Motor Carrier Safety: Commercial Vehicle Registration Program Has Kept Unsafe Carriers from Operating, but Effectiveness Is Difficult to Measure
Published: 2009-05-12T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: To reduce the number of crashes involving commercial motor carriers, the Federal Motor Carrier Safety Administration (FMCSA) within the Department of Transportation orders unsafe carriers out of service. To help keep these carriers off the road, FMCSA's voluntary Performance and Registration Information Systems Management (PRISM) grant program, a small program funded at $5 million per year, helps states establish information systems connections between state vehicle registration and FMCSA's safety databases. These connections provide states with up-to-date information on carriers' safety status when carriers try to register or renew registrations with the state. For states to deny, suspend, or revoke registrations to out-of service carriers, states must pass legislation enabling them to do so. As directed by a congressional committee, GAO examined (1) PRISM's effectiveness and (2) the potential to fully implement the program nationally. GAO reviewed FMCSA data and discussed PRISM with a wide variety of federal, state, industry, and safety stakeholders
section_title: What GAO Found
paragraphs: Twenty-five states have implemented PRISM to the point where they are able to keep carriers that FMCSA has ordered out of service from obtaining or maintaining vehicle registrations. However, PRISM's safety impact is hard to measure. FMCSA data show that vehicles associated with 972 out-of-service carriers in 2008 had registrations denied, suspended, or revoked--about 15 percent of carriers placed out of service that year. However, this is likely an underestimate because the data can be difficult to track. Officials from the 13 states GAO contacted that are denying, suspending, or revoking vehicle registrations of out-of-service carriers and representatives from safety and industry associations said PRISM is worth the effort, but its impact on safety is hard to measure. An evaluation of the program sponsored by FMCSA in 2007 concluded that PRISM states show some improved safety over time compared with other states, indicating PRISM could have contributed to lower crash rates. However, because all FMCSA programs are aimed at reducing crash rates, isolating PRISM's effect is difficult. Nonetheless, the evaluation recommended that FMCSA adopt program measures to assess PRISM's effectiveness. FMCSA has not adopted all of these measures for various reasons, including a lack of resources. In GAO's view, applying such measures, while ultimately useful, may be premature since PRISM's success is undercut by the 25 states--including states with the greatest numbers of registered commercial motor vehicles--and the District of Columbia that do not yet have the ability to deny, suspend, or revoke vehicle registrations of out-of-service carriers. National implementation may not occur for years if PRISM continues as a voluntary program. FMCSA data show that, on average, it took states about 3 years and 4 months to get to the point where they could deny, suspend, or revoke registrations once they decided to implement PRISM--a process that took as little as 10 months to more than 7 years. Officials in states GAO contacted said that PRISM implementation was facilitated by such things as hiring a contractor to help with the program's technical components, and was hindered by such things as difficulty in passing state legislation needed to implement the program. According to officials in states GAO met with, FMCSA has been helpful in encouraging states to adopt and implement the program, but can do little in other areas, such as when state legislation is needed. Officials in some states and representatives from safety associations told GAO that Congress should require PRISM implementation so that no state becomes a refuge for registering out-of-service carriers. Other officials said that such a requirement is unnecessary, since only three states have not committed to implementing PRISM. While there are benefits to a congressional requirement that could lead to speedier national implementation, there are several significant potential drawbacks to doing so (for example, some states may require substantial money to adapt their information systems to make PRISM work) that lead GAO not to recommend such a requirement.

section_title: Letter
paragraphs: In the United States, commercial motor carriers account for fewer than 5  percent of all highway crashes, but these crashes result in about 13  percent of all highway deaths, or about 5,500 of the approximately 43,000  highway fatalities that occur nationwide each year. In an attempt to  reduce the number and severity of crashes involving large trucks and  buses, the Federal Motor Carrier Safety Administration (FMCSA) within  the Department of Transportation (DOT) identifies unsafe motor carriers  and takes them off the road by ordering them out of service. Carriers that  have been ordered out of service by FMCSA may not operate until their  safety performance improves and FMCSA rescinds the out-of-service  order.
The primary way that FMCSA ensures that carriers the agency has ordered  out of service do not continue to operate is the Performance and  Registration Information Systems Management (PRISM) grant program.  PRISM works by allocating grant money to states to establish information  systems connections between state commercial vehicle registration  databases and FMCSA’s safety databases that, when fully implemented, (1)  provides up-to-date information on the safety status of the carrier  responsible for the safety of a commercial vehicle prior to issuing or  renewing the vehicle registration and (2) generates a daily list of vehicles  registered in the state that are associated with carriers that have just been  ordered out of service by FMCSA. For new registrations or renewals, when  state personnel enter carrier and vehicle information into the system, it  automatically checks the information against FMCSA databases, and a  notice will appear to deny the registration if the carrier is out of service.  For vehicles already registered in the state, state personnel use the list the  state creates each night to suspend or revoke the vehicle registrations  associated with newly ordered out-of-service carriers. To implement  PRISM, states must pass enabling legislation, providing state registration  agencies (motor vehicle administrations) with the ability to deny, suspend,  or revoke vehicle registrations of carriers ordered out of service by  FMCSA.
PRISM’s innovation is that it associates vehicle identification numbers  with out-of-service carriers to prevent the carrier from registering or  reregistering its vehicles (either under the carrier’s original name or, more  importantly, disguised under a new name) until FMCSA lifts the out-of- service order. Once the out-of-service order is lifted, the carrier may  obtain valid vehicle registrations. Preventing unsafe motor carriers from  obtaining or maintaining vehicle registrations deters these carriers from  operating, since state law enforcement agencies continually check  commercial vehicles for valid registrations.
In the Intermodal Surface Transportation Efficiency Act of 1991, Congress  mandated the PRISM pilot demonstration project to evaluate the potential  benefits of using state commercial motor vehicle registration sanctions as  an incentive to improve motor carrier safety. Five states participated in the  pilot, which ended in 1997, and a final report assessing the program was  submitted to Congress in 1998. In 1998, Congress authorized additional  funding to implement the program nationwide. As of April 2009, 47 states  and the District of Columbia participate in it to some degree. Twenty-five  of these states have implemented PRISM to the extent that they can  automatically identify out-of-service carriers and then deny, suspend, or  revoke their vehicle registrations.
The Senate Committee on Appropriations directed that we assess (1) the  PRISM grant program’s effectiveness in removing unsafe motor carriers  from U.S. roadways and (2) the potential to fully implement the program  nationally.
