Complete, cited records for federally funded construction.

Under 23 CFR 637.207, a materials certification is submitted for each construction project subject to FHWA construction oversight, and the certification form in the rule’s appendix A provides for exceptions to the plans and specifications to be explained. In a 2025 DOT Inspector General audit of construction quality assurance oversight, 8 of the 10 sampled project certifications did not comply with the regulatory requirements, and six used language that differed from the prescribed wording, including qualifying terms such as "substantial compliance" or "close conformity."

How Specset helps: Specset reads the test reports and certificates in the project record against the governing specification section and cites each result that does not meet it, so the exceptions list is drafted from every report on file. Upload your agency’s certification template and Specset’s agents fill it in from the record, with every value cited. The responsible State DOT official reviews the certification, decides what it says, and signs it.

The same Inspector General report notes, citing FHWA information, that construction quality on locally administered projects has been a particular concern, including material testing that was often not done or not documented. The 2025 OMB Compliance Supplement tells auditors of Federal-aid highway programs to review documentation of test results on a sample basis. On AIP-funded airport work, FAA AC 150/5370-12B requires a construction management program when a project’s paving costs exceed $500,000. The program lists all tests the contract specifications require, and at completion the sponsor submits a final test and quality assurance report that highlights failed tests.

How Specset helps: Specset builds the register the specifications require from the project manual, including test reports and certificates, with a section and paragraph citation on each row. As reports come in, it checks each one against the section that calls for it. A required report with nothing on file, or a result that does not meet the section, shows up while the work is still open, not at closeout.

In a 2025 DOT Inspector General audit of Buy America compliance on Federal-aid highway projects, 9 of the 162 materials certifications reviewed on one state’s projects were incomplete or missing. Some lacked chemical analysis results, the contract number, or any project-identifying information. The auditors could not independently tie 76 of the 162 back to the projects reviewed. The Inspector General’s FY2026 top management challenges report cites over $750,000 in questioned costs for material of unknown origin on three Federal-aid projects.

How Specset helps: When the contract’s Buy America provisions are in the project record, submittal review checks each product submittal for the certifications those provisions ask for, flags a required certificate or mill test report that is missing, and cites the paragraph behind each finding. It also flags a certificate that lacks a field the specifications require, such as the project or contract number. Specset does not verify where a product was made.

Missing FTA clauses is one of the top 10 deficiencies FTA reported from its FY2023 triennial reviews. The 2025 OMB Compliance Supplement tells auditors to test whether Build America, Buy America provisions were included in each sampled agreement for infrastructure projects. In a 2026 audit of IIJA-funded federal facility and equipment contracts, the DOT Inspector General found five of the nine reviewed were missing Buy American-related clauses.

How Specset helps: Upload the clause list your program requires, and Specset checks the agreement, conditions, Division 00 and 01 specifications, and the subcontracts and purchase orders in the record against it, citing where each clause appears or marking it not found. Your counsel and contracting officer decide what goes in.

On Federal-aid highway projects, the State DOT must perform and adequately document a cost analysis of each negotiated contract change. Uniform Guidance requires a cost or price analysis for every procurement transaction above the simplified acquisition threshold, including contract modifications. FHWA’s guidance for local agencies says to prepare documents that justify the need for the modification and the proposed cost changes, starting with why the change is necessary.

How Specset helps: Specset keeps the documents behind each change in one place: the RFI, the revised sheets, the governing paragraph, and a plan comparison showing what changed between sets. Your team cites those documents when it writes the justification. Specset does not prepare the cost analysis or the independent estimate. That stays with your estimators and the agency.

Uniform Guidance requires recipients and subrecipients to retain all Federal award records for three years from the final financial report, and longer while any litigation, claim, or audit finding is unresolved. FHWA tells local agencies that supporting documentation must be securely filed and available upon request for audits or reviews. FAA’s record keeping guidance for airport sponsors lists record drawings, Buy American documentation, a summary of test results, and daily records and reports among the project records to keep.

How Specset helps: Specifications, drawings, submittals, RFIs, and the revision history stay in one project record. Specset logs who confirmed, edited, or dismissed each finding, and when, and that decision log can be extracted onto the template or format your auditor asks for. At closeout, export the full project record. Record search spans the projects your organization can access, including retained past projects, so the documents behind a sampled item are found by asking. In Specset, the record is kept as long as your contract with Specset specifies.