AUTO RECALLS

NHTSA Should Take 

Steps to Further 

Improve the Usability 

of Its Website 

Report to Congressional Committees

December 2017

GAO-18-127

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-127, a report to 

congressional committees

December 2017

December 2017

AUTO RECALLS

NHTSA Should Take Steps to Further Improve the 

Usability of Its Website

What GAO Found

Consumers, manufacturers, and auto dealers use publicly available auto recall 

information differently. For example, the 94 consumers in 12 focus groups that 

GAO conducted used this information to decide whether to repair their vehicles.

These consumers overwhelmingly cited safety risk and convenience as the two 

most influential factors they considered. Most consumers reported a preference 

for receiving recall notification by at least one electronic means, such as by email or text message, in addition to mail. However, only 7 of 94 consumers 

reported receiving electronic notifications, suggesting a gap between the

industry’s auto recall notification practices and consumers’ preferences. (See 

fig.). In response to a mandate in law, in September 2016, the National Highway 

Traffic Safety Administration (NHTSA) issued a proposed rule that, if finalized, 

would require manufacturers to notify consumers about auto recalls by electronic 

means in addition to mail. 

How Consumers Who Participated in GAO’s Focus Groups Actually Received and Preferred to 

Receive Auto Recall Information 

Most consumers in GAO’s focus group website usability tests found the auto 

recall areas of NHTSA’s website—NHTSA.gov—easy to use; however, some 

consumers experienced difficulties when asked to complete auto recall related 

tasks. For example, when consumers attempted to search for recalls affecting 

their specific vehicles, some found the search results confusing, leading them to 

question the accuracy of the results. Similarly, some consumers were hampered 

in searching for recalls by their vehicles’ year, make, and model because the 

website did not always display model options using plain language. GAO found

that the auto recall areas of NHTSA.gov do not always reflect federal and 

industry key website usability practices, and that an independent evaluation 

conducted by website usability professionals at GAO’s request identified similar

issues. NHTSA is in the process of consolidating its websites and plans to 

conduct a website usability study of NHTSA.gov with consumers after the 

consolidation is complete. However, the agency has not determined a 

completion date for the consolidation effort—an essential step for organizations 

to effectively guide their information technology efforts. Without establishing a 

completion date and taking interim steps to improve the usability of NHTSA.gov, 

consumers will likely continue to experience difficulties, which may limit the 

effectiveness of the website’s primary means of providing consumers with 

information about recalls affecting their vehicles.

View GAO-18-127. For more information, 

contact Susan Fleming at (202) 512-2834 or 

flemings@gao.gov. 

Why GAO Did This Study

The number of vehicles affected by 

safety defect recalls increased sharply 

in recent years—from nearly 13 million 

in 2011 to over 51 million in 2016. 

Once a defect is identified, auto 

manufacturers are required to send 

written notification to vehicle owners by

mail. NHTSA also aims to enhance 

awareness of auto recalls by providing 

information on its website, NHTSA.gov.

The Fixing America’s Surface 

Transportation Act includes a provision 

requiring GAO to study the use of 

publicly available safety recall 

information. This report addresses: (1)

how consumers and industry 

stakeholders use such information and

(2) how easy to use do consumers find 

the auto recall areas of NHTSA.gov, 

among other objectives. To understand 

consumers’ use of auto recall 

information and to test website 

usability, GAO conducted 12 focus 

groups with 94 consumers who had a

recall. Focus groups were held in six 

locations selected for population and 

geographic variation. GAO identified 

key website usability practices and 

requested an evaluation by website 

usability professionals. GAO reviewed 

statutes, regulations, and NHTSA 

documents, and interviewed industry 

stakeholders—including 10 

manufacturers selected based on sales 

market share and other factors.

What GAO Recommends

GAO recommends that NHTSA

determine a completion date for its 

website consolidation effort and take 

interim steps to improve the usability of 

NHTSA.gov by addressing the website 

usability difficulties GAO identified. The 

Department of Transportation

concurred with the recommendations.
Page i GAO-18-127 Auto Recalls

Letter 1

Background 5

Auto Recall Information Use Varies, and Most Consumers in 

Focus Groups Preferred Electronic Recall Notifications in 

Addition to Mail 9

Most Consumers in Focus Groups Found the Auto Recall Areas of 

NHTSA.gov Generally Easy to Use, but Some Experienced 

Difficulties 15

NHTSA Has Initiated Activities to Raise Consumer Awareness 

about Recalls, but It Is Too Early to Evaluate the Agency’s 

Efforts 23

Conclusions 28

Recommendations for Executive Action 29

Agency Comments 29

Appendix I: Objectives, Scope, and Methodology 31

Appendix II: Example of an Auto Manufacturer’s 

Recall Notification Letter 39

Appendix III: Annual Recall Completion Rates by Vehicle Component 

and Vehicle Type 43

Appendix IV: Focus Group Participants’ Responses to 

Recall Notification Questionnaire 46

Appendix V: Focus Group Participants’ Responses to 

Website Usability Questionnaire 48

Appendix VI: Comments from the Department of Transportation 50

Contents
Page ii GAO-18-127 Auto Recalls

Appendix VII: GAO Contact and Staff Acknowledgments 52

Tables

Table 1: Most Influential Factors Selected by Consumers in Our 

Focus Groups when Deciding Whether to Repair Recalled 

Vehicles with Safety Defects 10

Table 2: How Easy or Difficult Did Consumers Who Participated in 

Our Focus Groups Find Performing Auto Recall Tasks on 

NHTSA.gov, by Number of Consumers 18

Table 3: Characteristics of Locations We Selected to Conduct 

Focus Groups with Consumers 32

Table 4: List of Industry Stakeholders We Interviewed 35

Table 5: Auto Recall Annual Completion Rates by Vehicle Type, 

Calendar Years 2011 through 2014 44

Table 6: Auto Recall Annual Completion Rates by Vehicle 

Component, Calendar Years 2011 through 2014 44

Table 7: Focus Group Participants’ Responses to Administered 

Recall Notification Questionnaire, by Age Group 46

Table 8: Focus Group Participants’ Responses to Administered 

Website Usability Questionnaire, by Age Group 48

Figures

Figure 1: Number of Safety Defect Vehicle Recalls and Vehicles 

Affected from Calendar Years 2011 through 2016 7

Figure 2: How Consumers in Our Focus Groups Received and 

Preferred to Receive Auto Recall Notifications 14

Figure 3: How Easy or Difficult to Use Were the Auto Recall Areas 

of NHTSA.gov for Consumers Who Participated in Our 

Focus Groups 16

Figure 4: Number of Auto Recall Searches by Vehicle 

Identification Number on the National Highway Traffic 

Safety Administration’s (NHTSA) Websites, Weekly from 

August 2014 through May 2017 20

Figure 5: Location of the National Highway Traffic Safety 

Administration’s (NHTSA) Recall Notification E-mail 

System Sign-Up Task on NHTSA.gov’s Homepage 22
Page iii GAO-18-127 Auto Recalls

Abbreviations

CY calendar year

DOT Department of Transportation

FAST Act Fixing America's Surface Transportation Act

FY fiscal year

GPRA Government Performance and Results Act of 1993

GSA General Services Administration

MSA Metropolitan Statistical Area

NHTSA National Highway Traffic Safety Administration

NPRM Notice of Proposed Rulemaking

OCCI Office of Communications and Consumer Information

VIN vehicle identification number

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-18-127 Auto Recalls

441 G St. N.W.

Washington, DC 20548

Letter

December 4, 2017

The Honorable John Thune

Chairman

The Honorable Bill Nelson

Ranking Member

Committee on Commerce, Science, and Transportation

United States Senate

The Honorable Greg Walden

Chairman

The Honorable Frank Pallone

Ranking Member

Committee on Energy and Commerce

House of Representatives

The number of vehicles affected by safety defect vehicle recalls (auto 

recalls) has increased dramatically in recent years—rising from nearly 13 

million in 2011 to over 51 million in 2016. This increase is driven in part by 

several large-scale recalls, such as the ongoing recall of 34 million 

vehicles with defective Takata air bag inflators that have caused at least 

13 deaths and more than 220 injuries in the United States.

Auto recalls seek to address a wide variety of safety risks, such as wiring 

system problems that may result in vehicle fires or windshield wiper 

assemblies that fail to operate properly. When safety defects are 

identified, auto manufacturers are required to notify consumers and 

remedy (repair) the problem without charge. The National Highway Traffic 

Safety Administration (NHTSA) monitors the percentage of defective 

vehicles that manufacturers ultimately remedy (completion rates). 

However, according to NHTSA’s Strategic Plan 2016–2020, auto recall 

completion rates are unacceptably low, leaving vehicles with potentially 

deadly safety defects on the road.1 In calendar year 2014—the latest year 

for which data are complete—67 percent of recalled light vehicles had 

been remedied. NHTSA aims to enhance the public’s awareness of auto 

recalls and improve completion rates by, for example, providing 

information on its website, NHTSA.gov

 1

National Highway Traffic Safety Administration, The Road Ahead: National Highway 

Traffic Safety Administration Strategic Plan 2016-2020 (October 2016).
Letter

Page 2 GAO-18-127 Auto Recalls

The Fixing America’s Surface Transportation Act (FAST Act) requires 

GAO to study the use of publicly available safety recall information.2 This 

report addresses the following objectives: (1) How do consumers and 

industry stakeholders use publicly available auto recall information? (2) 

How easy or difficult to use do consumers find the auto recall areas of 

NHTSA.gov? (3) What steps, if any, has NHTSA taken to raise consumer 

awareness about auto recalls and how has NHTSA evaluated the 

effectiveness of these steps?

For purposes of this report we define publicly available auto recall 

information to include information on the auto recall areas of NHTSA.gov, 

such as examples of notification letters that manufacturers mail to

consumers. This report focuses on safety defect vehicle recalls affecting 

passenger vehicles that are initiated when a defect in a vehicle or vehicle 

equipment creates an unreasonable safety risk, as determined by NHTSA 

or a manufacturer.3

To inform the first two objectives, we conducted 12 focus groups with new 

and used vehicle owners who had experienced an auto recall in the last 

24 months. Each focus group was split into two sessions: (1) a discussion 

session to explore participants’ thoughts, experiences, and preferences 

about auto recall information and (2) a session to test the usability of the 

auto recall areas of NHTSA.gov. We conducted focus groups at six 

locations across the country to provide population and geographic 

dispersion, with each group including 7 or 8 consumers for a total of 94 

participants. Half of the focus groups were comprised of consumers who 

had completed the repair and the remaining half included consumers who 

had not completed the repair. We selected focus group participants based 

 2

Pub. L. No. 114-94, § 24103(b), 129 Stat. 1312, 1702 (Dec. 4, 2015).

3

NHTSA is responsible for overseeing two types of recalls: compliance and safety defect 

recalls. Compliance recalls are initiated when vehicles are determined to be noncompliant 

with applicable Federal Motor Vehicle Safety Standards, as identified by NHTSA or a 

manufacturer. They represent a relatively small percentage of total vehicle recalls—about 

16 percent in calendar year 2016, according to NHTSA’s 2016 Annual Recall Report. We 

did not examine compliance recalls, nor did we examine car seat (e.g., child safety seat), 

tire, and other equipment (e.g., vehicle accessories and after-market equipment such as 

lighting, trailer hitches, and bike racks) recalls, as these products have different consumer 

notification requirements. We did not review Technical Service Bulletins. Passenger 

vehicles include cars, pickup trucks, sport utility vehicles, large passenger vans, and 

minivans, but exclude other vehicles, such as motorcycles, recreational vehicles, and 

commercial trucks.
Letter

Page 3 GAO-18-127 Auto Recalls

on age, income, gender, education level, race, and ethnicity to ensure we 

collected a range of perspectives.