To report on the extent to which the PRISM grants program has effectively  removed unsafe carriers from the roadway, we obtained FMCSA data on  the number of motor carriers that had vehicle registrations denied,  suspended, or revoked as a result of an FMCSA out-of-service order. We  interviewed FMCSA officials to discuss how data are collected and  verified and how the data are used to assess PRISM’s effectiveness. We  also conducted semistructured interviews with a nongeneralizable sample  of state motor vehicle administration officials and state law enforcement  officials from 13 states that deny, suspend, or revoke vehicle registrations  to discuss their experience implementing PRISM, how effective the  program has been, and the soundness of reported data. We obtained the  view of state officials and representatives from motor carrier industry and  safety associations on the extent to which PRISM has improved states’  ability to identify unsafe carriers and take them off the road by denying,  suspending, or revoking vehicle registrations and any factors that impact  PRISM’s effectiveness. We reviewed a 2007 Volpe National Transportation  Systems Center evaluation of the PRISM program that reported on the  extent to which PRISM has improved the safety and limitations of  FMCSA’s data on the denial, suspension, or revocation of vehicle  registrations of out-of-service carriers. We reviewed information from  interviews and the Volpe report to identify and describe the factors that  limit PRISM’s effectiveness.
To report on the potential to fully implement the program nationally, we  met with officials from FMCSA, state motor vehicle administrations, and  state law enforcement in 26 selected states, as well as representatives  from industry and safety associations. We conducted semistructured  interviews with state motor vehicle administrations from 13 states that  deny, suspend, or revoke vehicle registrations; 3 states that are  implementing PRISM but do not yet have the capability to affect vehicle  registrations; 8 states that have committed to implement PRISM but are  not far along in implementation; and 2 states that do not participate in  PRISM at all. We analyzed testimonial evidence to identify factors that  enabled states to deny, suspend, and revoke registrations and factors that  have delayed or prevented other states from moving forward with PRISM  implementation. We analyzed the information to identify the factors  FMCSA can affect and those it cannot. We also conducted a general  literature search to identify the conditions for when either a mandatory  approach or a voluntary approach is preferred for achieving program  participation and certain desired outcomes. In addition, we identified and  analyzed drawbacks to requiring state implementation of PRISM and  potential options available to Congress for encouraging—rather than  mandating—state legislative or regulatory action that could speed  nationwide PRISM implementation.
As part of our review, we assessed the reliability of FMCSA’s data on the  number of motor carriers that had vehicle registrations denied, suspended,  or revoked because of an FMCSA out-of-service order. While we identified  some shortcomings to the data (discussed later in this report), we  determined that the data were sufficiently reliable for our purpose, which  was to provide a general sense of the extent to which PRISM  implementation has resulted in vehicle registration sanctions. We  conducted this performance audit from June 2008 to May 2009 in  accordance with generally accepted government auditing standards. Those  standards require that we plan and perform the audit to obtain sufficient,  appropriate evidence to provide a reasonable basis for our findings and  conclusions based on our audit objectives. We believe that the evidence  obtained provides a reasonable basis for our findings and conclusions  based on our audit objectives. (See app. I for additional information on our  scope and methodology.)
subsections: section_title: Background
paragraphs: The interstate commercial motor carrier industry is large and dynamic.  According to FMCSA data, there are about 716,000 interstate carriers  registered with FMCSA to operate. While the largest motor carriers  operate upward of 50,000 vehicles, most carriers are small, with  approximately 80 percent operating between one and six vehicles.  Commercial motor vehicles travel over 222 billion miles each year over the  nation’s extensive road network.
FMCSA’s primary mission is to reduce the number and severity of crashes  involving large commercial trucks and buses involved in interstate  commerce. It carries out this mission by issuing, administering, and  enforcing federal motor carrier safety regulations and hazardous materials  regulations and gathering and analyzing data on motor carriers, drivers,  and vehicles, among other things. FMCSA also takes enforcement actions  itself and funds and oversees enforcement activities at the state level  through Motor Carrier Safety Assistance Program grants.
FMCSA ensures that motor carriers comply with safety regulations  primarily through compliance reviews of carriers already in the industry  and safety audits of carriers that have recently started operations.  Compliance reviews and safety audits help FMCSA determine whether  carriers are complying with its safety regulations and, if not, to take  enforcement action against them, including placing carriers out of  service. FMCSA makes its compliance determination based on a carrier’s  performance in six areas: one area is the carrier’s crash rate, and the other  five areas involve the carrier’s compliance with regulations, such as  insurance coverage, driver qualifications, and vehicle maintenance and  inspections. In addition, FMCSA places carriers out of service for failure to  pay civil penalties levied by FMCSA, failing a safety audit, and for failing to  schedule a safety audit. Out-of-service carriers must cease operations and  cannot resume operations until FMCSA determines that they have  corrected the conditions that rendered them out of service. If a carrier  fails to comply with or disregards an out-of-service order, FMCSA may  assess a civil monetary penalty each time the vehicle is operated in  violation of the order. In 2008, FMCSA ordered 6,707 carriers out of  service.
FMCSA and state law enforcement agencies are dwarfed by the size of the  industry and, as a result, are only able to conduct compliance reviews on a  very small percentage of carriers—about 18,400 in fiscal year 2008. Safety  audits are required for all new entrants to the trucking industry;  approximately 37,400 safety audits were conducted in fiscal year 2008. In  addition to compliance reviews and safety audits, FMCSA and state law  enforcement agencies conduct about 2.3 million vehicle inspections each  year at weigh stations and other locations to assess the safety compliance  of individual vehicles.
FMCSA and state law enforcement agencies use several methods to ensure  that carriers that have been ordered out of service do not continue to  operate. For example, FMCSA and its state partners monitor data on  roadside inspections, moving violations, and crashes to identify carriers  that may be violating an out-of-service order. FMCSA will visit some  suspect carriers that it identifies by monitoring crash and inspection data  to determine whether those carriers violated their orders. Also, recently,  the Commercial Vehicle Safety Alliance began to require checking for  carriers operating under an out-of-service order during roadside  inspections and to take enforcement action against any that are. However,  given the large size of the industry, the nation’s extensive road network,  and the relatively small size of federal and state enforcement staffs, it is  difficult to catch motor carriers that are violating out-of-service orders. In  addition, some carriers change their identities by changing their names  and obtaining new DOT numbers—which are generally referred to as  chameleon carriers—to avoid being caught.
FMCSA allocates PRISM grants to states to address the problems of out-of- service carriers registering or reregistering vehicles (when renewal is  needed), including chameleon carriers. PRISM grants enable states to  work through the registration protocol—known as the International  Registration Plan (IRP)—that state motor vehicle administrations use to  register vehicles of carriers involved in interstate commerce. In 2008, over  2 million vehicles had IRP (interstate) registrations. PRISM grants provide  the state motor vehicle administration where the vehicle is registered— called the “base state”—with the capability to check the safety status of  motor carriers, using the carrier’s DOT number and the vehicle  identification number, prior to issuing or renewing a carrier’s registration.
