July 2005 

Driver Violation Notification 

Service Feasibility Study 
Foreword 

The Driver Violation Notification (DVN) Feasibility Study analyzes the design of commercial 

driver history notification systems – sometimes called Employee/Employer Pull Notice (EPN) or 

Driver Pull Notice (DPN) programs – and their relationship to highway safety. The DVN 

systems provide the mechanism for addressing driver-based safety concerns by enabling 

regulatory agencies to notify employers of changes to a driver’s Commercial Driver’s License 

(CDL) record in a timely manner. Employers are not always notified about CDL driver 

convictions in a timely manner and, therefore, are unable to take immediate and appropriate 

corrective action. DVN programs attempt to address this basic problem. 

This study focused on providing a time-efficient means for notifying employers when their CDL 

drivers are convicted of driving violations or experience CDL status changes. The DVN Study 

Team started by developing the concept of a “benefits window” associated with the time between 

a conviction for a driving violation and the time an employer becomes aware of the convictions 

and takes action to mitigate the potential negative consequences of high-risk driving behavior. 

The study illustrates how reducing the time between conviction and notification of an employer 

can provide opportunities for employers to take action to reduce these consequences. 

Currently, ten states offer DVN programs, which provide the basis for assessing program design 

and success, and for establishing requirements for potential expansion to a national program. A 

key study component was the conduct of site visits to each of these states. The DVN Study 

Team conducted a five-stage research program, focused on determining whether an expanded 

DVN program would help meet the safety and productivity goals for both industry and 

government. This document presents an Executive Summary of the technical memoranda and 

analyses prepared for the five tasks of this project. 

The report is primarily targeted towards commercial motor vehicle employers that can use these 

programs, and the states that can create these opportunities for timely notification of driver 

convictions. 

This publication is considered a final report and does not supersede another publication. 

Notice

This document is disseminated under the sponsorship of the Department of Transportation in the 

interest of information exchange. The United States Government assumes no liability for its 

contents or use thereof. 

The contents of this report reflect the views of the contractor (and the individuals interviewed) 

who is responsible for the accuracy of the data presented herein. The contents do not necessarily 

reflect the official policy of the Department of Transportation. 

The United States Government does not endorse products or manufacturers. Trademarks or 

manufacturers' names appear herein only if they are considered essential to the objectives of the 

document. This document does not constitute a standard, specification, or regulation. 
Technical Report Documentation Page 

1. Report No. 

FMCSA-RT-05-003 

 

2. Government Accession No. 3. Recipient's Catalog No. 

4. Title and Subtitle: 

Driver Violation Notification Service Feasibility Study 

5. Report Date: July 2005 

 

6. Performing Organization Code 

7. Author(s): 

Michael Smith, Science Applications International Corporation (SAIC) 

Nick Owens, SAIC 

Dan Stock, SAIC 

Brenda Lantz, Upper Great Plains Transportation Institute 

Dan Murray, American Transportation Research Institute 

Greg Sensiba, American Association of Motor Vehicle Administrators 

8. Performing Organization Report No. 

9. Performing Organization Name and Address 

Science Applications International Corporation 

7990 Science Applications Court 

Vienna, VA 22182 

10. Work Unit No. (TRAIS) 

 

11. Contract or Grant No. 

DTMC75-03-Q-00103 

12. Sponsoring Agency Name and Address 

Federal Motor Carrier Safety Administration, USDOT 

400 Virginia Ave., SW 

Washington, DC 20024 

13. Type of Report and Period Covered 

Final Report; August 2003 – September 

2004

 

14. Sponsoring Agency Code 

15. Supplementary Notes 

The contracting officer’s technical representative was Jeff Loftus, FMCSA Office of Research and Technology. 

16. Abstract: The Driver Violation Notification Service Feasibility Study assessed the safety benefits of driver violation 

notification programs (also known as Employee Pull Notice or Driver Pull Notice programs). In these programs, States 

automatically notify motor carriers of changes in their drivers’ CDL records due to violations and convictions. The 

project team analyzed programs in ten States, and surveyed several motor carriers, in order to both determine how well 

these programs work and establish requirements for an expanded nationwide program. 

17. Key Words 

CMV, CVO, commercial motor vehicle, cost-benefit, DPN, DVN, Driver 

Pull Notice, Driver Violation Notification, EPN, Employee Pull Notice, 

ITS, ITS/CVO 

18. Distribution Statement 

No restrictions. 

19. Security Classif. (of this report) 

Unclassified 

20. Security Classif. (of this page) 

Unclassified 

21. No. of Pages 

41 

22. Price 

Form DOT F 1700.7 (8-72) Reproduction of completed page authorized 
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LENGTH LENGTH 

In inches 25.4 millimeters mm mm millimeters 0.039 inFt feet 0.305 meters m m meters 3.28 feYd yards 0.914 meters m m meters 1.09 yaMi miles 1.61 kilometers km km kilometers 0.621 m

AREA AREA 

in2 square inches 645.2 square millimeters mm2 mm2 square millimeters 0.0016 sqft2 square feet 0.093 square meters m2 m2 square meters 10.764 sqyd2 square yards 0.836 square meters m2 m2 square meters 1.195 sqAc acres 0.405 hectares ha ha hectares 2.47 acmi2 square miles 2.59 square kilometers km2 km2 square kilometers 0.386 sq

VOLUME VOLUME 

fl oz fluid ounces 29.57 milliliters ml ml milliliters 0.034 fluGal gallons 3.785 liters l l liters 0.264 gaft3 cubic feet 0.028 cubic meters m3 m3 cubic meters 35.71 cuyd3 cubic yards 0.765 cubic meters m3 m3 cubic meters 1.307 cu

MASS MASS 

Oz ounces 28.35 grams g g grams 0.035 ouLb pounds 0.454 kilograms kg kg kilograms 2.202 poT short tons (2000 lbs) 0.907 megagrams Mg Mg megagrams 1.103 sh

TEMPERATURE (exact) TEMPERATURE (exac

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ILLUMINATION ILLUMINATION 

Fc foot-candles 10.76 lux lx lx lux 0.0929 Fl foot-Lamberts 3.426 candela/m2 cd/m2 cd/m2 candela/m2 0.2919 

FORCE and PRESSURE or STRESS FORCE and PRESSURE or S

Lbf pound-force 4.45 newtons N N newtons 0.225 Psi pound-force per square inch 6.89 kilopascals kPa kPa kilopascals 0.145 
i 

Table of Contents 

Project Background........................................................................................................................................................1

Task 1 – State Visits: Government Agencies.................................................................................................................3

Task Overview and Data Collection ..........................................................................................................................3

Summary of State DVN Programs ............................................................................................................................3

State DVN Program Operational Components..........................................................................................................8

Enrollment ............................................................................................................................................................8

Driver History Monitoring ......................................................................................................................................8

Notification............................................................................................................................................................8

Account Updates ..................................................................................................................................................8

Flexible Enrollment ...............................................................................................................................................8

Driver Tracking .....................................................................................................................................................8

Annual Account Update........................................................................................................................................8

Account Audits......................................................................................................................................................9

Electronic Signature .............................................................................................................................................9

Signed Waivers Authorizing Driver History Pulls ..................................................................................................9

Periodic Invoicing .................................................................................................................................................9

Electronic Notification ...........................................................................................................................................9

Outreach...............................................................................................................................................................9

Task 2 – State Visits: Motor Carrier Industry..................................................................................................................9

Study Findings ........................................................................................................................................................10

User Requirements .................................................................................................................................................10

DVN Program Structure......................................................................................................................................10

DVN Notice Content ...........................................................................................................................................10

DVN Program Pricing and Payments .................................................................................................................10

DVN Program Participation.................................................................................................................................11

Data Integrity ......................................................................................................................................................11

Task 3 – Cost/Benefit Analysis ....................................................................................................................................11

Task 4 – Develop Alternate Approaches......................................................................................................................17

System Objective ....................................................................................................................................................17

Definitions...........................................................................................................................................................17

Functional Requirements ........................................................................................................................................18

Jurisdictional Deployment Consideration............................................................................................................18

Motor Carrier Deployment Considerations .........................................................................................................19

Work Breakdown Structure .....................................................................................................................................19

Deployment Alternatives .........................................................................................................................................19

Jurisdictional-Based Alternatives........................................................................................................................20

Multi-Jurisdictional Alternatives ..........................................................................................................................20

National System Alternatives..............................................................................................................................21

Federal System Alternatives...............................................................................................................................21

Recommended Approach – Employer Notification Service National Pointer System .............................................21

Advantages.........................................................................................................................................................22
ii 

Disadvantages....................................................................................................................................................22

Process Flow...........................................................................................................................................................22

Task 5 – Recommended Deployment Approach..........................................................................................................26

Task Overview ........................................................................................................................................................26

Recommended Deployment Approach ...................................................................................................................27

Benefits of Conducting a Pilot Project .....................................................................................................................27

Pilot Project Goals and Objectives .....................................................................................................................28

Proposed Pilot Project – State Participation............................................................................................................30

Proposed Pilot Project – Stakeholder Groups.........................................................................................................31

Appendix 1 – Project Deliverables ...............................................................................................................................32

Appendix 2 – Driver Violation Notification Feasibility Study Acronym List ...................................................................33
iii 

List of Figures 

Figure 1. ENS “Benefits Window” .................................................................................................................................1

Figure 2. Overview for 5-Stage DVN Feasibility Study..................................................................................................2

Figure 3. DVN and Non-DVN State Visits .....................................................................................................................3

Figure 4. Overview of Benefit Assessment Approach.................................................................................................12

Figure 5. Overview of Cost Assessment Approach.....................................................................................................12

Figure 6. ENS Work Breakdown Structure..................................................................................................................20

Figure 7. Primary Conceptual Design – Employer Registration ..................................................................................24

Figure 8. Preliminary Conceptual Design – Employer Notification Process................................................................25

List of Tables 

Table 1. DVN States – Program Summaries.................................................................................................................5

Table 2. Driver History Versus Last Crash, Suspension, or Conviction ......................................................................13

Table 3. Implementation Issues ..................................................................................................................................29
1 

Project Background 

The Driver Violation Notification (DVN) Feasibility Study analyzes the design of commercial driver history notification systems

– sometimes called Employee/Employer Pull Notice (EPN) or Driver Pull Notice (DPN) programs – and their relationship to 

highway safety. The DVN systems provide the mechanism for addressing driver-based safety concerns by enabling 

regulatory agencies to notify employers of changes to a driver’s Commercial Driver’s License (CDL) record in a timely 

manner. Currently, ten states offer DVN programs, which provide the basis for assessing program design and success, and 

for establishing requirements for potential expansion to a national program. 