• We evaluated transcripts of each focus group session using 

systematic content analysis to identify how consumers used auto 

recall information and to evaluate how easy or difficult consumers 

found the auto recall areas of NHTSA.gov to use.4

• We also analyzed participants’ responses to the questionnaires we 

administered for each session to quantify responses regarding how 

consumers used auto recall information—including how they received 

and preferred to receive auto recall notifications—and participants’ 

assessments of NHTSA.gov’s usability while performing certain auto 

recall tasks on the website.

Since we did not select a representative sample of participants, the 

results of our focus group analyses are not generalizable to all vehicle 

owners.

To determine how industry stakeholders use auto recall information, we 

interviewed representatives from 10 auto manufacturers, selected based 

on each manufacturer’s sales market share, place of ownership, and 

experience with auto recalls, collecting a range of perspectives on how 

manufacturers use auto recall information. We also interviewed four 

franchised dealerships and three independent auto dealerships across 

the country. The results of these interviews are not generalizable to all 

auto manufacturers and dealerships, but provide insights about how 

some industry stakeholders use auto recall information. To understand 

NHTSA’s role in the auto recall process as well as that of other 

stakeholders, we also interviewed NHTSA program officials, industry 

groups, and consumer associations, among others.

To evaluate how easy or difficult consumers find the auto recall areas of 

NHTSA.gov to use, we first analyzed guidance documents from NHTSA 

and other federal agencies to identify key website usability practices. For 

example, we analyzed the General Services Administration’s (GSA) and 

the Department of Health and Human Services’ Research-Based Web 

Design & Usability Guidelines, which includes quantified, peer-reviewed 

guidelines intended to help federal agencies improve the design and 

 4

Because the transcripts did not include a unique identifier for each focus group 

participant, we conducted our analysis of focus group session discussions at the group 

level.
Letter

Page 4 GAO-18-127 Auto Recalls

usability of their information-based websites.5 In addition, we reviewed 

federal standards for internal control related to communicating quality 

information externally.6 During our usability testing sessions, we asked 

consumers to attempt to complete auto recall tasks—the primary means 

NHTSA.gov provides for consumers to access information about auto 

recalls affecting their vehicles—and discuss their experiences. We then 

compared consumers’ experiences with the usability of the website 

against these practices. To corroborate the results of our usability testing 

sessions, we also requested that five website usability professionals from 

GSA’s Federal User Experience Community conduct an independent 

evaluation of the auto recall areas of NHTSA.gov.7

To determine any steps NHTSA has taken to raise consumer awareness 

about auto recalls and how NHTSA evaluates the effectiveness of any 

steps, we reviewed relevant statutes, regulations, and agency 

documents, such as NHTSA’s strategic planning and performance 

reports. We reviewed performance management practices as provided in 

the Government Performance and Results Act of 1993 (GPRA), the 

GPRA Modernization Act of 2010, and standards for internal control in the 

federal government to identify any opportunities for improvement.8 We 

also interviewed responsible agency officials and discussed NHTSA’s 

public awareness efforts during interviews with industry stakeholders 

(described above). We analyzed the results of these interviews along with 

the focus group discussions to identify perspectives on the effectiveness 

of NHTSA’s public awareness steps. See appendix I for more information 

on our objectives, scope, and methodology, including the organizations 

we interviewed for this engagement.

We conducted this performance audit from October 2016 to December 

2017 in accordance with generally accepted government auditing 

 5

GSA and the Department of Health and Human Services, Research-Based Web Design 

& Usability Guidelines (Washington, D.C.: August 2006). GSA also offers website usability 

evaluation services to federal agencies. The Department of Health and Human Services 

manages usability.gov, a website where the federal government has published ways to 

assess a website’s usability and, in partnership with GSA, issued guidance and best 

practices for designing federal websites.

6

GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014).

7

GSA’s Federal User Experience Community is comprised of federal program managers, 

subject matter experts, designers, and developers with expertise in website usability.

8

GAO-14-704G.
Letter

Page 5 GAO-18-127 Auto Recalls

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

Safety defect vehicle recalls (auto recalls) are initiated when a defect in a 

vehicle or vehicle equipment creates an unreasonable safety risk, as 

determined by NHTSA or a manufacturer.9 After a recall is initiated, 

manufacturers are required to provide written notification to vehicle 

owners via First-Class Mail within 60 days10 and remedy the defect.11

Franchised dealers—which sell or lease an auto manufacturer’s new 

vehicles—perform the recall remedy.12

Before manufacturers send recall notification letters to affected vehicle 

owners, NHTSA reviews draft letters and envelopes to ensure they 

include required information about the safety defect. Required information 

includes, among other things, a clear description of the safety defect, an 

evaluation of the risk to vehicle safety, and a statement that the 

manufacturer will remedy the defect without charge.13 See appendix II for 

an example of a notification letter.

 9

NHTSA does not categorize recalls according to the degree of safety risk they pose.

1049 U.S.C. § 30118; 49 C.F.R. § 577.7.

1149 U.S.C. § 30120(a). Manufacturers have three options for remedying the defect –

repair, replacement, or refund. In the case of a vehicle recall, the manufacturer may

choose to repair the vehicle at no charge; replace the vehicle with an identical or similar 

vehicle; or refund the purchase price in full, minus a reasonable allowance for 

depreciation. 

12Independent dealers—which sell only used vehicles—and independent repair facilities 

are not generally authorized by manufacturers to perform auto recall remedies. Franchise 

dealers may also sell used vehicles from other manufacturers. According to NHTSA 

officials, current law does not require auto dealers to repair auto recalls in used vehicles 

on their lots prior to sale, or taxi and ride-sharing services to repair auto recalls in vehicles 

being used to transport customers. 

13In June 2011, we reported on options NHTSA had to improve the safety defect recall 

process. See GAO, Auto Safety: NHTSA Has Options to Improve the Safety Defect Recall 

Process, GAO-11-603 (Washington, D.C.: June 15, 2011). We discuss steps NHTSA has 

taken to address these options later in this report.

Background
Letter

Page 6 GAO-18-127 Auto Recalls

The number of vehicles affected by safety defect vehicle recalls has 

increased dramatically since 2011 (see fig. 1). The increase reflects, in 

part, several large-scale recalls. For example, in 2014, General Motors 

initiated a recall of over 8 million vehicles with faulty ignition switches. 

Similarly, according to NHTSA in 2014 and 2015, some passenger 

vehicle manufacturers began recalling Takata air bag inflators, recalls that 

have grown to include approximately 34 million vehicles and 19 auto 

manufacturers. For the Takata recall, NHTSA issued various orders and 

established a Coordinated Remedy Program under which the agency 

oversees the supply of remedy parts and risk-based prioritization of 

vehicles for repair, and manages related recalls with the assistance of an 

Independent Monitor.14 The Independent Monitor assesses compliance 

with the applicable orders issued by NHTSA and makes 

recommendations aimed at enhancing the remedy program.

 14The Independent Monitor is not counsel to or an agent of the United States or any other 

government, although it operates under the supervision of NHTSA. See 

http://www.takatamonitor.org/faqs. According to NHTSA officials, about 44 percent of 

Takata air bag inflators had been remedied as of September 2017.
Letter

Page 7 GAO-18-127 Auto Recalls

Figure 1: Number of Safety Defect Vehicle Recalls and Vehicles Affected from 

Calendar Years 2011 through 2016

According to NHTSA’s Strategic Plan 2016–2020, this unprecedented 

recall activity encouraged the agency to improve its system for identifying 

and addressing defective vehicles. For example, the plan states that 

NHTSA’s “vision is to achieve a 100-percent completion rate for every 

recall by improving communication at every level, at every step of the 

way.” Thus, according to the plan, NHTSA and the auto industry have 

committed to identifying and implementing effective strategies to inform 

consumers of safety defects and envision that their coordination will 

bolster recall efforts to improve completion rates.

NHTSA reported that annual completion rates for passenger vehicle 

recalls have remained relatively flat, ranging from 63 to 67 percent 
Letter

Page 8 GAO-18-127 Auto Recalls

between calendar year 2011 and calendar year 2014.15 See appendix III 

for completion rates by vehicle component and vehicle type. In part, to 

improve communication and encourage consumers to complete repairs, 

NHTSA and manufacturers provide auto recall information to the public 

on their websites. For example, certain motor vehicle manufacturers are 

required to allow consumers to search a vehicle’s recall remedy status on 

the Internet using the vehicle identification number (VIN).16 NHTSA also 

provides publicly available auto recall information on its website, including 

examples of recall notification letters.

In December 2016, NHTSA began consolidating its websites into 

NHTSA.gov to provide a single access point for its auto recall content. 

One of these websites, safercar.gov, was once NHTSA’s primary method 

of communicating auto recall information to consumers; however, the 

agency is in the process of moving this information to NHTSA.gov. 

NHTSA’s Strategic Plan 2016–2020 states that the agency wants 

NHTSA.gov to be a comprehensive user-friendly platform that serves as 

the premier source of vehicle safety information by, for example, 

improving the website’s search capabilities.17 NHTSA also aims to 

encourage consumers to use its website’s auto recall information through 

its communications program.

NHTSA’s Office of Communications and Consumer Information (OCCI) is 

the primary office responsible for implementing the agency’s public 

communication efforts. OCCI intends to increase public engagement with 

the agency’s information through its social media channels, such as 

 15National Highway Traffic Safety Administration, Report to Congress: “Vehicle Safety 

Recall Completion Rates Report” (May 2017). NHTSA’s latest available annual completion 

rate counts (as of July 1, 2016) include recalls issued between 2010 and 2014 in which 

the manufacturer reported the recall’s completion status for at least five quarters after the 

remedy program became available. Recalls that had not reached this maturation point—

including recalls filed in 2015—were not counted.

1649 C.F.R. § 573.15. Requirements apply to manufacturers that have manufactured for 

sale, sold, offered for sale, introduced or delivered for introduction in interstate commerce, 

or imported into the United States 25,000 or more light vehicles or 5,000 or more 

motorcycles in the current calendar year or the prior calendar year. The VIN is a 17-

character number that uniquely identifies a vehicle.

17The FAST Act directs NHTSA to implement current information technology, web design 

trends, and best practices that will help ensure that motor vehicle safety recall information 

available to the public on its website is readily accessible and easy to use, including by 

improving the organization, availability, readability, and functionality of the website. Pub. L. 

No. 114-94, § 24103(a), 129 Stat. 1312, 1702.
Letter

Page 9 GAO-18-127 Auto Recalls

Instagram, Twitter, and Facebook. The amount OCCI obligated to support 

the agency’s auto recall efforts has increased from nearly $.5 million in 

fiscal year 2011 to about $2.5 million in fiscal year 2016.18 According to 

NHTSA officials, these obligations supported various efforts, including 

public awareness campaigns, an auto recall hotline, advertising agencies, 

exhibits at auto shows, and NHTSA’s mobile application.

As part of our focus group discussion sessions, consumers selected 

safety risk and convenience as the two most influential factors they 

considered when using auto recall information to decide whether to 

complete repairs.