According to FMCSA, sanctioning the IRP (interstate) registrations of  commercial motor vehicles is a powerful enforcement tool in deterring  out-of-service carriers from operating on U.S. roadways. If the carrier or  vehicle is associated with an out-of-service order at the time of  registration, the state motor vehicle administration will deny the  registration of that carrier if the state has implemented PRISM to the point  where it can deny registrations to out-of-service carriers. In addition, state  motor vehicle administrations also suspend or revoke the registrations of  vehicles associated with out-of-service carriers, without waiting for the  carrier to attempt to reregister. States use various methods to inform a  carrier that its vehicle registrations have been suspended or revoked. For  example, some states notify the carrier via letter, and some states request  that the carrier return the vehicle license plates. Other states send motor  vehicle administration personnel or state law enforcement to the carrier’s  place of business to retrieve the license plates following a registration  suspension or revocation.
Another benefit of PRISM is that it helps prevent an out-of-service carrier  from registering in a state other than its base state in an attempt to avoid  having its registration denied. This works to the extent that the nonbase  state or states in which the carrier seeks to register participate in and have  fully implemented the PRISM program (that is, deny, suspend, or revoke  vehicle registrations to out-of-service carriers). As of April 2009, 25 states  have this capability. (See fig. 1.) Six other states are collecting vehicle  identification numbers and the DOT number of the carriers associated  with those vehicles and may be checking the safety status of the carrier at  the time of registration. Sixteen other states and the District of Columbia  have entered into an agreement with FMCSA to implement PRISM grants  but have not yet moved forward substantially to implement the program.  The remaining three states do not participate.
Within FMCSA’s 2008 budget (including grants) of about $530 million, the  PRISM grants program is very small. Under the Safe, Accountable,  Flexible, Efficient Transportation Equity Act: A Legacy for Users, PRISM is  authorized $5 million annually from fiscal years 2005 through 2009. These  amounts have been appropriated each year. FMCSA officials told us that  they annually allocate about $4 million to participating states in the form  of grants and $1 million for FMCSA program administration.
States use PRISM grant funds—approximately $500,000 per state—to  implement several requirements. For example, for registration  requirements, states create and maintain information technology  connections to FMCSA’s safety databases and the state’s IRP system to  collect and validate the DOT number of the carrier each vehicle is  associated with and to check the safety status of those carriers. States also  develop the programs necessary to load and retrieve data and correctly  process the information to its system. In addition, in order to capture the  DOT number and other carrier information on each vehicle record, states  will need to modify existing forms, screen formats, and information  storage. States also develop procedures to check the carrier safety status  on each registration or renewal and train staff on how to do such checks.  Although PRISM grants are intended to pay for the total costs to carry out  all program requirements, states contribute some funds for program  implementation.
FMCSA uses its PRISM funds for technical support for its databases, as  well as for travel costs. Although FMCSA did not use PRISM funds to  support PRISM program personnel’s travel in fiscal year 2008, FMCSA  officials told us that it has done so to date in fiscal year 2009 due to  general agency travel budget constraints associated with the fiscal year  2009 continuing resolution.
section_title: PRISM Has Helped Keep Unsafe Carriers from Registering, but Its Impact on Safety Is Hard to Measure
subsections: section_title: PRISM Has Enabled 25 States to Identify and Keep Unsafe Carriers from Obtaining or Maintaining Vehicle Registrations
paragraphs: FMCSA data show that PRISM has resulted in the denial, suspension, or  revocation of the commercial motor vehicle registrations of 972 carriers in  2008. According to FMCSA data, 671 unsafe motor carriers had vehicle  registrations suspended or revoked, while 301 unsafe motor carriers had  vehicle registrations denied—together representing about 15 percent of  carriers that were ordered out of service in 2008. These results are likely  understated because some states that are reporting are not able to track  the data in a systematic or verifiable way. Three of the 13 states we  contacted that deny, suspend, and revoke vehicle registrations based on  an out-of-service order do not track the number of registration denials.  Officials in one of those three states told us that no record is created when  registrations are denied. Rather, after a carrier attempting to register or  reregister a vehicle associated with an out-of-service DOT number in that  state is told the out-of-service order precludes registration, the carrier  typically leaves the office, ending the matter. Officials in another state  manually track denials, but have no method of verifying the data. FMCSA  officials acknowledge that there are limitations to the data and that the  data probably underestimate the number of denials, suspensions, and  revocations that occur.
section_title: Stakeholders Contacted View PRISM Implementation as Worth the Effort, Although Its Impact on Safety Is Difficult to Measure
paragraphs: Officials from each of the 13 states we contacted that deny, suspend, or  revoke registrations told us that they believe PRISM is worth the effort to  implement because the grant program provides a deterrent against unsafe  carriers. State officials told us that the deterrent can increase safety, but  they could not quantify improved safety outside of tracking the number of  denials, suspensions, and revocations of vehicle registrations to out-of- service carriers. Law enforcement officials in one state we met with told  us that PRISM grants may enable them to identify these carriers by  providing officials with wireless connections to safety databases, allowing  officials to check a carrier’s safety status at weigh stations on the  roadside. As a result, several state officials believe that PRISM has helped  keep their roadways safer. For example, officials in one state told us that  PRISM implementation is worth the effort—even if it has only prevented a  few out-of-service carriers from registering. The state official said that if  PRISM implementation prevents a major, expensive crash, then the  program would be a success.
FMCSA officials told us that state denial of vehicle registrations associated  with out-of-service carriers serve as a sufficient deterrent to prevent some  unsafe carriers from attempting to obtain valid registrations.  Representatives from industry and safety groups echoed these comments.  Representatives from a safety association we met with told us that PRISM  is the only program that establishes a safety connection between a vehicle  and the motor carrier company on an up-to-date basis.
We believe that the PRISM program appears to have a very strong  potential cost-benefit component. The overall cost of implementing the  program ($5 million per year) is relatively small in comparison to the  potential benefit of increased roadway safety as a result of reduced out-of  service carriers operating on U.S. roadways, especially as more states  deny, suspend, and revoke the registrations of vehicles associated with  out-of-service carriers.
section_title: FMCSA Has Looked for Ways to Measure PRISM’s Impact on Safety, but Has Not Yet Adopted Measures
paragraphs: FMCSA sought to understand PRISM’s effectiveness by sponsoring an  evaluation of the PRISM program and the extent to which PRISM has  improved safety. In 2007, the Volpe Center, which conducted this  evaluation, concluded that states with denial, suspension, and revocation  capability show some improved safety over time compared with other  states, indicating that PRISM, when fully implemented, could have  contributed to lower crash rates, although its results were inconclusive in  several areas. The Volpe report used two measures to assess how  PRISM’s registration sanction component affected commercial vehicle  safety:    Comparison of commercial vehicle crash rates in pre-PRISM versus  post-PRISM states and in PRISM versus non-PRISM states by year. The  report found that the comparison of crash rates in eight states that  progressed from nonparticipating to denying, suspending, and revoking  vehicle registrations between 2000 and 2005 revealed a potential  downward influence on crash rates in states that fully implemented  PRISM. While almost all eight states had rising crash rates over time, the  increase was lower for these states compared with other states that did  not fully implement PRISM over the same time period. Comparisons  between commercial vehicle crash rates in states that do not participate in  PRISM and states that deny, suspend, and revoke vehicle registrations by  year were inconclusive.
