Phase: Applied learning · Worked scenarios · Calculations · Audit findings · Document drills
Apply what you've read — scenario by scenario, calculation by calculation
Delegation, RBPI, $100M/$500M thresholds, responsible charge. Each exercise has a hidden solution — work through your answer before revealing.
I
Scenario 01
Which projects need a financial plan?
Setup
The City of Modesto is planning three federal-aid projects:
• Project A: $80M total cost
• Project B: $250M total cost
• Project C: $600M total cost
Question
For each project, what financial planning and management documents are required?
Solution
Project A ($80M): Standard procedures. No PMP, IFP, FPAU, or CSRA required. Standard LAPM 3-A and PSA.
Project B ($250M — Mini-Major): Prepare IFP and FPAU. The Financial Plan must be approved prior to Construction Authorization and submitted with the Construction Authorization request. No PMP or CSRA required.
Project C ($600M — Major Project): Full requirements: PMP + IFP + FPAU + CSRA. Draft PMP submitted before IFP finalization. CSRA completed by FHWA before Final NEPA AND before construction authorization. FHWA HQ concurrence required for IFP approval. FPAU due no later than 90 days after end of annual reporting period.
Major Projects are also RBPI screening candidates (23 USC 106(h)).
Authority: LAPM Ch 2 §2.9
Scenario 02
Designating the responsible charge
Setup
A small city of 12,000 has its first federal-aid project — a $4M road rehab. The City Engineer is a contracted consultant (the city does not have a full-time engineering staff). The city wants to designate the consultant City Engineer as the person in responsible charge.
Question
Is this permitted? If not, what are the options?
Solution
Not permitted. Under 23 CFR 172.9, the LPA must designate a full-time, public employee in responsible charge. A consultant cannot serve in this role, regardless of title.
Options:
1. Designate a full-time public employee (e.g., the Public Works Director, City Manager, or other full-time city employee) as responsible charge. The regulation is silent about engineering credentials — they need not be an engineer.
2. The responsibilities may be shared among public employees. So if no single full-time employee can absorb the workload, multiple employees can split the responsible charge duties.
3. Contract with a larger LPA (e.g., the County) to administer the project on the city's behalf — see LAPG Ch 25 for service contract framework.
Note: the same public employee can serve as responsible charge of multiple projects. This is the standard solution for jurisdictions with many small federal-aid projects.
Authority: LAPM Ch 2 §2.12.2; 23 CFR 172.9
II
Calculation 01
When do records retention obligations end?
Given
A federal-aid project completes construction on March 15, 2024. The LPA submits the FROE on July 1, 2024. Caltrans finalizes invoicing and transmits the final voucher to FHWA on January 12, 2025.
Find
On what date does the 3-year records retention requirement expire?
Worked solution
Workings
- LAPM Ch 2 §2.12.4: "Project records are to be retained by LPAs for a period of three years once Caltrans transmits the final voucher to FHWA."
- Trigger date: January 12, 2025 (final voucher transmission), NOT construction completion or FROE submission.
- Retention expires: January 12, 2025 + 3 years = January 12, 2028.
Answer: January 12, 2028. Note this is nearly 4 years after construction completion — the FROE/voucher pipeline extends the retention period.
Authority: LAPM Ch 2 §2.12.4; 2 CFR 200.334
III
Audit Finding 01
Read the fact pattern — what's the finding?
Facts
A 2026 CIAO Pre-Award audit reviews an LPA seeking a first Master Agreement. The audit identifies that the LPA has no written conflict of interest policy covering employees engaged in award and administration of federal-aid contracts.
Analysis
What is the finding, citation, and corrective action?
Finding · Citation · Corrective action
Finding: Non-compliance with 49 CFR 19.36(b)(3): "grantees and subgrantees will maintain a written code of standards of conduct governing the performance of their employees engaged in the award and administration of contracts. No employee, officer, or agent shall participate in selection, award, or administration of a contract supported by federal funds if a conflict of interest, real or apparent, would be involved."
Citation: 49 CFR 19.36(b)(3); LAPM Ch 2 §2.11.3 (Caltrans implements via Deputy Directive DD-09-R5).
Corrective action: LPA adopts a written code of standards of conduct prior to Master Agreement execution. Document the policy with the LPA's authorizing resolution. Pre-Award audit findings must be resolved before the Master Agreement can be processed (LAPM Ch 4 §4.4).
Authority: LAPM Ch 2 §2.11.3; 49 CFR 19.36(b)(3); LAPM Ch 4 §4.4
Audit Finding 02
Read the fact pattern — what's the finding?
Facts
A maintenance review for the City of Riverbank in FFY 2026 identifies that the bicycle/pedestrian path completed in 2022 with federal STBGP funds has not been swept in over 18 months and shows significant pavement damage from root intrusion that has not been remediated.
Analysis
Under what authority does this become a federal finding? What is the LPA's obligation?
Finding · Citation · Corrective action
Authority: 23 USC §116 requires that the State (Caltrans) maintain or arrange for maintenance of facilities constructed with federal-aid. Through the Master Agreement, the LPA assumes this maintenance obligation. Caltrans maintenance reviews under the 4-year cycle (LAPM Ch 2 §2.11.6) verify ongoing compliance.
Finding: Failure to maintain the federally-funded facility in a condition that preserves the federal investment.
Corrective action: LPA must implement and document a maintenance plan addressing both the sweeping schedule and the structural pavement damage. Continued non-compliance can affect the LPA's standing for future federal-aid awards. The LPA may need to repair the damage with non-federal funds, since federal participation in routine maintenance is generally not allowed.
Authority: LAPM Ch 2 §2.11.6; LAPM Ch 18; 23 USC §116
Applied learning · Companion chapter
These exercises apply the procedural framework presented in LAPM Chapter 02: Roles and Responsibilities. For the full chapter reference, glossary, and recall quiz, see the deep chapter file.