• All factors considered: During each session, we first asked consumers 

to describe all the factors they considered.19 Across the sessions, 

consumers shared a wide variety of factors including availability of a 

loaner vehicle, time to schedule and complete the repair, safety risk, 

and other factors. For example, some consumers had not yet repaired 

their vehicles because they were “just waiting” for parts to become 

available. Other consumers considered their previous customer 

service experiences at the franchised dealership or the distance they 

would need to travel to complete the repair. For example, one 

 18An “obligation” is a definite commitment that creates a legal liability of the government 

for the payment of goods and services ordered or received. GAO, A Glossary of Terms 

Used in the Federal Budget Process, GAO-05-734SP (Washington, D.C.: September 

2005).

19For more information about how we conducted our focus groups, see appendix I.

Auto Recall 

Information Use 

Varies, and Most 

Consumers in Focus 

Groups Preferred 

Electronic Recall 

Notifications in 

Addition to Mail

Consumers in Our Focus 

Groups Primarily 

Considered Safety Risk 

and Convenience when 

Using Auto Recall 

Information to Make 

Repair Decisions
Letter

Page 10 GAO-18-127 Auto Recalls

consumer at our rural focus group location told us it would take 

roughly 2 hours to reach the dealership’s repair shop.

• Most influential factors considered: After the discussion of all factors, 

we then asked each consumer to select the single most influential 

factor they considered. Consumers in the sessions overwhelmingly 

selected safety risk and convenience as the two most influential 

factors (see table 1).

Table 1: Most Influential Factors Selected by Consumers in Our Focus Groups 

when Deciding Whether to Repair Recalled Vehicles with Safety Defects

Most influential 

factor

Consumers who 

completed repairs

Consumers who did not 

complete repairs

All 

consumers

Safety risk 30 19 49

Convenience 12 15 27

Parts availability 0 8 8

Dealer customer 

service

1 1 2

Repair without 

charge

2 0 2

Othera 2 4 6

Total 47 47 94

Source: GAO. | GAO-18-127

a

Other factors include dissatisfaction with dealer-proposed solutions, non-safety related consumer 

preferences, and forgetting about the recall.

Safety Risk 

More than half of consumers in our focus group discussion sessions 

selected safety risk as the most influential factor they considered when 

making repair decisions. They told us that their perception of the risk 

influenced whether or not they repaired their vehicle. For instance, some 

consumers stated that they completed repairs immediately, because the 

risks “sounded serious” or that they considered the defect a “safety 

concern.” Conversely, some consumers said they did not complete the 

repairs because the defect “didn’t sound very urgent.”

While each recall notification letter is required to include an evaluation of 

the risk to vehicle safety reasonably related to the defect, consumers in 

our focus group sessions shared mixed opinions about the quality and 

clarity of safety risk information included in the notification letter they 

Focus Group Participant’s Comment

“[A cover under the hood of the car] could 

come loose and spark a fire, cause electrical 

damage. So, I had that fixed right away.”

Source: GAO. | GAO-18-127
Letter

Page 11 GAO-18-127 Auto Recalls

received.20 For example, some consumers told us the letter’s safety risk 

information seemed vague. For instance, one consumer told us the 

letter’s description of the safety defect did not clearly state the chances of 

an increased risk of injury and so he “had to figure out [the risk] on his 

own.” In addition, some consumers commented that the safety risk 

information could be more prominent in the notification letter, that the 

letter could emphasize the severity of the risk, or that the letter could 

describe the risk in simpler language. However, other consumers stated 

the notification letter they received adequately described the recall’s 

safety risk. In June 2011, we recommended that NHTSA modify the 

requirements for defect notification letters to include additional information 

to obtain readers’ attention.21 In 2013, NHTSA responded to our 

recommendation by requiring manufacturers to include the statement 

“IMPORTANT SAFETY RECALL” at the top of auto recall notification 

letters.22

Convenience 

Consumers in our focus group discussion sessions selected convenience 

as the second most influential factor they considered in making repair 

decisions. While some consumers described the “hassle” of the repair 

and being “too busy” to schedule and fix the defect, other consumers told 

us they repaired their vehicles more easily because, for example, they 

could take advantage of previously scheduled service appointments to 

also repair the defect. Also, some consumers in our sessions stated that 

the letter or notification they received could better address the 

inconvenience of the recall, for example by including better estimates of 

how long repairs might take. In addition, some consumers recommended 

the letter include options for scheduling needed repairs.

As we discuss later in the report, NHTSA officials told us they continue to 

work with auto manufacturers to identify ways to encourage consumers to 

complete needed repairs, while representatives from some manufacturers 

we met with described specific steps they have taken to address some of 

the inconveniences consumers may experience in completing repairs. For 

example, one manufacturer facilitated a pilot program for a third-party 

 2049 U.S.C. § 30119(a)(2), 49 C.F.R. § 577.5(f). 

21See GAO-11-603.

2278 Fed. Reg. 51,382, 51,422 (Aug. 20, 2013) (codified as amended at 49 C.F.R. §

577.5(b)).

Focus Group Participant’s Comment

“I don't want to be without a car for half the 

day or stay [at the dealership] with my kids all 

day.”

Source: GAO. | GAO-18-127
Letter

Page 12 GAO-18-127 Auto Recalls

service provider in conjunction with dealers to repair vehicles at the 

owner’s home or place of work, while another manufacturer told us they 

work with individual dealers to hold events specifically for recall repairs 

when consumers can come in to have repairs performed after normal 

business hours.

Industry stakeholders’ use of auto recall information varies because these 

stakeholders play different roles in the auto recall process. Auto 

manufacturers are primarily responsible for providing auto recall 

information to the public and others, including NHTSA and auto dealers. 

Franchised dealers are responsible for performing the recall remedy for 

manufacturers and therefore use manufacturer-provided information for 

that purpose. Specifically, all of the franchised dealers we interviewed told 

us they identify recalls on new vehicles in their inventory primarily by 

accessing auto recall information through internal manufacturer 

databases.23 These franchised dealers may also use information from 

third-party providers or publicly available auto recall information on 

NHTSA’s website to identify recalls affecting used vehicles.

Independent dealers—which are not generally authorized by 

manufacturers to perform recall remedies—may use publicly available 

auto recall information to identify open recalls.24 Specifically, 2 of the 3 

independent dealers we met with told us they use NHTSA’s VIN look-up 

tool to search for open recalls affecting vehicles in their inventory before 

selling them to consumers.25 However, these dealers told us that the 

current design of the tool takes too much time to use, because it requires 

users to search each VIN individually. For example, one dealer told us 

each search took about 15 seconds to perform, resulting in significant 

time and cost because the dealership has tens of thousands of vehicles in 

its inventory. These dealers told us being able to search multiple VINs in 

a single search (i.e., VIN-batch search) could save them time or money. 

 23Manufacturers are required to provide notification of safety-related defects to dealers to 

whom a motor vehicle was delivered. 49 U.S.C. §§ 30118(c), 30119(d)(4); 49 C.F.R. § 

577.13. 

24Independent dealers sell only used vehicles; they do not have a franchise agreement 

with manufacturers to sell their new vehicles. 

25In June 2011, we recommended that NHTSA create a VIN search function on its website 

to provide vehicle owners with specific information about whether their vehicle is involved 

in a recall. See GAO-11-603. In August 2014, NHTSA launched its VIN look-up tool for 

consumers.

Industry Stakeholders’ Use 

of Publicly Available Auto 

Recall Information Varies
Letter

Page 13 GAO-18-127 Auto Recalls

Representatives from the Alliance of Automobile Manufacturers stated 

they—in coordination with other industry stakeholders—are working with 

a third-party provider to develop a search tool that would address this 

concern by enabling VIN-batch searches for use by government 

agencies, such as state departments of motor vehicles, and commercial 

entities. The group anticipates the tool will be available in the first half of 

2018.

Although the vast majority of consumers who participated in our focus 

group discussion sessions reported a preference to receive auto recall 

notification by mail, most preferred to receive notifications by at least one 

additional electronic means such as e-mail, phone calls, and text 

messages.26 Eighty of the 94 consumers in our sessions reported a 

preference for receiving notification by mail, and all but 4 reported actually

receiving mailed notification (see fig. 2).27 However, 69 of the 94 

consumers in our sessions also reported a preference for receiving recall 

notification by electronic means, but only 7 reported actually receiving at 

least one type of electronic notification. This result suggests a gap 

between industry recall notification practices and notification preferences 

for most consumers in our focus groups, especially for younger 

consumers who were more likely to report a preference for notification by 

electronic means. For complete results of the questionnaire we 

administered to consumers for the discussion session, see appendix IV. 

As we discuss later in this report, in September 2016, NHTSA issued a 

Notice of Proposed Rulemaking (NPRM) that proposes to require auto 

manufacturers to notify consumers about auto recalls by electronic means 

in addition to First-Class Mail.

28 NHTSA officials told us the agency is 

working with the administration on NHTSA’s regulatory portfolio and 

priorities, including this rulemaking.

 26As part of the questionnaire administered to consumers in our focus groups, consumers 

were asked to report the ways they preferred to be notified. In responding, participants 

could report more than one preference. 

27We previously reported on challenges that exist to identifying and notifying vehicle 

owners about auto recalls due to inaccurate mailing addresses, among other challenges. 

See GAO-11-603.

28Update Means of Providing Recall Notification, 81 Fed. Reg. 60,332 (Sept. 1, 2016). 

The FAST Act directs NHTSA to issue such a rule. Pub. L. No. 114-94, § 24104(a), 129 

Stat. 1312, 1703. 

Most Consumers in Our 

Focus Groups Prefer to 

Receive Recall Notification 

by Electronic Means in 

Addition to Mail 

Focus Group Participant’s Comment

“I would want every option possible...Send 

me an e-mail. Send me a text...Warn me in 

any way you can.”

Source: GAO. | GAO-18-127
Letter

Page 14 GAO-18-127 Auto Recalls

Figure 2: How Consumers in Our Focus Groups Received and Preferred to Receive Auto Recall Notifications

Some manufacturers told us they use additional methods to reach 

consumers, including notifying consumers by electronic means and 

translating recall information into Spanish.29 For example, representatives 

from one manufacturer told us they always notify consumers by e-mail 

before sending out the required First-Class Mail letter notification. These 

representatives told us using multiple recall notification means resulted in 

higher recall completion rates. In addition, eight of the remaining nine 

manufacturers told us they use supplemental electronic means 

notification on a case-by-case basis—generally using additional means to 

improve recall completion rates—while four manufacturers stated they 

consider safety risk severity when deciding when or how to use additional 

notification means for individual recalls. Also, representatives from 3 of 

 29Notification letters sent to vehicle owners whose address is in the Commonwealth of 

Puerto Rico are required to be written in both English and Spanish. 49 C.F.R. § 577.5(a). 

As part of this report, we asked manufacturers about their efforts to translate auto recall 

notifications into other languages, including Spanish. 
Letter

Page 15 GAO-18-127 Auto Recalls

the 10 manufacturers we spoke with told us they translate the entire 

mailed notification letter into Spanish.

In late 2016, NHTSA launched its redesigned NHTSA.gov website, 

including the auto recall areas consumers assessed during our testing 

sessions. According to responses to a questionnaire we administered 

during our testing sessions, 78 of the 94 consumers found the auto recall 

areas of NHTSA.gov either “somewhat” or “very easy” to use (see fig. 3). 