States’ success in denying registrations to out-of-service carriers. The  report found that, with few exceptions, PRISM states did not erroneously  issue registrations to out-of-service carriers.
The Volpe report concluded that PRISM cannot succeed alone, as it works  in conjunction with other FMCSA and state programs (for example,  compliance reviews, new entrant safety audits, and roadside inspections)  to reduce crashes and safety violation rates. Because all FMCSA programs  are aimed at reducing crash rates and because numerous factors  contribute to crash rates, isolating PRISM’s effect is difficult.
Although isolating PRISM’s impact on safety is difficult, measuring  performance when a significant number of states fully implement PRISM  could help FMCSA assess PRISM’s effectiveness in achieving the program  goal of improved safety. The 2007 Volpe report suggested that FMCSA  evaluate the program’s effectiveness by using the measures discussed  above, which Volpe initially used to assess PRISM’s effect on commercial  vehicle safety (that is, comparison of crash rates and state success in  sanctioning registrations). FMCSA officials told us they have not evaluated  crash rates in states pre- and post-PRISM implementation because of  insufficient resources and because of the difficulty of isolating PRISM’s  effect on crash rates. For example, the benefits of PRISM implementation  may not be seen in the state that implemented the program (that is, a  vehicle denied registration in one state may have had a crash in another  state). As such, isolating PRISM’s effect on state crash rates is  complicated, particularly when only about half the states have fully  implemented PRISM. Consequently, changes in crash rates pre- and post- PRISM may be attributable to other factors. FMCSA officials told us that  this may simply represent a correlation, rather than a cause and effect  relationship, or may be the result of the state implementing a variety of  safety-related actions. However, as the Volpe report noted, an effective  control method for factors that influence motor carrier crash occurrence  (for example, highway infrastructure or weather) is to observe the impact  of PRISM implementation one state at a time, comparing pre- and post- PRISM crash rates within the same states over time. The Volpe report  added that while such an approach does not eliminate the problem of  external factors that influence crash rates, it provides a degree of control  not possible in simple comparisons of crash rates between PRISM and  non-PRISM states.
While the current FMCSA data on PRISM—the number of denials,  suspensions, and revocations—are useful, they do not fully measure  PRISM’s effectiveness. In particular, the number of denials is an imperfect  measure. As the Volpe report points out, a reduction in the number of  denials over time may imply either that PRISM is not doing a good job or  that PRISM has had a substantial positive influence by functioning as a  deterrent that discourages carriers from attempting to register vehicles  while under an out-of-service order. Over time and as more states  participate in PRISM, the number of denials may decrease because  carriers will know that they will not be able to receive valid registrations if  they are out of service. Furthermore, until all—or nearly all—states are  fully implementing PRISM, the numbers of suspensions and revocations  are also imperfect measures, since out-of-service carriers can obtain  vehicle registrations in the states that are not fully implementing PRISM.
According to FMCSA officials, since the Volpe evaluation, PRISM has  implemented an alert report that identifies vehicles when they are placed  out of service. State officials then suspend these vehicles in a timely  manner, leaving very few vehicles that are available to fit into the category  of denial of registration at renewal.
FMCSA officials also told us that the number of carriers that have vehicle  registrations suspended and revoked under PRISM will not be equal to the  number of carriers ordered out of service in a given year for several  reasons. First, according to FMCSA data, the majority of carriers (about 87  percent) ordered out of service in 2008 were new entrants. These entrants  may not have tried to register vehicles, so there may not be any vehicle  registrations to suspend or revoke, or they may have mistakenly registered  as an interstate carrier when they should have registered as an intrastate  carrier or a registrant only. According to FMCSA officials, these  registrants provide a DOT number at the time of registration for the carrier  responsible for safety. Since the DOT number is not associated with a  carrier that is out of service, the vehicles will not be suspended even if the  registrant’s number is associated with an out-of-service order. Second, for  those carriers ordered out of service for failure to pay fines (about 8  percent in 2008, according to FMCSA data), FMCSA advises states to  check with the state FMCSA Division Office before they go through the  work of denying, suspending, and revoking vehicles. FMCSA advises this  action because the fines may be resolved within a couple of days, and it  would not be worth the effort of sanctioning the registrations to reinstate  them hours or days later. In addition, there are also out-of-service carriers  in non-PRISM states that will not have their vehicle registrations  suspended. Last, the numbers of out-of-service carriers include interstate  carriers that operate vehicles that weigh between 10,000 and 26,000  pounds. IRP does not require carriers to register vehicles that weigh less  than 26,000 pounds. Since PRISM only affects IRP registrations—these  carriers are not included in PRISM.
The Volpe report indicated that PRISM will struggle to achieve its full  potential until most states (perhaps 90 percent) are implementing PRISM  to the extent that they can deny, suspend, and revoke vehicle registrations.
FMCSA officials said that other than collecting data on the number of out- of-service carriers that had vehicle registrations sanctioned, it is difficult  to measure PRISM’s effectiveness. One official told us that as long as the  program is executed correctly, PRISM enables states to deny, suspend, or  revoke the vehicle registrations of out-of-service carriers. When most  states have the capability to sanction registrations, it may be easier to  demonstrate PRISM’s effect on safety. FMCSA officials have suggested  that this might be from about 38 to 40 states.
In response to the Volpe evaluation, FMCSA developed performance  measures for state participants, such as suspending or revoking the  registration of vehicles associated with an out-of-service carrier for all  reasons permitted by state law, and for the PRISM team, such as  performing annual implementation reviews on six states, assisting states in  preparing their implementation plans, and publishing two newsletters each  year. For the most part, these measures seem to be process-oriented and  do not appear to demonstrate the achievements of the program.
In our view, applying outcome performance measures such as Volpe’s two  measures and measuring the percentage of out-of-service carriers affected  by PRISM, while ultimately useful, may be premature at this time.  Currently, PRISM’s success is undercut by the 25 states and the District of  Columbia that either do not yet have the capability to deny, suspend, or  revoke vehicle registrations of out-of-service carriers or do not participate  in the program.
section_title: Patchwork Implementation Is One of Several Factors Limiting PRISM’s Effectiveness
paragraphs: According to FMCSA data, 22 states and the District of Columbia are not  far enough along in implementing PRISM to deny, suspend, or revoke  vehicle registrations of out-of-service carriers, and 3 states do not  participate in PRISM at all. As a result, out-of-service carriers in these 25  states and the District of Columbia can register and reregister vehicles and  keep operating with valid registrations, albeit in violation of FMCSA’s out- of-service orders. In addition, carriers that had been denied registration in  PRISM states may be able to register vehicles in non-PRISM states or  PRISM states that do not yet have the capability to deny, revoke, or  suspend registrations for out-of-service carriers. Of the over 2 million  vehicles with IRP registrations in 2007, about 1.3 million vehicles (or 65  percent) were registered in states that are not denying, suspending, or  revoking vehicle registrations. States with some of the largest numbers of  commercial vehicle registrations, such as Indiana, Illinois, Oklahoma, New  Jersey, and California, have not fully implemented PRISM.
