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TRANSPORTATION GRANTS:

Applicants Cited Benefits of Combined Application, but DOT Should Improve Transparency

GAO-25-107458. Published: May 22, 2025. Publicly Released: May 22, 2025.

TRANSPORTATION GRANTS

Applicants Cited Benefits of Combined Application, but DOT Should Improve Transparency

Report to Congressional Committees

May 2025

GAO-25-107458

United States Government Accountability Office

Highlights

For more information, contact Elizabeth Repko at repkoe@gao.gov.

Highlights of GAO-25-107458, a report to congressional committees

May 2025

transportation grants

Applicants Cited Benefits of Combined Application, but DOT Should Improve Transparency

Why GAO Did This Study

Federal discretionary transportation grants provide funding to help build the nation’s infrastructure. DOT combined the solicitation and evaluation processes for three such grant programs into the MPDG program. In December 2023 and January 2024, DOT announced $5.6 billion in MPDG awards for the fiscal year 2023-2024 funding round. 

The Infrastructure Investment and Jobs Act includes provisions for GAO to review the adequacy and fairness of two of the three individual grant programs in the MPDG program. This report assesses, for the fiscal year 2023-2024 MPDG program, (1) applicants’ views on DOT’s combination of three discretionary grant programs into the MPDG program, and (2) the extent to which DOT documented its criteria and rationale for selecting MPDG grant applications.

GAO reviewed DOT's notice of funding opportunity and evaluation plan; analyzed application and award data; and interviewed DOT officials. GAO also conducted a survey of all 236 applicants that submitted projects DOT determined were eligible to receive fiscal year 2023-2024 MPDG funding. The response rate was 74 percent.

What GAO Recommends

GAO has previously recommended that DOT define how an application may qualify as exemplary and improve documentation of key decisions. Implementing these recommendations would enhance transparency and consistency. GAO will continue to monitor DOT’s progress in addressing the recommendations.

What GAO Found

In 2022, the Department of Transportation (DOT) combined the applications for three grants into a single application for what DOT calls the Multimodal Project Discretionary Grants (MPDG) program. DOT stated that it combined the applications in part to streamline the process for applicants. In response to a GAO survey, MPDG applicants for fiscal year 2023-2024 funding cited several improvements resulting from combining the three applications. A majority of respondents who had applied for DOT grants previously found the combined process to be beneficial and found it easier to apply for multiple grants. Respondents also generally indicated that DOT’s application materials were helpful and easy to understand. Although survey respondents were largely positive about the combined application process, some reported challenges, including having sufficient staff expertise and staff capacity to complete the application.

Survey Respondents on Combined Application Process for Fiscal Year 2023-2024 Multimodal Project Discretionary Grants (MPDG) Compared to Previous Grant Application Experience(s)

Note: The above is based on survey responses from 116 of the 120 applicants for fiscal year 2023-2024 MPDG grants who also applied for Department of Transportation grants before fiscal year 2022.

GAO found that for the fiscal year 2023-2024 MPDG program, DOT lacked clear criteria and complete documentation of its rationale for advancing applications to the Secretary for possible award selection. As GAO found in prior reviews, DOT did not clearly describe how officials would identify “exemplary” applications that would advance to the Secretary for possible selection. Additionally, GAO found that DOT did not document the rationale for the decisions to advance several applications that later received awards. Taking such steps for combined programs is especially important because, as was the case for MPDG, selection decisions made for an applicant related to one program carried over into how DOT treated that applicant with respect to the two other grant programs.

GAO recommended in 2024 that DOT clearly define its criteria for discretionary grants. DOT disagreed with this recommendation—stating that it had discretion to advance applications—and has not implemented it. Additionally, in 2016, GAO recommended that DOT more fully document key decisions. DOT agreed with this recommendation but has not yet fully implemented it. Implementing these recommendations would help DOT enhance the transparency and consistency of its discretionary grant programs.

 

 

 

Abbreviations

 

DOT

Department of Transportation

IIJA

Infrastructure Investment and Jobs Act

INFRA

Infrastructure for Rebuilding America

Mega

National Infrastructure Project Assistance

MPDG

Multimodal Project Discretionary Grant

NOFO

Notice of Funding Opportunity

OMB

Office of Management and Budget

Rural

Rural Surface Transportation

 

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Letter

May 22, 2025

The Honorable Ted Cruz
Chairman
The Honorable Maria Cantwell
Ranking Member
Committee on Commerce, Science, and Transportation
United States Senate

The Honorable Shelley Moore Capito
Chairman
The Honorable Sheldon Whitehouse
Ranking Member
Committee on Environment and Public Works
United States Senate

The Honorable Sam Graves
Chairman
The Honorable Rick Larsen
Ranking Member
Committee on Transportation and Infrastructure
House of Representatives

Federal discretionary transportation grants provide critical funding to help build our nation’s infrastructure. The Infrastructure Investment and Jobs Act (IIJA)[1] authorized and appropriated approximately $125 billion for the Department of Transportation (DOT) to award in discretionary grants between fiscal years (FY) 2022 and 2026 for surface transportation infrastructure projects. Among other programs, the IIJA established or amended three transportation grant programs: the Infrastructure for Rebuilding America program (INFRA), the Rural Surface Transportation Grant program (Rural), and the National Infrastructure Project Assistance program (Mega).

In March 2022, DOT issued a Notice of Funding Opportunity (NOFO) that combined the solicitation and evaluation processes for the INFRA, Rural, and Mega grant programs, referred to as the Multimodal Project Discretionary Grant opportunity (MPDG) program. DOT has awarded the IIJA funding in three MPDG funding rounds: FY2022, FY2023-2024, and FY2025-2026.[2]

For the FY2023-2024 MPDG funding round, DOT announced MPDG awards between December 2023 and January 2024, totaling $5.6 billion in federal funds. This includes $2.9 billion for INFRA grants, $2.05 billion for Mega grants[3], and $645 million for Rural grants.[4]

In March 2022, DOT described the IIJA as “a once-in-a-generation opportunity to support transformational investments in our national transportation infrastructure.”[5] In recent years, GAO has found problems with the consistency and transparency of DOT’s approach to evaluating and selecting projects in a variety of its discretionary grant programs. Between July 2020 and December 2024, GAO made 20 related recommendations, of which 14 remain open as of March 2025. Additionally, in 2016, GAO recommended that DOT develop a department-wide approach for evaluating applications and documenting key decisions for its discretionary grant programs.[6] GAO identified this as a priority recommendation for DOT implementation, and as of April 2025, this recommendation remains open.[7]

The IIJA includes provisions for us to review the adequacy and fairness of two of the three individual grant programs that DOT combined into the MPDG program.[8] In 2024, we issued separate reports on DOT’s FY2022 INFRA, Rural, and Mega awards, which included recommendations to improve the transparency of the process.[9] This report reviews the FY2023-2024 MPDG program, including (1) applicants’ views on DOT’s combination of three discretionary grant programs into the MPDG program, and (2) the extent to which DOT documented its criteria and rationale for selecting MPDG grant applications.

We also present descriptive characteristics of FY2023-2024 MPDG applicants and awarded projects in Appendix I. We present information on how DOT developed the MPDG evaluation process and criteria, including its actions intended to ensure alignment with statutory provisions in Appendix II.

To address our objectives, we reviewed our prior work on DOT’s discretionary grant programs and DOT documentation of the FY2023-2024 MPDG program. This documentation included the evaluation plan—which described how DOT staff should evaluate applications—and the FY2023-2024 NOFO. The NOFO announced the availability of INFRA, Rural, and Mega funds, as well as the program’s key objectives and the criteria DOT would use to evaluate applications. We also interviewed DOT staff that oversaw the MPDG process.

To determine applicants’ views on DOT’s combination of three discretionary grant programs into the MPDG program, we conducted a survey of all grant applicants who submitted at least one eligible FY2023-2024 MPDG application.[10] The survey asked applicants about their views on the application, evaluation, and selection processes, along with DOT’s resources for applicants. Additional information on the survey methodology, along with the results of the survey, are contained in Appendix III.

To assess the extent to which DOT documented its selection criteria and rationale, we analyzed DOT’s MPDG grant application data and documentation.[11] We compared information from this data and documentation against federal requirements for discretionary grant programs. Specifically, we compared DOT’s documentation against requirements contained in the Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (OMB Regulations)[12] and DOT’s October 2019 Guide to Financial Assistance (DOT’s Financial Guide).[13] These federal regulations and DOT guidance establish requirements for discretionary grant programs including requirements related to consistency and transparency.

Additionally, we used DOT data on the MPDG program to compile descriptive statistics to describe the characteristics of FY2023-2024 MPDG applicants and awarded projects. This information is contained in Appendix I.[14] To assess the reliability of DOT data, we interviewed DOT officials and conducted data checks. We found the data were sufficiently reliable for the purpose of producing descriptive statistics about the characteristics of MPDG applicants.

We conducted this performance audit from March 2024 to May 2025 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Background

Historically, much of the federal spending for surface transportation programs has been through noncompetitive formula grants to states, which allocate funds based on distribution formulas prescribed by statute. In contrast, discretionary grant programs, such as those included in the MPDG program, award grants on a competitive basis. Federal discretionary transportation grant programs direct federal funding toward national transportation priorities—such as improving the condition of critical infrastructure, enhancing economic competitiveness, and reducing transportation fatalities. Such programs can be targeted to address key national challenges.

For the FY2023-2024 MPDG process, DOT used a three-phase process for evaluating and awarding discretionary grants:

·         Solicitation. As we reported previously, in March 2022, DOT combined the solicitation process and issued a single NOFO for the Mega, Rural, and INFRA programs. The NOFO announces the availability of funds, as well as the program’s funding priorities and the corresponding criteria by which DOT will evaluate applications. Applicants submit applications in response to the NOFO. According to DOT officials, the decision to combine these programs was, in part, to streamline the process for applicants.[15] Applicants could choose to apply to one, two, or all three statutory programs included in the MPDG program. DOT considered an application for all three programs unless applicants explicitly opted out of consideration for one or more programs. The NOFO also encouraged applicants to apply for multiple programs to maximize their potential for receiving federal funds.

·         Evaluation. In addition to combining the solicitation process, DOT combined the evaluation process for all three MPDG programs, meaning that DOT evaluated applications for all three grant programs at the same time against the same evaluation criteria.

To evaluate applications, teams comprised of DOT officials from across its modal administrations conducted three technical reviews of the applications, followed by a review to document whether they met the statutory project selection requirements applicable to the three grant programs.[16] For each of the three reviews, the teams evaluated and assigned a rating to signify how well an application addressed the criteria for each. The three reviews were:

1.    Project outcome review. Officials assessed the extent to which applications addressed each of the six outcome criteria outlined in the NOFO.

2.    Cost effectiveness review. Officials assessed applicants’ reported benefit-cost analyses to estimate anticipated project costs and benefits.

3.    Project readiness review. Officials assessed whether the project would be delivered in accordance with certain federal requirements, identified all funding sources for the full project budget, and was reasonably expected to begin construction in a timely manner.

According to the NOFO, applications that met all program specific statutory requirements[17] and received High ratings in all three technical reviews would automatically receive an overall rating of “Highly Recommended” going into the Senior Review phase.[18] See figure 1 for a full list of the selection criteria and possible ratings for FY2023-2024 applications.

Figure 1: Department of Transportation Selection Criteria for Evaluating Fiscal Year 2023-2024 Multimodal Project Discretionary Grant Program Applications

·         Selection and Award. Following the combined evaluation process—after each application had received its technical evaluation ratings—a “Senior Review Team” was to assign an overall rating to each application. The Senior Review Team was comprised of senior officials selected by the Secretary of Transportation. The Senior Review Team then compiled a list of the applications rated Highly Recommended to advance to the Secretary, who, then, was to select applications to award from that list.[19]

DOT held four Senior Review Team meetings for the FY2023-2024 MPDG funding round. The first meeting focused on what DOT refers to as small INFRA projects (<$100 million), the second and third meetings focused on what DOT refers to as large INFRA ($100 million+) and Mega projects, and the fourth focused on Rural projects.[20] According to DOT officials, they combined the large INFRA and Mega meetings to optimize the grant selection process. DOT announced the FY2023-2024 Rural awards in December 2023 and the INFRA and Mega awards in January 2024. See Appendix I for additional information on the awarded projects.

Applicants Appreciated Ease of Applying to Three Grant Programs in One Application, but Some Also Noted Challenges

Survey Respondents Generally Liked the Streamlined MPDG Application Process

Respondents to our survey of MPDG applicants generally indicated that DOT’s combined FY2023-2024 MPDG NOFO and application materials were helpful, clear, and easy to understand. Specifically, nearly all survey respondents reported that the FY2023-2024 NOFO was moderately or very helpful (94 percent), with two thirds (66 percent), responding that it was very helpful.[21] Additionally, almost all survey respondents found the NOFO to be moderately or very clear (91 percent).

Survey respondents also indicated that they found it very or somewhat easy to understand the differences between the three grant programs combined in the MPDG program (75 percent). These differences were detailed in two tables in the NOFO that compared eligibility criteria among the three MPDG programs for applicant organizations and projects. Respondents also indicated they found it very or somewhat easy to determine if their organization was eligible to apply for a MPDG grant (84 percent) as well as to determine if a particular project was eligible for one or more of the MPDG grant programs (79 percent). See Figure 2 below.

Figure 2: Survey Respondents’ Views on Ease or Difficulty of Determining Eligibility for Fiscal Year (FY) 2023-2024 Multimodal Project Discretionary Grants (MPDG) Applications

Note: These percentages were based on a survey of applicants. The response rate was 74 percent. Percentages may not add up to 100 percent due to rounding.

