Assurance and Compliance Office


The Assurance and Compliance Office advises the Commissioner of Highways, Commonwealth Transportation Board, Secretary of Transportation, and Governor’s Office on core matters relating to:

  • The condition of agency accounting, financial and administrative controls
  • Investigations to resolve allegations of fraudulent, illegal, and/or inappropriate activities
  • Prevention and detection of fraud, waste, and abuse
  • Coordination with federal and state law enforcement and prosecutorial agencies

The office promotes integrity, accountability, and process improvements in the Virginia Department of Transportation (“VDOT”).  In addition, the office promotes VDOT’s programs and goals by creating and working toward a shared vision of values and ethical behaviors.


Right of Way Ombudsman

VDOT has established the Right of Way Ombudsman effective Monday June 23, 2014 to be administered by the Assurance and Compliance Office.

The mission of the ombudsman is to provide independent and objective review of limited VDOT Right of Way actions, specific to eminent domain, that impacts constituents of the Commonwealth of Virginia.

The ombudsman will:

  • Identify involved/impacted parties.
  • Identify key documents, records and information relative to the dispute.
  • Identify specific action requested by constituent.
  • Identify options to resolve the dispute.
  • Assist all parties in the evaluation of dispute resolution options.

The ombudsman will not:

  • Advocate for one party or point of view.
  • Substitute and/or replace formal processes.
  • Provide legal advice or opinions.
  • Act as the final adjudicator.

The scope of assistance provided by the ombudsman will exclude the following Right of Way processes:

  • Just Compensation
  • Relocation Assistance
  • Civil Rights

Ombudsman Contact Info


Internal Audits

Independent and objective audits are conducted to determine whether VDOT’s network of risk management and internal control governance processes, as designed and represented by management, is adequate and functioning to ensure effectiveness and efficiency of operations; reliability of reporting; and in compliance with policies, procedures, laws, and regulations.

Recommendations are made for improvements in procedures and systems.


The staff reviews Fiscal Division’s internal control assessments and test plans for the Agency Risk Management and Internal Control Standards (“ARMICS”) Stage II Reviews as prescribed by the Department of Accounts (“DOA”).

Special Projects

Special projects are audits, reviews or investigations that are not scheduled on the Audit Plan based on the normal risk assessment process. The staff may, upon request, also be assigned to perform audits, reviews or investigations for other state agencies. The scope of the special project is determined at the time of the engagement.


State Fraud, Waste and Abuse Hotlines - The staff conduct investigations for the State Fraud, Waste, and Abuse Hotline (formally known as the State Employee Fraud, Waste, and Abuse Hotline), which is administered by the Office of State Inspector General (“OSIG”).

Investigations (non-Hotline related) - The staff conduct investigations based on detection, referral, or request by management of misconduct, policy misapplication, or fraud, waste, abuse or any other inappropriate activity.

External Reviews and Evaluations

CPA Workpaper Reviews on Indirect Cost Rate Audits – Contracts awarded for engineering and design services by state transportation departments must follow the with cost principles contained in the Federal Acquisition Regulations (“FAR”) of part 31 of title 48, Code of Federal Regulations (“CFR”).  As such, consulting firms are required to submit an indirect cost rate audit report (“Indirect Cost Rate Audit”) to the Assurance and Compliance Office (“ACO”) for the most recent fiscal year.  Additional information concerning indirect cost rate audits and the data to be submitted to ACO is provided at our Indirect Cost Rate Audit Home Page.

ACO will accept the consulting firm’s indirect cost rate(s) as initially submitted, subject to audit.  ACO reserves the right to review the workpapers of the consulting firm’s CPA as part of the acceptance of the consulting firm’s indirect cost rate(s).  Using a risk based approach, ACO or its designee will conduct CPA workpaper reviews on selected consultants using the guidance of the AASHTO Audit Guide, Chapter 12 and Appendix A-1 to determine:

  • the CPA’s audit was conducted in accordance with GAGAS;
  • the CPA adequately considered the auditee’s compliance with FAR Part 31 and other related laws, regulations and guidance; and
  • the audit report format is acceptable.

Based on the results or the CPA workpaper review, the indirect cost rate(s) may be adjusted and/or rejected.

Indirect Cost Allocation Plan Reviews - The ACO also performs reviews of Indirect Cost Allocation Plans (“ICAP”) prepared and submitted by Metropolitan Planning Organizations (“MPO”) and Planning District Commissions (“PDC”) that wish to be reimbursed for indirect costs on projects funded by the Federal Highway Administration (“FHWA”). These reviews are performed in accordance with 2 CFR Part 225 Section D.

Pre-Award Evaluations - To assist VDOT in the overall evaluation of architectural and engineering consultant proposals, pre-award evaluations are conducted to determine if the provisions of the proposed agreement are in compliance with VDOT policy and federal regulations (23 CFR Part 172). The pre-award evaluation should, to the fullest extent possible, determine the financial capability of the firm, the adequacy of the organization’s accounting system and the propriety of overhead and labor additives.

Final Reviews - At the completion of an architectural and engineering consultant contract, when a final invoice is completed, a final review is performed to ascertain that the correct FAR indirect cost rates were used, the costs represented on the invoices were in accordance with the terms and conditions of the contract and VDOT policy, the invoices were supported by proper source documentation, and the actual costs invoiced by the consultant for services performed on the project were fair and reasonable as required by 23 CFR Part 172.  This review can also be performed as an interim review, prior to contract completion.

Comprehensive Annual Financial Report Reviews - Comprehensive Annual Financial Reports

(“CAFR”) of localities and municipalities and PDC’s are reviewed by ACO staff to ensure compliance with OMB Circular A-133 requirements. VDOT is required to perform sub-recipient monitoring on entities that have received $500,000 or more in federal awards during the entities fiscal year, have met the audit requirements contained in the OMB Circular A-133.


Contact Information

Bradley Gales, Director
Right of Way Ombudsman
Assurance and Compliance Office
Virginia Department of Transportation
Central Office Annex Building, Room 1409
1401 E. Broad St.
Richmond, Va. 23219

Phone:  804-786-2825
Fax:  804-786-2487



Page last modified: Oct. 30, 2019