In addition, charter buses are exempt from IRP (interstate) registration  and thus not subject to PRISM. Charter bus crashes are relatively rare  but can be particularly deadly, since many people may be involved. T he  American Bus Association commissioned a 2008 motor coach census,  which found that in 2007, over 3,400 carriers operated about 33,500 buses  in the United States and Canada. charter services. Although some charter buses choose to register through  IRP, many do not and, therefore, are not included in PRISM.  Representatives from IRP, Inc., the American Association of Motor Vehicle  Administrators, and the United Motorcoach Association, as well as  officials from FMCSA, told us that charter buses are exempt from IRP  registrations because the vehicles are for hire and may not be able to  reliably predict which states they may travel to in order to properly  apportion registration fees. The representatives, however, were not able to  provide a rationale for why this exemption does not apply to for-hire  trucking companies that also may not be able to reliably predict the states  in which they may travel. Officials from FMCSA told us that charter buses  could be included in PRISM if charter buses were required to register  through IRP or if PRISM was expanded to include non-IRP vehicles.  Officials from nine states we met with that sanction vehicle registrations  of out-of-service carriers told us that charter buses should be included in  PRISM. According to representatives from IRP, Inc., there has been some  discussion on changing the exemption to require charter buses to register  through IRP; however, no changes have been formally submitted for  approval by its member states.
Nathan Associates, Motorcoach Census 2008: A Benchmarking Study of the Size and  Activity of the Motorcoach Industry in the United States and Canada in 2007 (Dec. 18,  2008). the 13 states we contacted that deny, suspend, and revoke vehicle  registrations told us that they provide registrations because they cannot  conclusively link the new carrier to the old out-of-service carrier at the  time of registration—even if the vehicle identification number is or has  been associated with an out-of-service carrier—especially when the new  carrier is presenting legitimate documentation of the new company. In one  state, officials told us that if a vehicle identification number for a new  registration is identified through PRISM as being associated with an out- of-service DOT number, the carrier is notified that the vehicle is attached  to the out-of-service DOT number. If the carrier provides proper  documentation to support ownership (for example, proof of an established  place of business in the state, proof of title for the vehicles being  registered, and other documents), the vehicle is registered. Officials  added that they would also provide registration for these carriers because  it would be next to impossible to prove differently based on speculation.
In another state, officials told us that once a chameleon carrier obtains a  new DOT number, the motor vehicle administration is unable to prevent  the carrier from obtaining an IRP registration—even if they know the  carrier is a chameleon carrier—because they do not deny the registration  until FMCSA connects the identity of the “new” carrier with the out-of- service carrier. According to those state officials, they issue new  registrations to carriers that have valid paperwork showing a new name  and DOT number, among other things. Those officials also told us that  they contact the state FMCSA division office when they suspect that a  carrier may be evading an out-of-service order. An official from the  FMCSA state division office told us they investigate the carrier by  reviewing carrier, driver, and vehicle records to determine whether the  carrier is in fact a chameleon carrier. If they are able to prove that the  carrier reinvented itself to evade an out-of-service order, the out-of-service  order will be transferred to the new DOT number, and the state can then  suspend the vehicle registrations associated with the new DOT number.
Chameleon carriers may also remain in operation in many states by  registering as intrastate carriers, but continuing to operate as interstate  carriers. By registering as intrastate carriers, these carriers are no longer  subject to federal regulation. Officials in 12 of the 13 states we contacted  were not using vehicle identification numbers to check for federal out-of  service orders prior to issuing an intrastate registration to a carrier.  According to FMCSA officials, FMCSA has been recommending that states  modify their laws to prohibit the issuance of any vehicle registration to a  carrier that has received a federal out-of-service order. FMCSA has also  allocated a supplemental grant to Washington state to incorporate non-IRP  registrations into the PRISM network to ensure that state motor vehicle  administrations check federal out-of-service orders before issuing  registrations to non-IRP vehicles. Georgia officials told us they requested  funds to expand PRISM to non-IRP commercial vehicles. According to  FMCSA officials, the agency provides funds to expand PRISM’s  registration sanction framework to include vehicles exempt from IRP  registrations. Most states have two databases for registering motor  vehicles—one for vehicles that are required to obtain IRP registrations and  one for vehicles that are exempt, such as charter buses that are under  FMCSA’s oversight and intrastate carriers. Thus, even though intrastate  carriers are not generally under FMCSA’s regulatory authority, they are  included within the registration database of other vehicles that are under  FMCSA’s regulatory authority.
section_title: National PRISM Implementation May Not Occur for Years if PRISM Is Maintained as a Voluntary Program
subsections: section_title: Time States Need to Implement PRISM Varies
paragraphs: PRISM will be most effective when all—or nearly all—states have the  ability to deny, suspend, and revoke registrations; only about half of them  have this capability now. At the outset of PRISM implementation, FMCSA  works with each state to create an implementation plan, which includes  identifying responsible parties, how the state will meet the program  requirements, timelines for completion, and estimated costs. States are  also required to report their progress to FMCSA on a regular basis, as  designated in the implementation plan. While some states have  implemented PRISM relatively quickly, it has taken other states much  longer. FMCSA data show that the average time it took states to affect  vehicle registrations after the states committed to implementing PRISM  was 3 years and 4 months, but it can take as little as 10 months or as long  as 7 years and 4 months. (See fig. 2.) In addition, FMCSA data show that  nine states have been implementing PRISM for 5 years or more but are not  yet able to deny, suspend, or revoke vehicle registrations of out-of-service  carriers for reasons discussed later in this report. FMCSA officials stated,  however, that in comparison with other voluntary programs, such as IRP  and the International Fuel Tax Agreement (a fuel use tax agreement that  establishes uniform administration of motor fuel taxation laws for  interstate motor vehicles), states are implementing PRISM at a satisfactory  pace. IRP began in 1973, while the International Fuel Tax Agreement  began in 1983. Neither program had participation among all 48 contiguous  states until the Intermodal Surface Transportation Efficiency Act of 1991  encouraged state participation.
State officials we met with identified several factors that affected the time  states needed to fully implement PRISM. Officials in all 13 states we met  with that are denying, suspending, and revoking vehicle registrations  identified one or more of the following three key factors that facilitated  implementation:    Hiring a contractor to implement technical aspects of PRISM, rather  than implementing PRISM with current state staff. Ten states hired a  contractor to implement technical aspects of PRISM. State officials told us  that an experienced contractor often provides states with the expertise to  properly implement PRISM’s technical components in a timely manner.  Officials from one state told us that hiring a contractor that had been used  by other states to implement technical aspects of PRISM made  implementation easy.