The basic problem that DVN programs attempt to address is that employers are not always notified about CDL driver 

convictions in a timely manner and, therefore, are unable to take immediate and appropriate corrective action. One 

response in resolving this problem is to provide a time-efficient means for notifying employers when their CDL drivers 

are convicted of driving violations or experience CDL status changes. This action will enable the motor carriers (MC) 

to take timely corrective action to potentially reduce crash risks caused by at-risk drivers. 

To solve this problem, the Federal Motor Carrier Safety Administration’s Office of Research and Technology awarded 

a contract to the Science Applications International Corporation (SAIC) DVN Study Team, which includes the 

American Transportation Research Institute (ATRI), the American Association of Motor Vehicle Administrators 

(AAMVA), and the Commercial Vehicle Safety Alliance (CVSA). This study team developed the concept of a 

“benefits window” associated with the time between a conviction for a driving violation and the time an employer 

becomes aware of the convictions and takes action to mitigate the potential negative consequences of high-risk 

driving behavior. The DVN Study Team sought ways to “close the window” to gain potential safety benefits. 

This activity has been labeled an “Employer Notification Service” or ENS to emphasize the fact that the employer is 

notified (not the driver) and the notification is not for violations but for convictions and any other events that affect the 

driving status of the CDL holder (including CDL withdrawals for any reason). The notification action is a service to 

employers that may be implemented through a variety of systems approaches. Figure 1 shows the DVN “benefits 

window” and illustrates how reducing the time between conviction and notification of an employer can provide 

opportunities for employers to take action to reduce high-risk driver behavior. 

Violation Adjudication Conviction Months After Conviction

& Citation

- t 0 3 6 12

Violation Adjudication Conviction Months After Conviction

& Citation

- t 0 3 6 12 Probability Employer is Notified1.0

0.8

0.6

0.4

0.2

Probability Employer is Notified1.0

0.8

0.6

0.4

0.2

Some MC require 

notification of 

citations

Annual driver histories 

provide MC with conviction 

notices (some MCs pull DHRs 

quarterly or semiannually)

Some 

convictions 

are never 

posted to DHR

30 days

Employer notified

DVN “Benefits Window”

(17% to 30% of area)

DVN Opportunity

Interviews suggest that 50%-80% of 

the drivers do notify employers 

within the currently required 30 days 

of convictions

Figure 1. ENS “Benefits Window” 
2 

The DVN Study Team conducted a 5-stage research program, as illustrated in Figure 2. This study is focused on 

determining whether an expanded DVN program would help meet the safety and productivity goals for both industry 

and government. 

Figure 2. Overview for 5-Stage DVN Feasibility Study. 

This document presents an Executive Summary of the technical memoranda and analyses prepared for Tasks 1 – 5 

presented in Figure 2. The document is organized into five sections, with each section summarizing the findings and 

analyses conducted for the particular task. 

A key study component was the conduct of site visits to ten states that are identified as already using a DVN-type 

program. In addition, site visits were conducted in four states that do not yet have DVN programs. The purpose of 

these visits was to: 

♦ Meet with state agencies to document how existing DVN-type programs are operated and obtain information 

on their effectiveness. 

♦ Collect information on the cost of each state’s existing Motor Vehicle Record (MVR) program as well as 

other data on the DVN program’s impact. 

♦ Meet with state agencies to identify potential implementation issues (technical, programmatic, financial) that 

would need to be addressed in states without an existing DVN-type program so that a national program 

could be successfully deployed. 

♦ Meet with the motor carrier industry in each state to obtain their views on existing programs and/or the need 

for an expanded (i.e., national) program. 

The ten states identified as having existing DVN-type programs included Arkansas, California, Illinois, Michigan, 

Nebraska, New York, North Carolina, Oregon, Virginia, and Wisconsin. The four non-DVN states selected were Iowa, 

Kentucky, Maryland, and North Dakota. In selecting these states, the DVN Study Team considered states located 

within the same regional location as the original ten states included in the study (East Coast/Mid Atlantic, Mid West) 

and with similar characteristics (Rural, Urban, Border). The site visits were conducted in the fall of 2003. A summary 

of state visits is shown in Figure 3. 

Task 2: Document User 

Requirements for Driver 

Violation Notification 

Programs

Task 1: Conduct Case 

Studies of Existing 

Driver Violation 

Notification Programs

Task 3: Conduct an 

In-Depth Cost-Benefit 

Analysis

Task 4: Develop Alternate 

Approaches for the 

Deployment of Driver 

Violation Notification 

Programs

Task 5: Recommend 

Deployment Approach 

and Work Plan for the 

Development of Driver 

Violation Notification 

Programs 
3 

Figure 3. DVN and Non-DVN State Visits. 

Task 1 – State Visits: Government Agencies 

Task Overview and Data Collection 

The DVN Study Team developed an interview guide that was used for the state visits. The interview guides included 

specific questions for DVN and non-DVN states. Each state was provided with a brief summary of the DVN Feasibility 

Study and a copy of the interview guide prior to the actual site visit. Interviews were scheduled by telephone and email and interview participants were identified by each state prior to the site visit. Interviews were conducted with 

representatives from the agency or agencies in each state responsible for implementing the DVN program. In 

addition, interviews also were conducted with representatives from selected Federal Motor Carrier Safety 

Administration (FMCSA) division offices. 

The DVN Study Team also participated in the Carrier Safety Committee meetings at the AAMVA International 

Conference in August 2003 and the CVSA Driver Committee meeting in October 2003. The DVN Study Team 

presented an overview of the DVN Feasibility Study at these two meetings to discuss issues and concerns identified 

by the two key stakeholder groups. 

Summary of State DVN Programs 

In general, state DVN programs are designed as employer programs, providing driver monitoring services to any 

employer whose employees operate motor vehicles as part of their jobs. Most states have limited participation by 

commercial motor carriers, but have significant participation from local governments. In many states, major 

customers are third-party service providers who monitor driver performance on behalf of the insurance industry 

Virginia 

Industry: July 21st

DMV/FMCSA: Aug. 27th

Maryland 

Industry: Oct. 27th 

DMV: Oct. 3rd

New York 

Industry: Nov. 5-6th 

DMV/FMCSA: Nov. 5 

Michigan 

DMV: Oct. 6th

Iowa 

Industry: Oct 14th

DMV: Oct 20th

FMCSA: Oct 21st Arkansas 

Industry: Oct. 7th 

DMV: Oct. 7th 

FMCSA: Oct. 8 

California 

Industry: Nov. 11th

DMV: Oct. 22nd

Oregon 

Industry: Oct. 24th 

DMV/FMCSA: Oct. 24th

Nebraska 

Industry: Sept. 22-23rd

DMV: Sept. 22nd

Wisconsin 

Industry: Oct 16th

DMV: Oct 16th

North Dakota 

Industry: Oct. 16th

DMV: Oct. 23rd

FMCSA: Oct. 16th

Kentucky 

DMV: Nov 18th

DVN 

Non-DVN

North Carolina 

DMV: Aug 31, 2004 

Note: All dates 2003 unless otherwise noted.

Illinois 

DMV: October 21st
4 

(ChoicePoint and Explorer) or the motor carrier industry (DAC and License Monitor). The programs are generally 

designed as voluntary programs with California being the only state that has mandatory participation for all Californiaissued commercial drivers’ licenses (CDLs). 

Several other states require that certain types of CDL or other license holders participate. The Illinois program, for 

example, is mandatory for all school bus drivers. The Virginia program is mandatory for school bus drivers and driver 

education instructors. The programs vary in size and with the exception of California, do not generally include more 

than 25 percent of a state’s total number of licensed drivers (CDL and non-CDL). 

States have used a variety of business models for implementing DVN programs. Some states offer the service 

directly through the Department of Motor Vehicles (DMV), including the New York License Event Notification System 

(LENS), the Oregon Automated Reporting Service, and the California Employer Pull Notice Program. 

A number of states use vendor-contracted services to provide e-government services on behalf of government. 

Nebraska (Nebrask@ OnLine) and Arkansas (Information Network for Arkansas) contract with the National 

Information Clearinghouse, Inc., (NIC) to provide a wide range of e-government services, including a DVN program. 

The NIC recovers cost through a transaction fee. This fee includes any state-related services charges (such as Driver 

History Records [DHR] charges), as well as providing a mark-up percentage to cover NIC costs and profit. 

In addition, a significant market has developed for third-party service bureaus that purchase DHRs. ChoicePoint and 

Explorer Information Services purchase DHRs and track driver history on behalf of the insurance industry. License 

Monitor, Inc., a New York company, established a master account with the New York DMV’s LENS program and 

markets this service to the motor carrier industry. Although a major provider for other services, DAC offers a similar 

driver monitoring service to the motor carrier industry. All of these vendors (including the NIC e-government model 

and the service bureaus) offer on-line subscription services. Registration is conducted electronically, with customers 

providing a list of drivers/employees to be monitored, usually through batch processing. Vendors receive daily record 

updates from DMVs, and monitor DHRs on a daily basis. 

In most states, changes in DHRs are based on judicial action. Most state court systems provide their respective 

DMVs with a daily update regarding convictions, which are then posted to driver records. Since many states have 

currently automated daily downloading processes, this data is transmitted electronically from the court system to the 

DMV legacy system, which automatically updates the driver history records. The DHR data update is generally 

performed via batch processing within 24 hours after being received from the court. 

Currently, some states do have the capability to update DHRs on a real-time basis. A number of states, however, are 

not yet using or have not yet fully implemented an automated process. For these states, manual data entry 

processes may result in taking from several days up to more than a month to update DHRs based on court 

convictions. States generally give priority to processing CDL convictions and post out-of-state CDL convictions to the 

Commercial Drivers License Information System (CDLIS). 

Table 1 presents a summary overview of state DVN programs included in the DVN Feasibility Study. 
Table 1. DVN States – Program Summaries 

State Program Name Why Program Was Started Who Participates Mandatory Participants Who Provides Service Number of Customers CDLs Covered Total CDLs in State Aver

Notific

Per M

Arkansas 

Driver Watch Established by INA 

as part of egovernment service 

Motor carrier companies 

 Information Network for 

Arkansas – third-party e-government vendor (NIC) 

20 motor carriers 

50 128,000 

California 

Employer Pull Notice (EPN) 

♦ Established in 

1982 to pro-mote driver safety 

♦ Mandatory for 

CA CDL drivers since 1989 

Any employer with employees who operate motor vehicles in the course of performing their jobs; includes private and public sector drivers with and without CDLs. All CA CDL drivers must be enrolled. 

