Welcome Performance and Registration Information Systems Management (PRISM) IRP Annual Meeting May 15, 2014 Monique Riddick, PRISM Program Technical Manager Federal Motor Carrier Safety Administration (FMCSA) Enforcement Division (FMCSA HQ) 1 Agenda 1. Recent State Upgrades 2. PRISM Requirements 3. URS Current Biennial Update Process URS Impact on PRISM States 4. 950 Status Code 5. PRISM Evaluation 6. Panel Discussion 2 1
PRISM State Vehicle Registration Connectivity March 2014 3 Recent State Upgrades State Implementation Upgrades since December 2013: CT, MT, and RI moved to Step 8 NM, SD, and VT moved to step 7 NY moved to Step 5 OK moved to Step 4 4 2
PRISM Requirements 15 PRISM Implementation Requirements listed by category Legislation Registration Processes Data Collection and Forms Communications and Training 6 Law Enforcement Requirements Legislation Operations and Training 5 Unified Registration System (URS) PRISM Impacts Overview August 23, 2013: URS Regulation published First effective date: November 1, 2013: New and enhanced enforcement penalties for failing to complete the Biennial Update requirement including deactivating USDOT numbers Prohibition of interstate transportation with an inactive or no USDOT number Second effective date: October 23, 2015: URS is operational Electronic filing, only, using online MCSA 1 form paper forms no longer accepted All new applicants subject to a $300 USDOT number registration fee 6 3
Current Biennial Update Process Step 1: On November 1, 2013, FMCSA sent Biennial Reminder/ Warning letters to Entities The biennial update due date for a carrier is determined by the last two digits of the USDOT Number Last digit represents the month the biennial update is due (e.g. USDOT Number ending in 2 is due February) Second to last digit represents which year the biennial update is due: Odd digits updated in odd numbered years Even digits updated in even numbered years The biennial reminder/warning letter is NOT sent to an entity that has updated its MCS 150 within a year of their biennial update due date 7 Current Biennial Update Process (cont.) Excerpt from Reminder/Warning Letter..An active USDOT Number is required for motor carrier transportation in interstate commerce, transportation without USDOT Registration and an active USDOT Number is specifically prohibited. See 49 USC 31134 and 49 CFR 392.9b. Continued operations after deactivation of a USDOT number may result in additional civil penalties, in accord with 49 U.S.C. 521. Failure to update the MCS 150 for USDOT Number 12345 on or before February 28, 2014 may result in DEACTIVATION of your USDOT number and civil penalties. USDOT Number 12345 will be deactivated on April 1, 2014, if no action is taken. You may update your USDOT Registration information by completing the biennial update process at no charge to your company.. 8 4
Current Biennial Update Process (cont.) Step 2: Biennial Deactivation letters sent to Entities failing to comply March 1, 2014: FMCSA began deactivating USDOT numbers of entities that failed to comply FMCSA assigned an MCSIP Step 52 Biennial Update not Completed Deactivated carriers and vehicles included on the PRISM Target File What happens after the USDOT Number deactivation? If carrier updates its MCS 150, the MCSIP Step 52 is cleared from the record, and the carrier is no longer included on the PRISM Target File If carrier does not update its MCS 150 after a 6 month period, and has no recent activity (e.g. inspection or crash record), carrier is removed from the PRISM Target File and operation status is made inactive 9 Current Biennial Update Process (cont.) Excerpt from Deactivation Letter..FMCSA records indicate that ABC Company failed to timely complete a biennial update or show good cause why an update was not required. FMCSA deactivated USDOT Number 123456, effective April 1, 2014. Pursuant to 49 CFR 392.9b, ABC Company is prohibited from providing interstate transportation with an inactive USDOT number. Pursuant to 49 CFR 390.19(b)(4), failure to complete a biennial update of the MCS 150 may result in the imposition of a civil penalty of up to $1,000 for each offense 10 5
How Does URS Impact PRISM States? No longer required to validate that the MCS 150 has been updated within the past year prior to issuing registration No longer required to mail pre printed MCS 150 forms as part of renewal packet PRISM states will deny or suspend registration of deactivated entities, similar to how the states currently deny and suspend registrations of carriers that are under a Federal Out of Service Order Ensure that state partners that use the Target File implement the correct MCSIP Step 52 description (e.g., for USDOT Readers, and License Plate readers) IRP System changes: Ensure that Step 52 is properly defined in all in house and online IRP systems In house IRP systems should remove the edit checks that identify if the MCS 150 has not been updated in the past year. Online IRP systems must also remove the MCS 150 date check, so that the carrier can continue their online registration process. 11 Why is Setting 950 Code Important? Confirms that the vehicle has been suspended by the State Provides law enforcement with Alert message within QC Suspended Vehicle without 950 Code Suspended Vehicle with 950 Code 12 6
Current Use of 950 Currently, 23 PRISM States use the 950 status code for suspensions (Steps 7 and 8) AL, AR, CA, CT, DE, IA, IN, KY, ME, MO, MS, MT, NE, NJ, NM, OH, RI, SC, SD, VA, VT, WA, and WI 13 PRISM Evaluation FMCSA s Strategic Planning and Program Evaluation Division is evaluating the PRISM Program Purpose: determine its effectiveness Timeframe: evaluation period ends December 31, 2014 Sample size: up to 9 States Contact may include: conference calls, questionnaires, site visits, etc. 14 7
Supports Buses joining IRP PRISM to become mandatory FMCSA Positions 15 PRISM CONTACT INFORMATION monique.riddick@dot.gov PRISMTechnicalSupport@dot.gov 16 8
Panel Discussion What Do You See as the Greatest Challenge Facing the PRISM Program? 17 9