See appendix V for complete participant responses to the questionnaire 

we administered to each consumer.

Most Consumers in 

Focus Groups Found 

the Auto Recall Areas 

of NHTSA.gov 

Generally Easy to 

Use, but Some 

Experienced 

Difficulties

Usability Testing with 

Consumers Found the 

Auto Recall Areas of 

NHTSA’s Website 

Generally Easy to Use

Focus Group Participant’s Comment

“[The NHTSA.gov homepage] is easy to get 

around even for people who aren’t that tech 

savvy.”

Source: GAO. | GAO-18-127
Letter

Page 16 GAO-18-127 Auto Recalls

Figure 3: How Easy or Difficult to Use Were the Auto Recall Areas of NHTSA.gov for 

Consumers Who Participated in Our Focus Groups

Note: The scale consumers used to rate ease of use also included “Very difficult” as an option; 

however, no consumers in our focus groups chose this option.

To inform the development of the redesigned website, NHTSA worked 

with a contractor to conduct a usability study in 2015 to evaluate users’ 

reactions to the agency’s websites, including NHTSA.gov. According to 

agency officials, NHTSA implemented several changes based on the 

findings from the usability study, including:

• the creation of a dedicated “recalls” area of NHTSA.gov, and

• the ability for users to access the VIN look-up tool in three different 

ways—on the homepage, in the “recalls” area, and through direct links 

either in a NHTSA e-mail for subscribers or from an external website.

In addition, NHTSA officials told us that Department of Transportation 

(DOT) and NHTSA staff meet as needed to discuss the website and 

consider improvements. For example, the officials said they monitor user 

searches for the relevance and accuracy of results and adjust the search 

software to better assist users in finding auto recall information. Officials 

also told us the agency collects a variety of other information about how 

visitors use NHTSA.gov, including how visitors access the website, and 

makes adjustments accordingly. For instance, NHTSA incorporated 

responsive web design as part of the agency’s ongoing consolidation 

National Highway Traffic Safety 

Administration’s (NHTSA) Website 

Strategy

“When consumers need information, the first 

place they typically turn is to the Internet. 

[NHTSA.gov is intended to be] a 

comprehensive, user-friendly platform that will 

serve as the premier source of traffic and 

vehicular safety information.”

Source: NHTSA Strategic Plan 2016-2020. | 

GAO-18-127
Letter

Page 17 GAO-18-127 Auto Recalls

effort—meaning the site is optimized for viewing on desktop, tablet, and 

mobile devices.30 In addition to monitoring searches and how visitors 

access NHTSA.gov, NHTSA officials told us they collect and consider 

online survey data to make website improvements and use web-analytic 

software to monitor, for example, where visitors choose to exit the 

website. Officials stated that such monitoring activities have allowed 

NHTSA to identify and correct problems with NHTSA.gov.

We did not directly evaluate the accessibility of the auto recall areas of 

NHTSA.gov to ensure the ability of people with physical or mental 

disabilities to use the website.31 However, NHTSA officials provided us 

with an overview of several steps the agency takes to ensure NHTSA.gov 

complies with website accessibility requirements. For example, according 

to officials, NHTSA subscribes to a service that provides monthly 

accessibility scans of the agency’s websites.

While most consumers in our usability testing sessions generally found 

the auto recall areas of NHTSA’s website easy to use, some consumers 

experienced difficulties completing tasks we asked them to perform (see 

table 2). Specifically, during each testing session we asked participants to 

perform tasks using the primary means NHTSA.gov provides for 

consumers to access information about auto recalls affecting their 

vehicles:

• searching for auto recalls using their vehicle’s VIN;

• searching for auto recalls using their vehicle’s year, make, and model; 

and

• locating NHTSA’s auto recall notification e-mail subscription service.

In addition, an evaluation we requested to corroborate the results of our 

consumer usability testing, identified similar issues. As discussed below, 

 30Desktop computers, including laptop computers, were used for the usability testing 

sessions we conducted with consumers as well as the usability evaluation we requested 

from website usability professionals. According to an April 2017 NHTSA.gov report, 59.5 

percent of visitors accessed the site via a desktop computer, 35 percent via a mobile 

device, and 5.5 percent via a tablet.

31When federal agencies develop, procure, maintain, or use electronic and information 

technology, they are required to make this technology accessible to people with 

disabilities. For additional details about accessibility requirements, see appendix I.

Consumers in Our Focus 

Groups Identified 

Opportunities to Improve 

the Usability of Certain 

Auto Recall Tasks on 

NHTSA’s Website
Letter

Page 18 GAO-18-127 Auto Recalls

consumers experienced these difficulties because the auto recall areas of 

NHTSA.gov do not always reflect federal and industry key website 

usability practices, which describe standards and guidelines for making 

websites easy to use.32 Following such practices can assist agencies in 

creating quality websites while providing the flexibility necessary to meet 

organizational needs. Website usability is particularly important for 

agencies, such as NHTSA, that are responsible for conveying safety 

information to the public. Federal standards for internal control state that 

agencies should communicate quality information externally and select 

appropriate methods for communicating with the public.33

Table 2: How Easy or Difficult Did Consumers Who Participated in Our Focus Groups Find Performing Auto Recall Tasks on 

NHTSA.gov, by Number of Consumers

Task Very easy Somewhat easy

Neither easy nor 

difficult

Somewhat 

difficult Very difficult

Search for recall using vehicle 

identification number 

76 12 3 1 2

Search for recall using vehicle 

year, make, and model

62 16 3 10 3

Find Recall Notification E-mail 

System sign-up

34 32 15 8 5

Source: GAO. | GAO-18-127

Recall Search Using VIN

While most consumers in our usability testing sessions found searching 

for recalls by VIN somewhat or very easy, some consumers found the 

search results did not provide the information they were seeking. When 

we asked consumers to perform VIN searches, they generally found the 

VIN look-up tool easy to use—88 of 94 consumers found searching with a 

VIN either somewhat or very easy. But some consumers experienced 

difficulties performing this task. Specifically, some consumers who had 

had their vehicles repaired expected to find the completed recall on the 

search results page. However, they were confused because the page is 

designed to display only open (i.e., unrepaired) recalls, not completed 

 32To identify key website usability practices, we reviewed and analyzed relevant guidance 

documents from NHTSA and other federal agencies. For additional details on how we 

identified these key practices, see appendix I.

33GAO-14-704G.

Focus Group Participant’s Comment

“I found my car [using the VIN look-up tool]. 

But it said zero recalls. So to me, that could 

mean, okay, I fixed it and you guys marked it 

out, or you guys can’t find my recall.”

Source: GAO. | GAO-18-127
Letter

Page 19 GAO-18-127 Auto Recalls

(i.e., repaired) recalls—leading these consumers to question the accuracy 

of the results. In addition, the evaluation conducted by website usability 

professionals found that, when an error occurred during a VIN search, the 

error message was too difficult to locate on the search results page. The 

evaluation recommended the error message have greater weight and 

more prominence on the page.

Federal key website usability practices state that agencies should ensure 

that results of user searches provide the precise information being 

sought, and in a format matching users’ expectations. When users are 

confused by search results, or do not immediately find what they are 

searching for, they become frustrated and may abandon the search or the 

website entirely. Since NHTSA launched the VIN look-up tool in August 

2014, the number of VIN searches performed has increased (see fig. 4). 

According to NHTSA officials, major increases occurred in mid-2015—

when the Takata air bag inflator recalls were announced—and in early 

2017, when NHTSA made the VIN look-up tool search function available 

on NHTSA.gov and displayed it prominently on the website. Ensuring the

usability of NHTSA’s VIN look-up tool is particularly important because it 

is the only way on NHTSA.gov for a consumer to determine whether their 

specific vehicle has an open safety recall.
Letter

Page 20 GAO-18-127 Auto Recalls

Figure 4: Number of Auto Recall Searches by Vehicle Identification Number on the National Highway Traffic Safety 

Administration’s (NHTSA) Websites, Weekly from August 2014 through May 2017

Recall Search Using Vehicle Year, Make, and Model

Some consumers’ vehicle year, make, and model searches were 

hampered by the information required to conduct an accurate search, as 

the content on the website is not always in plain language. We asked 

consumers to perform a recall search using their vehicles’ year, make, 

and model, and 78 of 94 consumers found the task to be either somewhat 

or very easy. However, some consumers found that they did not know 

enough information about their specific vehicles to feel confident that they 

were searching for the correct vehicle. For example, a year, make, and 

model search for a 2009 Toyota Tacoma may ask the consumer to 

choose among vehicle options, including “2009 TOYOTA TACOMA 

REGULAR CAB W/SAB RWD/AWD.”34 Acronyms such as “W/SAB”—

which stands for “with side air bags”—may be confusing to consumers.

 34“RWD/AWD” stands for “rear-wheel drive/all-wheel drive.”

Focus Group Participant’s Comment

“The acronyms weren’t spelled out...I don’t 

know what they stand for.”

Source: GAO. | GAO-18-127
Letter

Page 21 GAO-18-127 Auto Recalls

Federal key website usability practices state that federal agencies should 

write website content using plain language, so website visitors can easily 

find and use what they need.

Recall Notification E-mail System Sign-Up

Some consumers suggested improvements to make the Recall 

Notification E-mail System Sign-Up easier to locate on the homepage. 

NHTSA first made its Recall Notification E-mail System Sign-Up available 

in March 2008.35 Of the 94 consumers in our testing sessions, 66 found it 

either “somewhat” or “very easy” to find the Recall Notification E-mail 

System Sign-Up—making this the least easy of the three tasks we asked 

consumers to perform. Specifically, several consumers said the Recall 

Notification E-mail System Sign-Up should include a clearer description, 

be easier to find, and be located at the top of the homepage (see fig. 5). 

These improvements are particularly important because some consumers 

in our focus group sessions told us that the ability to sign up for auto 

recall e-mail notifications was the most useful part of the auto recall areas 

of NHTSA.gov.

 35According to NHTSA, the system had 273,312 active subscribers as of May 31, 2017. Of 

the 94 consumers who participated in focus groups we conducted, 1 indicated having 

signed up for alerts from a government website. 

Focus Group Participant’s Comment

“I think [the Recall Notification E-mail System 

Sign-Up is] poorly placed. I had to scroll to 

find it. I had to search for it. You want [it] at 

the top [of the page].”

Source: GAO. | GAO-18-127
Letter

Page 22 GAO-18-127 Auto Recalls

Figure 5: Location of the National Highway Traffic Safety Administration’s (NHTSA) Recall Notification E-mail System Sign-Up 

Task on NHTSA.gov’s Homepage

The website evaluation conducted by website usability professionals 

recommended that NHTSA streamline its homepage with more of a focus 

on primary website tasks. The evaluation also found that users must 

move through too many pages to sign up for recall e-mails.