Having one agency responsible for motor carrier issues. Officials from  five states told us that having one agency responsible for issuing motor  carrier registrations and providing motor-carrier safety oversight helped  facilitate implementation. Officials from one of those states told us that  three separate motor vehicle agencies (registration, enforcement, and  oversight) came together into a single motor carrier services division,  which made PRISM implementation much easier. Prior to that time,  agreeing on an agenda and coordinating between the agencies was  difficult.
Sufficient financial support to fully implement the program. Each year,  FMCSA allocates $4 million to various states to implement PRISM. Some  states receive more grant funds or a second grant allocation. Officials from  11 states told us that these PRISM grant allocations were sufficient; 6 of  these 11 states received a second grant.
Officials from the 26 states we contacted identified one or more of the  following three key factors that prevented or delayed PRISM  implementation:    Overhauling outdated commercial vehicle registration systems that have  difficulty incorporating technical aspects of PRISM. Officials in nine  states cited having outdated state IRP registration systems that needed  significant updating to incorporate PRISM functions. One state was  implementing a new, updated IRP system. According to officials from that  state, the cost of the new system was approximately $11 million. FMCSA  officials told us that they were aware that the state had to improve its  technical connectivity because its system was insufficient to support  PRISM.
Competing priorities within state motor vehicle registration  administrations. Officials from eight states told us that competing  priorities within state motor vehicle administrations delayed or hampered  PRISM implementation. State motor vehicle administrations typically have  multiple responsibilities (such as licensing drivers and registering  passenger vehicles), and the registration of commercial vehicles may only  be a small part of these responsibilities. Officials in one state told us that  they prioritize programs that deal with licensing drivers and registering  passenger vehicles due to those registration volume demands. Also,  officials from four states said that they were working on other commercial  vehicle safety efforts, such as the commercial vehicle information  exchange window system, and unable to move forward with PRISM  implementation. Furthermore, PRISM may conflict with a state motor  vehicle administration’s focus on timely and efficient customer service.  State motor vehicle administrations often focus on processing registration  applicants as quickly as possible. PRISM may impose some time- consuming requirements, depending on the state’s registration system  capabilities. For example, two states have to manually check an  applicant’s safety status and work with the carrier to update carrier  information (also required by PRISM), which can slow down the  registration process.
Inability to or difficulty in passing enabling legislation needed to deny,  suspend, or revoke commercial vehicle registrations based on a federal  out-of-service order. Officials from five states told us that their states do  not have PRISM-enabling legislation to revoke, deny, or suspend  registrations of out-of-service carriers. States need the legal authority to  impose vehicle registration sanctions against motor carriers that FMCSA  has prohibited from operating. State trucking associations, however, may  stall or block such enabling legislation. For example, officials from one  state told us that in trying to pass legislation, the state trucking association  was initially concerned about the timeliness for carriers to get vehicle  registrations reinstated once the out-of-service order is rescinded. Once  the association understood that timeliness would not be an issue, it  supported PRISM.
section_title: FMCSA Is Limited in Accelerating National PRISM Implementation
paragraphs: FMCSA has worked to address some of the factors states cited that delay  or prevent PRISM implementation, but is limited in its ability to speed  national implementation. Due largely to its voluntary nature, FMCSA is  limited in its ability to compel states to pass PRISM-enabling legislation,  prioritize PRISM implementation, or overhaul outdated commercial  vehicle registration systems. However, FMCSA has taken some action to  address these factors. First, FMCSA has drafted model PRISM-enabling  legislation that is available on its Web site. State legislatures, however,  may meet infrequently and may not value PRISM-enabling legislation as an  important agenda item, thereby delaying the passage of needed legal  authority to deny, suspend, or revoke the registration of out-of-service  motor carriers. Second, FMCSA holds a 2-day training session with states  to identify and begin to work through the issues related to implementing  PRISM, and develops an implementation plan that presents step-by-step  procedures to implement PRISM. FMCSA cannot, however, compel states  to move quickly on taking those steps. Finally, FMCSA works with older  state registration systems (referred to as legacy systems) to facilitate  connectivity to FMCSA databases, and FMCSA staff provide technical  assistance to help states identify and address technical barriers to  establishing connectivity. FMCSA officials, however, told us that PRISM  grants cannot fund a multimillion dollar overhaul of the state’s legacy  system just to establish PRISM connectivity, since PRISM connectivity is a  relatively minor aspect of such a registration system.
States we contacted that do not have the ability to deny, suspend, or  revoke vehicle registrations had differing views regarding actions that  FMCSA could have taken to help them implement PRISM more quickly.  Officials in three of the nine states that have been implementing PRISM for  5 years or more without the ability to deny, suspend, or revoke vehicle  registrations of out-of-service carriers did not identify actions that FMCSA  could have taken to encourage them to implement PRISM more quickly.  Most state officials we contacted in states not fully implementing PRISM  told us that FMCSA consistently offered to provide whatever support it  could to help the state move forward with implementation, although as  previously mentioned, FMCSA was often limited in its ability to influence  certain factors. Officials in two states, however, told us that FMCSA  officials could have contacted them more often or otherwise put more  pressure on them to raise PRISM’s priority to ensure their state’s  participation in PRISM. In addition, states that have fully implemented  PRISM were generally satisfied with FMCSA’s actions to assist them in  continuing to operate PRISM.
section_title: Requiring Full PRISM Implementation Would Accelerate National Implementation, but Faces Significant Drawbacks
paragraphs: We conducted a general search of public policy literature for when a  mandatory or voluntary approach is preferred for program participation and  to achieve certain desired outcomes. Our review indicates that requiring  states to fully implement PRISM—thereby enabling them to deny, suspend,  or revoke the commercial vehicle registration of carriers that FMCSA has  ordered out of service (the desired outcome)—may be a quicker approach  toward achieving national PRISM implementation than the current  voluntary approach. PRISM implementation and the program’s desired  safety outcome are consistent with conditions indicating that a mandatory,  rather than voluntary, approach would work best. (See table 1.)
Stakeholders we met with differed on whether Congress should enact  legislation that would require states to fully implement PRISM. According  to officials in 12 states and representatives from safety associations we  interviewed, Congress should require all states to fully implement PRISM.  These officials and representatives suggested that all states should be  required to implement PRISM to ensure nationwide coverage so that no  state becomes a “dumping ground” for unsafe or chameleon carriers. In  addition, requiring states to implement PRISM by a certain date could  result in timely national implementation. Conversely, officials in 3 of the  26 states supported keeping PRISM a voluntary program. These officials  noted that a mandate was unnecessary, since only 3 states have not  committed to PRISM implementation. Furthermore, several state officials  that are currently implementing PRISM told us that even though they did  not implement PRISM quickly, the factors that prevented them from  moving forward were eventually overcome. In addition, states are making  progress in fully implementing PRISM. Since 2000, state participation and  implementation of PRISM has increased steadily. (See fig. 3.) For example,  in 2000, 33 states and the District of Columbia were not participating in  PRISM, and as of April 2009, only 3 states were not participating. FMCSA  data also indicate progress toward increased PRISM participation.