CA CDL drivers 

California Department of Motor Vehicles administers the program in-house 

About 48,000 employers 

All CDLs 928,882 About 75,00

per month aall enrolled including nodrivers who approximatethe enrolled 

Illinois 

Safe Ride Response to 

exposure by local newspaper on school bus drivers 

School bus operators 

School bus drivers 

Secretary of State – Driver Services Department 

 526,139 245 

Michigan 

Subscription Service Program 

State initiative in response to Commercial Vehicle Safety Act of 1987 notification requirement 

♦ Insurance 

companies 

♦ Explorer ♦ ChoicePoint ♦ TML-driver checks 

for car rental companies. 

♦ General Motors ♦ U.S. Military 

♦ Limousine 

drivers 

♦ Driver 

Education teachers licensed by BDVR 

Secretary of StateBureau of Driver and Vehicle Records 

♦ 1,187 

commercial (paying) customers 

♦ 930 

government agencies 

149,843 

Nebraska 

Driver’s License Record Search 

Legislative Mandate 

Explorer Information Services 

 Nebrask@OnLine – 

third party e-government vendor (NIC) 

1Type of enrollment and notification process used depends on customer’s IT capabilities. 
State Program Name Why Program Was Started Who Participates Mandatory Participants Who Provides Service Number of Customers CDLs Covered Total CDLs in State Aver

Notific

Per M

Nebraska 

ChoicePoint Werner Trucking Domino’s Pizza Schools, law firms, and private detectives. 

New York 

License Event Notification Service (LENS) 

♦ Expansion of 

critical driver program 

♦ Y2K created 

opportunity to develop LENS 

♦ Third-party service 

providers (ChoicePoint, Explorer, License Monitor)2

♦ New York City 

Taxi Commission 

♦ Government 

agencies 

♦ Private companies 

 DMV 687 ♦ Accident

♦ Accident 

Preventiocompleti

♦ Convictio♦ License 

(both typnotices): 

♦ Restorat♦ Suspens

revocatio

North 

Carolina 

Transportation Notification System 

Motor coach industry concerns about obtaining accurate reports from drivers on convictions 

Pilot Project: 28 government agencies and seven motor coach companies are participating at DMV invitation 

None Division of Motor 

Vehicles, NC DOT 

35 2,2144 32 to 35 

Oregon 

Automated Reporting System (ARS) 

♦ Any Oregon 

employer (public or private sector) that obtains permission from employees who drive as part of their employment for their employer 

None Oregon DMV 671, 

including both CDL employers and nonCDL employers 

20,404 Over 

400,000 

About 500 (both CDL aCDL drivers 

2Master account holder – service provider to motor carrier industry. 3Based on May 2002 through May 2003 data. 4Pilot project includes CDL and non-commercial drivers. 
State Program Name Why Program Was Started Who Participates Mandatory Participants Who Provides Service Number of Customers CDLs Covered Total CDLs in State Aver

Notific

Per M

Oregon 

to monitor their driving records 

♦ This is a voluntary 

program for all participants 

Virginia 

 Legislative 

mandate 

♦ Public school bus 

operators 

♦ Mass transit 

companies 

♦ Private school bus 

and day care facilities 

♦ Commercial and 

private businesses (driver education instructors, motor carrier industry) 

♦ Governmental 

entities 

School bus operators and driving instructors 

DMV 1,466 800 

Wisconsin 

Employer Notification Program 

Legislative mandate 

 School bus 

operators and driving instructors 

DMV 1,055 

employers 

70,054 250,000 
8 

State DVN Program Operational Components 

The operational components of a state DVN program are summarized in the following subsections. 

Enrollment 

An employer enrolls with a state or a vendor, and provides the license numbers of all employees and drivers to be 

included in the program. States require that employers obtain a signed waiver from each enrolled employee to permit 

employers to receive driver history records. Most states provide employers with DHRs at the time of enrollment. 

Driver History Monitoring 

The DMV updates DHRs as conviction information is received from the judiciary. Information from a state’s judiciary 

is provided both electronically and in hard copy. For states receiving information electronically, DHRs are updated 

within 24 hours. For states receiving information in hard copy, the process takes several days to a week, although 

priority is given to updating CDL DHRs. 

Notification 

When a change in a DHR is identified, notice is provided as follows: 

♦ The DMV legacy system generates a notice of change in history or a complete DHR. The document 

generated is then printed in hard copy and mailed to the employer or sent electronically to an employer. 

♦ Third-party vendors, who monitor DHRs on behalf of employers, insurance companies, or other businesses, 

are generally notified electronically. These vendors then notify the employer. 

♦ If an employer receives a notice of a change in a DHR, the employer then has the option of obtaining a 

complete driver history for the employee/driver in question.

Account Updates 

Employers are responsible for notifying a state DMV or a third-party vendor regarding any changes in employee/ 

driver eligibility, including additions and deletions. If the account is not updated, most states or third parties will 

generate notices and bill an employer for those drivers/employees who may no longer be with the employer. 

Employers are generally provided with a periodic account statement (most commonly on an annual basis) that lists all 

drivers/employees included in the employer’s account. 

Flexible Enrollment 

♦ Electronic Enrollment: Web-based applications for small- and medium-sized employers and batch file 

processing application for large-scale end. 

♦ Paper Enrollment: Paper applications for smaller companies or companies with limited or no information 

technology capabilities, and walk-in, fax, or telephone enrollment using paper applications. 

Driver Tracking 

States assign each employer a unique identifier used to link individual drivers to a specific employer account. 

Employers are responsible for notifying DMVs regarding all driver additions and deletions. 

Annual Account Update 

States provide each program participant with an annual statement listing all drivers enrolled through a particular 

employer. Employers use this annual statement to update account records. 
9 

Account Audits 

Some states periodically audit program participants to ensure that the information provided to the DMV (both at the 

time of application and ongoing information) is accurate, and that the employer is complying with program 

requirements. 

Electronic Signature 

States using electronic enrollment capabilities enacted legislation authorizing electronic signatures. 

Signed Waivers Authorizing Driver History Pulls 

Employers are able to obtain a DHR as part of the employment screening process. However, states require that 

employers obtain a signed waiver from each individual driver for whom an employer wishes to monitor that driver’s 

history record. 

Periodic Invoicing 

States generally send an invoice to employers listing all account transactions over a specified period of time (e.g., 

monthly, quarterly). This helps employers match service charges with records received. The invoice also makes 

payment easier for employers by incorporating the service as a regular monthly obligation and the cost of doing 

business. 

Electronic Notification 

The notification method most preferred by employers is to receive an electronic notice for changes in a driver history 

record or to receive an electronic DHR copy. 

Outreach 

Several states have engaged in extensive outreach activities to promote their driver-monitoring programs. Some 

promotional activities include posting information on the Internet, participating in industry and association meetings to 

promote a driver-monitoring program, and mass mailings of printed material to potential customers. 

Task 2 – State Visits: Motor Carrier Industry 

Task 2 (b) of the Driver Violation Notification (DVN) Service Feasibility Study required that the DVN Study Team 

develop documentation regarding the motor carrier industry’s DVN user requirements. 

Data collection techniques supporting this task included focus groups, interviews, and a motor carrier survey. Data 

was collected in ten states currently using a DVN-type program. The DVN Study Team used the focus groups and 

interviews to obtain information on these existing programs and their effectiveness, to identify particular user 

requirements, and to identify lessons learned and best practices. Focus groups were conducted in Arkansas, 

California, New York, Oregon, Virginia, and Wisconsin. Telephone interviews were conducted with the state trucking 

associations in Michigan and Illinois, and an interview was conducted with the Nebraska state trucking association in 

person. The same data collection techniques were used to collect information in the four non-DVN states (Maryland, 

Kentucky, North Dakota, and Iowa) selected for the study, as well. 

Focus group participants were recruited through the each state’s trucking association. Focus group and interview 

guides for both DVN and non-DVN states were developed prior to state visits and/or interviews. Focus groups were 

conducted by two DVN Study Team members, with one member serving as facilitator and the other serving as scribe. 

The results of the focus groups and interviews were used to develop the survey instruments. Two surveys were 

developed: one for carriers in DVN states and one for carriers in non-DVN states. Surveys were distributed through 

the state motor carrier associations. 
10 

Study Findings 

Both DVN and non-DVN participants expressed support for a national DVN program. The motor carriers understand 

the importance of safe performance as a good business practice. The carriers’ understanding and practices related to 

safe performance are underscored by including certain safety criteria for hiring drivers and terms of employment. All 

participants indicated they pulled a motor vehicle record (MVR) at the time of hire and then at least once a year as 

Federally-mandated. A surprising number of carriers pulled additional MVRs more frequently, with the greatest 

frequency being quarterly. 

Approximately two-thirds of the carrier participants had formal safety policies in place, ranging from severe penalties 

for violations to less restrictive disciplinary actions. Following are examples of typical safety policies: 

♦ Termination would result from two moving violations in 1 year or three moving violations in 3 years. 

♦ A driver may be required to report a citation within 24 hours, or the next business day that the driver may be 

on the schedule. Some motor carriers assign a point value to violations, and after accumulating a certain 

number of points, the driver is terminated. 

DVN participants felt that the timeliness of the reports generated by their DVN programs had an impact on safety. 

Although not yet quantified, carriers do believe that participation in a DVN program allows them to learn about and 

respond to convicted violations much more quickly than is possible by receiving only the mandated annual MVR. 

Non-DVN participants were enthusiastic about the potential to decrease liability, while at the same time increase their 

safety level by participating in a DVN program. Overall, the majority of carriers felt DVN programs represented a 

“win/win” proposition. 

Participants expressed concern that many drivers do not report either citations or convictions. The motor carriers have no 

way to identify any change in CDL status until the annual MVR pull. An additional concern is that drivers will report a citation 

or conviction, but the same event is not posted to the DHR in the state issuing the driver’s CDL. Thus, while the driver has 

submitted the report as required by law, the DHR is not updated, and an employer is unable to verify the driver’s report for an

infraction or conviction. 

User Requirements 

Specific user requirements were identified through the data collection process. 

DVN Program Structure 

Motor carriers expressed a preference for a national program with a centralized registration and notification system. Carriers 

indicated that a decentralized program requiring registration in multiple jurisdictions would be complex and would not attract 

industry members. 

Motor carriers also indicated a preference for a program that enabled them to register via the Internet, and that they preferred 

to receive e-mail notification to any type of paper notification. 

DVN Notice Content 

Motor carriers stated that they would prefer to receive a complete DHR rather than a notice stating that a DHR had changed 

and that the motor carrier needed to request a copy. The consensus was that receiving the information in one step rather 

than two or more steps would be more efficient and timely. 

Motor carriers also stated that they would like to obtain information on citations as well as on convictions. In addition, motor 

carriers stated that they would like to receive information such as address changes, CDL expiration, and positive drug tests. 

