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entitled 'Motor Carrier Safety: FMCSA Has Devoted a Small but 
Increasing Amount of Resources to Develop the Compliance, Safety, 
Accountability Program but Is Requesting a Significant Increase for 
Full Implementation' which was released on February 28, 2011. 

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United States Government Accountability Office: 
Washington, DC 20548: 

February 25, 2011 

The Honorable Patty Murray:
The Honorable Susan Collins:
Ranking Member:
Subcommittee on Transportation, Housing and Urban Development and 
Related Agencies:
Committee on Appropriations:
United States Senate: 

The Honorable Tom Latham:
The Honorable John W. Olver:
Ranking Member:
Subcommittee on Transportation, Housing and Urban Development and 
Related Agencies:
Committee on Appropriations:
House of Representatives: 

Subject: Motor Carrier Safety: FMCSA Has Devoted a Small but 
Increasing Amount of Resources to Develop the Compliance, Safety, 
Accountability Program but Is Requesting a Significant Increase for 
Full Implementation: 

In 2004, the Federal Motor Carrier Safety Administration (FMCSA) began 
work on its Compliance, Safety, Accountability (CSA) initiative 
[Footnote 1] to improve the safety of commercial motor vehicles, such 
as trucks and buses. FMCSA, whose primary mission is to reduce 
commercial motor vehicle-related crashes, fatalities and injuries, has 
made progress on CSA but needs to complete both implementation 
throughout all states and a Carrier Safety Fitness Determination 
rulemaking before CSA is fully implemented. CSA represents a 
different, more data-driven approach to motor carrier safety. Under 
CSA, which introduces a new system for identifying and responding to 
carrier safety risks, FMCSA intends to increase the number of carriers 
it evaluates and reduce crashes involving commercial vehicles. 

In light of delays in implementing CSA, Congress is concerned about 
FMCSA's ability to implement the program and directed GAO to monitor 
the program's implementation and review FMCSA's capacity to meet 
milestones within its planned cost estimates.[Footnote 2] As part of 
this work, you asked us to provide detailed information on the 
resources FMCSA has devoted and plans to devote to implementing CSA. 
[Footnote 3] This report provides information on (1) the amount of 
actual and proposed funding for FMCSA to develop and implement CSA to 
date and how the funding has been used, (2) the number of staff FMCSA 
has employed to develop and implement CSA to date, and (3) the funding 
and staffing resources FMCSA anticipates it will need to fully 
implement CSA going forward. 

To address these objectives, we reviewed and analyzed information on 
FMCSA resources used to develop and implement CSA, including 
information on funding used to develop the methodology to assess motor 
carrier safety, train FMCSA field staff and state agencies on CSA, 
conduct outreach, evaluate the CSA pilot tests, and develop software 
to facilitate investigators' access to carrier information. We also 
reviewed and analyzed information on the number and duties of FMCSA 
staff devoted to CSA development and implementation, the President's 
Budget Request for Fiscal Year 2012, and FMCSA's budget request for 
fiscal year 2012. We interviewed FMCSA officials to clarify and expand 
on this information. We conducted our work during February 2011 in 
accordance with all sections of GAO's Quality Assurance Framework that 
are relevant to our objectives. The framework requires that we plan 
and perform the engagement to obtain sufficient and appropriate 
evidence to meet our stated objectives and to discuss any limitations 
in our work. We believe that the information and data obtained, and 
the analysis conducted, provide a reasonable basis for any findings 
and conclusions in this report. 


To date, FMCSA has used a small number of its existing staff, combined 
with contractors, to implement CSA; however, obligations for CSA have 
increased, and the agency is requesting significantly more resources 
for future implementation efforts. 

* Much of FMCSA's early obligations used for CSA development were 
covered by existing budgetary resources. Specifically, obligations for 
CSA in fiscal year 2007 were $2.3 million. Obligations increased to 
$6.6 million in fiscal year 2008 and, as a result of FMCSA-wide 
software modernization costs, increased significantly over 2008 levels 
in 2009 and 2010, to $11.8 million and $9.5 million, respectively. 
FMCSA's budget request for fiscal year 2011 was $14.3 million. 

* In terms of full-time equivalent (FTE) staff, FMCSA used a 
relatively small number of existing staff to develop CSA to date. At 
most, 5 of its more than 1,000 FTEs have worked full time to develop 
and implement CSA since 2006. In addition, FMCSA used up to 40 of its 
staff on CSA development and implementation on a limited basis. Much 
of CSA's development, however, has been performed by contractors. 