While our review of public policy literature indicated that requiring states  to fully implement PRISM may be a quicker approach toward achieving  national PRISM implementation than the current voluntary approach,  requiring states to implement PRISM within a certain time frame faces  significant potential drawbacks and barriers—both technical and legal.  First, such a requirement will likely cause PRISM implementation to move  toward the top of a state motor vehicle registration administration’s  priority. PRISM implementation, however, may not be the most important  activity for a state motor vehicle administration and may inhibit the  administration’s ability to complete other responsibilities, such as  processing driver’s licenses. Second, some states with significant barriers  to PRISM implementation may need to obtain substantial funds in order to  comply with a PRISM requirement. States with legacy registration systems  that do not allow connectivity to FMCSA safety databases, for example,  may need substantially more funds to enable them to fully implement  PRISM than PRISM grants generally can provide. This could be  problematic in today’s recessionary climate. PRISM grants are intended to  fund the costs of creating technology interfaces between the states’  systems and FMCSA databases and not to fund complete registration  system overhauls, which could cost millions of dollars. In addition to these  technical issues, Congress may not have the legal authority to require  states to implement PRISM. Congress can impose nationwide  requirements pursuant to authorities specified in the Constitution. Under  the Tenth Amendment, however, Congress cannot require states to enact  laws or regulations that would compel a state to enforce a federal  regulatory program.
While Congress is limited in its ability to require state adoption of PRISM,  it has three options that may enable it to strongly encourage state  participation. First, Congress can attach conditions upon the receipt of  federal funds. For example, as it has done in the past, Congress could  require that states will lose a certain percentage of highway construction  funds if they fail to fully implement PRISM within a given time. In DOT’s  2001 appropriations act, Congress provided the National Highway Traffic  Safety Administration with the ability to encourage states to adopt stricter  standards for making it illegal for people to drive with a specified blood  alcohol concentration (BAC) of .08 percent. Under this provision, later  codified, states that did not adopt a conforming .08 percent BAC law by  October 1, 2003, would have a percentage of highway construction funds  withheld each year. Consequently, by July 2004, the legislatures in all 50  states and the District of Columbia passed laws defining it as a crime to  drive with a BAC at or above .08 percent, whereas in 1999, only 16 states  had enacted such a law. If this approach was applied to PRISM, a state  motor vehicle administration that chooses not to implement PRISM would  trigger a reduction in that state’s transportation department’s highway  construction funds. As a result, Congress may be withholding funds from a  state agency that is not responsible for implementing PRISM. But, such a  scenario is similar to states adopting .08 percent BAC laws.
A second option available to Congress is to provide financial incentives to  states that speed PRISM implementation. Congress can provide an  incentive payment, such as a one-time payment for implementing PRISM  within a predetermined number of years. Furthermore, Congress can  require states that do not stay in the program for a predetermined period  to return the payment to ensure states stay committed to full PRISM  implementation. States, however, may find that financial incentives such  as payments are insufficient to overcome the factors that prevent or delay  them from fully implementing PRISM—particularly in states that need  expensive overhauls of outdated registration systems. Furthermore, as  more states move forward with PRISM implementation, Congress may end  up allocating a substantial amount of financial incentives to states that  eventually would have fully implemented PRISM without such an  enticement. In addition, according to FMCSA officials, states that have  already implemented PRISM may find this option unfair.
Finally, Congress can strongly encourage state participation by developing  associated mandatory elements. As discussed earlier, Congress, through  the Intermodal Surface Transportation Efficiency Act of 1991, developed  mandatory elements of enforcement, regulation, and reporting that  strongly encouraged states to participate in IRP and the International Fuel  Tax Agreement. With the IRP, the act stated that after September 1996, a  nonparticipating state could not establish or enforce its own motor vehicle  registration laws and regulations on vehicles that have IRP registrations  from other states. With the International Fuel Tax Agreement, the act  stated that after September 1996, a state can establish or enforce a law or  regulation that has a fuel tax reporting requirement or provides for the  payment of fuel tax only if it does so in a way that meets the requirements  of the International Fuel Tax Agreement. In applying a similar approach  to PRISM, Congress could condition states’ ability to issue IRP  registrations on using PRISM functions to check or deny a carrier’s  operating status prior to issuing such registrations. Such strong  encouragement to impose PRISM, however, may cause problems for states  that do not have the money needed to overhaul an outdated registration  system to enable PRISM functionality.
Similar to IRP and the International Fuel Tax Agreement, Congress can  look to the National Driver Registry (NDR) as a comparison of a voluntary  roadway safety initiative that achieved significant state participation  following strong federal encouragement. The National Highway Traffic  Safety Administration administers the NDR database system, which is  similar to PRISM in its purpose and framework. Similar to PRISM, states  are not required to participate in the NDR. The NDR facilitates the  exchange of driver information between participating states to ensure that  commercial vehicle drivers who have had their licenses suspended or  revoked or who have been convicted of serious traffic violations (for  example, driving while impaired by alcohol or drugs) in one state do not  receive a new or renewed license in another state. State motor vehicle  administrations provide the NDR with the names of individuals who have  lost driving privileges or who have been convicted of a serious traffic  violation. When a person applies or reapplies for a driver’s license, the  state queries the system—maintained by the American Association of  Motor Vehicle Administrators—to see if that applicant is listed on the  NDR. If a state has reported the applicant on the NDR as a problem driver,  the state may deny the applicant’s request for a license.
According to a National Highway Traffic Safety Administration official,  before 1986, the NDR was not fully effective since not all states were  checking the NDR prior to issuing commercial driver’s licenses. Congress,  however, passed the Commercial Motor Vehicle Safety Act of 1986,  which required states to check the NDR prior to issuing new commercial  driver’s licenses in the state. Still, while all states checked the NDR wh en  new licenses were issued, not all states were checking the system du ring  renewals. Consequently, commercial vehicle drivers who were convicted  of serious traffic violations in a state other than where they were licensed  were still able to have their licenses renewed in their home states.  Subsequently, Congress passed the Motor Carrier Safety Improvement Act  of 1999, which required states to check the NDR for all new license  issues and renewals. A National Highway Traffic Safety Administration  official told us that, partly due to this requirement, state queries of the  NDR went from 35 million per year in 2001 to over 100 million per year in  2008.
section_title: Conclusions
paragraphs: As a relatively small program, FMCSA’s PRISM grants appear to have great  potential to improve highway safety by preventing motor carriers that  FMCSA has ordered out of service from obtaining or maintaining valid  vehicle registrations, thereby inhibiting their ability to operate unlawfully.  r  Although 47 states and the District of Columbia are either committed to o already implementing PRISM, the program’s impact is unknown because  FMCSA has not adopted measures of program effectiveness. This makes  some sense, since the program has not been fully implemented in 25 states and the District of Columbia. Until a sufficient number of states have th ability to prevent unsafe motor carriers from obtaining or maintaining  vehicle registrations, attempting to measure the effectiveness of PRISM  grants will not be particularly fruitful. FMCSA officials a sufficient number of states might be 38 to 40 states.