DVN Program Pricing and Payments 

Participants were comfortable with the price structures of the New York and California programs. These programs were 

structured around a $5 per driver fee and a $1 per notice generated fee. These programs do not have an employer 

enrollment fee. Motor carriers stated that $10 per driver or higher would be priced too high, and preferred to be invoiced for 

account activity each month. 
11 

Motor carriers stated that the preference was a program providing a standardized billing process, such as a monthly invoice, 

rather than a system that required payment for each individual transaction. There was also a stated preference for paying 

invoices electronically, through such venues as credit card or electronic funds transfer. 

DVN Program Participation 

A considerable number of participants would prefer that a national program be mandatory to create a level playing field 

between all carriers. 

The motor carriers indicated that there should be some type of incentive for enrollment in a DVN program. Incentives 

suggested included exempting an employer from having to do an annual MVR, possible premium reductions or a slowed rate 

of increase from insurance providers, or factoring program participation into a carrier’s safety rating. 

Motor carriers widely agreed that a nationwide DVN program would require a significant outreach effort to educate carriers 

and promote participation. 

Data Integrity 

Motor carriers expressed concern about data accuracy, specifically that DHRs provided by states might contain errors. The 

motor carriers want to ensure that a process is established to enable them to correct inaccurate information. 

Additional concerns were expressed by the motor carriers regarding who has access to what data, and how that data will be 

used. The motor carriers want to ensure that data is not incorrectly used or that proprietary data about a company and its 

drivers is not made available to competitors. 

Task 3 – Cost/Benefit Analysis 

The Cost/Benefit Analysis detailed in the Task 3 Technical Memorandum was focused on determining the economic 

feasibility of expanding DVN programs on a nationwide basis. Task 3 draws upon results of previous tasks: 

♦ The convictions notification processes, costs, and issues documented in the Task 1 report;5 and the motor 

carrier user requirements for a DVN system; 

♦ Their perceptions of effectiveness of current DVN and other state or third-party-based notification systems; 

♦ Their standard safety management practices in dealing with employee convictions; and 

♦ Their willingness to pay for notification of driver performance documented in the Task 2 report.6 

The results from these two tasks provide valuable insights into current and desired DVN program capabilities, a 

baseline estimate of DVN program costs, an assessment of potential use of DVN notifications to enhance motor 

carrier safety programs, and a sense of what motor carriers and other DVN customers might reasonably expect to 

pay for timely driver conviction notification. 

Available costs and benefits data for DVN programs are mostly estimated and anecdotal, often lacking insight into specific 

DVN program costs.7 Motor carriers’ perceptions of benefits are derived primarily from focus group and individual company 

interviews and are not intended to represent views of the entire motor carrier population. Nonetheless, these interviews and 

 

5DVN-States and Non-DVN States, Task 1 Technical Memoranda Deliverables, “State DVN Processes and Best Practices;” and 

“Volume 2 – State Visit Case Studies.” DRAFT January 2003, SAIC. 

6DVN-States and Non-DVN States, Task 2 Technical Memorandum Deliverable, “Documentation of User Requirements for 

Driver Violation Notification Programs.” DRAFT January 2003, SAIC. 

7Task 1 described the difficulty most state agencies have in breaking out DVN-specific costs from the costs for overall program or 

departmental activities. 
12 

focus groups help frame the key issues for analysis of economic feasibility and identify potential deployment models for a 

national DVN program. Safety benefits, however, are derived from analysis of driver convictions and accident data contained 

in national data systems. 

The benefit of a DVN program accrues during the 12 months following a driver’s conviction. Results from Task 2 indicate that 

some portion of drivers report their violations (prior to conviction) to employers; other drivers report their convictions within the 

30 days required by law. Together, this may account for between 50 and 80 percent of all convictions posted to DHRs being 

reported within 30 days of the conviction. 

Employers learn of other convictions over the succeeding year during the required annual driver history review. The DVN 

“benefits window” is defined as the time between posting a conviction to a driver history and the time the employer learns of 

the conviction. This window specifically refers to the time after convictions are posted to DHRs, during which employers are 

typically unaware of the conviction, and less likely to take action to remove unsafe drivers from the road or to take other 

action to modify unsafe driving behavior. 

The hypothesis for this analysis is that if conviction history is related to the likelihood of a crash, then eliminating or reducing 

the timeframe of the DVN “benefits window” will result in fewer crashes and associated injuries and fatalities. A DVN program 

can reduce the timeframe during which an employer is notified, which then reduces public exposure to poor driver behavior. 

This difference in notification time, combined with the differential in crash risk for drivers with convictions, can result in 

reduced crashes, injuries, and fatalities, as noted in Figure 4. 

Crash Risk Exposure 

Differential

Benefits in 

Terms of 

Reduced 

Number 

and 

Severity of 

Crashes

Benefits in 

Terms of 

Reduced 

Number 

and 

Severity of 

Crashes

Crash Risk Exposure 

Differential

Benefits in 

Terms of 

Reduced 

Number 

and 

Severity of 

Crashes

Benefits in 

Terms of 

Reduced 

Number 

and 

Severity of 

Crashes

Current Average Time For Notification 

Based on Motor Carrier Frequency of 

DHR Pulls, Driver Self-Reporting

Current or Expected Time For DVN 

Notification of Carriers

Delta Notification 

Time 

Current Average Time For Notification 

Based on Motor Carrier Frequency of 

DHR Pulls, Driver Self-Reporting

Current or Expected Time For DVN 

Notification of Carriers

Delta Notification 

Time 

Conviction v. Crash Analysis Crash Risk over 

12 Month Horizon

Figure 4. Overview of Benefit Assessment Approach 

The cost assessment approach shown in Figure 5 examines costs from both public and private sector perspectives. This 

approach is derived by drawing on information from existing state DVN programs and national programs similar in scope to 

estimate design and implementation costs for a national DVN program. Assuming pricing would reflect program cost, these 

cost estimates are used to develop a ratio of cost per conviction notification for comparison with overall benefit per conviction 

notification. 

Public Sector Costs Private Sector Costs

Operational Costs

♦System Design

♦System Implementation

♦Ongoing Operational Costs

♦“Full Deployment” Expansion 

Costs

♦Third Party Arrangements and 

Costs

Operational Costs

♦System Design

♦System Implementation

♦Ongoing Operational Costs

♦“Full Deployment” Expansion 

Costs

♦Third Party Arrangements and 

Costs

Non-DVN Carrier Costs

♦Annual DHR Pull Cost 

per Driver

♦Off-Annual DHR Pull 

Cost per Driver

Non-DVN Carrier Costs

♦Annual DHR Pull Cost 

per Driver

♦Off-Annual DHR Pull 

Cost per Driver

DVN Carrier Costs

♦Annual DHR Pull Cost 

per Driver

♦Off-Annual DHR Pull 

Cost per Driver

♦DVN Costs per Year or 

per Notice

DVN Carrier Costs

♦Annual DHR Pull Cost 

per Driver

♦Off-Annual DHR Pull 

Cost per Driver

♦DVN Costs per Year or 

per Notice

Non-DVN Carrier Costs

♦Annual DHR Pull Cost 

per Driver

♦Off-Annual DHR Pull 

Cost per Driver

Non-DVN Carrier Costs

♦Annual DHR Pull Cost 

per Driver

♦Off-Annual DHR Pull 

Cost per Driver

DVN Carrier Costs

♦Annual DHR Pull Cost 

per Driver

♦Off-Annual DHR Pull 

Cost per Driver

♦DVN Costs per Year or 

per Notice

DVN Carrier Costs

♦Annual DHR Pull Cost 

per Driver

♦Off-Annual DHR Pull 

Cost per Driver

♦DVN Costs per Year or 

per Notice

Figure 5. Overview of Cost Assessment Approach 

Two analyses were conducted for this research effort. The first analysis used data from national commercial vehicle and CDL 

databases to assess the relationship between previous serious convictions or crash involvement for two sets of drivers 

involved in fatal crashes. The two sets were defined as drivers with a conviction or involvement in a crash within 1 year of the 
13 

fatal crash, and those in which the most recent conviction or involvement in a crash was more than 1 year prior to 

involvement in the fatal crash. 

This analysis confirms the hypothesis that poor driving behavior as demonstrated by prior convictions and involvement in 

crashes increase the risks of involvement in future crashes. This result was obtained by examining 14,491 fatal 

accidents reported in the Fatal Accident Reporting System (FARS) for the calendar years 2000 through 2002. The analysis 

examined the occurrence of previous serious driver convictions or crashes for incidents involving two driver populations: 

those with a crash or serious driving conviction within 1 year prior to involvement in a fatal crash and those without a crash or 

serious driving within 1 year of their involvement in a fatal crash. The analysis further established potential risk factors for the 

assumed maximum exposure window of 12 months, the maximum time period between a motor carrier’s annual driver 

record pull as required by regulation. 

This analysis shows that among drivers involved in fatal crashes, those with convictions, suspensions, or crashes within the 

12 months prior to the fatal crash had overall driving records that were significantly worse than the drivers with no 

convictions, suspensions, or crashes within the prior 12 months. The results of this analysis are shown in Table 2. 

Table 2. Driver History Versus Last Crash, Suspension, or Conviction 

Last Crash, 

Suspension, 

Convictions within 1 

Year of Fatal Crash 

Observations Previous DWI 

Convictions 

Previous Other

Harmful MV 

Convictions 

Previous 

Recorded 

Accidents 

Previous 

Recorded 

Speeding 

Convictions 

Previous 

Recorded 

Suspensions & 

Revocations 

Yes 5,007 (35%) 3.5% 49.2% 34.0% 54.1% 15.8% 

No 9,484 (65%) 0.5% 9.6% 8.3% 11.3% 3.1% 

Ratio 6.7 5.1 4.1 4.8 5.2 

The second analysis conducted also used data from national CMV and CDL databases and is the key analysis used to 

define DVN benefits. This analysis examined relationships between prior conviction severity and severity of subsequent 

crashes; between crash risk given a conviction within 1 year of a crash event versus crash risk when there were no 

convictions during the year prior to the crash; and the distribution of crash events over a 12-month period following the last 

conviction prior to a crash occurrence. The analysis specifically defined the risk differential of crash involvement 

within the previously described “DVN Benefits Window.” 

This analysis focused on identifying the difference in crash risk between drivers with no convictions in the prior 12 months 

and those having had a crash within 12 months of the most recent conviction. This analysis also examined the distribution of 

crashes over the 12 months subsequent to a conviction to define where in the DVN Benefits Window crashes occur. Further 

examination identified the relationship between the severity of convictions and the severity of subsequent crashes to assess 

relative crash risk based on severity of conviction. 

The data sources used for this analysis included Motor Carrier Management Information System (MCMIS) driver and crash 

data, and the Commercial Drivers License Information System (CDLIS) conviction data. Records for a total of 129,306 

drivers were examined for the time period of April 1, 2000 through May 31, 2003, and the analysis assumed that these 

drivers have been in the driver population throughout the analysis period. 