Beyond the NOFO, respondents also reported positive experiences with DOT’s other resources for applicants. For example, most respondents reported that they found DOT’s MPDG website to be very or moderately helpful (72 percent). Most also found DOT’s webinars for potential applicants to be very or moderately helpful (65 percent). See Figure 3 below.

Figure 3: Survey Respondents’ Views on Helpfulness of Department of Transportation Fiscal Year (FY) 2023-2024 Multimodal Project Discretionary Grants (MPDG) Website and Webinars

Note: These percentages were based on a survey of applicants The response rate was 74 percent. Percentages may not add up to 100 percent due to rounding.

Further, survey respondents cited several improvements resulting from combining the three MPDG grants into a single application and evaluation process. Specifically, we asked applicants who had applied previously for INFRA, Mega, and Rural grants about their experience with the new, combined process.[22] A majority of these respondents found the combined process to be beneficial and reported that it made it easier to apply for multiple grants.[23] Specifically, of the 120 respondents who had applied for DOT grants prior to the MPDG program’s introduction in FY2022, more than two-thirds (68 percent) reported that the combined application process was very or moderately beneficial compared to their prior experience, while about 23 percent reported that it was slightly or not at all beneficial. In addition, nearly two-thirds of respondents (63 percent) reported that the combined application process made it easier for them to apply for multiple grants, with 34 percent saying it made it much easier. See Figure 4 below.

Figure 4: Survey Respondents’ Views on the Benefits of the Combined Fiscal Year (FY) 2023-2024 Multimodal Project Discretionary Grants (MPDG) Application Process

Note: These percentages were based on survey responses from the 120 applicants who indicated that they had applied for Department of Transportation (DOT) grants prior to fiscal year 2022. Percentages may not add up to 100 percent due to rounding.

Given the opportunity to offer written comments, about two-thirds of the respondents who provided comments (30 of 45) said that the combined process generally resulted in a more efficient use of resources. Multiple applicants noted that the combined process saved them time and staffing resources by allowing them to submit a single application for multiple programs. For example, two applicants said the combined process saved them money because they only needed to hire a consultant for a single grant application, rather than three applications.[24]

Some Survey Respondents Cited Challenges Applying for Grants, Including Lack of Staff Capacity and Difficulty Addressing Several Evaluation Criteria

Although survey respondents were largely positive about the combined application process, some reported several challenges. These included challenges resulting from combining the application process (for three statutory programs) and available funding (for two fiscal years instead of one). Applicants also noted challenges in addressing several of the criteria DOT used to evaluate applications as well as more broadly related to the processes DOT used to solicit, evaluate, and select projects.[25]

Challenges Arising from the Combined Application Process

While most respondents who had filed applications for DOT discretionary grants prior to the combined MPDG application found DOT’s new, combined process easier than in the past, 23 percent (26 of 116) reported that the combined process was moderately or very challenging. See Figure 5 below.

Figure 5: Survey Respondents’ Views on Challenges from the Combined Fiscal Year (FY) 2023-2024 Multimodal Project Discretionary Grants (MPDG) Application Process

Note: These percentages were based on survey responses from 116 of the 120 applicants who indicated that they applied for Department of Transportation (DOT) grants prior to fiscal year 2022. Four applicants did not respond to this question. Percentages may not add up to 100 percent due to rounding.

Respondents noted several specific staffing and resources challenges their organization faced with the combined MPDG application. While one of the benefits of the combined application noted by respondents was to save time and potentially reduce consultant costs, some respondents also reported difficulty with having sufficient staff expertise and staff capacity to complete the application. More specifically, respondents reported that having sufficient staff expertise (36 percent) and sufficient staff capacity (50 percent) to apply for the FY2023-2024 MPDG program was “somewhat or very difficult.” Similarly, respondents that provided written responses said that they faced additional resource challenges in crafting the more complex application to address three statutory programs (13 of 30). In particular, respondents noted difficulties using a single application to provide required information across the differing eligibility criteria. Other respondents cited the limited time and resources available to complete the more complex applications.

Challenges Arising from Combined Funding Years

In addition to combining the applications for three grant programs into a single MPDG application, DOT also combined funding for two fiscal years in the FY2023-2024 MPDG cycle. Survey respondents expressed mixed opinions about combining the funding years, with 31 percent reporting it made their application process easier, 22 percent reporting it made their application process more difficult, and 33 percent reported the process was neither easier nor more difficult. See Figure 6 below.

Figure 6: Survey Respondents’ Views on the Effects of Combining Funding Years for the Fiscal Year (FY) 2023-2024 Multimodal Project Discretionary Grants (MPDG) Program on Project Planning

Note: These percentages were based on survey responses from 173 of 174 survey responses (one respondent did not answer the question.) Percentages may not add up to 100 percent due to rounding.

Survey respondents’ written comments identified several challenges the combined funding round had on their project planning process, including impacts on project planning timelines and overall funding opportunities. For example, 13 of 47 survey respondents that submitted written responses to this question noted challenges from the combined funding round such as reducing the number of opportunities to apply for funding (from two to one). In addition, 19 of 47 noted in written responses that the combined funding years presented challenges with project timelines. As a result, some included projects in their applications that were not yet ready in terms of design and planning. Another respondent added that the combined funding rounds created project planning challenges, particularly with aligning project timelines with the obligation dates required by the FY2023-2024 MDPG program. In addition, one respondent noted that the challenges posed by combining the funding years were exacerbated by the lack of advance notice on the part of DOT. Another respondent said prior notice of the combined funding years would have been helpful to the extent that they could have planned to have additional projects ready for the application.

Challenges Addressing Evaluation Criteria

The FY2023-2024 MPDG NOFO described the criteria DOT would use to evaluate applications, including six project outcome criteria. While most survey respondents reported that three of the criteria were easy to address, some respondents reported difficulty addressing the other three criteria. For example, most survey respondents reported that the “Safety,” “State of Good Repair,” and “Economic impacts, freight movement and job creation” criteria were easy to address (71 percent, 66 percent, and 57 percent, respectively.) However, smaller proportions of applicants felt that the other three criteria were easy to address. Specifically, less than half of respondents stated that “Climate change resiliency and the environment,” “Equity, multimodal options and quality of life,” and “Innovation areas: technology, project delivery and financing” were easy to address (36 percent, 41 percent, and 28 percent, respectively). See Figure 7 below.

Figure 7: Survey Respondents’ Views on Ease or Difficulty of Addressing the Fiscal Year (FY) 2023-2024 Multimodal Project Discretionary Grants (MPDG) Project Outcome Criteria

Notes: For detailed descriptions of the six project outcome criteria, see the Fiscal Year 2023-2024 MPDG Notice of Funding Opportunity. These percentages were based on a survey of applicants. The response rate was 74 percent. Percentages may not add up to 100 percent due to rounding.

Survey respondents also noted that it was hard to apply several outcome criteria to their specific projects. For example, in written comments some respondents said that meeting merit criteria such as those requiring innovative concepts in technology, project delivery, or financing was difficult for routine projects or those located in rural areas.[26] One respondent also noted that it was difficult to address the equity and climate change criteria for a project focused on safety improvements to an 80-year-old bridge. Another respondent similarly noted that their project needed pavement, signage, and lane turns––improvements that the respondent felt would not have any impact on the environment or climate change.[27]

Ongoing Challenges with Transparency of Evaluation and Award Processes and with Benefit-Cost Analysis

Survey respondents also highlighted ongoing challenges with the processes DOT uses to solicit, evaluate, and select discretionary grants that we have reported on in the past. For example, while a majority (60 percent) of all survey respondents reported that they found the DOT evaluation process at least moderately transparent, nearly a third (31 percent) did not.[28] See Figure 8 below.

Figure 8: Survey Respondents’ Views on the Transparency of the Department of Transportation’s (DOT) Evaluation Process for the Fiscal Year (FY) 2023-2024 Multimodal Project Discretionary Grants (MPDG) Program

Note: These percentages were based on survey responses from 173 of 174 survey responses (one respondent did not answer the question). Percentages may not add up to 100 percent due to rounding.

In addition, among the 45 respondents that offered general comments about the FY2023-2024 process, 21 indicated that they would prefer more transparency about award or denial decisions, when NOFOs and awards would be announced, and greater communication during the evaluation process. For example, some respondents said they would like greater transparency on the reasoning for DOT’s award or denial decisions. Other respondents said that greater clarity on the timing of NOFO release dates and award announcements would help with project planning­, applications, and resource procurement, while still others noted that greater communication to clarify questions that may arise during the evaluation process would be helpful.

In contrast, respondents generally felt that DOT was helpful when providing feedback after the awards were announced. Specifically, of the 102 respondents that indicated they had received a debrief from DOT about its award decisions after FY2023-2024 awards were announced, nearly two-thirds (64 percent) reported the debrief they received would be very or moderately helpful in terms of applying for DOT grants in the future.

In addition, consistent with our past work, slightly more than half (51 percent) of respondents reported difficulty with developing a benefit-cost analysis, which outlines the extent to which a project is expected to provide greater benefits than costs. See Figure 9 below.

Figure 9: Survey Respondents’ Views on Ease or Difficulty of Developing a Benefit-Cost Analysis for Fiscal Year (FY) 2023-2024 Multimodal Project Discretionary Grants (MPDG) Program Applications

Note: These percentages were based on a survey of applicants. The response rate was 74 percent. Percentages may not add up to 100 percent due to rounding.

In our prior work, applicants to other DOT discretionary grant programs have noted that this benefit-cost analysis was difficult to complete, given their lack of economic expertise or resources.[29]

DOT Did Not Fully Document Criteria or Rationale for Advancing Applications, Including Some That Were Selected for Award

For the FY2023-2024 MPDG program, DOT continued to lack clear criteria and complete documentation for advancing applications to the Secretary. As we found in prior reviews of the MPDG program, DOT relied primarily on the professional judgement of Senior Review Team members to determine which applications were rated Highly Recommended and therefore advanced to the Secretary. However, it did not clearly define the criteria the team used or consistently document the rationale for the team’s decisions.[30]

Specifically, DOT and its Senior Review Team continued to use the overall rating system it developed and outlined in the NOFO for the FY2022 MPDG program in its FY2023-2024 funding round. According to the NOFO, the Senior Review Team is to assign each eligible project a rating of Highly Recommended, Recommended, or Not Recommended for each of the grant programs for which the applicant has applied. The Senior Review Team is to assign a Highly Recommended rating to an application that either (a) received high scores across the selection criteria in the evaluation process, or (b) that Senior Review Team members determined to be “an exemplary project of national or regional significance that generates significant benefits in one of the project outcome areas”.[31]

For the FY2023-2024 MPDG program, the Senior Review Team predominantly used the “exemplary” criteria to rate applications as Highly Recommended. Specifically, only one out of 310 MPDG applications deemed eligible by DOT received high enough scores from the evaluation team to receive a Highly Recommended rating based on those evaluations.[32] During a series of meetings, the Senior Review Team subsequently assigned Highly Recommended ratings to an additional 64 applications based on the “exemplary” criteria.

We found that the Senior Review Team cited certain project outcome criteria more frequently when identifying “exemplary” applications that it assigned Highly Recommended ratings. For example, the Senior Review Team most often cited the economic impacts criteria (38 applications) and the safety criteria (30 applications). Other criteria were less frequently cited—the climate change and innovation criteria were each cited for five applications.[33] See Figure 10 below.

Figure 10: Project Outcome Criteria Cited by Senior Review Team Members for Identifying “Exemplary” Applications for the Fiscal Year 2023-2024 Multimodal Project Discretionary Grants (MPDG) Program

However, DOT did not clearly describe how it would identify applications that met the “exemplary” criterion. We reported previously in our FY2022 INFRA review, and continued to find for FY2023-2024, that neither the NOFO nor the evaluation plan provided a clear definition of what constituted an “exemplary project of national or regional significance that generates significant benefits in one of the project outcome areas.”[34] Specifically, neither the NOFO nor evaluation plan described what factors Senior Review Team members would consider when determining which applications met this criterion. DOT officials had previously stated, for example, that applications that are a first-of-its-kind for the region or state might be considered exemplary if the project generates significant benefits in one of the project outcome areas. However, DOT did not describe this, or any other, factors DOT would consider when identifying exemplary projects in the FY2023-2024 NOFO or evaluation plan.

Without clear criteria, DOT cannot demonstrate the appropriateness of its rationale for funding some FY2023-2024 MPDG projects over others, particularly in cases when the given rationale is not clearly supported by the scores generated during the evaluation process. As in our FY2022 INFRA review, we found FY2023-2024 applications that the Senior Review Team deemed “exemplary” even though they did not receive the highest possible evaluation score of “three” in the outcome area used to justify their advancement. For example, the Senior Review Team identified one project as “exemplary” because of its safety benefits, but it was scored a “two” in the safety outcome area during the evaluation process; this application later received an award. Conversely, several applications that scored a “three” in the safety outcome area were not deemed “exemplary” by the Senior Review Team and, therefore, were not assigned Highly Recommended or considered by the Secretary for an award. Of the 64 applications deemed “exemplary” in the FY2023-2024 funding round, we found eight applications that did not receive the highest score in the outcome area cited by the Senior Review Team. Five of these were awarded funding.

In our review of the FY2022 INFRA program, we identified a similar lack of clarity for supporting decisions to advance certain MPDG applications over others, and recommended in January 2024 that DOT should clearly define how an application may qualify as an “exemplary project of national or regional significance that generates significant benefits in one of the project outcome areas.” DOT disagreed with this recommendation, stating that the Senior Review Team had discretion to use professional expertise when determining which projects are exemplary projects. However, we continue to believe that clearly defining criteria, such as what constitutes an “exemplary project,” would enhance the consistency and transparency of discretionary grants and provide better information to applicants.

