Inspector General: Internal administration of CSA needs shored up

By Jami Jones, Land Line managing editor | Monday, March 10, 2014

CSA was dealt another investigative blow recently when the Department of Transportation’s Office of Inspector General found that FMCSA still has work to do.

After three full years since the nationwide launch of the Compliance, Safety, Accountability program, some of the same nagging problems still exist for the Federal Motor Carrier Safety Administration.

While a recent GAO report on CSA focused on the wheels-on-the-ground effects of the program, a new Inspector General audit zeroed in on the administration, implementation and rollout of the program.

The program collects data from roadside inspections and crash reports to weight, score and arrive at a compliance ranking for motor carriers. Consistency of reporting from jurisdiction to jurisdiction has always been a concern.

Data quality, correction
The Inspector General found that the data quality submitted by the different states has generally improved. But that doesn’t mean all data are 100 percent accurate. The audit found that FMCSA has not yet implemented planned actions to revise guidance for its data correction process – called DataQs. The agency concurred with that finding and responded that the guidance is in the works.

Universal enforcement
To date, according to the audit, only 10 states have fully implemented CSA enforcement interventions. Interventions are various enforcement-related actions taken on motor carriers ranging from a warning letter that does not require any follow-up to full-blown compliance reviews. That leaves 41 jurisdictions (including the District of Columbia) waiting on delivery of new software to assess and monitor interventions. FMCSA said it is working toward the release of the software along with training for the states.

Motor carrier reporting
Motor carriers are required to submit a MCS-150 form to FMCSA every other year. Less than half of active interstate carriers were found to have updated their information as required, according to the audit. The Inspector General said that lack of reporting interferes with accurate calculations of motor carrier safety compliance.

To motivate carriers to submit their MCS-150, FMCSA issued a policy in November 2013 to deactivate USDOT numbers for carriers that do not submit required information. Those deactivations are to begin in March.

Does CSA even work right?
There are tried-and-true methods to developing a system like CSA. They’re called “best practices. There is also federal guidance that agencies must follow.

Whether FMCSA adhered to those best practices and federal guidance is unknown because of a lack of documentation that the agency took the necessary steps to make sure CSA operates correctly, has the necessary information system components, etc.

When the audit was first announced in early 2013, FMCSA compiled its “requirements document,” which describes the functions the CSA system is intended to perform. However, the audit states that the document did not include a complete list of the 51 data fields used in CSA to calculate motor carrier compliance.

“Without a complete and documented list of the 51 data fields, it is difficult for FMCSA to demonstrate the quality of the data it relies on to calculate percentile rankings,” the audit states.

The agency also does not have a formal process of validating the data in the system that leads to compliance rankings or a process for validating that the system works after modifications to the programming. Without that formal process being laid out, in writing, the audit concludes that there is no assurance that the staff will carry out these validation processes.

The audit also pointed out that the agency lacks a documented process for making changes to an IT system. The staff of FMCSA was able to describe to the Inspector General the steps they took when making changes to CSA. But the agency cannot demonstrate that the processes were followed, and it cannot show that testing was conducted after each of the four changes to CSA that have been implemented since it launched nationally.

FMCSA concurred with all of the Inspector General’s findings and is in the process of formalizing and documenting the processes for validating the data, resulting compliance rankings, modifying the programming and testing of the system after changes.

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