Data for the entire sample of 129,306 drivers used in this analysis were examined for convictions occurring between April 

2001 and March 2002 and 1 year of crashes, April 2002 to March 2003. This analysis shows a relationship between 

convictions and the likelihood that a driver experiences a crash during the subsequent 12 months. For those drivers with no 

convictions between April 2001 and March 2002, 2.17 percent had one or more crashes. For those drivers who had one or 

more convictions, 2.99 percent had one or more crashes, indicating that drivers with convictions have crashes at a rate that 

is about 37 percent higher than those without convictions. These results are statistically significant at the .0001 level. 

To confirm these results, this same analysis was completed with the 129,306 drivers, using the 1-year period of convictions 

from April 2000 to March 2001 and the 1-year period of crashes from April 2001 to March 2002. Again, the analysis shows a 

relationship between convictions and the likelihood that a driver experiences a crash during the subsequent 12 months. For 
14 

those drivers without a conviction between April 2000 and March 2001, 1.86 percent had one or more crashes. For those 

drivers who had one or more convictions, 2.80 percent had one or more crashes, at a rate 50 percent higher than drivers 

without convictions. These results are also significant at the .0001 level. The overall lower conviction and crash rates in this 

earlier data may reflect the fact that some of the 129,306 drivers identified in the April 2003 data may not have been active 

drivers during the April 2000 to March 2002 period of this earlier analysis. 

This analysis validates the relationship between a conviction and the likelihood that a driver is involved in one or more 

crashes in the 12 months subsequent to the conviction. The analysis showed that the fraction of drivers having one or more 

crashes within the 12-month period following a conviction is 0.029859. The same fraction for drivers with no convictions in 

the previous 12 months is 0.021745. The difference in these two fractions is 0.008114. This 0.008114 difference in crash 

likelihood within a 12-month period bounds the potential benefit of a DVN program compared to an annual driver record pull 

and the current state of intervention effectiveness by all motor carriers employing drivers in the sample size. This factor, 

multiplied by the number of convictions nationally, represents the maximum potential DVN benefits, in terms of reducing the 

number of drivers involved in crashes. 

CMV facts defined on the FMCSA website note that there are between 3.0 million and 3.3 million employed CDL drivers in 

the United States.8 If the likelihood of a conviction for these drivers is comparable to that found for the 129,306 drivers used 

in the analysis described above (0.280505 for drivers in the April 2001 to March 2002 period), the upper limit on crashes 

avoided can be estimated as follows: 

3.0 million drivers ± 0.280505 = 841,515 drivers with convictions per year for all employed CDL drivers.9

841,515 drivers with convictions ± 0.008114 crash likelihood differential for drivers with convictions = 6,828 fewer 

drivers with crashes/year 

Assuming that these drivers would have had at most one crash in the 12-month period following a conviction, the associated 

reduction in loss of life and injuries can be estimated using findings from previous studies. An analysis of 5 years of large 

truck crash data (1996 through 2000) available from the Volpe Center shows that on average: 

1.1 percent of crashes were fatal crashes with 1.17 persons killed per crash. 

22 percent of crashes were injury-related with 1.46 persons injured per crash. 

Applying these factors to the baseline for total crashes avoided based on total drivers with convictions translates to 

approximately 88 lives saved and 2,166 injuries avoided per year: 

 6,828 crashes avoided ± 1.1% fatalities ± 1.17 fatality/crash = 88 lives saved. 

 6,828 crashes avoided ± 22% crashes with injuries ± 1.46 injuries/crash = 2,193 injuries avoided. 

However, since this estimate is based on total employed commercial drivers, including those who may not actually operate 

commercial vehicles as their primary occupation, this is an upper limit on the maximum potential safety benefits. 

Based on the work of Zaloshnja, Miller, & Spicer for FMCSA in 2000,10 the average cost of large truck crashes was 

estimated at: $3,419,202 for fatal crashes; $217,000 for injury-related crashes; and $11,300 for property-damage only 

crashes (in 1999 dollars). Using the Consumer Price Index to inflate these crash costs to 2004 dollars, the estimated costs of 

large truck crashes are: 

♦ Fatal $3,800,700 per crash with one or more fatalities 

 

8Accessed from: http://www.fmcsa.dot.gov/factsfigs/cmvfacts.htm. 

9According to some estimates, about half of all convictions are in-state convictions and only about half of out-of-state convictions 

are actually reported to the issuing state. If this is the case, and approximately 215,000 out-of-state convictions are reported 

through CDLIS each year, the estimated total convictions of 841,515 per year is consistent with these estimates. See Appendix B

for a review of an analysis of reporting out-of-state convictions via CDLIS. 

10From: “Cost of Large-Truck and Bus-Involved Crashes, Final Report”, for Federal Motor Carrier Safety Administration, 

Zaloshnja, Miller, & Spicer, 2000. 
15 

♦ Injury-Related $241,300 per crash with one or more injuries 

♦ Property-damage-only $12,560 per crash with property damage only 

Given the finding that the presence of a conviction does not significantly impact the severity of the crash, the following benefit 

calculation is used: 

Total Baseline Benefit 

 = value of fatalities avoided + value of injuries avoided + value of property damage avoided 

 Upper limit on benefit 

= (6,828 crashes avoided) ± [(1.1% fatals x $3,800,700/fatal crash) + (22% injury-related x $241,300/injury crash) + 

 (76.9% property-damage-only ± $12,560/property damage crash)] 

 = $714 million per year, or approximately $848 in avoided crash costs per conviction notification 

 ($714 million/841,515 convictions). 

The DVN Study Team recognizes that the statistical relationships and differential probabilities for crash occurrence are 

derived from a large sample of drivers and their motor carrier employers that represent the status quo for an important 

segment of the motor carrier industry. These statistical relationships are recognized in terms of current levels and timeliness

of notification and levels of effectiveness of remedial safety management actions. 

This notwithstanding, baseline benefits may not be realized because some motor carriers already learn of convictions shortly 

after they occur. Task 2 findings suggest that 50 to 80 percent of motor carriers receive voluntary notification of convictions

and changes in CDL status within at least 1 month of occurrence.11 This leaves the possibility of eliminating the 30-day delay 

for many motor carriers and, for other motor carriers, the additional 11-month window during which an annual driver record 

pull reveals a previously undiscovered conviction. Assuming the annual driver history reviews are uniformly distributed over 

the 12-month period following a conviction, the expected time between conviction and the employer’s review of the driver 

history is about 6 months, with the likelihood of the employer learning of the conviction increasing linearly with each month 

(see Figure 1 for the DVN Benefits Window). The proportion of the area in Figure 1 that falls in the DVN Benefits Window is a 

reasonable discount factor to be applied to the baseline benefit to account for the fact that 50 to 80 percent of motor carriers 

learn of convictions within 30 days of the conviction. Using this approach, if motor carriers learn of 50 percent of the 

convictions within 30 days, the DVN Benefit Window is about 30 percent of the total area. If motor carriers learn of 80 

percent of all convictions within 30 days, the DVN Benefit Window is about 17 percent of the total area. 

Additionally, about two-thirds of the motor carriers providing information to this study have documented procedures for the 

remediation of poor driving behavior through the adoption of “best” driver management programs, which would enhance the 

overall effectiveness of a DVN program. However, the same could be said for the status quo. Therefore, this variable will be 

assumed to remain unchanged in this analysis. 

Assuming that the DVN program benefits are achieved through more timely notification and that motor carriers use the 

notification with 100 percent effectiveness, the overall improvement in effectiveness of a DVN-enhanced safety management 

program can be estimated based on the expected percentage of motor carriers that would learn of convictions earlier than 

they do now. 

Estimated realizable benefit 

= (Baseline Benefits) ± (discount factor for current conviction notification practices)

Using the baseline benefit of $835/conviction notice, the estimated realizable benefit is between $144 (reflecting a 17 

percent DVN Benefit Window) and $255 (reflecting a 30 percent DVN Benefit Window) per conviction notice 

provided to motor carriers. 

 

11Some motor carriers require reporting of violations as a condition of employment and are actually aware of the impending 

conviction before it actually occurs. 
16 

Using the estimated total annual convictions shown above of 841,515, a benefit range is calculated to fall between $121 

million (841,515 ± $144) and $214 million (814,515 ± $255) per year in avoided crash costs, with a midpoint estimate of 

$168 million per year, assuming motor carriers use this new information to correct driver behavior so that drivers with 

convictions are at no greater crash risk than the overall commercial driver population. Therefore, given current conviction 

notification practices, DVN benefits range from a minimum of $121 million to a maximum of $214 million per year in 

potential crash avoidance benefits. 

The same discount factors can be used to estimate the minimum lives saved and injuries avoided: 

Estimated number of lives saved 

= (Baseline lives saved) ± (discount factor for current conviction notification practice). 

Estimated number of injuries avoided 

= (Baseline injuries avoided) ± (discount factor for current conviction notification practices). 

This estimate for total crashes avoided based on total convictions translates to approximately 15 lives saved (88 lives 

saved ± 17%) and 373 injuries avoided (2,193 injuries avoided ± 17%) per year based on conservative estimates of 

the potential benefit. 

One component of DVN costs is the expense for developing or modifying information systems and the supporting personnel 

and other administrative costs to provide the capabilities for collecting conviction information. Other costs include assigning 

the convictions to drivers and their employers, and delivering conviction notification to authorized parties. All of these costs 

are first broken into system development and deployment expenses; then into the costs of ongoing operation and 

maintenance. 

As previously noted, the level of cost accounting across the DVN provider states is variable and often inadequate for the 

specific assigning of costs to a DVN program, which may fall under the systems development and operations budgets of 

several other broader agency activities. For a DVN state-by-state estimation of costs, it is assumed that the “loaded” 

notification charges for the service fully reflect all recapture of initial system investment plus ongoing operational costs. With 

this in mind, data was considered complete enough to develop fully loaded DVN provisioning costs for the states of Michigan, 

New York, and Virginia. 

These costs were developed using the DVN rate structures, numbers of participating companies and registered drivers, and 

levels of notifications issued by the states. Across these three states, the range of all-inclusive charges is $7.00 to $14.61 per 

notification. These charges are in addition to the costs associated with annual or sub-annual MVR pulls by carriers. It should 

be noted that these are representative of effectively pilot or relatively small deployments that are sub-optimized in terms of 

volume efficiencies. Even at these rates, given the level of conviction notifications observed through the CDLIS center and 

the minimum calculated potential benefits of more timely notification in terms of crashes avoided ($141 per notification), the 

following minimal benefit cost ratio is calculated: 

Benefit ($144/notification): Cost ($14.61/notification) = 9.9:1 benefits over costs could be achieved 

over current practices, through a nationally deployed DVN program. 