In our review of the FY2023-2024 MPDG program, we continued to find that DOT did not consistently document the rationale for its decisions to advance applications to the Secretary. Specifically, the Senior Review Team did not fully document its decision to assign a Highly Recommended rating to three projects that initially defaulted to a Not Recommended rating after the Senior Review Team meetings. According to DOT officials, the Senior Review Team had requested additional information for these projects, which DOT determined may not have clearly met all statutory requirements at the time of the meetings and were, therefore, not discussed.[35] Although DOT documented receiving some additional material from the applicants which DOT considered to have addressed statutory requirements, there was no documentation explaining why the Senior Review Team subsequently assigned them a Highly Recommended rating, or how those projects compared to other eligible applications that did not receive such a rating. As a result, it was unclear how DOT officials identified the projects as “exemplary” that should be highly recommended and what factors they considered in reaching their conclusions. Ultimately, all three of these applications were selected for award, two for Mega and one for Rural. Combined, they represent $999 million—or 18 percent of the $5.6 billion awarded through the FY2023-2024 MPDG program.

To address similar documentation issues that we found in prior reviews, we had recommended in 2016 that the Secretary of Transportation issue department-wide guidance for discretionary grants. Our recommendation further stated that such guidance should include requirements to document key decisions, including the reason for any rating changes and the officials responsible for those changes.[36] DOT agreed with this recommendation, and we subsequently designated it as a priority recommendation.[37]

DOT has since taken steps to develop this departmental guidance and improve its documentation of selection decisions. For example, it has implemented some guidance on NOFOs and updated its Financial Assistance Manual. Additionally, our review of the FY2022 INFRA program found that DOT’s selection memos provided greater transparency into the Secretary’s decision-making and rationale for awarding grants than prior years. DOT continued to create similar selection memos for the FY2023-2024 MPDG program.

However, DOT has yet to issue department-wide guidance for discretionary grants that requires documenting key decisions. We have also continued to find areas for improvement related to documenting why certain applications advanced to the Secretary for selection, particularly when compared to other applications which received similar evaluation scores. We noted similar issues in our reviews of the other statutory grant programs—Rural and Mega—that were included under the FY2022 MPDG program.[38] As a result, DOT remains vulnerable to questions about the integrity of the selection process. Documenting its selection decisions could further ensure DOT’s accountability over federal funds and help the agency prevent potential instances of fraud, waste or abuse when making award decisions for grant funds.

Fully addressing our 2016 and 2024 recommendations to clearly define criteria and fully document decisions is especially important when DOT combines grant programs, like it did for the MPDG program. Specifically, in the case of the MPDG program, an application identified as “exemplary” by the Senior Review Team—and, therefore, assigned a Highly Recommended rating—carried that rating across all the other grants that it applied to and was deemed eligible for. As such, decisions to deem a project exemplary for one statutory program carried over into how such a project was treated with respect to two other grant programs and, therefore, may have a greater impact on which grants are selected for award. Moving forward, clearly defining criteria and fully documenting its decisions could help DOT improve transparency if DOT again chooses to combine discretionary grant programs. We are continuing to monitor DOT’s efforts to fully address our prior recommendations.

Agency Comments

We provided a draft of this report to DOT for review and comment. DOT did not have any comments on the report.

We are sending copies of this report to the appropriate congressional committees, the Secretary of Transportation, and other interested parties. In addition, the report is available at no charge on the GAO website at https://www.gao.gov.

If you and your staff have any questions about this report, please contact me at repkoe@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made key contributions to this report are listed in appendix IV.

Elizabeth Repko
Director
Physical Infrastructure Issues

Appendix I: Characteristics of Fiscal Year 2023-2024 Multimodal Project Discretionary Grant Program Applicants and Projects Selected for Award

The following appendix provides descriptive information on the Fiscal Year (FY) 2023-2024 Multimodal Project Discretionary Grant (MPDG) program applicants and awards. This information was also included in an interim briefing document provided to congressional staff in November 2024.

Characteristics of Applications

The Department of Transportation (DOT) evaluated 310 applications for MPDG awards that requested a total of $30.8 billion during the FY2023-2024 funding round, according to DOT data.[39] Nearly 30 percent of applications requested funding from all three MPDG programs. The remaining applicants requested funding from various program combinations. About 20 percent of applications requested funding from only the Rural Surface Transportation Grant program (Rural), while another 20 percent requested funding from both the Infrastructure for Rebuilding America (INFRA) and the National Infrastructure Project Assistance (Mega) programs—but opted out of consideration for Rural funding (see fig. 11).

Figure 11: Number of Multimodal Project Discretionary Grant (MPDG) Program Applications Submitted to DOT and Combinations of Funding Types Requested Fiscal Year 2023-2024 Funding Round

Note: Totals do not add to 100.0 percent due to rounding. This figure depicts the number of applications submitted and the combinations of MPDG funding types for which applicants requested to be considered during the FY2023-2024 funding round, prior to the Department of Transportation’s (DOT) assessment of the applications’ eligibility for these MDPG programs. The abbreviations in this figure represent the Infrastructure for Rebuilding America program (INFRA), National Infrastructure Project Assistance program (Mega), and Rural Surface Transportation Grant program (Rural) discretionary grant programs.

Table 1 lists the states that submitted the most MPDG program applications, as well as the amount of funding they requested. For the FY2023-2024 funding round, nearly a third of all MPDG grant applications (95, or 30.7 percent) and a quarter of all requested funding ($7.4 billion, or 24.1 percent) were attributable to five states.

The table shows application counts and total amount of funding requested (in millions) for each of the three grant programs, separating the information from the five states that submitted the most applications from others.

Table 1: Number and amounts requested (in Millions of Dollars) for the Multimodal Project Discretionary Grant (MPDG) Program by State and Grant Program, Fiscal Year (FY) 2023-2024 Round

State

INFRA

Mega

Rural

Totala

California

30 ($2,811.4)

24 ($3,164.0)

17 ($1,696.7)

35 ($3,764.9)

Colorado

15 ($452.0)

9 ($209.3)

17 ($463.9)

18 ($480.7)

Michigan

11 ($217.1)

10 ($504.2)

10 ($88.3)

15 ($620.0)

Texas

11 ($1,015.5)

10 ($1,005.9)

10 ($585.7)

14 ($1,233.5)

Florida

10 ($886.6)

9 ($874.3)

6 ($360.4)

13 ($1,326.0)

All other states combined

153 ($20,516.9)

107 ($20,159.1)

136 ($10,231.8)

215 ($23,380.4)

Totala

 

 

 

310 ($30,805.5)

Source: GAO analysis of Department of Transportation data.  |  GAO‑25‑107458

aThe applications and funding requests for the Infrastructure for Rebuilding America program (INFRA), National Infrastructure Project Assistance program (Mega), and Rural Surface Transportation Grant program (Rural) reported in this table do not sum to the totals, as individual applications for the FY2023-2024 MPDG program may include funding requests for multiple programs. Under the FY2023-2024 MPDG NOFO, applicants were to be automatically considered for INFRA, Mega, and Rural funding unless they opt-out of consideration for one or two of the programs.

Characteristics of Fiscal Year 2023-2024 Award Selections

The FY2023-2024 NOFO announced that, with up to approximately $5.6 billion available for FY2023-2024 MPDG opportunity funding, up to $3.1 billion would be made available for the INFRA program, up to $1.8 billion would be made available for the Mega program, and up to $675.0 million would be made available for the Rural program.[40] DOT selected 55 MPDG grant applications to receive a total of $5.6 billion for the FY2023-2024 awards.[41] Of these 55 awards, 37 were for INFRA, Mega, or combined INFRA and Mega grants, totaling $5.0 billion.[42] DOT also awarded 18 Rural grants worth a total of $645.3 million. Table 2 shows the number of awards and amount of funding by grant program.

Table 2: Multimodal Project Discretionary Grant Program Award Selections, Fiscal Year 2023-2024 Round

Multimodal Project Discretionary Grant program

Number of awards

Funding awarded

(millions)

INFRA

26

$2,657.5

Mega

9

$1,939.9

Rural

18

$645.3

Infra / Mega

2

$366.4

Total

55

$ 5,609.1

Source: GAO analysis of Department of Transportation (DOT) data.  |  GAO‑25‑107458

Notes: The abbreviations in this table represent the Infrastructure for Rebuilding America program (INFRA), National Infrastructure Project Assistance program (Mega), and Rural Surface Transportation Grant program (Rural) discretionary grant programs.

The total includes $212 million in fiscal year 2025-2026 funding that DOT awarded in multi-year awards for two Mega projects.

Table 3 shows the FY2023-2024 MPDG grant awards and award amounts by state. Four states each received three MPDG awards. Minnesota was awarded the greatest amount ($1.1 billion) and percentage (19.8 percent) of MPDG funding for the FY2023-2024 round, and California received the second greatest amount ($764 million) and percentage (13.6 percent) of total funding.

Table 3: Number and Amounts (in Millions of Dollars) of Multimodal Project Discretionary Grant Program Awards by State and Grant Program, Fiscal Year 2023-2024 Round

State

INFRA

Mega

Rural

INFRA /

Megaa

Totalb

Alaska

1 ($17.1)

 

 

 

1 ($17.1)

Arizona

1 ($95.0)

 

1 ($25.0)

 

2 ($120.0)

California

2 ($480.6)

1 ($283.4)

 

 

3 ($764.0)

Colorado

2 ($88.1)

 

1 ($49.7)

 

3 ($137.8)

District of Columbia

1 ($34.0)

 

 

 

1 ($34.0)

Florida

1 ($180.0)

1 ($130.5)

 

 

2 ($310.5)

Georgia

1 ($15.1)

 

1 ($12.0)

 

2 ($27.1)

Hawaii

1 ($74.6)

 

 

 

1 ($74.6)

Iowa

1 ($34.0)

 

1 ($57.3)

 

2 ($91.3)

Illinois

1 ($25.0)

 

1 ($52.9)

 

2 ($77.9)

Indiana

 

1 ($127.5)

 

 

1 ($127.5)

Louisiana

 

 

 

1 ($300.0)

1 ($300.0)

Massachusetts

 

1 ($371.9)

 

 

1 ($371.9)

Maryland

 

1 ($80.0)

 

 

1 ($80.0)

Maine

 

 

1 ($27.7)

 

1 ($27.7)

Michigan

 

 

1 ($14.4)

 

1 ($14.4)

Minnesota

2 ($1,083.1)

 

1 ($25.0)

 

3 ($1,108.1)

Missouri

1 ($92.9)

 

 

 

1 ($92.9)

Mississippi

 

 

1 ($35.0)

 

1 ($35.0)

Montana

 

 

1 ($24.3)

1 ($66.4)

2 ($90.7)

North Dakota

 

 

1 ($55.0)

 

1 ($55.0)

Nebraska

1 ($21.2)

 

 

 

1 ($21.2)

New Jersey

1 ($8.0)

 

 

 

1 ($8.0)

New Mexico

 

 

1 ($59.8)

 

1 ($59.8)

Nevada

1 ($28.0)

 

 

 

1 ($28.1)

New York

 

1 ($150.0)

 

 

1 ($150.0)

Ohio

1 ($8.8)

 

1 ($29.7)

 

2 ($38.5)

Oklahoma

 

 

1 ($0.4)

 

1 ($0.4)

Oregon

1 ($200.0)

 

 

 

1 ($200.0)

Pennsylvania

2 ($53.8)

1 ($142.3)

 

 

 3 ($196.2)

Rhode Island

1 ($81.0)

 

 

 

1 ($81.0)

South Dakota

1 ($16.8)

 

1 ($66.7)

 

2 ($83.5)

Utah

 

 

1 ($70.4)

 

1 ($70.4)

Washington

1 ($12.3)

1 ($600.0)

 

 

2 ($612.3)

Wisconsin

1 ($8.0)

 

 

 

1 ($8.0)

West Virginia

 

1 ($54.3)

1 ($13.5)

 

2 ($67.8)

Wyoming

 

 

1 ($26.6)

 

1 ($26.6)

Total

26 ($2,657.5)

9 ($1,939.9)

18 ($645.3)

2 ($366.4)

55 ($5,609.1)

Source: GAO analysis of Department of Transportation data.  |  GAO‑25‑107458

Note: The abbreviations in this table represent the Infrastructure for Rebuilding America program (INFRA), National Infrastructure Project Assistance program (Mega), and Rural Surface Transportation Grant program (Rural) discretionary grant programs.

aTwo projects were awarded a combination of INFRA and Mega funding in the fiscal year 2023-2024 funding round. A project in Louisiana was awarded a total of $300.0 million, comprised of $226.2 million in INFRA funding and $73.8 million in Mega funding. Another project in Montana was awarded a total of $66.4 million, comprised of $34.4 million in INFRA funding and $32.0 million in Mega funding. Additionally, DOT awarded $212 million in FY2025-2026 funding for multi-year awards to two Mega projects.

bDOT officials noted that, of the 55 FY2023-2024 MPDG awards, four awards made to three states—Minnesota, Oregon, and Washington—funded multi-state projects for which these states were the primary contact.

Table 4 illustrates the amounts and percentages of awarded FY2023-2024 MPDG applications and funding by grant program type and whether they were in an urban or rural area. In the FY2023-2024 funding round, the majority of the MPDG awards (38) and the total funding across the three programs ($3.4 billion) went to projects in rural areas.