Federal key website design and usability practices state that agencies 

should put important items closer to the top of the page, where users can 

better locate the information. Key practices also state that agencies 

should design their websites so users can successfully complete the most 

common tasks in the fewest number of steps.
Letter

Page 23 GAO-18-127 Auto Recalls

The website usability difficulties that consumers in our focus groups 

experienced may be due to the fact that NHTSA has not studied the 

website’s usability since the agency redesigned NHTSA.gov in late 2016 

and, therefore, may have been unaware of these difficulties prior to our 

review. NHTSA plans to conduct a website usability study with consumers 

after the consolidation effort, discussed above, is complete. However, 

NHTSA could not provide a general time frame for conducting the study 

because it has not yet determined when the consolidation effort will be 

complete.36 We have previously reported that it is essential for 

organizations to effectively guide their information technology efforts by 

establishing timelines to complete them, among other strategic planning 

best practices.37 Without establishing a completion date for its website 

consolidation effort, the website usability difficulties we identified may 

persist and limit the effectiveness of NHTSA’s primary means of providing 

consumers with safety recall information about their vehicles on 

NHTSA.gov.

In January 2016, NHTSA launched a national advertising campaign 

encouraging consumers to check for open recalls using the agency’s VIN 

and year, make, and model look-up tools. Through March 2017, NHTSA 

spent about $1 million on its Safe Cars Save Lives campaign, which 

sponsors advertisements on Google, Facebook, and other media 

 36As noted previously, the FAST Act requires NHTSA to make certain improvements to its 

website. Pub. L. No. 114-94, § 24103(a), 129 Stat. 1312, 1702.

37GAO, Federal Motor Carrier Safety Administration Needs to Strengthen Its Strategic 

Planning and Oversight to Modernize Legacy Systems, GAO-17-488 (Washington, D.C.: 

Jul. 13, 2017) and Library of Congress: Strong Leadership Needed to Address Serious 

Information Technology Management Weaknesses, GAO-15-315 (Washington, D.C.: Mar. 

31, 2015).

NHTSA Has Initiated 

Activities to Raise 

Consumer Awareness 

about Recalls, but It 

Is Too Early to 

Evaluate the Agency’s 

Efforts

Public Awareness 

Campaign
Letter

Page 24 GAO-18-127 Auto Recalls

platforms. For example, Google might place NHTSA’s advertisement 

above other search results, when a consumer typed certain keywords—

such as “recall,” “airbag recalls,” or “safercar.gov”—into the search.

NHTSA evaluated the campaign’s effectiveness by monitoring website 

traffic performance reports to determine how frequently consumers 

clicked on NHTSA-sponsored advertisements and ultimately searched for 

open recalls using the agency’s look-up tools. NHTSA also compared 

results across media platforms and adjusted the campaign’s strategy to 

improve performance. For example, NHTSA optimized advertisements on 

mobile devices, since mobile-device users performed more recall 

searches than other users. According to NHTSA data, the awareness 

campaign resulted in consumers performing 1.1 million recall searches 

through March 2017—a cost of about $0.90 per search. Agency data 

indicate that this cost generally decreased as NHTSA improved the 

campaign’s strategy. Agency officials told us NHTSA plans to spend 

another approximately $1.8 million on Safe Cars Save Lives from 

September 2017 through September 2018 due to the campaign’s 

effectiveness in raising the public’s awareness about auto recalls.

NHTSA began implementing a mandated 2-year pilot grant program 

intended to evaluate the feasibility and effectiveness of informing 

consumers about open auto recalls during state vehicle registration.38 In 

September 2016, NHTSA solicited applications to participate in the 

program, wherein selected states would inform consumers—at no 

charge—about open recalls using all means that permit consumers to 

register vehicles within the state (e.g., in person, Internet, and mail).39

 38The FAST Act directs NHTSA to implement such a pilot program. Pub. L. No. 114-94, § 

24105, 129 Stat. 1312, 1704.

39NHTSA, State Notification to Consumers of Motor Vehicle Recall Status, RFA No. 

DTNH2216R00096 (Sept. 28, 2016). Eligibility was limited to the state department or 

office responsible for motor vehicle registration.

Pilot Program with States
Letter

Page 25 GAO-18-127 Auto Recalls

According to NHTSA, only one state applied for the grant. In September

2017, NHTSA awarded the sole applicant $223,000.40

Under the program, the grantee needs to collect and report program 

performance data, including the extent to which open recalls have been 

identified and repaired. In addition, the grantee must report whether 

certain notification means were more effective than others and what could 

be done to improve the program. Upon completion of the pilot program, 

NHTSA is required to evaluate the extent to which open recalls identified 

have been remedied. Auto manufacturers we met with were generally 

supportive of the program. Specifically, representatives from 9 of the 10 

manufacturers told us that notifying consumers about open recalls during 

vehicle registration can raise consumer awareness or improve recall 

completion rates.

In September 2016, NHTSA issued a Notice of Proposed Rulemaking 

(NPRM), which proposes to require auto manufacturers to notify 

consumers about open recalls by electronic means—such as e-mails, 

phone calls, and text messages, in addition to First-Class Mail.41 As we 

described earlier, auto manufacturers are currently required to notify 

consumers about safety recalls affecting their vehicles via First-Class 

Mail. According to NHTSA, the NPRM aims to aid in efficiently and 

effectively improving recall completion rates, by proposing that 

manufacturers provide notification using electronic means in addition to 

First-Class Mail.

Consumers in our focus groups as well as auto manufacturers and 

consumer associations we interviewed generally supported additional 

notification using electronic means.

 40NHTSA awarded the grant to the Maryland Department of Transportation Motor Vehicle 

Administration. See https://www.nhtsa.gov/press-releases/us-dot-and-maryland-mvacollaborate-improve-recall-remedy-rates. When NHTSA published the Request for 

Application, the Administrator approved $2 million out of the Enforcement Office’s budget 

to fund the pilot program grants. Congress then appropriated funds that were available to 

be used for this grant program in the Consolidated Appropriations Act of fiscal year 2017, 

and in the explanatory statement accompanying the Act, Congress directed NHTSA to use 

$1.5 million for the pilot program grants. 

41Update Means of Providing Recall Notification, 81 Fed. Reg. 60,332 (Sept. 1, 2016). 

The FAST Act directs NHTSA to issue such a rule. Pub. L. No. 114-94, § 24104(a), 129 

Stat. 1312, 1703. 

Proposed Rulemaking
Letter

Page 26 GAO-18-127 Auto Recalls

• Consumers in our focus groups: As we discussed earlier, 69 of the 

consumers in our focus group discussion sessions reported they 

would prefer to receive additional notification by at least one type of 

electronic means. However, only 7 consumers actually received such 

notifications—suggesting a gap between industry notification practices 

and notification preferences for these consumers.

• Auto manufacturers: Representatives from 9 of 10 manufacturers we 

interviewed told us they generally support providing notification using 

electronic means. Although the NPRM proposes a broad definition of 

electronic means to give manufacturers flexibility to determine the 

most effective means, these representatives also shared 

implementation concerns.42 For example, representatives from 1 of 

the 9 manufacturers told us that—although the company collects email addresses from some customers for other purposes—not all 

customers provide e-mail addresses, and those collected are not 

always accurate. As we discussed previously, most manufacturers we 

met with currently use supplemental electronic means notification on a 

case-by-case basis.

• Consumer associations: Similarly, both consumer associations we 

interviewed told us additional electronic notification can help reach 

consumers who do not complete repairs after receiving initial mailed 

notification.

NHTSA’s proposal would maintain manufacturer reporting requirements, 

though it may result in additional reporting.43 This additional information 

could help the agency evaluate the effectiveness of various means of 

 42Specifically, the NPRM defines electronic means to include notification by electronic 

mail, text messages, radio or television notifications, vehicle infotainment console 

messages, over-the-air alerts, social media or targeted online campaigns, telephone calls, 

automated or otherwise, or other real time means. 

43Manufacturers are required to include in their reports to NHTSA “representative copies 

of all notices, bulletins, and other communications that relate directly to the defect...and 

are sent to more than one manufacturer, distributor, dealer or purchaser.” 49 C.F.R. § 

573.6(c)(10). Because electronic notifications are already encompassed within “notices, 

bulletins, and other communications,” manufacturers voluntarily providing 577-compliant 

notices via electronic means are already required to provide representative copies of 

those notices to NHTSA. If the NPRM is finalized, manufacturers would be required to 

provide electronic notification, in addition to First-Class Mail. Accordingly, manufacturer 

reporting would likely increase, since manufacturers would have to provide NHTSA with 

representative copies of all electronic and mailed notifications.
Letter

Page 27 GAO-18-127 Auto Recalls

consumer notification.44 We previously found that NHTSA may be able to 

use manufacturers’ data to identify what factors make some recalls more 

or less successful than others. We recommended that NHTSA use the 

recall data it collects to analyze particular patterns or trends that may 

characterize successful recalls and determine whether these factors 

represent best practices.45

If the NPRM is finalized, manufacturers would provide NHTSA with 

representative copies of the newly required electronic notifications, in 

addition to mailed notifications, and would specify the electronic means 

used, such as e-mail or text message. According to NHTSA officials, this 

information could allow the agency to track and evaluate the effectiveness 

of various notification means used by manufacturers by, for example, 

comparing completion rates across means—a key step in identifying best 

practices that could encourage consumers to complete repairs. However, 

it is too early for NHTSA to conduct such an evaluation, because the 

agency has not issued a final rule. NHTSA officials told us the agency is 

working with the administration on NHTSA’s regulatory portfolio and 

priorities, including this rulemaking.

NHTSA has also taken steps to collaborate with industry stakeholders 

and explore consumer education best practices. For example, in April 

2015 NHTSA hosted a day-long workshop that brought together auto 

industry stakeholders to examine public education of the recall process. 

During the workshop, participants identified current barriers to the public’s 

awareness of auto recalls and discussed potential solutions to address 

them, such as using text messages and social media to communicate 

 44According to NHTSA officials, currently, if a manufacturer is voluntarily providing 577-

compliant notices via electronic means, they are providing representative copies of those 

notifications to NHTSA through the online Recalls Portal. However, the current Recalls 

Portal does not allow manufacturers to select the means of the notice (e.g., mail, e-mail, 

text, etc.). If the NPRM is finalized, NHTSA plans to update the online Recalls Portal so 

manufacturers can select the type of electronic means used for the notification. 

45GAO-11-603. NHTSA has taken steps to address this recommendation, for example, by 

analyzing annual recall completion rates by manufacturer, model year, and vehicle 

component to determine trends and identify risk factors associated with lower recall rates. 

We are currently reviewing whether NHTSA’s analysis is sufficient to close the 

recommendation as implemented. The report also included three additional 

recommendations to encourage vehicle owners to comply with safety recalls, provide 

vehicle owners with specific information about whether their vehicle is involved in a recall, 

and identify factors that affect recall completion rates, among other things. NHTSA 

implemented these three recommendations.

Collaboration with 

Stakeholders
Letter

Page 28 GAO-18-127 Auto Recalls

with younger consumers and using different delivery methods for recall 

notices. Similarly, in January 2016 NHTSA and 18 auto manufacturers 

adopted a set of Proactive Safety Principles to explore and employ new 

ways to increase safety recall participation rates.46 For example, NHTSA 

and auto manufacturers agreed to share industry best practices and 

policies based on lessons learned from ongoing safety recalls.

The Independent Monitor of Takata in conjunction with NHTSA has also 

issued a set of coordinated communications recommendations based on 

consumer research, best practices observed during the Takata recall, and 

discussions with manufacturers.47 For example, the recommendations 

encourage manufacturers to:

• pursue a “multi-touch” communications strategy that employs nontraditional means, such as e-mail and text messages;

• convey risk in clear, accurate and urgent terms; and

• include a clear “call to action” designed to facilitate prompt and 

efficient scheduling of repairs.