On a macro-level, the implementation of the system, known as DRIVerS, is intended to combine the functions of the CDLIS, 

the Problem Driver Pointer System (PDPS) and the Driver License Reciprocity System (DLR). It is anticipated that DRIVerS 

will be a distributed database system with a central pointer file like CDLIS and encompass more than 200 million records. It is

expected that this deployment will cost $7.8 million between the CDLIS central site and participating jurisdictions. Although 

encompassing many system improvements that could readily support a DVN process, experts suggest that this model for 

enhanced driver record management could be used as a potential maximum cost for the deployment of a national DVN 

capability. 

Using this figure, a baseline cost of DVN deployment, assuming a 10-year system life and assuming minimum potential 

DVN benefits in cost avoidance of crashes, the following payback period and benefit/cost ratios for DVN deployment is 

calculated: 

Minimum Benefit / Maximum Cost Scenario: $121 million benefits/year versus $78 million investment, 

with a payback period of less than 1 year. 
17 

Benefit/Cost Ratio = $121 million / $7.8 million per year = 15.6 

To date, neither state agencies nor motor carriers have measured DVN program benefits in a comprehensive manner. 

Stakeholders generally agree that more timely information on driver performance can reduce crash risk. For state licensing 

agencies, DVN programs are seen as an important information service to motor carriers. Motor carriers view more frequent 

review of driver records, whether through third-party service providers, carrier-initiated pulls with state licensing agencies, or 

enrollment in a state DVN as one of many tools in an overall effective safety management program. In this sense, DVN 

benefits increase when they are part of an overall systems approach to motor carrier safety management. 

Achievement of the benefits of a DVN program is defined by current operational constraints and stakeholder opinions 

regarding what the functionalities of the program should include and what the market (the motor carrier end users of a DVN 

program) will bear in terms of pricing and trade-offs compared to current programs. These are well documented in the Tasks 

1 and 2 deliverables. To summarize these concerns and recommendations, a DVN program must address: 

♦ Cost-Effectiveness: Motor carriers have voiced a pricing preference of annual costs of $5 per driver fixed fee 

and a transaction fee of $1 per notification. Additionally, 75 percent of motor carriers providing input to the 

study are in favor of replacing the requirement of an annual driver record pull in favor of DVN exceptionbased reporting. The remaining 25 percent of carriers providing their input would be willing to maintain the 

annual driver record pull, in addition to participation in a DVN program. 

♦ Timeliness: The benefits of a DVN program can only be fully realized through timely processing of “driverinvolved events” and delivery of notification of the event to employers. The information is time sensitive – for 

every day that an “at risk” driver operates, safety is compromised.

♦ Programmatic Effectiveness: To fully realize the potential benefits of a DVN program, issues relating to full 

posting of all changes in driver status and convictions need to be available to motor carrier employers. Well 

documented efforts are underway to improve intra- and inter-jurisdictional reporting of driver performance 

and CDL status. Opportunity exists to leverage these efforts in the development of a national DVN program. 

♦ Resource Constraints: The ability to develop and offer new motor carrier services is constrained by current 

levels of state funding, either through investment in the active pursuit of new information services or the 

potential loss of legacy services currently providing revenue for agencies. These issues need to be mapped 

to the goals and likely implementation scenarios for a DVN program to effectively manage change with a 

minimum amount of disruption to the status quo, while maximizing attainment of potential DVN-related 

benefits. 

Task 4 – Develop Alternate Approaches 

System Objective 

The objective of the CDL Employer Notification Service (ENS) established by the DVN Study Team, as derived from 

the findings of Tasks 1 through 3, is to enable the jurisdiction of record to provide accurate and timely information to 

authorized entities concerning pertinent changes in the CDL status and history of a driver. This objective statement 

serves as guidance for developing deployment alternatives and includes terms that must be understood consistently. 

Definitions 

♦ Jurisdiction of Record: The jurisdiction responsible for maintaining the driver history record. This is typically 

the jurisdiction’s motor vehicle agency.

♦ Information: Notification that a conviction or withdrawal has been posted or that a change in CDL status has 

occurred. 
18 

♦ Authorized Entity: The entity receiving the “notification” information must be authorized by the CDL holder to 

receive the information from the state agency. In the case of third parties (insurance companies, service 

bureaus), this may require both an employee and employer authorization. If no employer or extended 

contractual relationship exists (an owner/operator that works for multiple customers), the “entity” to be 

notified is the state agency with oversight responsibility for CDL driver performance. 

♦ Pertinent Changes: Changes in the CDL status that directly affect the legal right to operate a commercial 

vehicle or are directly related to driver performance (e.g., moving violations, crashes). 

♦ CDL Status: Licensed, Eligible, Not Eligible, Reported Deceased.

♦ CDL History: A chronological series of events and related information including convictions, accidents, 

withdrawals, previous CDL numbers, personal information, restrictions, endorsements, permits, CDL, and 

non-CDL license status. 

Functional Requirements 

The functional requirements for an ENS are derived from interviews conducted with DVN and non-DVN states and 

with motor carriers. All of the requirements identified in these interviews are mutually supportive and, in some cases, 

are contradictory. They are all listed here as a reference point for evaluating alternative designs. 

Jurisdictional Deployment Consideration 

The state DMVs and law enforcement agencies interviewed offered suggestions based on their own state’s 

experience with DVN program or based on how they felt their system could be improved. In non-DVN states, the 

suggestions are based on what they believe would be needed for an effective employer notification service. The 

primary requirements include: 

♦ Electronic (e.g., batch file or web-based) enrollment and changes to simplify administrative functions. 

♦ Flexibility based on employers’ Information Technology (IT) capabilities (e.g., paper-based enrollment and 

notification option) to permit broad participation in the program. 

♦ Electronic signatures for authentication and verification to ensure accuracy, authorized access, and 

confidentiality. 

♦ ”Positive” CDL tracking so that every CDL is associated with an authorized ‘entity’ to be notified. 

♦ Provide for annual (or periodic) account audit/update to detect unreported changes and assess system 

performance. 

♦ Provide for authorization for access to CDL driver history to protect driver privacy to the extent now provided 

under FMCSA regulations and state laws. 

♦ Provide for periodic billing and payment to avoid costly transaction-based invoicing (unless the transaction 

costs can be processed electronically and seamlessly). 

♦ Provide for electronic funds transfer to reduce administrative cost and ensure accuracy. 

♦ Use electronic notification of CDL convictions and CDL driver status changes to reduce time delays between 

conviction or status change events and employer notification. 

♦ Employ effective outreach/enrollment/marketing strategy so that the program is as comprehensive as 

possible. 

♦ Single point of entry for enrollment and update to reduce the number of interfaces for both state agencies 

and motor carriers. 
19 

♦ Tracking changes in employment so that drivers with high-risk driving behavior can be identified more 

easily. 

♦ Error resolution process to catch and correct errors to protect drivers and motor carriers from inaccuracies in 

the data. 

♦ Compatibility with legacy systems to facilitate implementation and operations. 

Motor Carrier Deployment Considerations 

Motor carriers also offered their perspectives on how an ENS should operate. Motor carriers, however, are not 

homogeneous and, as might be expected, did not all agree on every aspect of the service. Further, many of the 

motor carriers interviewed were regional carriers, and some operate in only a few states. These carriers may benefit 

less from a national program than would those entities that operate nationwide. The most important requirements that 

most carriers agreed upon include the need for: 

♦ Consistent standards for enrollment and notification data on a national basis for uniformity in reporting and 

administrative efficiency. 

♦ Timely notification (within 30 days of conviction) so that motor carriers can take appropriate action. 

♦ A single national “portal” for enrollment, update, and notification interactions so that carriers do not need to 

interact with every state DMV or licensing agency. 

♦ A price structure consistent with current notification system costs that reflect reasonable costs for deploying 

and operating the systems. 

♦ Flat fees per transaction or a monthly subscription fee that reflects the number of drivers enrolled and the 

level of activity associated with those drivers. 

♦ Notification delivery via email, fax, or, in some cases, U.S. Postal Service so that all motor carriers can 

participate regardless of the level of technology they employ. 

♦ Access to a complete DHR when a notification event occurs so that motor carriers can view recent 

convictions in the context of the driver’s total driving history and take action that reflects this more informed 

perspective. 

Work Breakdown Structure 

These functional requirements determine the basis functions that the ENS must provide. Figure 6 provides a Work 

Breakdown Structure (WBS) that shows how these functional requirements might be implemented in a national 

system. The individual functional elements depicted in Figure 6 are described in greater detail below. 

Deployment Alternatives 

The DVN Study Team considered several approaches for meeting the functional requirements described. The DVN 

Study Team sought to balance effectiveness with system complexity and ease of implementation when addressing 

the ENS system functional requirements. The options considered range from the ad hoc current jurisdiction-based 

approach, where each jurisdiction determines how best to notify employers, to a national system that provides a full 

driver history record each time an employer is notified. The operational concepts cut across two dimensions of scope 

and standardization. Scope refers to the size of the program: individual jurisdiction, multi-jurisdictional/regional, or 

national; control refers to the extent to which the notification system adheres to standards beyond that of a single 

jurisdiction. These approaches are summarized briefly below and illustrated graphically in sections that follow. 
20 

Figure 6. ENS Work Breakdown Structure 

Jurisdictional-Based Alternatives 

♦ As Is: Let each jurisdiction determine whether or not to offer an employer notification service, which 

employers to include, and how best to provide it. 

♦ Ad hoc: Through either regulation or incentives (or penalties), require or motivate jurisdictions to offer an 

ENS without specifying how it should be done. Specify how the program will be assessed for compliance 

purposes. 

♦ ENS Standards: Provide national standards to guide deployment and operation. Require each state to offer 

an ENS, but let each jurisdiction develop its own program. 

Multi-Jurisdictional Alternatives 

♦ Decentralized: Groups of jurisdictions agree to exchange enrollment and notification data via an agent that 

interacts with employers. Each jurisdiction continues to provide DHRs to employers upon request. 

♦ Centralized: Groups of jurisdictions provide CDL status and history information to a designated repository 

that interacts with employers directly so that individual jurisdictions do not have to deal directly with 

employers. 

Employer 

Notification Service

Account 

Maintenance Nottification Finance System Admininstration Outreach

Open New 

Account

Account 

Validation

Add Driver

Delete Driver

Reports

Withdrawal

Conviction

Close

Account

Change in 

CDL status

Billing

Accounts 

Payable

Electronic 

Funds 

Transfer

Authorization

Authentication

Education

Training

Tracking and 

Matching

Archived Data

Promotion

Error 

Correction

Error 

Correction

Audit and

Evaluation

Reporting 

Processes

Accuracy and 

Timeliness

Regulatory 

Compliance

Notification System 

Administration
21 

National System Alternatives12

♦ Decentralized: All jurisdictions exchange enrollment and notification data via an agent that interacts with 

employers. Each jurisdiction continues to provide DHRs to employers upon request. 