Table 4: Number and Amounts of Funding Awarded for the Multimodal Project Discretionary Grant Program (MPDG) by Urban Area versus Rural Area, Fiscal Year 2023-2024 Round

Urban area or rural area

INFRA

Mega

INFRA /

Mega

Rural

Total

Total funding awarded
(millions)

Rural area

17

1

2

18

38

$3,421.5

Urban area

9

8

0

0

17

$2,187.6

Total

26

9

2

18

55

$5,609.1

Source: GAO analysis of Department of Transportation data.  |  GAO‑25‑107458

Notes: The Infrastructure for Rebuilding America (INFRA) and Rural Surface Transportation Grant (Rural) program statutes define a rural area as an area that is outside an urbanized area that has a population of over 200,000. According to the fiscal year 2023-2024 MPDG NOFO, projects located partly in an area designated as “urban” and partly in an area designated as “rural” are categorized by the location in which most grant funds were spent. Under the INFRA program statute, in making such grants, the Department of Transportation must consider geographic diversity among grant recipients, including the need for a balance in addressing the needs of urban and rural areas. Under the National Infrastructure Project Assistance (Mega) program statute, in making such grants the Department of Transportation is to ensure that there is geographic diversity and a balance between rural and urban communities among grant recipients.

The total funding awarded includes $212 million in fiscal year 2025-2026 funding that DOT awarded in multi-year awards for two Mega projects.

Appendix II: Description of DOT’s Use of Statutory Provisions to Create the Fiscal Year 2023-2024 Multimodal Project Discretionary Grant Program Evaluation Criteria

This appendix describes the Department of Transportation’s (DOT) responses to a series of questions we asked in August and October 2024, regarding the alignment of program statutes with executive priorities that were incorporated into the Multimodal Project Discretionary Grant (MPDG) Notice of Funding Opportunity (NOFO) for funding awarded for fiscal years (FY) 2023-2024.[43] DOT issued the NOFO in June 2023, and announced the awards between December 2023 and January 2024. This NOFO combined the solicitation and evaluation processes for three discretionary grant programs: (1) the Nationally Significant Multimodal Freight and Highway Projects (INFRA) grants program, (2) the Rural Surface Transportation Grant (Rural) program, and (3) the National Infrastructure Project Assistance (Mega) grants program.[44] In addition, DOT’s NOFO provided that “awards will be made for each of the three grant programs as appropriate and consistent with each grant program’s statutory language.” The NOFO additionally provided that the FY2023-2024 round would:

1.    be “implemented, as appropriate and consistent with law,” in alignment with specified Executive Branch priorities;[45]

2.    focus on supporting projects related to specified aspects consistent with DOT’s strategic goals;[46] and

3.    seek “to award projects that address environmental justice, particularly for communities (including rural and tribal communities) that may disproportionately experience consequences from climate change and pollutants.”

In response to our questions on the process for developing the MPDG NOFO, officials reported that DOT used the broad authority granted to federal agencies to implement grants programs in a manner not inconsistent with statute. Additionally, in general, during each level of review of the NOFO, DOT officials stated that its Office of the General Counsel (OGC) reviewed the NOFO in conjunction with the MPDG program statutes to determine if there was any program statutory language that might conflict with or prohibit the criteria or an element in the NOFO. If DOT OGC had legal concerns about an issue, such as a conflict with MDPG program statutory language, it was first discussed internally within OGC, then discussed with program office staff. If OGC continued to have legal concerns, DOT would not move forward or would move forward with an alternative plan, according to DOT officials. A more detailed version of DOT’s responses is included below.

DOT’s Review of NOFO for Alignment with Statutory Program Provisions

We asked about guidance or other policies or procedures regarding DOT OGC review functions of NOFOs. DOT responded that the Evaluation Plans that accompany NOFOs state the role of OGC, but it does not have guidance or other policies for OGC’s review functions of NOFOs. DOT noted, however, that OGC assists the program office in drafting the NOFO in accordance with applicable laws, and formally reviews and clears NOFOs. As part of the Operating Administration (OA) official clearance process, OA Counsel offices may also review and comment on sections of the NOFO that pertain to OA-specific applicable laws, according to DOT.

DOT elaborated that there is a process whereby OGC staff informally works with the program office to provide comments while program staff draft the NOFO. Once the NOFO is completed, OGC will review the language through formal processes. According to DOT, during this process, DOT program staff can ask OGC any legal questions that arise during the development of the NOFO. DOT program staff draft the NOFO, and OGC is typically provided an initial informal review opportunity for staff-level attorney comments, after which the NOFO goes into DOT’s Electronic Document Management System for formal review and clearance. According to DOT, in accordance with the Under Secretary for Policy’s Discretionary Grants Guidance Memo, the formal process reviews are undertaken by attorney staff, the relevant Assistant General Counsel, and then senior leadership.

In addition, with respect to its general process, according to DOT, OGC assists the program office in drafting a NOFO to ensure that the explicitly incorporated executive branch priorities are consistent with the statutory program provisions. For MPDG programs, these priorities are incorporated into the Project Outcome Criteria (1. Safety, 2. State of Good Repair, 3. Economic Impacts, Freight Movement, and Job Creation, 4. Climate Change, Resiliency, and the Environment, 5. Equity, Multimodal Options, and Quality of Life, and 6. Innovation Areas: Technology, Project Delivery, and Financing) which are based on statutory criteria, according to DOT.

According to DOT, during each level of review of the NOFO, OGC reviews the NOFO in conjunction with the program statutes at 23 U.S.C. § 117 (INFRA), 49 U.S.C. § 6701 (Mega), and 23 U.S.C. § 173 (Rural) to determine if there is any program statutory language that might conflict with or prohibit the criteria or an element in the NOFO. If no statutory conflict or prohibition is identified, OGC typically will advise the program office of DOT OGC’s conclusion.

If DOT OGC has legal concerns about an issue, such as a conflict with MDPG program statutory language, it is discussed internally within OGC first, after which the issue is discussed with the program office staff. If OGC continues to have legal concerns, DOT does not move forward until the issue is resolved or until an alternative plan is identified. The language used, according to DOT, must be legally sufficient.

DOT Utilization of Equity and Climate and Sustainability Strategic Goals

The NOFO provided that (1) one of the objectives of the MPDG FY2023-2024 round was to support projects that were consistent with DOT’s strategic goals, including equity, and climate and sustainability, and (2) the MPDG FY2023-2024 round was to be implemented, as appropriate and consistent with law, to focus on supporting projects that, among other things, improve equity and climate and sustainability.

We asked DOT to describe how, if at all, it was determined that the implementation of such equity, and climate and sustainability aspects are consistent with statutory provisions of the three MPDG programs. According to DOT, OGC reviewed the MPDG program statutes and determined that nothing in those statutes conflicted with or prohibited adding the Administration’s equity or climate and sustainability strategic goals, as part of DOT’s implementation of those programs.[47] DOT also provided that in addition to the agency’s “broad authority to implement grant programs in a manner not inconsistent with the statute, the authorizing statutes additionally expressly authorize USDOT to define the form and content of applications as the Secretary considers to be appropriate.”[48] DOT also noted, however, that, in general, DOT would not view the absence of such “form and content” language alone as 1) constraining DOT authority, or 2) preventing DOT from incorporating Administration priorities into DOT’s implementation of the MPDG programs to the extent that such priorities are consistent with each grant program’s statutory provisions. DOT views this language as providing additional support to the position that DOT has discretion.

DOT Utilization of the Six Project Outcome Criteria

The MPDG FY2023-2024 NOFO provided that DOT would evaluate projects against specified Project Outcome Criteria by considering the extent to which a project addresses the following: (1) safety; (2) state of good repair; (3) economic impacts, freight movement, and job creation; (4) climate change, resiliency, and the environment; (5) equity, multimodal options, and quality of life; and (6) innovation areas: technology, project delivery, and financing. We asked DOT to describe the rationale under which it was determined that evaluating applications for MPDG projects against the six project outcome criteria to help determine award decisions was consistent with the respective MPDG program statutes. DOT provided the following:

1.    Alignment with Statutory Provisions: According to DOT, each evaluation criterion assessed for each program aligns with specific statutory provisions. To show this alignment, DOT provided the following annotated version of its Statutory Program Goals, Evaluation Criteria and Additional Considerations Crosswalk, Appendix IV of its MPDG Evaluation Guidelines (fig. 12).

Figure 12: The Department of Transportation’s Annotated Version of Appendix IV of the Multimodal Project Discretionary Grants Evaluation Guidelines for Fiscal Year 2023-2024

Source: Department of Transportation.  |  GAO‑25‑107458

2.    DOT Discretion: DOT recognized some of the six project outcome criteria evaluation areas were very similar to the language used in the respective MPDG programs’ statutes (e.g., the safety evaluation area criteria) and were formulated with little DOT discretionary interpretation needed. However, DOT recognized for other areas such as Equity, Multimodal Options, and Quality of Life, where the term “equity” was not specifically used in the respective program statutory provisions cited, some level of DOT discretion was used in its interpretation. DOT noted that it also used the DOT strategic plan in implementing programs. DOT further noted that in addition to the use of DOT discretion, DOT was also implementing executive branch orders that, for example, provided definitions of terms such as “equity” and “underserved.”[49] Similarly, DOT stated that it used discretion to implement executive branch memos on how to implement administration priorities.[50]

3.    Disadvantaged Communities: Two of the project outcome criteria (Climate Change, Resiliency, and the Environment; and Equity, Multimodal Options, and Quality of Life) incorporate aspects related to disadvantaged communities. While the Mega program statute contains some language specifically relating to disadvantaged communities that requires the Secretary to take into consideration whether a project would benefit a historically disadvantaged community or population, the INFRA and Rural program statutes do not contain language specifically relating to disadvantaged communities.

We asked DOT to describe how, if at all, it was determined that a DOT evaluation of INFRA and Rural projects against the project outcome criteria relating to disadvantaged communities, would be consistent with the statutory provisions of the INFRA and Rural programs. DOT responded that OGC reviewed the program statutes for INFRA and Rural and determined that nothing in those statutes conflicted with or prohibited considering disadvantaged communities under the “equity, multimodal options, and quality of life” project outcome criterion as part of DOT’s implementation of those programs.

DOT additionally noted that federal regulations require it to incorporate certain general terms and conditions in federal award programs, such as MPDG, or by reference such as “national policy requirements” including “statutory, executive order, other Presidential directive, or regulatory requirements that apply by specific reference and are not program-specific.”[51] To this point, according to DOT, it incorporated the equity goal described in DOT’s FY2022-2026 Strategic Plan as well as the national equity requirements provided in Executive Order 13985, Advancing Racial Equity and Support for Underserved Communities Through the Federal Government.[52] Lastly, DOT noted that for the FY2023-2024 round the Mega and INFRA programs were covered under the President’s Justice40 Initiative that set as goal that 40 percent of the overall benefits from certain federal investments in climate and clean energy and other areas, flow to disadvantaged communities.

4.    Economic Impacts, Freight Movement, and Job Creation: Under the Economic Impacts, Freight Movement, and Job Creation criterion, the NOFO provided that DOT would consider the extent to which a project can be anticipated to contribute to specified outcomes including those resulting in “high quality job creation by supporting good-paying jobs with a free and fair choice to join a union, in project construction and in on-going operations and maintenance, and incorporate strong labor standards, such as through the use of project labor agreements.”

We asked DOT to describe how, if at all, it was determined that DOT evaluation of MPDG projects against this project outcome criterion was consistent with statutory provisions of the respective MPDG program statutes. DOT responded that OGC reviewed the MPDG program statutes and determined that nothing in those statutes conflicted with or prohibited DOT’s considering job creation and labor standards, consistent with administration priorities, and as part of DOT’s implementation of those programs.

DOT additionally noted that, as a federal awarding agency, federal regulations require it to incorporate certain general terms and conditions, as applicable, either in the federal award or by reference in federal award programs, such as MPDG. Such terms and conditions include “national policy requirements” such as “statutory, executive order, other Presidential directive, or regulatory requirements that apply by specific reference and are not program-specific.”[53] To this point, according to DOT, it incorporated the goal of creating good-paying jobs described in DOT’s FY2022-2026 Strategic Plan as well as the national labor standard requirements provided in Executive Order No. 14126, Investing in America and Investing in American Workers, and the use of project labor agreements provided in Executive Order No. 14063, Use of Project Labor Agreements for Federal Construction Projects.[54]

Additional Statutory Considerations

The Mega and INFRA statutes included some additional evaluation considerations beyond what was included in the six criteria described above. We asked DOT to identify where, if at all, these Mega and INFRA provisions were accounted for in the FY2023-2024 MPDG NOFO or evaluation process.

1.    Benefit to Multiple States Consideration (Mega): The Mega program statute requires that in selecting projects to receive grants, the Secretary shall take into consideration “whether multiple States would benefit from the project.” While this aspect was identified for consideration under the MPDG’s Geographic Diversity evaluation area set out in its Evaluation Guidelines (see table 5), DOT confirmed that such use was not directly stated in the NOFO. According to DOT, such use was included indirectly via what the Senior Review Team (SRT) may consider. To this point, the NOFO provided that a rating of Highly Recommended will be assigned to projects that, among other things, meet all statutory requirements for award and are otherwise determined by the SRT to be an exemplary project of national or regional significance that generates significant benefits in one of the project outcome areas. According to DOT, the determination that a project was of national or regional significance inherently included benefits to multiple states.

