Beginning this year, the Texas Department of Transportation (TxDOT) Traffic Safety Section implemented specific requirements for ethical conduct for cities receiving grant funds. This new initiative resulted in TxDOT conducting audits with all cities that receive traffic safety grant funds to ensure compliance with their Internal Ethics and Compliance Program.
Although this compliance audit focused on traffic safety grant funds, the City's finance staff was informed this requirement will apply to additional TxDOT grant funds in the future. In 2017, the City received $53,000 from TxDOT for the STEP grant program and $132,440 from the TAPS grant program for sidewalk connectivity to schools.
TxDOT recently completed their review and issued an Improvement Action Plan for the City of Allen. As a result, TxDOT recommends the City provide a system for employees and volunteers to report ethics violations anonymously and without fear of retaliation, which is sometimes referred to as a "Whistleblowing Policy." To meet the TxDOT's findings, the Personnel Policies and Procedures Manual needs to be amended to include an Ethics Hotline Policy and related ethics training. Staff recommends using a third party hotline service, which allows for anonymous reports to be submitted and established practices will ensure the validity of such claims, which is consistent with other cities' practices and internal auditing standards.
If the City does not implement these changes it will not be eligible for future grant appropriations and additional grant awards.