♦ Centralized: All jurisdictions provide CDL status and history information to a central repository that interacts 

with employers. 

Federal System Alternatives 

♦ Decentralized: All jurisdictions exchange enrollment and notification data via FMCSA or its agent, which 

interacts directly with employers. 

Recommended Approach – Employer Notification Service National Pointer System 

In assessing the alternative approaches for the deployment of an expanded ENS system, the DVN Study Team used 

the following criteria. The intent was to identify the alternative that best meets the national need for improved safety 

in what the DVN Study Team determined to be the most cost-effective manner, and had the most support from the 

states included in the study. 

♦ Would the proposed system be: 

• Compatible with current jurisdictional systems? 

• A burden on jurisdictions to deploy and participate? 

♦ What are the institutional requirements (legal, administrative, etc.)? 

♦ Which approach is the most responsive to motor carrier needs and preferences (timeliness, accuracy, 

accessibility)? 

♦ Which proposed alternative has: 

• Consistency across jurisdictions and motor carriers? 

• Flexibility to accommodate different users (manual, electronic)? 

• Greatest ease of maintaining accurate employer/employee linkages (adding, deleting, updating)? 

♦ What content should be included in notification? 

♦ What is the required authorization/authentication capability? 

♦ Which alternative offers the greatest degree of accountability for “orphan” CDLs (those not associated with 

an employer or employers)? 

♦ How would the system interface with existing third-party services? 

♦ What are the requirements for access to supporting technologies (hardware, software, communications)? 

The DVN Study Team determined that a decentralized ENS national pointer system represents the best alternative to 

meet these criteria. While the proposed system does have some disadvantages, the DVN Study Team recommends 

this approach as the most effective for the development and deployment of a national ENS system. The advantages 

and disadvantages of the proposed alternative ENS national pointer system are summarized as follows: 

 

12The “national” alternatives might well be extended internationally to include Canadian and Mexican drivers should those nations

choose to participate in a larger ENS program. 
22 

Advantages 

♦ Minimum impact on state DMVs systems and procedures. 

♦ Minimum impact on state DHR revenue generation. 

♦ Avoids many privacy issues that may require legislation. 

♦ Provides single interface for both employers and state DMVs. 

♦ Can accommodate multiple interfaces (electronic, paper, fax, etc.). 

♦ Could be integrated with other national systems (CDLIS). 

Disadvantages 

♦ Does not provide full DHR; employers or agents would still request DHR from state DMV. 

♦ Notification information alone may be inadequate for employers to take further action. 

♦ Does not provide standard DHR format, definitions, and content. 

♦ Depends on timely response from state DMVs to provide DHR to employers. 

Process Flow 

A proposed conceptual design for the ENS national pointer system is presented in Figure 7 and Figure 8. The first 

figure presents the conceptual design for employer registration. The second presents the conceptual design for 

employer notification. 

Employer Registration (see Figure 7) 

♦ Employer establishes Notification Account: 

• With National Pointer System or with Agent or Designated Third Party which establishes account with 

National Pointer System. 

• CDL information submitted by employer: 

― Employees to be monitored by CDL number. 

― Jurisdiction issuing CDLs to employees in program. 

• Graphic includes three boxes that represent DMVs, but no information is sent to the state in order to set 

up accounts with the National Pointer System 

Employer Notification (see Figure 8) 

♦ DMV in jurisdiction issuing CDL receives information: 

• Judiciary for in-state convictions posted. 

• CDLIS for out-of-state convictions posted. 

― Jurisdiction of Record mails conviction information to the DMV state. 

♦ Driver history for CDL holder is updated at the DMV. 

♦ DMV generates the CDL change notice with information if history change includes: 

• CDL withdrawal. 

• CDL conviction. 
23 

• Change in CDL status. 

♦ Notice is sent to National Pointer System. 

♦ National Pointer System directs the notice that the driver’s record has changed to: 

• Employer. 

• Agent/designated third party who provides notice to employer. 

♦ Driver History Request submitted by Employer or Agent to DMV that issued CDL. 

♦ DMV generates driver history record and sends to requesting employer or agent. 
Figure 7. Primary Conceptual Design – Employer Registration 

DMV State 1 DMV State 2 DMV State 3 

ENS 

National 

Pointer 

Employer 1 

Agent – 

Designated 

Third Party 

Employer 2 

Driver 

Information 

Driver 

Information 

Driver 

Information 

Driver 

Information 

Driver 

Information 
Figure 8. Preliminary Conceptual Design – Employer Notification Process 

ENS 

National 

Pointer 

DMV State 1 

DMV State 2 

DMV State 3 

CDL Change 

Notice 

Employer 1 

Agent – 

Designated 

Third Party 

Employer 2 

Employer 

Notification 

Driver History 

Request 

Driver 

History 

Employer 

Notification 

Employer 

Notification 

CDL Change 

Notice 

Driver History 

Request 

Driver 

History 
26

Task 5 – Recommended Deployment Approach 

Task Overview 

The recommended deployment approach presented in the Task 5 Technical Memorandum was developed using the 

findings of the preceding four tasks of the study, in particular, the preferences stated by government and industry 

stakeholders as identified through Tasks 1 and 2. The development of the particular deployment approach was done 

using the following criteria: 

♦ Is the approach acceptable to state agencies, motor carriers, and commercial vehicle drivers? 

♦ Are the expected deployment and operating costs to states and motor carriers prohibitive? 

♦ What is the availability of existing infrastructure to support deployment? 

♦ Does the proposed approach ensure that violation and conviction information is provided to motor carriers in 

a timely manner? 

♦ Does the proposed approach create the capability to quickly and carefully identify, isolate, and correct errors 

in CDL violation and conviction records based on primary sources (judicial records)? 

♦ Are the key issues that would limit or deter state and motor carrier participation adequately addressed by 

the proposed approach? 

♦ What would be anticipated participation rates and time needed to enroll motor carriers? 

The recommended deployment approach also takes into consideration the TEA-21 requirement that FMCSA conduct 

a pilot program that meets the objectives specified in Section 4022 of the legislation: 

(a) PILOT PROGRAM 

(1) IN GENERAL — The Secretary shall carry out a pilot program in cooperation with one or more States to 

improve upon the timely exchange of pertinent driver performance and safety records data to motor carriers. 

(2) PURPOSE — The purpose of the program shall be to 

(A) Determine to what extent driver performance records data, including relevant fines, penalties, 

and failures to appear for a hearing or trial, should be included as part of any information 

systems under the Department of Transportation’s oversight; 

(B) Assess the feasibility, costs, safety impact, pricing impact, and benefits of record exchanges; 

and 

(C) Assess methods for the efficient exchange of driver safety data available from existing State 

information systems and sources. 

(3) COMPLETION DATE — The pilot program shall end on the last day of the 18-month period beginning on 

the date of initiation of the pilot program. 

(b) RULEMAKING — After completion of the pilot program, the Secretary shall initiate, if appropriate, a rulemaking to 

revise the information system under section 31309 of title 49, United States Code, to take into account the results of 

the pilot program. 
27

Recommended Deployment Approach 

The driver violation notification program model that best matches the criteria discussed in the preceding section and 

that meets the requirements identified by states and the motor carrier industry is the National Pointer Employer 

Notification System. Key design features of this recommended approach include: 

♦ A nationwide system that would allow a DMV to post a notice of a change in a driver’s history record to the 

National Pointer System, which would in turn direct the notice to the driver’s employer. The notice would be 

posted for both in-state postings and postings received from out of state. 

♦ Public domain ownership of the system, with system operation done through either the Federal government 

(for example, FMCSA) or through an association representing public agencies involved in motor carrier 

regulation and/or credentialing (for example, AAMVA). 

♦ Jurisdictions maintaining control of their CDL data files and information and providing driver history 

information through the nationwide system. 

♦ A single portal for program registration with nationwide coverage. Motor carriers would register with the 

national program and would in turn receive driver violation notifications from all states. 

♦ Web-based, batch processing and/or manual processes to enable access to all motor carriers irrespective of 

size or technical capability access to program services. 

♦ A flexible approach that enables multiple business strategies to fund ongoing operation of the driver 

violation notification program. This reflects the different business models that have been used by states to 

provide existing DVN services (state funded program, vendor provided e-government program) and by 

motor carriers to access these services (direct registration, use of service bureaus and third-party vendors). 

Benefits of Conducting a Pilot Project 

While a national pointer system offers a viable approach for developing a nationwide DVN system, there are a 

number of issues identified during the study that will need to be addressed prior to the development of a national 

system. Given this, and the requirements of TEA-21 for a pilot project, the SAIC Team recommends the following for 

consideration as a deployment approach for a DVN program:

♦ The pilot program that addresses the requirements of TEA-21 should be implemented prior to a decision to 

implement a nationwide DVN program. 

♦ The pilot program would be used as a vehicle for testing and addressing implementation issues identified 

during Tasks 1 and 2, as summarized in Table 3. 

♦ The pilot program would also be used as a means to expand on data collected during the feasibility study 

and to fill in data gaps identified during the feasibility study, in particular cost data and cost/benefit analysis. 

♦ An evaluation would be conducted to assess the effectiveness of the pilot program in meeting the purposes 

stated in TEA-21. 

♦ The results of the pilot program would be used to develop: a system architecture and high-level design for a 

national program; a prototype system that has been field tested and can be used to develop a production 

level system; cost estimates for a national program; an implementation plan and schedule, and a proposed 

business model and organizational structure including recommendations on system ownership and system 

operation. 
28

Pilot Project Goals and Objectives 

A key component of the pilot project will be to establish goals and objectives against which actual performance can 

be measured. This will enable performance measures to be developed and the types and sources of data necessary 

for assessing performance to be identified. These goals and objectives must also accurately reflect the same as 

established by FMCSA for a DVN program and the TEA-21 requirements. The SAIC Team has developed a set of 

five pilot project goals and objectives that are designed to meet the FMCSA and TEA-21 requirements, as follows: 

Goal #1 – Identify the potential safety impact of DVN Program: 

1. Objective #1 – Assess changes in motor carrier safety management programs. 

2. Objective #2 – Assess changes in driver behavior. 

3. Objective #3 – Identify changes in motor carrier performance and/or safety rating before and after DVN 

program participation. 

4. Objective #4 – Identify changes in crash rates before and after project, differentiating between causation 

factors and severity of crashes. 