According to NHTSA officials, the agency relies on auto manufacturers to 

evaluate the effectiveness of these efforts.48 However, agency officials 

told us NHTSA reviews manufacturers communication plans as part of 

the Takata recall’s Coordinated Remedy Program and provides ongoing 

recommendations on manufacturers’ communication language, approach, 

and strategies.

With the recent steep increase in safety defect vehicle recalls and 

continued low recall completion rates, it is vital for consumers to be able 

to easily access and use publicly available auto recall information. 

 46U.S. Department of Transportation, et al., Proactive Safety Principles (Jan. 15, 2016).

47John Buretta, Letter to Affected Vehicle Manufacturers, Independent Monitor of Takata 

and the Coordinated Remedy Program (New York, N.Y.: Dec. 23, 2016).

48According to NHTSA officials and most manufacturers we met with, NHTSA initially 

worked with manufacturers on an ad hoc basis to help ensure manufacturers’ auto recall 

websites made information available to the public, as required. In January 2016, NHTSA 

took steps to formalize this process by conducting an overarching review of the auto recall 

websites of manufacturers who, as previously noted, are required to allow consumers to 

search a vehicle’s recall remedy status on their website using the VIN. In January 2017, 

NHTSA established this process as an annual review.

Conclusions
Letter

Page 29 GAO-18-127 Auto Recalls

NHTSA has taken important steps to improve its website—which provides 

safety recall information to consumers—resulting in most consumers in 

our focus groups finding the website easy to use. However, the difficulties 

some experienced in attempting to complete essential auto recall tasks 

demonstrated that NHTSA.gov does not always reflect key website 

usability practices for website design. Although NHTSA plans to conduct 

a website usability study with consumers after consolidating its websites, 

it has not determined a completion date for this effort—an essential step 

for organizations to effectively guide their information technology efforts. 

Without such a date, the website usability difficulties may persist and limit 

the effectiveness of NHTSA.gov in providing consumers with recall 

information about their vehicles. By addressing these difficulties in the 

interim, NHTSA can better assure that consumers obtain this information, 

which can be vital to their safety.

We are making the following two recommendations to NHTSA:

The Administrator of NHTSA should determine a completion date for the 

agency’s website consolidation effort. (Recommendation 1)

The Administrator of NHTSA should, while the agency continues its 

website consolidation effort, take interim steps to improve the usability of 

the auto recall areas of NHTSA.gov by addressing the website usability 

difficulties we identified. (Recommendation 2)

We provided a draft of this report to DOT for review and comment. In its 

written comments, reproduced in appendix VI, DOT stated that it 

concurred with our recommendations. The department also provided 

technical comments, which we incorporated as appropriate.

We are sending copies of this report to relevant congressional 

committees, the Secretary of Transportation, and the Administrator of 

NHTSA. In addition, the report is available at no charge on the GAO 

website at http://www.gao.gov.

Recommendations for 

Executive Action

Agency Comments
Letter

Page 30 GAO-18-127 Auto Recalls

If you or your staff have any questions about this report, please contact 

me at (202) 512-2834 or flemings@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix VII.

Susan Fleming

Director, Physical Infrastructure Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-18-127 Auto Recalls

This report examines the use of publicly available auto recall information 

for safety defects affecting passenger vehicles.1 The report addresses the 

following objectives: (1) How do consumers and industry stakeholders 

use publicly available auto recall information? (2) How easy or difficult to 

use do consumers find the auto recall areas of NHTSA.gov? (3) What 

steps, if any, has the National Highway Traffic Safety Administration 

(NHTSA) taken to raise consumer awareness about auto recalls and how 

has NHTSA evaluated the effectiveness of these steps?

We define publicly available auto recall information to include information 

on the auto recall areas of NHTSA.gov, such as examples of notification 

letters that manufacturers mail to consumers. This report focuses on

safety defect vehicle recalls affecting passenger vehicles that are initiated 

when a defect in a vehicle or vehicle equipment creates an unreasonable 

safety risk, as determined by NHTSA or a manufacturer.2

To determine how consumers use publicly available auto recall 

information, we conducted and analyzed transcripts and questionnaires 

from 12 consumer focus groups we conducted with used and new vehicle 

owners who had experienced an auto recall in the last 24 months. Each 

focus group was split into two sessions: (1) a discussion session to 

explore participants’ thoughts, experiences, and preferences about auto 

recall information and (2) a website usability testing session. Also, we 

administered a questionnaire as part of each of these sessions. For the 

discussion session, we asked consumers about the recall notification 

process and how they used the recall information, and for the website 

usability testing session, we asked consumers to fill in a questionnaire 

during the session itself as they assessed the usability of the auto recall 

areas of NHTSA’s website. We conducted the 12 focus groups at six 

locations across the country, with each group including 7 or 8 consumers 

for a total of 94 participants. Half of the focus groups were comprised of 

consumers who had completed the repair and the remaining half included 

consumers who had not completed the repair.

 1

Passenger vehicles include cars, pickup trucks, sport utility vehicles, large passenger 

vans, and minivans, but exclude other vehicles, such as motorcycles, recreational 

vehicles, and commercial trucks. 

2

NHTSA is responsible for overseeing two types of recalls: compliance and safety defect 

recalls. We did not examine compliance recalls, nor did we examine car seat, tire, and 

other equipment (e.g., vehicle accessories and after-market equipment such as lighting, 

trailer hitches, and bike racks) recalls as these products have different consumer 

notification requirements. We did not review Technical Service Bulletins.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-18-127 Auto Recalls

We selected the six focus group locations to provide population and 

geographic dispersion. To ensure geographic dispersion, we selected at 

least one location in each U.S. Census region (see table 3). To ensure 

population dispersion, we selected Metropolitan Statistical Areas 

representing a range of population sizes based on 2015 U.S. Census 

estimates.3 To ensure our selection included the perspectives of vehicle 

owners in geographically distant or isolated communities, we also 

selected a rural location, which we defined as a city or town that has a 

population of less than 50,000 inhabitants and is not an urbanized area 

contiguous and adjacent to a city or town that has a population of greater 

than 50,000 inhabitants.

Table 3: Characteristics of Locations We Selected to Conduct Focus Groups with Consumers

Location Census region Metropolitan Statistical Area (MSA) Rank of MSA (population)a

Bethesda, Maryland South Washington-Arlington-Alexandria, DC-VA-MDWV Metro Area6th (6,097,684) 

Chicago, Illinois Midwest Chicago-Naperville-Elgin, IL-IN-WI Metro Area 3rd (9,551,031)

East Rutherford, New 

Jersey

Northeast New York-Newark-Jersey City, NY-NJ-PA Metro 

Area

1st (20,182,305)

Fresno, California West Fresno, CA, Metro Area 56th (974,861)

Jackson, California West —b —b (4,613)

Raleigh, North Carolina South Raleigh, NC, Metro Area 44th (1,273,568)

Source: GAO. | GAO-18-127

a

MSA rank and population estimates based on 2015 Census population estimates as of July 1, 2015.

b

Jackson, CA, is not part of an MSA.

Using information provided by the participants, we selected focus group 

participants based on age, income, gender, education level, race, and 

ethnicity to ensure we collected a range of perspectives on auto recall 

information use. However, since we did not select a representative 

sample of participants, focus group results are not generalizable to all 

vehicle owners.

During focus group discussion sessions, we asked participants to discuss 

factors they considered when deciding whether to repair their recalled 

vehicle and then to select the single most influential factor. Each of the 12 

 3

Metropolitan Statistical Areas are locations that are associated with one or more 

urbanized areas with at least 50,000 people and include the central county or counties 

along with the surrounding commuting population.
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-18-127 Auto Recalls

focus group sessions was audio recorded and transcriptions were 

created; transcripts served as the record for each group. We then 

evaluated those transcripts using systematic content analysis to identify 

the factors consumers considered when deciding whether to complete 

repairs and any suggested improvements to the auto recall 

communication process. The analysis was conducted in three steps. First, 

two analysts independently developed a code framework and then 

worked together to resolve any discrepancies. Second, each transcript 

was coded independently by analysts using the framework and any 

discrepancies were resolved by both analysts agreeing on the coding of 

the associated statement by a participant. Third, if needed, another 

analyst adjudicated any continued disagreement between coders.

Because the transcripts did not include a unique identifier for each focus 

group participant, we conducted our analysis of focus group session 

discussions at the group level (i.e., of the 12 focus groups we conducted). 

We also administered and analyzed a questionnaire as part of each 

discussion session to quantify responses regarding consumers’ use of 

auto recall information, including how they received and preferred to 

receive auto recall notifications. Our analysis of the questionnaire 

responses was conducted at the individual consumer level (i.e., of the 94 

consumers who participated).

These focus group sessions were structured, guided by a moderator who 

used a standardized list of questions to encourage participants to share 

their thoughts, experiences, and preferences. We also conducted two 

pretest focus groups at our headquarters and made some revisions to the 

focus group guide prior to beginning the sessions with consumers. 

Methodologically, focus groups are not designed to demonstrate the 

extent of a problem or to generalize results to a larger population or 

provide statistically representative samples or reliable quantitative 

estimates. Instead, they are intended to generate in-depth information 

about the reasons for the focus group participants’ thoughts, experiences, 

and preferences on specific topics.

The projectability of the information produced by our focus group 

sessions is limited. For example, the information includes only the 

responses from the vehicle owners from the 12 selected groups and their 

individual responses to questions we asked. The experiences and 

preferences expressed may not reflect other vehicle owners’ thoughts 

and preferences. In addition, while the composition of the groups was 

designed to ensure a range of age and education levels, among the other 
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-18-127 Auto Recalls

criteria mentioned previously, the groups were not constructed using a 

random sampling method.

To determine how industry stakeholders use auto recall information, we 

interviewed selected auto manufacturers, selected franchised and 

independent auto dealerships, NHTSA program officials, and other 

industry stakeholders. Specifically, we interviewed representatives from 

the following 10 auto manufacturers, selected based on each 

manufacturer’s sales market share (small, medium, and large), place of

ownership (foreign and domestic), and experience with auto recalls (lower 

to higher based on the average annual number of auto recall campaigns 

and average market share of each manufacturer from 2010 to 2014) to 

collect a range of perspectives on how manufacturers use auto recall 

information:

• General Motors

• Ford Motor Company

• Toyota Motor Corporation

• Fiat Chrysler Automobiles

• Honda Motor Company

• Kia Motors Corporation

• BMW

• Volvo Cars

• Jaguar Land Rover

• Tesla Motors, Inc.

To understand the perspective of auto dealers, we interviewed four 

franchised dealerships, one in each of the four U.S. Census regions 

where we conducted focus groups with consumers. We also interviewed 

three independent auto dealerships in two U.S. Census regions. The 

results of these interviews are not generalizable to all auto manufacturers 

and dealerships, but provide insights about how some industry 

stakeholders use auto recall information.

