DOT IG Releases their Audit of the CSA Program


Last week the DOT Inspector General’s office released their audit on the CSA program late last week. In brief summary the IG found that while FMCSA has strengthened its controls to improve the quality of State-reported data used to assess carriers’ safety performance, the Agency has not fully implemented planned improvements to its processes for reviewing data correction requests and for ensuring that carriers submit accurate information. In addition, FMCSA has not fully implemented the CSA enforcement intervention process nationwide; at the time of their report, only 10 States had fully implemented CSA enforcement interventions. Finally, FMCSA has limited documentation demonstrating it followed information technology best practices and Federal guidance for its Carrier Safety Measurement System. FMCSA concurred with all six of our recommendations to strengthen CSA.

The IG notes that FMCSA has made progress in moving toward a more data-driven, risk-based approach to oversight of the motor carrier industry, as called for by CSA. Quality data are critical to accurately identifying the highest risk carriers for enforcement interventions. While FMCSA has strengthened quality controls for State-reported data, more action is needed in key areas, including improving census data and completing its roll out of CSA enforcement interventions. Given that CSMS is such a highvisibility system within the motor carrier industry, FMCSA can also enhance its documentation of system processes to better adhere to best practices and Federal guidance. Without sustained management attention in these areas, FMCSA will be hindered in its ability to effectively implement CSA nationwide and address the key concerns of industry stakeholders.

Specifically, the IG recommends that the Agency:

1. Issue updated DataQs guidance;
2. Implement the process for deactivating USDOT numbers when carriers do not submit required census data, as described in FMCSA memorandum MC-ECS-2013-0009;
3. Develop a comprehensive plan to fully implement CSA enforcement interventions in the remaining 41 States. The plan should include an estimated completion date and milestones for releasing Sentri software, developing and delivering training, and using the enforcement interventions;
4. Update the CSMS requirements document to (a) specify all sources of CSMS data, including each of the MCMIS fields used , and (b) fully describe CSMS validation procedures;
5. Develop and implement a process for managing CSMS system documentation that includes a central file for validation records and testing results; and
6. Develop and implement a configuration management policy that includes documentation of system changes and associated testing for CSMS.