Goal #2 – Assess motor carrier demand for DVN services: 

1. Objective #5 – Assess motor carrier perceptions on need for service. 

2. Objective #6 – Identify factors that encourage a motor carrier to participate in the program: 

a. Type of information provided. 

b. Timeliness of information provided. 

c. Cost of service. 

d. Reliability of service. 

Goal #3 – Assess states’ perception of DVN services: 

1. Objective #7 – Determine how DVN can be used as a tool by enforcement community. 

2. Objective #8 – Assess potential fiscal impact of DVN program. 

3. Objective #9 – Assess how DVN services are integrated into ongoing state motor carrier services. 

4. Objective #10 – Assess states’ perception on safety impact. 

Goal #4 – Identify implementation issues that impact potential nationwide program deployment:

1. Objective #11 – Effectiveness of alternative business models. 

2. Objective #12 – Assess information systems and technology-related issues: 

a. Data exchange requirements within states and between states. 

b. Software modifications and/or development. 

Goal #5 – Develop a Working Prototype System 

1. Objective #13 – Develop software and interfaces necessary for supporting a prototype system. 

2. Objective #14 – Test the Prototype System with two or more states. 

3. Objective #15 – Test the Prototype System with inter- and intrastate motor carriers. 
29

Table 3. Implementation Issues 

Implementation Issues Pilot Project Test 

Issue #1 – Loss of MVR Pull Revenues. States are concerned 

about losing revenues from MVR programs if a DVN program is 

implemented and the annual MVR pull requirement is eliminated 

or phased back. The sale of MVRs represents a major revenue 

source for states. 

Currently, data on revenue generated from motor carrier 

driver history record sales is not disaggregated from 

overall records. The pilot project should develop an 

estimate of revenues generated by sales of these records 

to the motor carrier industry. The pilot project should also 

test pricing options for DVN services to determine the level 

of pricing required to achieve a full off-set of lost revenues 

should the annual pull requirement be eliminated. This 

analysis should also look at price sensitivity with respect to 

industry to determine what level of pricing potentially 

deters program participation. 

Issues #2 – Lack of Perceived Demand. The states do not 

perceive a strong need for this DVN program. Their rationale 

appears to be based on the fact that there is no strong demand 

from customers (industry or the enforcement community) for this 

service. 

As a component of the pilot project, a needs assessment 

should be conducted to determine potential industry 

demand for this service. In addition, a similar assessment 

should be conducted with law enforcement personnel to 

assess their views on how a DVN program would provide 

benefit or be integrated into their ongoing programs (i.e., 

include DVN participation as a factor in compliance 

reviews). 

Issue #3 – Need for a State DVN Champion. The agencies 

visited during the course of the study, while in support of safety 

and safe highways, are not charged with highway safety as their 

core mission or business. Establishing a DVN project is an 

additional technical/administrative requirement that does not have 

a direct impact on their core business. A successful national DVN 

program will need state champions who are able to obtain 

management support and the allocation of technical and financial 

resources to support program development and deployment. 

Pilot project states should be required to designate a lead 

agency responsible for overall DVN program management, 

establish a steering committee comprised of all 

stakeholder groups to oversee the pilot project, and 

establish a memorandum of understanding that establishes 

the role of each participating stakeholder. 

Issue #4 – Lack of State Resources. The states lack the funds 

and technical resources needed to implement a new program or 

significantly expand their existing programs. A number of states 

are facing budget cuts and layoffs and other projects (Patriot Act 

and HazMat endorsement) have received priority from 

management. Establishing a DVN is not a state priority. A concern 

expressed by the states was the need for federal funding to 

support a DVN program. 

The pilot project should include an assessment of what 

level of funding states would need in order to implement a 

DVN program. This assessment would take into account 

variations by state with respect to size, industry structure, 

and other variables that would impact costs. 

Issue #5 – Need for a National Program. The states would 

prefer to see a national system or database as the core of a DVN 

program. States do not want to have to build interfaces to 

exchange data directly with other jurisdictions, and believe that a 

national clearinghouse would enable states to keep their existing 

systems (in particular, for those states with a DVN/DVN-type 

program) while facilitating the exchange of data. A consideration 

for a national program, however, is that some states expressed 

concern about a “one-size-fits-all” approach. 

A component of the pilot project should be the 

development of design alternatives for a national program. 

The design alternatives would include assessments of 

types of data to be exchanged (notice or full driver history 

record), methods for data exchange, identification of 

authoritative sources for data, required standards, and 

other related system development issues. 
30

Implementation Issues Pilot Project Test 

Issue #6 – Linking Drivers with Companies. The most 

significant technical concern identified by the states was how to 

track drivers and link them to companies. Given the high rate of 

driver turnover, many states seem to feel that linking drivers to 

companies would be a difficult task. 

The pilot program would test alternative methods for 

tracking drivers and linking drivers with companies. 

Issue #7 – Small Companies and Owner-Operators. An 

additional concern along the same line was how this service would 

be provided to smaller trucking companies and owner-operators 

where the owner or owner-operators may be driving and not 

receive notice in a timely manner. In addition, how would the 

program work for companies that employ owner-operators – who 

would ultimately be responsible for registering the owner-operator, 

monitoring performance, and receiving notice? 

The pilot project would assess alternative means for 

providing DVN services to small companies and owneroperators. 

Issue #8 – Authoritative Data Source. Several states have 

indicated concern about having a third-party vendor serve as the 

authoritative source for data. The states prefer a model where the 

states or a national clearinghouse could serve as an authoritative 

source for data on changes in driver history. 

This issue should be included in the development of design 

alternatives for a potential national program. 

Issue #9 – Outreach. Several states have developed significant 

outreach and education programs in support of their programs. 

Those states that have not, either through the state or through a 

third party vendor, had significant success in enrolling motor 

carriers in their programs. 

The pilot program should provide outreach in three areas: 

♦ Education: Why ENS improves safety 

♦ Training: How ENS works 

♦ Promotion: Participation in employer state 

association meetings 

Proposed Pilot Project – State Participation 

The SAIC Team recommends that FMCSA consider including both states with an existing DVN program and nonDVN program states in the pilot project. The SAIC Team further recommends that FMCSA consider the following in 

identifying states with existing programs to participate in the pilot study:

♦ The DVN states included in the feasibility study have used several different business models for 

implementing DVN services, including state-developed systems (such as Virginia and New York) and 

vendor-developed systems (Arkansas and Nebraska using NIC). The pilot project could, therefore, be used 

both to test the effectiveness of DVN programs and the use of different business models for providing 

program services. 

♦ Baseline data has already been collected from each of these states, and existing DVN program activities 

have been documented. 

♦ The state motor truck associations participated in the feasibility study through the Task 2 focus groups and 

surveys. This prior experience can be used to help gain industry support for the pilot project. 

♦ These states are familiar with the feasibility study and employer notification programs and would thus not 

require significant time to plan and prepare for participation in a pilot project. 

In identifying potential non-DVN states, the SAIC Team recommends that FMCSA consider: 

♦ Geographic Location: States that are in the same geographic location as DVN states. This will enable the 

pilot test to identify data exchange capabilities between states that are along existing truck routes. 
31

♦ Industry Mix: Selecting states that have a representative mix of trucking industry operations by type of 

carrier and intra- as well as inter-state will enable the testing of a wide range of technical issues (enrollment 

processes, linking drivers to motor carriers, accessibility to smaller motor carriers as well as owneroperators). 

♦ Involvement of State Trucking Associations: Based on the success of industry involvement in Phase I, 

including state trucking associations in the pilot test will help with testing industry outreach, recruitment of 

pilot test participants, and evaluating the effectiveness of the pilot test. 

Proposed Pilot Project – Stakeholder Groups 

In addition to the participating states, the DVN Study Team recommends that AAMVA, ATRI, and CVSA continue as 

partners during the Pilot Project. As is noted in the Task 1 Technical Memorandum, DVN programs at present are run 

by motor vehicle agencies whose core business is the licensing and registration of drivers and vehicles, not safety 

enforcement. CVSA’s participation will provide a venue whereby the enforcement community can be involved in the 

pilot project. In addition, CVSA will be able to provide the national perspective needed to determine the potential of a 

national DVN program. As was done with Task 2 of the feasibility study and ATRI, CVSA would be able to conduct a 

national survey of enforcement personnel to determine their views on how a DVN program could be of benefit. 

AAMVA would lead the development of design alternatives for a national DVN program. This would include the 

assessment of funding needs and authoritative data sources and recommendation of an organizational structure for 

supporting a national program. 

As with the feasibility study, ATRI will assist with coordinating industry outreach and data collection. In particular, 

ATRI would lead the assessments of linking motor carriers and drivers, and how small companies and owneroperators can participate in a DVN program. To this end, ATRI would establish relationships with the state trucking 

associations in participating states to assist with testing industry outreach methods – informational mailings, 

presentations at association meetings, and association membership access to DVN information in order to evaluate 

motor carrier views on the value of a DVN program. 

FMCSA will serve as the sponsor for the pilot project and will be responsible for overall management and direction of 

the project, and will work directly with participating states. AAMVA, CVSA, ATRI, and the state motor carrier 

associations will support the pilot project activities under the general direction of FMCSA. 
32

Appendix 1 – Project Deliverables 

Note: The following project deliverables are provided under a separate cover. 

♦ Task 1 Deliverable: Technical Memorandum – State DVN Processes and Best Practices 

♦ Task 2 Deliverable: Technical Memorandum – Documentation of User Requirements for 

Driver Violation Notification Programs 

♦ Task 3 Deliverable: Technical Memorandum – DVN Cost-Benefit Analysis 

♦ Task 4 Deliverable: Technical Memorandum – Alternative Approaches for the Deployment of 

Driver Violation Notification Programs (also available in briefing format)

♦ Task 5 Deliverable: Technical Memorandum – Recommended Deployment Approach and 

Work Plan for the Development of DVN Programs 

♦ Final Report Briefing to FMCSA Senior Management 
33

Appendix 2 – Driver Violation Notification Feasibility Study Acronym List 

Acronyms Titles 

AAMVA American Association of Motor Vehicle Administrators 

ATRI American Transportation Research Institute 

CDL Commercial Drivers License 

CDLIS Commercial Drivers License Information System 

CVSA Commercial Vehicle Safety Alliance 

DHR Driver History Record (same as MVR for purposes of this study) 

DMV Department of Motor Vehicles 

DRIVerS Driver Record Information Verification System 

DVN Driver Violation Notification 

ENS Employer Notification Service 

FMCSA Federal Motor Carrier Safety Administration 

MC Motor Carrier 

MVR Motor Vehicle Record (same as DHR for purposes of this study) 

SAIC Science Applications International Corporation 
Report No.FMCSA-RT-05-003 For more information on the Federal 

Motor Carrier Safety Administration, 

check our website at www.fmcsa.dot.gov