Table 5: Multimodal Project Discretionary Grants Evaluation Guidelines: DOT’s Statutory Program Goals, Evaluation Criteria and Additional Consideration Crosswalk for the Evaluation Area of Geographic Diversity for Fiscal Year 2023-2024

Evaluation Area

Mega

INFRA

Rural

Geographic Diversity

-Geographical Diversity, balance between the needs of urban/rural

-whether multiple states will benefit

-Contributions of geographic diversity among recipients, including urban rural balance

-Prioritizing projects in states that haven’t won awards

Contribute to Geographic Diversity

 Source: Department of Transportation (DOT).  |  GAO‑25‑107458

2.    Improve the Shared Transportation Corridor Consideration (INFRA): The INFRA program statute requires that in making a grant, the Secretary shall consider whether the project will improve the shared transportation corridor of a multistate corridor organization. While this aspect was identified for consideration under the MPDG’s Economic Impacts, Freight Movement, and Job Creation evaluation area set out in its Evaluation Guidelines (see table 6), DOT confirmed that such use was not directly stated in the NOFO. According to DOT, such use was included indirectly via what the SRT may consider. To this point, the NOFO provided that a rating of Highly Recommended would be assigned to projects that, among other things, met all statutory requirements for award and were otherwise determined by the SRT to be an exemplary project of national or regional significance that generates significant benefits in one of the project outcome areas. According to DOT, the determination that a project is of national or regional significance inherently indicates the inclusion of a shared transportation corridor of a multistate corridor organization.

Table 6: Multimodal Project Discretionary Grants Evaluation Guidelines: DOT’s Statutory Program Goals, Evaluation Criteria and Additional Consideration Crosswalk for the Evaluation Area of Economic Impacts, Freight Movement, and Job Creation for Fiscal Year 2023-2024

Evaluation Area

Mega

INFRA

Rural

Economic Impacts, Freight Movement, and Job Creation

Improved person or freight throughput, including improved mobility and reliability

-The number of persons or volume of freight supported by the project

-Short and Long-term job access, growth, creation

-Connectivity between modes

-Whether the project is on a shared multi-state Corridor represented by a Corridor Organization

Address economic development and job creation challenges, including energy sector job losses in energy communities

-Enhance Recreational and tourism opportunities by providing access to fed land, national parks, etc.

 Source: Department of Transportation (DOT).  |  GAO‑25‑107458

3.    Prioritization of Projects in States Not Previously Receiving Grants (INFRA): The INFRA program statute requires that in making a grant, the Secretary shall consider prioritizing projects located in states in which neither the state nor an eligible entity in that state has been awarded an INFRA grant. While this aspect was identified for consideration under the MPDG’s Geographic Diversity evaluation area set out in its Evaluation Guidelines (see table 7), DOT confirmed that such use was not directly stated in the NOFO. According to DOT, such use was included indirectly via what the SRT may consider. To this point, DOT referenced language in its Non-Selection Memo providing that “[i]n general, the Department defines geographic diversity for the INFRA and Mega program by State. However, the Department would make more than one award to a State in certain circumstances, such as if the applications were coming from larger, more populous states or from States with demonstrable investment needs or with a modal diversity of projects, or if multiple applications stood out in a given round.”

Table 7: Multimodal Project Discretionary Grants Evaluation Guidelines: DOT’s Statutory Program Goals, Evaluation Criteria and Additional Consideration Crosswalk for the Evaluation Area of Geographic Diversity for Fiscal Year 2023-2024

Evaluation Area

Mega

INFRA

Rural

Geographic Diversity

-Geographical Diversity, balance between the needs of urban/rural

-whether multiple states will benefit

-Contributions of geographic diversity among recipients, including urban rural balance

-Prioritizing projects in states that haven’t won awards

Contribute to Geographic Diversity

Source: Department of Transportation (DOT).  |  GAO‑25‑107458

DOT Utilization of Mega Ratings Structure to Rate INFRA and Rural Proposed Projects

The Mega program statute sets out a ratings structure requiring the Secretary to, for example, assign a rating of Highly Recommended, Recommended, or Not Recommended to proposed Mega projects. The Highly Recommended rating was to be assigned to projects that were, among other things, determined by the Secretary to be exemplary projects of national or regional significance.[55] Under the MPDG FY2023-2024 NOFO, DOT provided that it would use this Mega program statute ratings structure to rate proposed INFRA and Rural projects under the MPDG application review process. The NOFO provided, for example, that a rating of “Highly Recommended” would be assigned to projects that the Department determined to have met all statutory requirements for award and were otherwise determined by the Senior Review Team to be an exemplary project of national or regional significance, among other things.

We asked DOT to describe how, if at all, DOT determined that the use of the Mega program statute ratings structure to rate INFRA and Rural proposed projects under the MPDG application review process was consistent with the INFRA and Rural statutory program statutes. According to DOT, given that OGC reviewed the INFRA and Rural statutes and determined that there was no statutorily mandated evaluation scheme for either program, OGC determined that there was no legal prohibition on applying the ratings mandated by the Mega statute to all three MPDG programs.[56] DOT noted that the Mega ratings structure is a common scheme used by DOT. DOT additionally noted that where prohibitions do exist, DOT and OGC would conclude, and has concluded in the past, that proposed NOFO language would not be consistent with statutory program language.

DOT MPDG Evaluation Guidelines

Some of the language in DOT’s MPDG Evaluation Guidelines was broader than, and included additional factors not explicitly stated in, the language in the associated statutory sections identified in the crosswalk DOT provided to GAO. We asked how DOT determined that these other factors identified in the Evaluation Guidelines could be considered by DOT during the FY2023-2024 MPDG round across several evaluation areas:

1.    Climate Change, Resiliency, and the Environment: For INFRA, the crosswalk to the project outcome criterion Climate Change, Resiliency, and the Environment cited 23 U.S.C. § 117(h)(4). This statutory INFRA program provision requires the Secretary to consider “the enhancement of freight resilience to natural hazards or disasters, including high winds, heavy snowfall, flooding, rockslides, mudslides, wildfire, wildlife crossing onto the roadway, or steep grades.” The Climate Change, Resiliency, and the Environment-related description examples in the Evaluation Guidelines (page 17) for ratings 2 and 3 allowed for a higher rating based on additional listed factors beyond the INFRA statute “freight resilience” language (e.g., reduces air pollution and greenhouse gas emissions from transportation, promotes energy efficiencies).

In response to our question regarding how DOT determined that these other factors could be considered for the INFRA Climate Change criteria, DOT responded that agencies have broad authority to implement grant programs in a manner not inconsistent with the statute. According to DOT, the INFRA program statute references the Secretary’s authority to establish evaluation criteria[57] and does not have a statutorily mandated evaluation scheme; accordingly, the statute does not dictate how criteria will be considered or the relative importance of such criteria within the rating structure, according to DOT.

DOT additionally noted that OGC reviewed the INFRA program statute and determined that nothing required using “enhancement of freight resilience to natural hazards or disasters” (the language of (h)(4)) as the exclusive way to assess an application’s merit under the “climate change, resiliency, and the environment” project outcome criterion. According to DOT, it was therefore appropriate to factor numerous statutory and other programmatic goals into this criterion. DOT cited the example of one of the statutory goals of the program being to “enhance the resiliency of critical highway or freight infrastructure and help protect the environment” (23 U.S.C. § 117(a)(2)(E)). DOT further noted that the statute requires that “the project will contribute to the accomplishment of 1 or more of the national goals described under section 150 of this title” (23 U.S.C. § 117(g)(3)) and one of the national goals and performance measures under 23 U.S.C. § 150(b)(6), entitled, Environmental Sustainability, is to “to enhance the performance of the transportation system while protecting and enhancing the environment.” DOT stated that it accordingly considered enhancement of freight resilience to natural hazards or disasters as just one component of the larger evaluation criterion of “Climate Change, Resiliency, and the Environment.”

2.    Equity, Multimodal Options, and Quality of Life: Similarly, for Rural, the crosswalk to the Equity, Multimodal Options, and Quality of Life project outcome criterion cites to 23 U.S.C. § 173(h)(8). This statutory Rural program provision requires the Secretary to consider the extent to which an eligible project will “improve access to emergency care, essential services, healthcare providers, or drug and alcohol treatment and rehabilitation resources.” The Equity, Multimodal Options, and Quality of Life-related descriptions in the Evaluation Guidelines allow the higher ratings of 2 or 3 for meeting specified Evaluation Guideline factors beyond the statutory factors (e.g., the project is located in an Area of Persistent Poverty or Historically Disadvantaged Community and the project directly benefits the population in that area).

We asked how DOT determined that these other factors could be considered when evaluating Rural proposed projects on the Equity, Multimodal Options, and Quality of Life project outcome criterion. As with DOT’s previous response, DOT stated that agencies have broad authority to implement grant programs in a manner not inconsistent with the statute. According to DOT, the Rural program statute does not have a statutorily mandated evaluation scheme; and thus does not dictate how criteria will be considered or the relative importance of such criteria within the rating structure. According to DOT, OGC also reviewed the Rural program statute and determined that nothing required using the Rural statutorily required consideration of improving “access to emergency care, essential services, healthcare providers, or drug and alcohol treatment and rehabilitation resources” (the language of 23 U.S.C. § 173(h)(8)) as the exclusive way to assess an application’s merit under the Equity, Multimodal Options, and Quality of Life project outcome criterion. Therefore, according to DOT, it was determined to be appropriate to factor numerous statutory and other programmatic goals into this criterion, including whether the project will address another Rural statutorily required consideration relating to the “economic development and job creation challenges” language of 23 U.S.C. § 173(h)(3). According to DOT, it thus considered improved access to emergency care, essential services, healthcare providers, or drug and alcohol treatment and rehabilitation resources as just one component of the larger project outcome evaluation criterion of Equity, Multimodal Options, and Quality of Life.

In addition, while the Evaluation Guidelines related to the Equity, Multimodal, and Quality of Life criterion indicates that proposed projects can receive a 2 rating on equity based on meeting the language from 23 U.S.C. § 173(h)(8) (“improving access to emergency care, essential services, healthcare providers, or drug and alcohol treatment and rehabilitation resources”), the guidelines do not allow for the higher rating of 3 based on the same factors. When asked about this difference in the basis for rating scores, DOT stated that because the Rural program statute does not have a statutorily mandated evaluation scheme, it does not dictate how criteria will be considered or the relative importance of such criteria within the rating structure. Therefore, according to DOT, nothing prohibited DOT from considering the Rural statutory considerations in 23 U.S.C. § 173(h)(8) for supporting a rating of 2 on equity, with a rating of 3 only possible if additional factors were met (i.e., the project was also located in an Area of Persistent Poverty or Historically Disadvantaged Community and directly benefitted the population in that area).

Appendix III: GAO Survey of Fiscal Year 2023-2024 Multimodal Project Discretionary Grants Program Applicants

Survey Development

To obtain applicants’ perspectives on the U.S. Department of Transportation’s (DOT) Multimodal Project Discretionary Grants (MPDG) application solicitation, evaluation, and the award decision process, we developed and conducted a web-based survey. From the 310 applications submitted during the Fiscal Year (FY) 2023-2024 MPDG application process, we identified and distributed our survey to 236 unique grant applicants who submitted at least one eligible application.[58] We provided each applicant a unique survey link to a GAO-operated website. We asked each applicant about their experiences with the FY2023-2024 MPDG Notice of Funding Opportunity (NOFO) and other DOT provided resources; DOT’s application, evaluation, and award decision process[59]; as well as challenges they experienced applying for FY2023-2024 MPDG funding; among other topics. We conducted our survey from October 2024 to November 2024.

To help ensure questions were clear, answer choices were appropriate, and the survey was not burdensome, we conducted pre-tests of our survey instrument with five applicants who submitted applications for the FY2023-2024 MPDG program. We selected applicants to pretest to ensure participation by those that applied for different combinations of the three different statutory grant programs in the MPDG program––the Infrastructure for Rebuilding America (INFRA), the Rural Surface Transportation Grant (Rural), and the National Infrastructure Project Assistance (Mega) programs. The five selected applicants included two that were awarded a grant, and three that were not. In addition, an independent GAO survey methodologist reviewed the survey instrument. We revised the survey based on feedback from those pre-tests and the reviewer.

Following the distribution of the survey in October 2024, we emailed applicants reminders about completing the survey and called some applicants directly to confirm they had received the email with the survey link. We closed the survey in November 2024. We received 174 completed surveys from 236 eligible applicants surveyed, for a response rate of 74 percent. Not every respondent answered every question, which is reflected in the total counts reported below.

Survey Results

Tables 8 through 42 provide survey questions and summarized applicant responses on the FY2023-2024 MPDG program. Not all respondents answered each question. In some cases, based on survey design and responses provided, some questions were not applicable to certain respondents. Applicants may also have chosen not to answer some questions. In addition, we asked several open-ended questions, which are included in the tables below along with the number of respondents that answered them. For those questions, we do not provide applicant narrative written responses to protect confidentiality.

Application Process Questions

Table 8: Question 1. How Helpful, if at all, Did Your Organization Find the Following Resources When Preparing Its Fiscal Year 2023-2024 Multimodal Project Discretionary Grants Application(s)?

Resource

Very helpful

Moderately helpful

Slightly helpful

Not at all helpful

Did not use

Total

 

#

%

#

%

#

%

#

%

#

%

 

MPDG Notice of Funding FY23-24

114

66.3%

48

27.9%

5

2.9%

2

1.2%

3

1.7%

172

DOT website

51

30.0%

72

42.4%

26

15.3%

0

0%

21

12.3%

170

DOT webinars

51

30.0%

59

34.7%

19

 1.2%

2

1.2%

39

22.9%

170

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grants program applicants.  |  GAO‑25‑107458

Table 9: Question 2. How Helpful, if at all, Did Your Organization Find This Specific Table Detailing Multimodal Project Discretionary Grants Eligibility Information When Preparing Its Fiscal Year 2023-2024 Multimodal Project Discretionary Grants Application(s)?

Response

Number of respondents

Percent of respondents

Very helpful

112

64.7%

Moderately helpful

45

 26.1%

Slightly helpful

12

6.9%

Not at all helpful

1

0.6%

Did not use

3

1.7%

Total

173

100%

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant program applicants.  |  GAO‑25‑107458

Note: The table cited in this survey question listed applicant eligibility requirements for each of the three MPDG programs, Mega, INFRA, and Rural. It can be found on pages 10-11 of the FY2023-2024 MPDG Notice of Funding Opportunity.