Finally, despite the potential safety advantages in having all states and th District of Columbia fully implement PRISM and a variety of options for  doing so, we are not suggesting that Congress legislate because of the drawbacks and challenges of doing so.
section_title: Recommendation for Executive Action
paragraphs: In order to assess PRISM’s effectiveness in keeping unsafe carriers of road, we recommend that the Secretary of Transportation direct the  Administrator of FMCSA to measure PRISM program effectiveness wh the number of states that have the ability to deny, suspend, or revoke  registrations to out-of-service carriers is sufficient to make such  measurements meaningful.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Department of Transporta its review and comment. The department generally agreed with the  recommendation. It also offered one technical comment, which  we  incorporated.
We are sending copies of this report to congressional committees  interested in motor carrier safety issues; the Secretary of Transportation;  the Administrator of FMCSA; and the Director of the Office of  Management and Budget. In addition, the report will be available at no  charge on the GAO Web site at http://www.gao.gov.
If you or your staffs have any questions about this report, please contact  me at (202) 512-2834 or flemings@gao.gov. Contact points for Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. Staff who made key contributions to this report are listed in  appendix II.
section_title: Appendix I: Scope and Methodology
paragraphs: To report on the extent to which the Performance Registration  Information Systems Management (PRISM) grants program has effectively  removed unsafe carriers from the roadway, we obtained Federal Motor  Carrier Safety Administration (FMCSA) data on the number of motor  carriers that had vehicle registrations denied, suspended, or revoked.  These data are to be reported to FMCSA on a quarterly basis by states that  have implemented PRISM to the point where they are denying,  suspending, and revoking vehicle registrations of out-of-service carriers.  We interviewed officials from FMCSA to discuss how data are collected  and verified and how the data are used to assess PRISM’s effectiveness.  We also conducted semistructured interviews with a nongeneralizable  sample of state motor vehicle administration officials and state law  enforcement officials from 13 states that deny, suspend, or revoke vehicle  registrations to discuss their state’s experience implementing PRISM, how  effective the program has been, and the soundness and conclusiveness of  reported data. We selected the 13 states based on their progress  implementing PRISM and their status as states with the largest numbers of  commercial vehicles registered through the International Registration Plan  (IRP). We selected states with the most vehicles registered, assuming that  the proportion of out-of-service vehicles are distributed relatively evenly  across states. State data on out-of-service vehicles are incomplete, and we  did not test this assumption.
In determining the reliability of FMCSA’s data on the number of motor  carriers that had vehicle registrations denied, suspended, or revoked  because of an out-of-service order, we interviewed officials from FMCSA  who are knowledgeable about the data and how the data are collected and  analyzed. We also attempted to obtain similar information from states that  are fully implementing PRISM. We identified shortcomings with these  data, which we disclosed in this report, but found the data sufficiently  reliable for our purpose, which was to provide a general sense of the  extent to which PRISM implementation has resulted in vehicle registration  sanctions.
We met with state officials and representatives from motor carrier  industry and safety associations and obtained their views on the extent to  which PRISM has improved highway safety or had other benefits. (See  table 2 at the end of this appendix for a list of industry and safety  associations we interviewed.) We reviewed a 2007 Volpe National  Transportation Systems Center evaluation of the PRISM program that  reported on the extent to which PRISM has improved roadway safety and  the limitations to FMCSA’s data on the denial of commercial vehicle  registrations to motor carriers FMCSA placed out of service. Finally, we  reviewed information from interviews and the 2007 Volpe report to  identify and describe the factors that limit PRISM’s effectiveness.
To report on the potential to fully implement the program nationally, we  met with officials from FMCSA, state motor vehicle administrations, and  state law enforcement offices in 26 selected states, as well as  representatives from industry and safety associations. We conducted  semistructured interviews with state motor vehicle administrations from  13 states that have fully implemented PRISM; 3 states that are  implementing the grant program (that is, they are collecting vehicle  identification numbers and the DOT numbers of the carriers associated  with those vehicles and may be checking the safety status of the carrier at  the time of registration) but do not yet have the capability to affect vehicle  registrations; 8 states that have entered into an agreement with FMCSA to  implement PRISM grants but have not yet moved forward substantially to  implement the program; and 2 states that do not participate in PRISM at  all. (See table 2 for a list of state agencies we interviewed.) We selected  these states based on their progress implementing PRISM and their status  as states with the largest numbers of commercial vehicles registered  through the IRP in 2006, the latest year for which full data were available  at the time we selected states to interview. We reviewed FMCSA data  regarding the time states have taken to reach the ability to deny, suspend,  or revoke vehicle registrations of out-of-service carriers, after signing a  statement of intent to participate in the PRISM program. We analyzed  testimonial evidence to identify factors that enabled states to deny,  suspend, and revoke registrations and factors that have delayed or  prevented other states from moving forward. We also analyzed the  information to identify the factors FMCSA can affect and those it cannot.
As part of our work on the potential to implement the program nationally,  we conducted a general search of public policy literature for when a  mandatory or voluntary approach is preferred for program participation  and to achieve certain desired outcomes. Through our literature search,  which covered materials dating from 1998 to 2008, we identified and  analyzed five articles that listed conditions for when a mandatory or  voluntary approach works best. The articles described when a mandatory  or voluntary approach is preferable for implementing environmental,  animal production and processing, and food safety regulations on private  sector entities; we did not find literature that identified conditions for  when a federal agency should administer a mandatory or voluntary  approach on state governments to achieve a certain desired outcome.  Furthermore, we identified similar, comparative programs that have  mandatory elements. In addition, we identified and analyzed drawbacks to  mandating state implementation of PRISM and potential options available  to Congress for encouraging—rather than mandating—state legislative or  regulatory action that could speed nationwide PRISM implementation.  Finally, we assessed FMCSA’s oversight for those states that are denying,  suspending, and revoking registrations by obtaining testimonial  information on FMCSA’s efforts to assist them in continuing to operate  PRISM.
section_title: Appendix II: GAO Contact and Staff Acknowledgments
paragraphs: Susan A. Fleming, (202) 512-2834 or flemings@gao.gov.
subsections: section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, James Ratzenberger (Assistant  Director), Michelle Everett (Analyst-in-Charge), Samer Abbas, Brandon  Haller, Delwen Jones, Hannah Laufe, Joshua Ormond, and made key  contributions to this report.