Internal Ethics and Compliance Required

Organizations must demonstrate compliance with Title 43 Texas Administrative Code §25.906(b) by certifying adoption of an internal ethics and compliance program that satisfies the requirements of Title 43 Texas Administrative Code §10.51 (relating to Internal Ethics and Compliance Program).
TxDOT’s Compliance Division (CMP) will need to review and approve each agency's Internal Compliance Program (ICP) prior to any grant execution.
For a new agency or an agency that the ICP is determined out of compliance, one of the following two processes will be used to review and approve the agency’s ICP:
Process 1:
  1. The BTS Section Director will notify CMP on which agencies need to have their ICPs reviewed.
  2. CMP will review the agencies’ policies and either approve or deny compliance of the ICP. If an agency’s ICP is not approved, CMP will work with the agency to recommend ways to bring their policies into compliance.
  3. CMP will inform the agency and the BTS Program Planner of the status of the ICP.
  4. The BTS Program Planner will relay information on the status of the ICP to lead workers and/or supervisors.
Process 2:
  1. The BTS Project Manager will notify a Selective Traffic Enforcement Program (STEP) agency if they are eligible to self-certify their agency’s ICP using Form 2433.
  2. Eligible STEP agencies will complete Form 2433 and provide it to the Project Manager.
  3. The Project Manager will inform BTS lead workers for tracking.
  4. The agency or Project Manager will upload Form 2433 to the eGrants ICP page under Organizational Information.
An agency can self-certify under the following specific conditions: 1) if applying for an IDM/CIOT grant, or 2) if the agency previously had an IDM/CIOT or yearlong grant and is requesting a yearlong grant of $12,000 or less.
Allegations of fraud, waste, abuse or non-compliance with grant requirements could lead to an Internal Ethics & Compliance Program effectiveness review to ensure the agency is following their approved Internal Compliance Program.
Each agency's Internal Compliance Program must be submitted for review and approval by TxDOT every five years.