Table 10: Question 3. Overall, How Clear, if at all, Was the Fiscal Year 2023-2024 Multimodal Project Discretionary Grants Notice of Funding Opportunity (NOFO)?

Response

Number of respondents

Percent of respondents

Very clear

68

39.1%

Moderately clear

90

51.7%

Slightly clear

10

5.8%

Not at all clear

3

1.7%

Unsure

3

1.7%

Total

174

100%

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant program applicants.  |  GAO‑25‑107458

If applicants indicated that they did not opt-out of at least one of the three MPDG programs, then the survey asked Question 4 in Table 11.

Table 11: Question 4. Was Your Organization Aware That It Could Opt-out of Applying for Any of the Three Fiscal Year 2023-2024 Multimodal Project Discretionary Grants Programs (i.e., INFRA, Rural, and Mega)?

Response

Number of respondents

Percent of respondents

Yes, but we wanted to be considered for all three MPDG programs

34

72.3%

No, we did not know `we could opt-out of any MPDG programs

3

6.4%

Unsure

10

21.3%

Total

47

100%

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant program applicants.  |  GAO‑25‑107458

If applicants indicated that they opted-out of at least one of the three MPDG programs, then the survey asked Question 5 in Table 12.

Table 12: Question 5. Department of Transportation Data Shows That Your Organization Opted-out of Applying to One or More Grant Programs. For What Reason(s) Did Your Organization Opt-out of Any Fiscal Year 2023-2024 Multimodal Project Discretionary Grants Program(s)? (Select All That Apply)

Response

Number of responses

The project would not meet the eligibility or other statutory requirements

76

The project timeline did not align with the grant award announcement or funding timeline

16

The project would not be competitive

34

Did not wish to prepare different materials needed for different grant program(s)

10

Unfamiliar with grant program(s)

2

Did not have sufficient staffing/time resources to apply for different grant program(s)

27

Other

13

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant program applicants.  |  GAO‑25‑107458

If applicants indicated that they opted-out of at least one of the three MPDG programs, then the survey asked question 5a in Table 13.

Table 13: Question 5a. For What Other Reason Did Your Organization Opt-out of Applying to an FY2023-24 MPDG Program?

Number of written responses

12

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant program applicants.  |  GAO‑25‑107458

Note: We do not publish narrative responses to open-ended question to protect respondents’ confidentiality.

Table 14: Question 6. How Easy or Difficult, if at all, Did Your Organization Find Each of the Following While Applying for Fiscal Year 2023-2024 Multimodal Project Discretionary Grants Combined Application Funding?

 

Very easy

Somewhat easy

Neither easy nor difficult

Somewhat difficult

Very difficult

No opinion

Total

Response

#

%

#

%

#

%

#

%

#

%

#

%

 

Understanding the differences between the MPDG programs (INFRA, Mega, Rural)

75

43.1%

56

32.2%

22

12.6%

15

8.6%

1

0.6%

5

2.9%

174

Determining whether your organization was eligible to apply for MPDG funding

112

64.4%

35

20.1%

14

8.1%

8

4.6%

0

0.0%

5

2.9%

174

Determining your project(s)’ eligibility for one or more of the MPDG programs(s).

80

46.0%

57

32.8%

19

10.9%

12

6.9%

0

0.0%

6

3.5%

174

Planning your project(s) based on timing of DOT’s NOFO announcement

30

17.2%

42

24.1%

38

21.8%

33

21.8%

15

8.6%

16

9.2%

174

Planning your project(s) based on anticipated timing of DOT’s award announcements

29

16.7%

32

18.4%

39

22.4%

38

21.8%

21

12.1%

15

8.6%

174

Completing the applications by the submission deadline.

28

16.3%

44

25.6%

35

20.4%

45

26.2%

11

6.4%

9

5.2%

172

Having sufficient staff expertise to complete the applications(s).

27

15.5%

44

25.3%

33

19.0%

28

16.0%

35

20.1%

7

4.0%

174

Having sufficient staff capacity to complete the application(s).

18

10.3%

34

19.5%

28

16.0%

55

31.6%

32

18.4%

7

4.0%

174

Procuring a consultant or contractor to help prepare the application(s).

41

23.6%

42

24.1%

27

15.5%

18

10.3%

9

5.2%

37

21.3%

174

Developing a benefit-cost analysis

11

6.3%

27

15.5%

36

20.7%

46

26.4%

44

25.3%

10

5.8%

174

Identifying sources of matching funds

28

16.1%

36

20.7%

49

28.2%

22

12.6%

29

16.7%

10

5.8%

174

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant program applicants.  |  GAO‑25‑107458

Project Outcome Criteria Questions

The Project Outcome Criteria section of the FY2023-2024 MPDG NOFO states the following:

·         The project outcome criteria section of the application should demonstrate how (a) project aligns with six specific criteria;

·         DOT encourages applicants to address each criterion as it applies to the funding programs to which they are applying or else to expressly state that (a) project does not address the criterion;

·         Insufficient information to assess any criterion will negatively impact (a) project rating.

Table 15: Question 7. How Easy or Difficult, if at all, Did Your Organization Find It to Address Each of the Following Six Project Outcome Criteria in Your Fiscal Year 2023-2024 Multimodal Project Discretionary Grants Application?

 

Very easy

Somewhat easy

Neither easy nor difficult

Somewhat difficult

Very difficult

Did not address this criterion

Total

Response

#

%

#

%

#

%

#

%

#

%

#

%

 

Safety

64

37.2%

58

33.7%

33

19.2%

11

6.4%

0

0%

6

3.5%

172

State of Good Repair

53

30.5%

62

35.6%

34

19.5%

16

9.2%

0

0%

9

5.2%

174

Economic Impacts. Freight Movement, & Job Creation

33

19.1%

66

38.2%

36

20.8%

23

13.3%

8

4.6%

7

4.1%

173

Climate Change, Resiliency, and the Environment

20

11.5%

43

24.7%

46

26.4%

40

23.0%

17

9.8%

8

4.6%

174

Equity, Multimodal Options, and Quality of Life

27

15.5%

44

25.3%

39

22.4%

40

23.0%

16

9.2%

8

4.6%

174

Innovation areas: Technology, Project Delivery, and Financing

19

10.9%

30

17.2%

43

24.7%

56

32.2%

15

8.6%

11

6.3%

174

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant program applicants.  |  GAO‑25‑107458

Table 16: Question 8. Please Describe Any Challenges Your Organization May Have Faced in Addressing Any of the Six Project Outcome Criteria in Your Fiscal Year 2023-2024 MPDG Application.

Number of written responses

76

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant program applicants.  |  GAO‑25‑107458

Note: We do not publish narrative responses to open-ended question to protect respondents’ confidentiality.

Table 17: Question 9. Did Your Organization Tailor Its Fiscal Year 2023-2024 Application to a Specific Multimodal Project Discretionary Grants Program or Programs (i.e., INFRA, Rural, or Mega)?

Response

Number of respondents

Percent of respondents

Yes

140

80.9%

No

19

11%

Unsure

14

8.1%

Total

173

100%

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant program applicants.  |  GAO‑25‑107458

If applicant indicated that they tailored their application to a specific MPDG program or programs, then the survey asked Question 10 in Table 18.

Table 18: Question 10. Which Grant Program(s) Did Your Organization Tailor Its Application Towards? (Check all that apply.)

Response

Number of respondents

INFRA

84

Rural

72

Mega

52

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant program applicants.  |  GAO‑25‑107458

Note: Applicants may have tailored their application for more than one of the three MPDG programs.

Combined Application Process Questions

For the FY2023-2024 MPDG funding round, DOT used a combined application—as it did for the FY2022 funding round—for all three MPDG programs (INFRA, Mega, Rural) rather than requiring a separate application for each program.

Table 19: Question 11. Prior to Fiscal Year 2022, Did Your Organization Apply for Any Department of Transportation Discretionary Grant Programs Between Fiscal Years 2016 and 2021?

Response

Number of respondents

Percent of respondents

Yes

120

69.4%

No

23

13.2%

Unsure

30

17.3%

Total

173

100%

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

If applicants answered “yes” to the question above, then the survey asked the following five questions (see tables 20 – 24).

Table 20: Question 12. Compared to Your Experience(s) Applying to Individual Department of Transportation Discretionary Grant Programs Prior to Fiscal Year 2022, Did the Combined Application Process Make the Following Aspects of Applying Easier, More Difficult, or Neither for Your Organization?

 

Much

easier

Somewhat easier

Neither

Somewhat more difficult

Much more difficult

No basis to Judge

Total

Response

#

%

#

%

#

%

#

%

#

%

#

%

 

Applying to multiple US DOT grant programs

41

34.2%

35

29.2%

22

18.3%

6

5.0%

2

1.7%

14

11.7%

120

Demonstrating project eligibility

15

12.5%

37

30.8%

39

32.5%

16

13.3%

1

0.8%

12

10.0%

120

Address the Project Outcome Criteria (i.e. Safety, State of Good Repair, etc.)

16

13.3%

39

32.5%

41

34.2%

10

8.3%

2

1.7%

12

10.0%

120

Completing the required benefit-cost analysis

14

11.7%

24

20.0%

46

38.3%

14

11.7%

8

6.7%

14

11.7%

120

Demonstrating Project Readiness (i.e.) Environmental Risk, Technical Capacity, Financial Completeness)

19

15.8%

37

30.8%

38

31.7%

8

6.7%

3

2.5%

15

12.5%

120

Obtaining sufficient resources to complete the application

21

17.5%

20

16.7%

48

40%

12

10%

6

5%

13

10.8%

120

Completing the application materials by the deadline

16

13.3%

23

19.2%

52

43.3%

13

10.8%

1

0.8%

15

12.5%

120

Responding to questions from US DOT regarding the application

19

15.8%

23

19.2%

42

35.0%

11

9.2%

1

0.8%

24

20.0%

120

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

Table 21: Question 13. Overall, When Comparing the Fiscal Year 2023-2024 Multimodal Project Discretionary Grants Combined Application Process and Your Organization’s Previous Experience(s) Applying to a Single Department of Transportation Grant Program, How Beneficial, if at all, Was the Combined Application Process to Your Organization?

Response

Number of respondents

Percent of respondents

Very beneficial

29

24.2%

Moderately beneficial

52

43.3%

Slightly beneficial

19

15.8%

Not at all beneficial

9

7.5%

No basis to respond

11

9.2%

Total

120

100%

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

Table 22: Question 14. Please Describe any Specific Benefits that Your Organization Experienced in Preparing a Single Application Across the Three MPDG Programs. (Open-ended question).

Number of written responses

 45

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

Note: We do not include narrative responses to open-ended question to protect respondents’ confidentiality.

Table 23: Question 15. Overall, When Comparing the Fiscal Year 2023-2024 Multimodal Project Discretionary Grants Combined Application Process and Your Organization’s Previous Experience(s) Applying to a Single Department of Transportation Grant Program, How Challenging, if at all, Was the Combined Application Process to Your Organization?

Response

Number of respondents

Percent of respondents

Very challenging

3

2.6%

Moderately challenging

23

19.8%

Slightly challenging

38

32.8%

Not at all challenging

43

37.1%

No basis to respond

9

7.8%

Total

116

100%

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

Table 24: Question 16. Please Describe any Specific Challenges that Your Organization Experienced in Preparing a Single Application Across the Three MPDG Programs.

Number of written responses

 30

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

Note: We do not include narrative responses to open-ended question to protect respondents’ confidentiality.

Combined MPDG Funding Round Questions

Prior to the FY2023-2024 MPDG funding round, DOT accepted applications for a single fiscal year of funding (i.e., the FY2022 MPDG funding round). In FY2023-2024, in addition to using a combined application process, DOT also combined two fiscal years of funding into a single funding round.

Table 25: Question 17. Did Combining Two Fiscal Years of Multimodal Project Discretionary Grants Funding into a Single Fiscal Year 2023-2024 Funding Round Make Your Organization’s Project Planning Easier or More Difficult, if at all?

Response

Number of respondents

Percent of respondents

Much easier

16

9.3%

Somewhat easier

38

22.0%

Neither

57

33.0%

Somewhat more difficult

28

16.2%

Much more difficult

10

5.8%

No basis to judge

 24

13.9%

Total

173

100%

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

Table 26: Question 18. Please Describe any Impact that the Combined Application Process and/or the Combined Funding Round May or May Not Have Had on Your Organization’s Project Planning.

Number of written responses

47

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

Note: We do not include narrative responses to open-ended question to protect respondents’ confidentiality.

DOT Correspondence During Application Evaluation Process

Table 27: Question 19. After Your Organization Submitted Its Fiscal Year 2023-2024 Multimodal Project Discretionary Grants Application(s), Did the Department of Transportation Contact Your Organization During the Evaluation Process About Any of Your Application(s)?

Response

Number of respondents

Percent of respondents

Yes

99

57.0%

No

42

24.1%

Unsure

33

19.0%

Total

174

100%

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  | GAO‑25‑107458

If applicants answered ‘yes” to Question 19, the survey asked Question 20 in Table 28.

Table 28: Question 20. Did the Department of Transportation Contact Your Organization Regarding any of the Following Issues Related to Your Fiscal Year 2023-2024 Multimodal Project Discretionary Grants Application(s)?

 

Yes

No

Unsure

Total

Response

#

%

#

%

#

%

 

Incomplete/insufficient application materials related to the specific requirements of one MPDG program (i.e. INFRA, Mega, or Rural)

16

17.8%

68

75.6%

6

6.7%

90

Incomplete/insufficient applications materials, in general

9

10.3%

74

85.0%

4

4.6%

87

More clarity and details about the project related to the specific requirements of an MPDG gran program (i.e., INFRA, Mega, or Rural)

61

63.5%

32

33.3%

3

3.1%

96

More clarity and details about the project, in general.

