accordance with the approved source documents. Compliance with the functional area will be determined by examination of each. It will be the responsibility of the right of way liaison to ensure that the scope of the review is sufficient to support a determination regarding compliance or noncompliance with the functional areas being reviewed.
236.12.4.5 Recommendation Reviews
Recommendation reviews will be held at the conclusion of each review. The right of way manager will be requested to attend along with any other supervisory personnel responsible for the functional area being reviewed. The review team will advise the district/division office of factual findings of the review. No conclusions regarding compliance or recommendations for corrective action will be provided at this interview.
Each recommendation review will include a discussion of current procedures. The right of way manager will be provided an opportunity to discuss the procedures and make recommendations for changes. A discussion of these recommendations and the actions taken will be included in the QAR Report.
236.12.4.6 Reports
Within fifteen (15) working days of completion of the review, a written draft report will be provided to the district right of way manager. The format of this report will be in accordance with the format adopted for all QAR Reports. The district will be permitted fifteen (15) working days within which to comment regarding the accuracy of the factual data in the draft report. It is not expected that the district will fully respond to the conclusions or the recommendations as reflected in the draft report.
A final report will be completed within fifteen (15) working days of receipt of the comments or expiration of the review period. Extensions to the review period may be granted at the discretion of the Asst. to the State Design Engineer - Right of Way, upon request from the district.
The final report will be provided to the Asst. to the State Design Engineer - Right of Way, district and FHWA and the findings and recommendations will be retained in the division office. A review period of thirty (30) days will be allowed for response to the findings and recommendations within the report. It is the responsibility of the QAR administrative team leader to ensure that appropriate responses are obtained to each recommendation contained in the report. The agreed upon responses are to be filed with the report.
236.12.5 QAR Guideline
236.12.5.1 Plan
Schedule QARs
Each year, coordinate with appropriate units and develop a schedule for reviews. Avoiding overlapping reviews or overloading, and adjust if necessary.
QAR Team
Assign the most knowledgeable staff.
Team members conducting the review should adequately prepare prior to the execution of the review.
Review Past QARs
Review reports from management, Audits and Investigations, FHWA and others.
Identify unresolved areas of noncompliance and areas marked for improvement.
Plan QAR Content
Base the QAR on right of way procedures and processes. Be sure supporting procedures, rules, statutes and critical requirements are current, correct and available to participants.
Prepare a list of activities and/or documentation that supports critical requirements.
236.12.5.2 Conduct
Notify district/division office of QAR Content.
Prior to the QAR, notify districts/division office of all areas to be covered.
Conduct Review
Focus on right of way processes and procedures.
Cover critical requirements and source documents.
At the initial meeting reconfirm:
- Where the work will be performed.
- Procedures for obtaining files and copies.
- District contact person for assistance.
Look for positive areas as well as noncompliance.
Base the QAR on critical requirements and unresolved issues from prior QARs.
Verify that previous corrective action is effective.
When the critical requirements indicate a problem exists, follow up and verify the problem and its magnitude.
Review parallel issues identified in audits performed by Audits and Investigations, by the FHWA and other performance reports.
Talk with district/division office staff.
Take complete notes of specifics and impressions.
Prepare for recommendation reviews. QAR team leader and team members should review and analyze information; organize presentation.
236.12.5.3 Conduct Recommendation Review with District/Division Office Staff
Arrange a meeting for all participants.
Prepare a list of general impressions; cite specifics only when necessary to illustrate the magnitude of the praise or issue.
Clearly state urgent or high impact issues.
Be prepared for discussion (anticipate questions, develop appropriate responses, etc.).
Agree on appropriate items for district and division office action.
Take notes to help with development of the written QAR Report.
Include general items (impressions, findings that indicate lack of quality control or attention to detail).
If an issue can be immediately corrected, report the corrective action rather than a negative finding.
Discuss all issues you expect to include in the QAR Report.
Ask district/division office staff for specific recommendations to improve procedures, meeting requirements, training, and statewide problems. Identify areas that are inefficient or that adversely impact other areas.
Emphasize steps that will follow the review. For example, clarification or additional information may be requested during report preparation.
236.12.5.4 Prepare QAR Report
Prepare draft report and send to the district/division office. Content of the report should reflect what was discussed at the recommendation review.
Address action items in report.
Work to resolve disagreements regarding report contents.
Contact the district/division office if a response is not received within fifteen (15) working days after receipt of draft report.
Prepare final report and send to district/division office within fifteen (15) working days after receipt of comments to the draft report.
Share outstanding methods or issues without identifying the source of the issue.
236.12.5.5 Track Critical Issues until Remedied or Resolved
Track the corrective action and/or make a follow-up visit. Disagreements with report recommendations are resolved through upper management. The Asst. to the State Design Engineer - Right of Way is the final arbiter.
236.12.6 QAR Report
236.12.6.1 Purpose And Scope Of Review
This report summarizes the results of the QAR conducted. The review was done to assess process performance relating to critical functions such as:
- Administration
- Appraisal
- Negotiations
- Realty Asset
- Relocation
- Right of Way Parcel Acquisition (RWPA) and Realty Asset Inventory (RAI) with in the Transportation Management System (TMS).
Identify those areas in which there may be a need for closer adherence to existing process standards or indications that the existing process standards warrant modification.
Identify best practices that may be shared with other districts to the benefit of the overall right of way program.
236.12.6.2 QAR Team Members
List the names of those that performed the review.
236.12.6.3 Background
Titles 23 and 49 of the Code of Federal Regulations and 7 CSR (Code of State Regulations) Chapter 4 10-4.010-.020 broadly mandate the state's responsibilities for compliance with the provisions of the Uniform Relocation Assistance and Real Property Acquisition Regulations, Federally Assisted Programs. To assure proper recognition of, and adherence to, those regulations, MoDOT has developed, with the approval of the FHWA, procedures covering all aspects of right of way acquisition, management, and disposition. These procedures provide the basis for the periodic QAR of all current processes.
Provide the date of the last review.
Follow-up of recommendations from previous reviews.
236.12.6.4 Methodology and Findings
Sampling Technique
A letter notifies all right of way managers of the scheduled reviews. This letter identifies the critical functions that are to be reviewed, the calendar period that would be covered, and the dates the review will be conducted.
In the schedule, the administration, appraisal, negotiation, realty asset, relocation, RWPA and RAI files have been reviewed and all functions are then discussed during the recommendation review.
Sample Reviewed and Findings
Samples may be reviewed from any or all of the following categories: administration, appraisals, negotiations, realty assets, relocation, RWPA and RAI. The files reviewed for each category shall be documented.
Note the following information for the files that were reviewed:
- Project No.
- Route
- County
- Parcel No.
- Findings
Recommendation Review
At the conclusion of the review a brief recommendation review is conducted.
Note the following items in the report:
- Names of district personnel who were present;
- Who conducted the interview;
- A discussion of positive/negative findings in the report;
- Recommendation review responses; and
- Follow-up on previous recommendations.
236.12.6.5 Conclusion and Recommendations
Clearly state the conclusions and recommendations contained in the report.