We conducted interviews with NHTSA program officials to understand 

NHTSA’s role in the auto recall process. In addition, we interviewed other 

stakeholders, including the Independent Monitor of Takata, which assists 

NHTSA in overseeing the Takata recall, as well as officials from 

consumer associations and other industry groups (see table 4).
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-18-127 Auto Recalls

Table 4: List of Industry Stakeholders We Interviewed

Advocates for Highway and Auto Safety

Alliance of Automobile Manufacturers

Center for Auto Safety

National Automobile Dealers Association

National Independent Automobile Dealers Association

Source: GAO. | GAO-18-127

To evaluate how easy or difficult consumers find the auto recall areas of 

NHTSA.gov to use, we reviewed various website usability resources to 

understand federal and industry key website usability practices for making 

websites easy to use, such as focusing on design and how easily users 

can find information. In addition, we reviewed federal standards for 

internal control related to communicating quality information externally.4

During our usability testing sessions, we asked consumers to attempt to 

complete auto recall tasks—the primary means NHTSA.gov provides for 

consumers to access information about auto recalls affecting their 

vehicles—and discuss their experiences. We then compared consumers’ 

experiences with the usability of the website against these practices.

To identify key website usability practices, we analyzed guidance 

documents from NHTSA and other federal agencies. For example, we 

analyzed the General Services Administration’s (GSA) and the 

Department of Health and Human Services’ Research-Based Web 

Design & Usability Guidelines, which includes quantified, peer-reviewed 

guidelines intended to help federal agencies improve the design and 

usability of their information-based websites.5 We also analyzed GSA’s 

Requirements for Federal Websites and Digital Services, and the U.S. 

Digital Services Playbook to identify key practices for making websites 

easy to use. Identified key practices are: (1) design and content—

focusing on the layout, headers, and design; (2) navigation—how easily 

users can find information; (3) clarity—the ability to read and digest 

 4

GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014).

5

GSA and the Department of Health and Human Services, Research-Based Web Design 

& Usability Guidelines (Washington, D.C.: August 2006). GSA also offers website usability 

evaluation services to federal agencies. The Department of Health and Human Services 

manages usability.gov, a website where the federal government has published ways to 

assess a website’s usability and, in partnership with GSA, issued guidance and best 

practices for designing federal websites.
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-18-127 Auto Recalls

content; (4) identity and purpose—whether the site clearly presents its 

purpose; and (5) accessibility—the ability of people with physical or 

mental disabilities to use the site.

To analyze the results of focus group website testing sessions, we 

performed a systematic content analysis of the session transcripts using 

the same content analysis methods described above and an analysis of 

the questionnaire we administered to each participant during the website 

usability sessions. Specifically, we analyzed the transcripts from the 

website usability testing sessions to account for consumers’ experiences, 

including their initial impressions of the website and any suggested 

usability improvements. We also analyzed the results of the questionnaire 

that each participant completed where participants were asked to mark 

responses regarding their experience including an assessment of the 

usability of the auto recall areas of NHTSA.gov. Our analysis of the 

results from the questionnaire responses was conducted at the individual 

consumer level (i.e., of the 94 consumers who participated) while our 

analysis of focus group session discussions was conducted at the group 

level (i.e., of the 12 focus groups we conducted).

To corroborate the results of usability testing sessions we conducted with 

the consumers in our focus groups, we requested that five website 

usability professionals from GSA’s Federal User Experience Community 

conduct an independent evaluation of the auto recall areas of NHTSA.gov 

against federal and industry key website usability practices (described 

above).6 The website usability professionals developed a website 

usability evaluation form, which they used to individually evaluate the auto 

recall areas of NHTSA’s website. The website usability professionals then 

met to form a consensus and provided us with one final group evaluation 

of the website usability of the auto recall areas of NHTSA.gov. Also, 

although neither our usability testing nor the website usability evaluation 

conducted by website usability professionals directly addressed 

accessibility, we interviewed responsible agency officials about how the 

agency assesses the accessibility of NHTSA.gov.7

 6

GSA’s Federal User Experience Community is comprised of federal program managers, 

subject matter experts, designers, and developers with expertise in website usability.

7

Section 794d of Title 29 of the U.S. Code requires that federal agency information 

technology allows members of the public with disabilities to have access to and use of 

information and data that is comparable to the access to and use of those without 

disabilities.
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-18-127 Auto Recalls

We also requested and analyzed website data provided by NHTSA to 

understand how consumers access and use NHTSA.gov. Requested data 

included the number of subscribers to NHTSA’s Recall Notification E-mail 

System Sign-up; the number of weekly vehicle identification number (VIN) 

searches performed on NHTSA.gov from August 2014 through May 2017; 

and NHTSA.gov usage data by device (i.e., usage by mobile devices, 

tablets, and desktop computers). We assessed the reliability of these data 

by reviewing any supporting documents provided by the agency and 

interviewing responsible NHTSA officials, and concluded the data were 

sufficiently reliable for our reporting purposes.

While we did not independently review the usability of auto 

manufacturers’ auto recall websites, we requested and reviewed the 

results of any audits that NHTSA performed of these websites, including 

whether the websites met statutory and regulatory requirements for 

providing auto recall information to the public. We then corroborated any 

audit findings by reviewing the auto recall websites of the selected auto 

manufacturers that we interviewed.

To determine any steps NHTSA has taken to raise consumer awareness 

about auto recalls and how NHTSA evaluates the effectiveness of any 

steps, we reviewed relevant statutes, regulations, and proposed rules, 

including the Fixing America’s Surface Transportation Act and a Notice of 

Proposed Rulemaking related to recall notification methods.8 We also 

reviewed agency and other documents that describe or evaluate 

NHTSA’s public awareness activities. For example, we analyzed 

NHTSA’s strategic planning documents—such as NHTSA’s Strategic 

Plan 2016–2020—to identify ongoing public awareness activities along 

with their related goals, objectives, or performance metrics. Similarly, we 

requested and analyzed any documents NHTSA uses to evaluate the 

effectiveness of its public awareness activities, including performance 

reports for NHTSA’s ongoing Safe Cars Save Lives campaign.

To assess the reliability of data included in these performance reports—

such as VIN searches performed—we reviewed agency documentation 

and interviewed agency officials about the reliability, accuracy, and 

completeness of the data and determined the data were sufficiently 

reliable for our reporting purposes. We reviewed performance 

 8

Pub. L. No. 114-94, 129 Stat. 1312; and Update Means of Providing Recall Notification, 

81 Fed. Reg. 60,332 (Sept. 1, 2016). 
Appendix I: Objectives, Scope, and 

Methodology

Page 38 GAO-18-127 Auto Recalls

management practices as provided in the Government Performance and 

Results Act of 1993 (GPRA), the GPRA Modernization Act of 2010, and 

standards for internal control in the federal government to identify any 

opportunities for improvement.9 We also performed a literature review to 

identify any related published articles and research studies.

To understand how NHTSA implements and evaluates any public 

awareness activities, we also interviewed responsible agency officials 

from NHTSA’s Office of Communications and Consumer Information and 

other offices. In addition, we discussed NHTSA’s public awareness efforts 

during interviews with industry stakeholders, including selected auto 

manufacturers, selected franchised and independent auto dealerships, 

and other industry stakeholders. We analyzed the results of these 

interviews along with the focus group discussions we conducted with 

consumers (discussed above) to identify perspectives on the 

effectiveness of NHTSA’s public awareness steps.

We conducted this performance audit from October 2016 to December 

2017 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

 9

GAO-14-704G.
Appendix II: Example of an Auto 

Manufacturer’s Recall Notification Letter

Page 39 GAO-18-127 Auto Recalls

Appendix II: Example of an Auto 

Manufacturer’s Recall Notification Letter
Appendix II: Example of an Auto 

Manufacturer’s Recall Notification Letter

Page 40 GAO-18-127 Auto Recalls
Appendix II: Example of an Auto 

Manufacturer’s Recall Notification Letter

Page 41 GAO-18-127 Auto Recalls
Appendix II: Example of an Auto 

Manufacturer’s Recall Notification Letter

Page 42 GAO-18-127 Auto Recalls
Appendix III: Annual Recall Completion Rates 

by Vehicle Component and Vehicle Type

Page 43 GAO-18-127 Auto Recalls

The National Highway Traffic Safety Administration (NHTSA) is required 

to conduct a biennial analysis of vehicle safety recall completion rates 

and submit the results of its analysis in a report to certain congressional 

committees.1 The report must include, among other things, the annual 

recall completion rate by vehicle type and vehicle component (such as 

brakes, fuel systems, and air bags) for each of the 5 years preceding the 

year the report is submitted. According to NHTSA’s May 2017 report, 

completion rates for all vehicles combined ranged between 63 percent 

and 67 percent between calendar year 2011 and calendar year 2014 (see 

table 5). However, NHTSA reported wider variation when the recall 

completion rates are broken down by vehicle type. Similarly, the report 

found that completion rates for most component categories fall within a 

range of 60 percent to 75 percent (see table 6).2

NHTSA’s completion rate formula is:

� Count of vehicles remedied

Count of vehicles in recall − vehicles exported, stolen, scrapped, other� ∗ 100

The annual completion rate is a volume-based, weighted metric, such that 

the more vehicles affected by the recall, the more weight or influence it 

has on the computed rate.3

 1

Pub. L. No. 114-94, § 24104(c), 129 Stat. 1312, 1703-04. NHTSA must conduct an 

analysis and submit a report not later than 1 year after December 4, 2015, and biennially 

thereafter for 4 years.

2

National Highway Traffic Safety Administration, Report to Congress: “Vehicle Safety 

Recall Completion Rates Report” (May 2017), 14.

3

According to NHTSA, the agency is unable to verify the numbers of remedied vehicles 

reported by manufacturers with the available data. Likewise, the agency cannot verify the 

numbers of vehicles reported as exported, stolen, scrapped, or otherwise legitimately 

deducted from the number of vehicles recalled.

Appendix III: Annual Recall Completion 

Rates by Vehicle Component and Vehicle 

Type
Appendix III: Annual Recall Completion Rates 

by Vehicle Component and Vehicle Type

Page 44 GAO-18-127 Auto Recalls

Table 5: Auto Recall Annual Completion Rates by Vehicle Type, Calendar Years 

2011 through 2014

Annual completion ratea

Vehicle type 2011 2012 2013 2014

Passenger Car 73% 76% 76% 60%

Multipurpose Passenger Vehicleb 74% 52% 59% 67%

Light Truck 46% 58% 45% 93%

Mixc 75% 65% 62% 73%

Percent remedied by calendar year 65% 65% 63% 67%

Source: National Highway Traffic Safety Administration (NHTSA). | GAO-18-127

a

NHTSA’s annual completion rate counts include recalls issued between calendar years 2010 and 

2014 in which the manufacturer reported the recall’s completion status for at least 5 quarters after the 

remedy program became available (as of July 1, 2016). The rate is a volume-based, weighted metric, 

such that the more vehicles affected by the recall, the more weight or influence it has on the 

computed rate.

b

Multipurpose passenger vehicles include, for example, sport utility vehicles and mini vans.

c

The mix category includes recalls that involved a combination of passenger cars, multipurpose 

vehicles, and light trucks.