48

52.8%

41

45.1%

2

2.2%

91

Negotiation about flexibility of project scope or amount/type of potential grant award amount(s)

18

20.5%

67

76.1%

3

3.4%

88

Letter(s) of support for the project

3

3.5%

81

94.1%

2

2.3%

86

Other

3

4.6%

50

75.8%

13

19.7%

66

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

If applicants answered ‘other” in Question 20, the survey asked the Questions 20a in Table 29.

Table 29: Question 20a. If DOT Contacted Your Organization for Another Reason During the Fiscal Year 2023-2024 MPDG Applications Evaluation Process, Please Describe Below

Number of written responses

2

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

Note: We do not include narrative responses to open-ended question to protect respondents’ confidentiality.

If applicants answered “yes” in Question 20 that DOT had contacted the applicant organization regarding any of the following issues:

·         Incomplete/insufficient application materials related to the specific requirements of INFRA, Mega or Rural; or

·         More clarity and details about the project related INFRA, Mega, or Rural grant programs

the survey asked Questions 21 and 22 in Tables 30 and 31.

Table 30: Question 21. For Which Fiscal Year 2023-2024 Multimodal Project Discretionary Grants program(s) Was Your Organization Specifically Asked to Submit Additional Details, Information, or Materials?

Response

Number of respondents

INFRA

36

Mega

33

Rural

28

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

Table 31: Question 22. Was Your Organization Contacted Specifically About a Multimodal Project Discretionary Grants Program to Which It Did Not Intend to Apply?

Response

Number of respondents

Percent of respondents

Yes

1

1.5%

No

55

84.6%

Unsure

9

13.9%

Total

65

100%

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

If applicants answered ‘yes” in Question 20 that DOT had contacted the applicant organization regarding any of the following issues:

·         Incomplete/insufficient application materials related to the specific requirements of one MPDG program (INFRA, Mega or Rural);

·         Incomplete/insufficient applications materials, in general;

·         More clarity and details about the project related to specific requirements of one MPDG program (INFRA, Mega, or Rural); or

·         More clarity and details about the project, in general

the survey asked Question 23 in Table 32.

Table 32: Question 23. Please Explain How, if at all, Being Considered for Multiple MPDG programs May Have Affected, if at all, the Supplementary Information or Materials That Your Organization Was Asked to Provide.

Number of written responses

38

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

Note: We do not include narrative responses to open-ended question to protect respondents’ confidentiality.

FY2023-2024 MPDG Award Decisions

We used DOT data to identify those organizations that received INFRA, Rural, or Mega awards from the fiscal year 2023-2024 MPDG funding cycle. We programmed the survey to present this question to the 55 applicant organizations receiving an award. Forty-eight of the 55 (87 percent) provided responses. If DOT data indicated that the applicant had received a grant award for the FY2023-2024 MPDG funding cycle, then the survey asked the following two questions (see tables 33-34).[60]

Table 33: Question 24. Our Records Indicate Your Organization Received a Fiscal Year 2023-2024 Grant Award. In Your Opinion, Was This the Program for Which Your Project Was Best Suited?

Response

Number of respondents

Percent of respondents

Yes

41

85.4%

No

4

8.3%

Unsure

3

6.3%

Total

48

100%

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

Table 34: Question 25. How Clear Is It to Your Organization Why It Was Awarded Funding from This Multimodal Project Discretionary Grants Program?

Response

Number of respondents

Percent of respondents

Very clear

22

45.8%

Moderately clear

19

39.6%

Slightly clear

6

12.5%

Not at all clear

1

2.1%

Unsure

0

0.0%

Total

48

100%

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

DOT Correspondence After Grant Award Decisions

Table 35: Question 26. Did DOT Offer to Debrief Your Organization About Its Fiscal Year 2023-2024 Multimodal Project Discretionary Grants Applications(s) After the Award Decisions Were Announced?

Response

Number of respondents

Percent of respondents

Yes

116

67.1%

No

28

16.2%

Unsure

29

16.8%

Total

173

100%

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

Table 36: Question 27. Did Your Organization Obtain a Debriefing from the Department of Transportation About Any of the Fiscal Year 2023-2024 Award Decisions?

Response

Number of respondents

Percent of respondents

Yes

102

59.3%

No

49

28.5%

Unsure

21

12.2%

Total

172

100%

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

If applicants answered “yes” to Question 27 above, the survey asked Question 28 in Table 37.

Table 37: Question 28. During Your Fiscal Year 2023-2024 MPDG Debrief(s), Did the Department of Transportation Give Your Organization Specific Feedback Concerning Any Award Decisions for Any Individual Program (i.e., INFRA, Mega, and/or Rural)?

Response

Number of respondents

Percent of respondents

Yes, we received feedback regarding one or more individual MPDG programs we applied for

85

83.3%

No, our organization received general application feedback without reference to specific MPDG programs

12

11.8%

Unsure

5

4.9%

Total

102

100%

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

If applicants answered ‘no” to Question 28, the survey asked Question 29 in Table 38.

Table 38: Question 29. How Helpful, if at all, Would More Specific Feedback Concerning Individual Multimodal Project Discretionary Grants Programs Be to Your Organization?

Response

Number of respondents

Percent of respondents

Very helpful

7

58.3%

Moderately helpful

2

16.7%

Slightly helpful

3

25.0%

Not at all helpful

0

0.0%

Unsure

0

0.0%

Total

12

100%

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

If applicants indicated they had obtained a debriefing from DOT about any of the FY2023-2024 MPDG award decisions in question 27, the survey asked Question 30 in table 39 below.

Table 39: Question 30. How Helpful Was the Debrief that Your Organization Received in Terms of Applying for Department of Transportation Grants in the Future?

Response

Number of respondents

Percent of respondents

Very helpful

37

36.3%

Moderately helpful

28

27.5%

Slightly helpful

26

25.5%

Not at all helpful

11

10.8%

Unsure

0

0.0%

Total

102

100%

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

If applicants indicated they had obtained a debriefing from DOT about any of the FY2023-2024 award decisions, the survey asked Question 31 in Table 40.

Table 40: Question 31. Please Describe What Was Helpful or Not Helpful About the Feedback That Your Organization Received from DOT.

Number of written responses

57

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

Note: We do not include narrative responses to open-ended question to protect respondents’ confidentiality.

Additional Feedback on FY2023-2024 Application Process and/or Funding Round

Table 41: Question 32. Based on Your Organization’s Experience, How Transparent Was the Evaluation Process the Department of Transportation Used to Award the 2023-2024 Multimodal Project Discretionary Grants Funding?

Response

Number of respondents

Percent of respondents

Very transparent

31

17.9%

Moderately transparent

72

41.6%

Slightly transparent

31

17.9%

Not at all transparent

23

13.3%

Unsure

16

9.3%

Total

173

100%

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

Table 42: Question 33. Please Offer Any Other Additional Feedback That Your Organization May Have About the FY 2023-24 MPDG Combined Notice of Funding Opportunity (NOFO) and Application Process.

Number of written responses

45

Source: GAO survey of fiscal year 2023-2024 Multimodal Project Discretionary Grant applicants.  |  GAO‑25‑107458

Note: We do not include narrative responses to open-ended question to protect respondents’ confidentiality.

Appendix IV: GAO Contact and Staff Acknowledgments

GAO Contact

Elizabeth Repko, repkoe@gao.gov

Staff Acknowledgments

In addition to the contact named above, Matt Cook (Assistant Director), Catrin Jones (Analyst-in-Charge), Lindsay Bach, Melissa Bodeau, Sean Connolly, Geoffrey Hamilton, Josh Ormond, Jerry Sandau, Chad Williams (Analyst-in-Charge), Alicia Wilson, and Elizabeth Wood made key contributions to this report.

GAO’s Mission

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[1]Pub. L. No. 117-58, 135 Stat. 429 (2021).

[2]Unless indicated otherwise, for the purposes of this report, terminology related to MPDG awards such as “were awarded,” “has awarded,” “was awarded,” “received a grant award,” “INFRA awards,” “Mega awards,” “Rural awards,” “projects awarded,” and “MPDG awards,” generally refer to instances in which DOT announced that it had selected an applicant or applicants to receive an award under the MPDG program. We did not evaluate the extent to which funds for these awards have been obligated or expended.

[3]This includes $212 million in FY2025-2026 funding that DOT awarded in multi-year awards for two Mega projects.

[4]DOT announced the FY2025-2026 INFRA and Mega awards in October 2024 and the FY2025-2026 Rural awards in January 2025. As of April 2025, DOT was reviewing awards for all grant programs, including the MPDG program, for compliance with Administration priorities and Executive Orders. These executive orders include Executive Order 14154, Unleashing American Energy (90 Fed. Reg. 8353 (Jan. 29, 2025)), and Executive Order 14151, Ending Radical And Wasteful Government DEI Programs and Preferencing (90 Fed. Reg. 8339 (Jan. 29, 2025)), among others. DOT is specifically reviewing awards that do not have a signed grant agreement. A DOT grant awardee must sign a grant agreement, which is a legal instrument of financial assistance generally between a federal agency and a recipient and includes terms and conditions of the grant, prior to receiving funding for their projects. The term “grant agreement” is defined at 2 C.F.R. § 200.1 as adopted by DOT at 2 C.F.R. Part 1201.

[5]DOT, U.S. Department of Transportation Strategic Plan FY 2022-2026, (Washington, D.C.: Mar. 28, 2022).

[6]GAO’s Snapshot Report on DOT’s Discretionary Grants provides additional information on these problems with consistency and transparency, and the related recommendations. See GAO, Discretionary Grants: DOT Should Improve Clarity and Transparency of Program Management, GAO‑24‑107264 (Washington, D.C.: Apr. 18, 2024).

[7]GAO, Priority Open Recommendations: Department of Transportation, GAO‑24‑107347 (Washington, D.C.: June 10, 2024). 

[8]IIJA §§ 11132, 21201,135 Stat. at 510, 633. The MPDG FY2022 NOFO provided that FY2022 awards would be “made for each of the three grant programs as appropriate and consistent with each grant program’s statutory language.” 87 Fed. Reg. 17108, 17109 (Mar. 25, 2022).

[9]GAO made three recommendations in these reports. Two recommendations—that DOT clearly define criteria and document its decisions—remain open. GAO, Discretionary Transportation Grants: DOT Should Improve Transparency in the Infrastructure for Rebuilding America Program, GAO‑24‑106378 (Washington, D.C.: Jan. 10, 2024); Discretionary Transportation Grants: DOT Should Fully Document Key Selection Decisions for Its Rural Program, GAO‑24‑106882 (Washington, D.C.: Aug. 12, 2024); and Transportation Grants: Implementation of Recommendations to Improve Documentation Would Enhance Program for Large, Complex Projects, GAO‑25‑107102 (Washington, D.C.: Nov. 13. 2024).

[10]We received 174 responses from 236 eligible applicants surveyed, for a response rate of 74 percent.

[11]We refer to FY2023-2024 MPDG grant program applications as those applications the Senior Review Team evaluated for the INFRA, Rural, and Mega grant programs.

[12]Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 C.F.R. Part 200 (2024), and App. I to Part 200 (2024). DOT has generally adopted these provisions in regulation. 2 C.F.R. § 1201.1 (2024).

[13]DOT’s Guide to Financial Assistance incorporates the OMB Regulations. The October 2019 edition is effective for awards issued on or after January 1, 2020.

[14]We also provided the results of this analysis in an interim briefing document provided to congressional staff in November 2024. This briefing satisfied recurring statutory mandates for GAO to report on the INFRA program (calendar year 2024) and the Rural program (fiscal year 2025).

[16]For example, the five statutory Mega project selection requirements are whether each proposed project: (1) will likely generate national or regional economic, mobility, or safety benefits; (2) is in need of significant federal funding; (3) will be cost-effective; (4) have stable and dependable sources of funding and financing available; and (5) has sufficient legal, financial, and technical capacity. 49 U.S.C. § 6701(f)(1). In addition, an eligible entity seeking a grant under the Mega program is required to submit with its application a plan for the collection and analysis of data to measure and analyze, among other things, the consistency of predicted project characteristics with actual outcomes. 49 U.S.C. § 6701(g).

[17]Under DOT’s MPDG Evaluation Guidelines, if a team review or the Senior Review Team finds that there is information sufficient to determine that the project meets a statutory project requirement, the basis for that determination is to be documented.  

[18]According to the NOFO, the Senior Review Team was to assign a Highly Recommended rating to an application that they determine to be an “exemplary project of national or regional significance that generates significant benefits in one of the project outcome areas” and meets all statutory requirements for award.

 

[19]The Senior Review Team may also add applications rated “Recommended” to each program’s proposed list of Projects for Consideration until each program’s list can satisfy necessary program set asides and geographic diversity requirements.

[20]The FY2023-2024 NOFO provides that the minimum project size for large INFRA projects is “the lesser of (1) $100 million; (2) 30 percent of a States’s FY 2021 Federal-aid apportionment if the project is located in one State; or (3) 50 percent of the larger participating States’s FY 2021 apportionment for projects located in more than one State.” The NOFO also provides that small INFRA projects are those that do not meet the minimum project size criteria for large projects.

[21]See Appendix III for information on the survey methodology and full survey results.

[22]Only those applicants who had applied for a DOT discretionary grant from FY 2016 through FY 2021 were asked to compare the streamlined application process to prior application rounds.

[23]We previously reported that DOT combined the solicitation process for the three grant programs in part to save applicants time and resources since they did not have to submit different applications for each program. GAO‑24‑106378.

[24]We previously reported on applicants’ use of consultants, particularly for those organizations that did not have sufficient staff capacity or expertise to complete technical aspects of the application process such as the benefit-cost analysis. GAO. Discretionary Transportation Grants: DOT Should Better Align Its Application Evaluation Process with Federal Guidance, GAO‑24‑106280 (Washington, D.C.: Nov. 6, 2023

[25]Among the criteria used to evaluate and rate grant applications are six project outcome criteria: (1) Safety; (2) State of Good Repair; (3) Economic Impacts, Freight Movement, and Job Creation; (4) Climate Change, Resiliency, and the Environment; (5) Equity, Multimodal Options, and Quality of Life; (6) Innovation Areas: Technology, Project Delivery, and Financing. For the purposes of this report, we characterize these as “merit criteria.”

[26]We received 76 out of 174 possible written responses to this question. Of those 76 written responses, 14 expressed difficulty meeting innovation concepts in technology, project delivery or financing; 12 noted difficulties faced by rural areas in meeting criteria.

[27]A January 29, 2025 memorandum by the Secretary of DOT implementing various Presidential actions (described earlier) requires specified aspects of DOT programs, such as orders, directives, rules, and funding agreements, among other things, that reference or relate in any way to climate change, “greenhouse gas” emissions, racial equity, gender identity, “diversity, equity, and inclusion” goals, environmental justice, or the Justice40 Initiative, be identified and listed for which actions are to be initiated to rescind, cancel, revoke, and terminate such program aspects, or portions thereof.

[28]Our prior work has highlighted issues with transparency of DOT’s discretionary grant processes. See GAO, Discretionary Transportation Grants: DOT Should Better Communicate Federal Share Requirements to Applicants, GAO‑23‑105639 (Washington, D.C.: Nov. 17, 2022); Discretionary Transportation Grants: DOT Should Clarify Application Requirements and Oversight Activities, GAO‑22‑104532 (Washington, D.C.: Apr. 6, 2022); Discretionary Transportation Grants: Actions Needed to Improve Consistency and Transparency in DOT’s Application Evaluations, GAO‑19‑541 (Washington, D.C.: June 26, 2019); DOT Discretionary Grants: Problems with Hurricane Sandy Transit Grant Selection Process Highlight the Need for Additional Accountability, GAO‑17‑20 (Washington, D.C.: Dec. 14, 2016); and Surface Transportation: Department of Transportation Should Measure the Overall Performance and Outcomes of the TIGER Discretionary Grant Program, GAO‑14‑766 (Washington, D.C.: Sept. 23, 2014). 

[29]GAO, Bridge Investment Program: DOT Should Refine Processes to Improve Consistency, GAO‑25‑107227 (Washington, D.C.: Dec. 11, 2024) and GAO‑24‑106280. In light of applicant experiences in the Rebuilding American Infrastructure with Sustainability and Equity (RAISE) grants, we recommended that DOT should review what additional resources and flexibilities would best address challenges applicants face developing a benefit-cost analysis and take steps to implement them. We determined in February 2025 that DOT had addressed this recommendation by publishing a benefit-cost analysis template on the DOT website to assist RAISE applicants in completing their analyses and held interactive webinars to demonstrate the process. The template and the webinars are now available to applicants on the DOT website.

[30]See GAO‑24‑106378, GAO‑24‑106882, GAO‑25‑107102 for our recent reports on the INFRA, Rural and Mega grant programs, respectively.

[31]According to the NOFO, applications must also meet all statutory requirements for award.

[32]An application would receive a Highly Recommended rating if DOT determined the project meets all statutory requirements for award and it received High ratings in all of project outcomes, cost effectiveness, and project readiness.

[33]The Senior Review Team sometimes cited multiple criteria, therefore the number of criteria cited is higher than the total number of Highly Recommended applications. Additionally, there are no statutory requirements to have a specific diversity in project outcomes that raise a project to a level upon which it was recognized as exemplary, according to DOT officials.

[35]The Evaluation Guide states that the Senior Review Team can request additional information from an applicant if the project received a High in any of the project outcome areas, or if the Senior Review Team provides additional information to demonstrate that the project outcome area has benefits that are aligned with a High rating (whether or not the project outcome analysis team assigned a High rating).

[37]See GAO, Priority Open Recommendations: Department of Transportation, GAO‑23‑106477 (Washington, D.C.: May 9, 2023). DOT concurred with this recommendation, and as of January 2025, DOT officials stated that the Department is in the process of establishing a plan to: (1) establish a department-wide working group and (2) identify deliverables and milestones to address the recommendation.

 

[39]According to DOT officials, DOT initially received a total of 428 applications via the grants.gov website before determining that 89 of these were duplicate applications and 29 were ineligible based upon MPDG program statutory requirements.

[40]The fiscal year 2023-24 NOFO also provided that in addition to the fiscal year 2023-34 funds, prior year INFRA amounts, estimated at up to $50 million, may be made available and awarded under the fiscal year 2023-24 MPDG NOFO.

[41]This includes $212 million in FY2025-2026 funding that DOT awarded in multi-year awards for two Mega projects.

[42]Of the 55 projects awarded MPDG funding, two received a combination of INFRA and Mega funding. See table 2 for details on the specifics of these combined awards. 

[43]The responses provided in this appendix apply only to the FY2023-2024 NOFO. We did not ask DOT about evaluation criteria for future funding rounds.

[44]Notice of Funding Opportunity for the Department of Transportation’s FY2023-2024 Multimodal Project Discretionary Grant Opportunity (MPDG). See also 23 U.S.C. § 117; 23 U.S.C. § 173; 49 U.S.C. § 6701, respectively.

[45]The NOFO identified priorities in Executive Order No. 14052, Implementation of the Infrastructure Investment and Jobs Act, 86 Fed. Reg. 64355 (Nov. 18, 2021). Implementation priorities in this executive order require covered agencies to, as appropriate and to the extent consistent with law, prioritize: (a) investing public dollars efficiently, working to avoid waste, and focusing on measurable outcomes for the American people; (b) increasing the competitiveness of the United States economy, including through implementing the Act’s Made-in-America requirements and bolstering United States manufacturing and supply chains; (c) improving job opportunities for millions of Americans by focusing on high labor standards for these jobs, including prevailing wages and the free and fair chance to join a union; (d) investing public dollars equitably, including through the Justice40 Initiative (Executive Order No. 14008, § 223, 86 Fed. Reg. 7619, 7631 (Feb. 1, 2021)), which is a Government-wide effort toward a goal that 40 percent of the overall benefits from Federal investments in climate and clean energy flow to disadvantaged communities; (e) building infrastructure that is resilient and that helps combat the crisis of climate change; and (f) effectively coordinating with State, local, Tribal, and territorial governments in implementing these critical investments. Executive Order No. 14052 was revoked by Executive Order No. 14148, Initial Recissions of Harmful Executive Orders and Actions, 90 Fed. Reg. 8237 (Jan. 29, 2025), and Executive Order No. 14008 was revoked by Executive Order No. 14148, Initial Recissions of Harmful Executive Orders and Actions, 90 Fed. Reg. 8237 (Jan. 29, 2025) and by Executive Order No. 14154, Unleashing American Energy, 90 Fed. Reg. 8353 (Jan. 29, 2025).

[46]The specific aspects identified in the NOFO were those that improve safety, economic strength and global competitiveness, equity, and climate change and sustainability.

[47]With respect to how these strategic goals were considered, DOT pointed to the MPDG Evaluation Guidelines, Appendix IV – Statutory Program Goals, Evaluation Criteria and Additional Consideration Crosswalk: For the “Equity, Multimodal Options, and Quality of Life” evaluation area, DOT provided the following: Mega – “whether a project would benefit (i) a historically disadvantaged community or population or (ii) an area of persistent poverty” (49 U.S.C. § 6701(f)(3)(D)); INFRA - “address the impact of population growth on the movement of people and freight” (23 U.S.C. § 177(a)(2)(G)); and Rural - “improve access to emergency care, essential services, healthcare providers, or drug and alcohol treatment and rehabilitation resources” (23 USC § 173(h)(8)). For the “Climate Change, Resiliency, and the Environment” evaluation area, DOT provided the following: Mega – “reduction in GHG emissions, air quality benefits, preventing stormwater runoff” (49 U.S.C. § 6701(f)(2)(B)(v)); Rural - “improve reliability” (23 U.S.C. § 173(b)(2)); and INFRA - “enhancement of freight resilience to natural hazards or disasters (23 U.S.C. § 117(h)(4)).

[48]DOT cited to respective MPDG program form and content provisions at 49 U.S.C. § 6701(c)(1), 23 U.S.C. § 117(c)(2), and 23 U.S.C. § 173(d). The Mega statute’s form and content provisions, for example, provide that “to be eligible for a grant under the program, an eligible entity shall submit to the Secretary an application at such time, in such manner, and containing such information as the Secretary determines to be appropriate. 49 U.S.C. § 6701(c)(1).

 

[49]The FY2023-2024 MPDG NOFO cites to, for example, the following priorities in Executive Order 14052, Implementation of the Infrastructure Investment and Jobs Act. 86 Fed. Reg. 64335 (Nov. 18, 2021): to invest efficiently and equitably, promote the competitiveness of the U.S. economy, improve job opportunities by focusing on high labor standards and equal employment opportunity, strengthen infrastructure resilience to all hazards including climate change, and to effectively coordinate with State, local, Tribal, and territorial government partners. Executive Order No. 14052 was revoked by Executive Order No. 14148, Initial Recissions of Harmful Executive Orders and Actions, 90 Fed. Reg. 8237 (Jan. 29, 2025).

[50]For the FY2023-2024 MPDG round, and during part of the period of time in which we conducted this audit, these executive branch memos included Office of Management and Budget, Council on Environmental Quality, and White House Office of Domestic Climate Policy, Interim Implementation Guidance for the Justice40 Initiative, M-21-28 (July 20, 2021); and Addendum to the Interim Implementation Guidance for the Justice40 Initiative, M-21-28, on using the Climate and Economic Justice Screening Tool (CEJST), M-23-09 (Jan. 27, 2023). Underlying Executive Orders for these memos (Exec. Order No. 14008, Tackling the Climate Crisis at Home and Abroad, 86 Fed. Reg. 7619 (Feb. 1, 2021); Exec. Order No. 13985, Advancing Racial Equity and Support for Underserved Communities Through the Federal Government, 86 Fed. Reg. 7009 (Jan. 25, 2021)) have been revoked and administration priorities have changed. See Exec. Order No. 14154, Unleashing American Energy, 90 Fed. Reg. 8353 (Jan. 20, 2025), Exec. Order No. 14148, Initial Recissions of Harmful Executive Orders and Actions, 90 Fed. Reg. 8237 (Jan. 20, 2025).

[51]2 C.F.R. § 200.211(c)(1)(ii) (2024).

[52]Executive Order No. 13985, 86 Fed. Reg. 7009 (Jan. 20, 2021). Exec. Order No. 13985, Advancing Racial Equity and Support for Underserved Communities Through the Federal Government, 86 Fed. Reg. 7009 (Jan. 25, 2021)) has been revoked. See Exec. Order No. 14148, Initial Recissions of Harmful Executive Orders and Actions, 90 Fed. Reg. 8237 (Jan. 20, 2025). 

[53]See 2 C.F.R. § 200.211(c)(1) (2024). 

[54]Executive Order No. 14126, 89 Fed. Reg. 73559 (Sept. 6, 2024); Executive Order No. 14063, 87 Fed. Reg. 7363 (Feb. 4, 2002). Exec. Order No. 14126, Investing in America and Investing in American Workers was revoked by Exec. Order No. 14236, Additional Rescissions of Harmful Executive Orders and Actions, 90 Fed. Reg. 13037 (Mar. 14, 2025). Executive Order No. 14063 has since been the subject of litigation. See, e.g., MVL USA, Inc. v. United States, 74 Fed. Cl. 437 (2025), MVL USA, Inc. v. United States, 2025 U.S. Claims LEXIS 1153 (2025), Complaint of Ass'n Builders & Contractors Florida First Coast Chapter v. Gen. Servs. Admin., No. 3:24-cv-318 (M.D. Fla. 2025), Complaint of N. Am.'s Bldg. Trades Unions v. Dep't of Def., No. 1:25-cv-1070 (D.C. Cir. 2024).

[55]The Mega program statute requires the Secretary to assign a rating of Highly Recommended to projects that, in the determination of the Secretary – (1) are exemplary projects of national or regional significance; and (2) would provide public benefit, as determined based on the applicable criteria described the Mega program statute project “evaluation and selection” subsection, if funded under the program. 49 U.S.C. § 6701(f)(4)(B)(I).

[56]DOT noted that both the Mega grant program statute (49 U.S.C. § 6701) and the Capital Investment Grants program statute (49 U.S.C. § 5309) are examples of programs with statutorily mandated evaluation schemes. 

[57]For INFRA projects that are selected for funding, this provision requires the Secretary to submit reports to specified congressional committees describing the reasons for selecting the project, based on any criteria established by the Secretary in accordance with the INFRA program statute. 23 U.S.C. § 117(p)(1)(A).

[58]This quantity represents the total population of officials responsible for one or more MPDG project applications; officials responsible for more than one application were surveyed only once.

[59]Unless indicated otherwise, for the purposes of this report, terminology related to MPDG awards, such as “were awarded,” “has awarded,” “was awarded,” “received a grant award,” “INFRA awards,” “Mega awards,” “Rural awards,” “projects awarded,” and “MPDG awards,” generally refer to instances in which DOT announced that it had selected an applicant or applicants to receive an award under the MPDG program. We did not evaluate the extent to which funds for these awards have been obligated or expended.

[60]See Appendix I for more information on the characteristics of the awards and the locations of the organizations that received them.