Table 6: Auto Recall Annual Completion Rates by Vehicle Component, Calendar 

Years 2011 through 2014

Annual completion ratea

Component nameb 2011 2012 2013 2014

Air Bags 59% 51% 66% 70%

Electrical System 86% 61% 79% 62%

Electronic Stability Control/Traction Control 92% —c 79% 63%

Engine and Engine Cooling 72% 68% 83% 81%

Equipment 84% 47% 85% 67%

Fuel System 49% 79% 50% 73%

Latches/Locks/Linkages —c 80% 61% 78%

Lighting 51% 59% 60% 58%

Power Train 76% 65% 67% 76%

Seat Belts 82% 73% 58% 77%

Seats 78% 89% 49% 67%

Service/Parking Brakes 78% 58% 68% 68%

Steering 70% 72% 49% 67%

Structure 46% 83% 42% 66%

Suspension 61% 67% 59% 65%

Tires and Wheels 86% 38% 89% 81%
Appendix III: Annual Recall Completion Rates 

by Vehicle Component and Vehicle Type

Page 45 GAO-18-127 Auto Recalls

Annual completion ratea

2011 2012 2013 2014

Vehicle Speed Control 69% 48% 65% 60%

Visibility 83% 68% 60% 62%

Source: National Highway Traffic Safety Administration (NHTSA). | GAO-18-127

a

NHTSA’s annual completion rate counts include recalls issued between calendar years 2010 and 

2014 in which the manufacturer reported the recall’s completion status for at least five quarters after 

the remedy program became available (as of July 1, 2016). Recalls that had not reached this 

maturation point—including recalls filed in calendar year 2015—were not counted. Completion rates 

include light vehicles in the following major categories: light trucks, multipurpose passenger vehicles 

such as sport utility vehicles and mini vans, and passenger cars. The rate is a volume-based, 

weighted metric, such that the more vehicles affected by the recall, the more weight or influence it 

has on the computed rate.

b

When a recall included multiple defective components, that recall was included in each component 

category. According to NHTSA, while the agency strives to be consistent in its component 

classification approach, a degree of subjectivity is required in classifying some vehicle components, 

given the variety of components that can necessitate a recall. Also, inconsistencies across 

manufacturers can present challenges to utilizing a uniform taxonomy for vehicle components.

c

NHTSA did not report a completion rate for this component.
Appendix IV: Focus Group Participants’ 

Responses to Recall Notification 

Questionnaire

Page 46 GAO-18-127 Auto Recalls

Focus group participants responded to a questionnaire we administered 

to collect information on consumers’ auto recall notification preferences 

during our discussion sessions. Table 7 shows participants’ responses to 

the administered questionnaire, by age group. We present these 

responses by age group, because consumers’ notification preferences 

may vary according to their ages.

Table 7: Focus Group Participants’ Responses to Administered Recall Notification Questionnaire, by Age Group

Responses

Number of responses

(percentage of age group)

Total

(94)

21-34 years old

(21)

35-54 years old

(44)

55+ years old

(29)

Question: Did you receive a notification letter in 

the mail from the manufacturer informing you 

about the recall on your specific vehicle? 

(Select one)

Yes 18 (86%) 43 (98%) 29 (100%) 90

No 3 (14%) 1 (2%) 0 (0%) 4

Question: In what other ways were you notified 

or did you become aware of the safety recall on 

your specific vehicle? (Select all that apply)

Other mailed correspondence from the 

manufacturer

4 (19%) 11 (25%) 11 (38%) 26

Mail from a dealer 6 (29%) 13 (30%) 5 (17%) 24

Automated phone call 1 (5%) 1 (2%) 1 (3%) 3

Live/non-automated phone call 2 (10%) 0 (0%) 0 (0%) 2

Electronic mail (e-mail) message 2 (10%) 1 (2%) 0 (0%) 3

Text message 0 (0%) 0 (0%) 0 (0%) 0

In person at a dealership 3 (14%) 6 (14%) 3 (10%) 12

In person at an auto repair shop (non-dealership) 0 (0%) 1 (2%) 0 (0%) 1

Other 4 (19%) 1 (2%) 7 (24%) 12

Question: How would you prefer to be notified 

about safety recalls affecting your specific 

vehicle? (Select all that apply)

Mail 19 (90%) 37 (84%) 24 (83%) 80

Automated phone call 7 (33%) 7 (16%) 2 (7%) 16

Live/non-automated phone call 6 (29%) 7 (16%) 2 (7%) 15

Electronic mail (e-mail) message 13 (62%) 30 (68%) 13 (45%) 56

Text message 5 (24%) 13 (30%) 4 (14%) 22

In person at a dealership 9 (43%) 7 (16%) 3 (10%) 19

In person at an auto repair shop (non-dealership) 5 (24%) 5 (11%) 1 (3%) 11

Appendix IV: Focus Group Participants’ 

Responses to Recall Notification 

Questionnaire
Appendix IV: Focus Group Participants’ 

Responses to Recall Notification 

Questionnaire

Page 47 GAO-18-127 Auto Recalls

Responses

Number of responses

(percentage of age group)

Total

(94)

21-34 years old

(21)

35-54 years old

(44)

55+ years old

(29)

Other 0 (0%) 0 (0%) 0 (0%) 0

Question: Have you sought out additional 

information about the safety recall on your 

specific vehicle? (Select one)

Yes 9 (43%) 15 (34%) 10 (34%) 34

No 12 (57%) 29 (66%) 19 (66%) 60

Question: If you sought out additional 

information, how did you seek out additional 

information? (Select all that apply)

Searched the Internet 7 (33%) 9 (20%) 6 (21%) 22

Contacted the manufacturer 0 (0%) 5 (11%) 0 (0%) 5

Contacted a dealer 4 (19%) 8 (18%) 6 (21%) 18

Other 1 (5%) 0 (0%) 0 (0%) 1

Question: Have you ever signed up to receive email alerts about safety recalls that may affect 

your vehicle? (Select one)

Yes 1 (5%) 3 (7%) 0 (0%) 4

No 20 (95%) 41 (93%) 29 (100%) 90

Question: If you signed up, where did you sign 

up to receive the e-mail alerts? 

(Select all that apply)a

Manufacturer website 0 (0%) 2 (5%) 0 (0%) 2

Dealer website 0 (0%) 2 (5%) 0 (0%) 2

Government website 1 (5%) 0 (0%) 0 (0%) 1

Other 0 (0%) 0 (0%) 0 (0%) 0

Question: Have you ever downloaded a mobile 

application to view information about safety 

recalls that may affect your vehicle? 

(Select one)

Yes 0 (0%) 0 (0%) 0 (0%) 0

No 21 (100%) 44 (100%) 29 (100%) 94

Source: GAO. | GAO-18-127

a

One participant marked more than one response for this question.
Appendix V: Focus Group Participants’ 

Responses to Website Usability Questionnaire

Page 48 GAO-18-127 Auto Recalls

Focus group participants responded to a questionnaire we administered

to collect information on the usability of NHTSA.gov during our usability 

testing sessions. Table 8 shows focus group participants’ responses to 

the administered questionnaire, by age group. We present these 

responses by age group, because consumers’ website usability needs or 

preferences may vary according to their ages.

Table 8: Focus Group Participants’ Responses to Administered Website Usability Questionnaire, by Age Group

Responses

Number of responses

(percentage of age group)

Total

(94)

21-34 years old

(21)

35-54 years old

(44)

55+ years old

(29)

1) In the space provided, please write down the 

website you would have chosen to find 

information about your vehicle’s recall.

NHTSA.gov 0 (0%) 1 (2%) 2 (7%) 3

Safercar.gov 2 (10%) 4 (9%) 2 (7%) 8

Manufacturer website 7 (33%) 18 (41%) 13 (45%) 38

Other 12 (57%) 21 (48%) 12 (41%) 45

2a) Try to find out if there are any recalls on 

your vehicle’s Year, Make, and Model. Did you 

find any recalls for this vehicle? (If so, mark 

only one response below to indicate how easy it 

was to find the information)

Very easy 16 (76%) 31 (70%) 15 (52%) 62

Somewhat easy 3 (14%) 7 (16%) 6 (21%) 16

Neither easy nor difficult 0 (0%) 1 (2%) 2 (7%) 3

Somewhat difficult 1 (5%) 5 (11%) 4 (14%) 10

Very difficult 1 (5%) 0 (0%) 2 (7%) 3

2b) For those of you who found that there were 

recalls on your vehicle’s Year, Make, and Model, 

try to find more information about these recalls. 

(Mark only one response below to indicate how 

easy it was to find the information)a

Very easy 13 (62%) 24 (56%) 13 (46%) 50

Somewhat easy 7 (33%) 8 (19%) 7 (25%) 22

Neither easy nor difficult 0 (0%) 3 (7%) 2 (7%) 5

Somewhat difficult 1 (5%) 6 (14%) 6 (21%) 13

Very difficult 0 (0%) 2 (5%) 0 (0%) 2

Appendix V: Focus Group Participants’ 

Responses to Website Usability 

Questionnaire
Appendix V: Focus Group Participants’ 

Responses to Website Usability Questionnaire

Page 49 GAO-18-127 Auto Recalls

Responses

Number of responses

(percentage of age group)

Total

(94)

21-34 years old

(21)

35-54 years old

(44)

55+ years old

(29)

3) Using your vehicle identification number, try 

to determine if there are any recalls affecting 

your vehicle. (Mark only one response below to 

indicate how easy it was to find the information)

Very easy 11 (52%) 42 (95%) 23 (79%) 76

Somewhat easy 7 (33%) 2 (5%) 3 (10%) 12

Neither easy nor difficult 2 (10%) 0 (0%) 1 (3%) 3

Somewhat difficult 0 (0%) 0 (0%) 1 (3%) 1

Very difficult 1 (5%) 0 (0%) 1 (3%) 2

4) You just bought a new vehicle. Try to find out 

if there is a way to sign up for e-mail recall 

alerts. (Mark only one response below to 

indicate how easy it was to find the information)

Very easy 4 (19%) 20 (45%) 10 (34%) 34

Somewhat easy 6 (29%) 15 (34%) 11 (38%) 32

Neither easy nor difficult 8 (38%) 3 (7%) 4 (14%) 15

Somewhat difficult 3 (14%) 3 (7%) 2 (7%) 8

Very difficult 0 (0%) 3 (7%) 2 (7%) 5

5) Having performed these tasks, what are your 

overall impressions of how easy it is to use the 

auto recall areas of NHTSA.gov? (Mark only one 

response below to indicate how easy it was to 

perform all of these tasks)

Very easy 4 (19%) 20 (45%) 5 (17%) 29

Somewhat easy 15 (71%) 17 (39%) 17 (59%) 49

Neither easy nor difficult 1 (5%) 2 (5%) 5 (17%) 8

Somewhat difficult 1 (5%) 5 (11%) 2 (7%) 8

Very difficult 0 (0%) 0 (0%) 0 (0%) 0

Source: GAO. | GAO-18-127

a

Only the 92 respondents who completed the vehicle year, make, and model search in 2a and found 

recalls for their vehicles responded to 2b.

Note: Some percentages do not add up to 100 percent due to rounding.
Appendix VI: Comments from the Department 

of Transportation

Page 50 GAO-18-127 Auto Recalls

Appendix VI: Comments from the 

Department of Transportation
Appendix VI: Comments from the Department 

of Transportation

Page 51 GAO-18-127 Auto Recalls
Appendix VII: GAO Contact and Staff 

Acknowledgments

Page 52 GAO-18-127 Auto Recalls

Susan A. Fleming, (202) 512-2834 or flemings@gao.gov

In addition to the individual named above, H. Brandon Haller (Assistant 

Director); Katherine Blair; Jason Blake; Melissa Bodeau; Alicia Cackley; 

William Colwell (Analyst in Charge); Lacey Coppage; Elizabeth Dretsch; 

Jaci Evans; Marcia Fernandez; Sarah Kaczmarek; Malika Rice; Todd 

Schartung; and Andrew Stavisky made key contributions to this report.

Appendix VII: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(101163)
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