* For 2012, however, FMCSA requested significantly more budgetary and 
staffing resources to fully implement the program. Specifically, FMCSA 
is requesting $78 million and 98 new full-time positions in addition 
to its existing field staff for fiscal year 2012 to fully implement 
CSA and integrate it into FMCSA's operations. 


FMCSA has relied on comprehensive on-site compliance reviews to 
determine whether motor carriers were operating safely. These reviews 
assess carriers' compliance with safety regulations through interviews 
with company officials and reviews of records that pertain, as 
applicable, to alcohol and drug testing of drivers, insurance 
coverage, crashes, driver qualifications, the number of hours a driver 
may work, vehicle maintenance and inspections, and transportation of 
hazardous materials. While FMCSA believes these to be effective, 
compliance reviews are resource intensive and allow only a small 
percentage of the motor carrier industry to be evaluated. 
Historically, for example, FMCSA and its state partners were able to 
conduct compliance reviews of about 3 percent of registered motor 
carriers. As a result, FMCSA was not able to contact the vast majority 
of registered motor carriers, and most were not assigned a safety 

In 2004, FMCSA began to design and develop CSA, a data-driven approach 
to evaluate safety performance that is not contingent on compliance 
reviews. Under this approach, FMCSA has developed the Safety 
Measurement System (SMS)--a computer algorithm that uses safety data 
inputs to measure the safety performance of carriers and individual 
drivers[Footnote 4] and prompt an expanded set of interventions with 
carriers such as warning letters and off-site investigations to 
address safety problems. Through implementation of CSA, FMCSA expects 
to not only assess a larger portion of the motor carrier industry but 
also better identify unsafe carriers and drivers; hold carriers and 
drivers more accountable for sustained performance by regularly 
determining their safety fitness; and expand the range of 
interventions to be used with carriers and drivers that fail to comply 
with safety requirements. Ultimately, FMCSA officials expect this 
approach to reduce motor carrier crashes, fatalities, and injuries. 

FMCSA has begun program implementation but has more tasks to complete 
before CSA will be fully implemented. In 2008 FMCSA launched an 
operational-model test (pilot test)[Footnote 5] of the initiative in 
four states and later expanded the pilot to nine states over 30 months 
through June 2010. The University of Michigan's Transportation 
Research Institute (UMTRI) is analyzing the results, with its final 
report due in late summer 2011. FMCSA officials believe that the 
preliminary pilot-test results have been positive and have helped 
inform key changes to CSA's design and implementation as issues 

As part of CSA implementation, FMCSA has made carriers' safety data 
collected by states publicly available since December 2010. Also, 
FMCSA has implemented all of its CSA interventions in pilot states and 
has begun implementing CSA interventions, such as onsite focused 
compliance investigations, in non-pilot states. According to FMCSA 
officials, once nationwide training of investigators and inspectors 
has been accomplished (targeted for summer 2011), other interventions--
such as offsite investigations and cooperative safety plans--will be 
rolled out nationwide as well. FMCSA is seeking to gain new authority 
to regulate drivers through the next surface transportation 
reauthorization bill; if it gains this authority, the agency plans to 
make driver safety data public as well.[Footnote 6] Finally, according 
to FMCSA officials, they will not be able to use the SMS scoring 
system to determine whether carriers are fit and safe to operate until 
their rulemaking on the Carrier Safety Fitness Determination is 
completed, most likely in 2012.[Footnote 7] Until then, FMCSA will 
continue to determine whether a carrier is fit to operate and base 
carrier safety fitness determinations on the outcomes of comprehensive 
onsite reviews only. According to FMCSA, in order to fully implement 
CSA, a new Carrier Safety Fitness Determination rulemaking is 

Obligations to Develop CSA Have Generally Increased Since Fiscal Year 
2007 to Support Safety Measurement, Software Modernization, and 
Training, Among Other Things: 

Obligations for CSA development increased from fiscal year 2007 
through fiscal year 2009, and FMCSA requested further funding 
increases for fiscal year 2011. 

* Fiscal years 2007 through 2008: According to FMCSA officials, the 
agency used existing resources in the early stages of developing the 
program and implementing the pilot. FMCSA's obligations for CSA in 
fiscal year 2007 were $2.3 million. This included travel for FMCSA 
staff involved in developing CSA, outreach efforts, and a contract 
with the Department of Transportation's John A. Volpe National 
Transportation Systems Center (Volpe) to develop SMS to measure the 
safety of motor carriers and drivers and help develop new 
interventions under CSA and other technical support (see fig. 1). 
Obligations increased to $6.6 million in fiscal year 2008 as FMCSA 
began pilot testing CSA and training its field staff and state 
partners, and continued outreach efforts and work under the Volpe 
contract. In addition, under a cooperative agreement with UMTRI, FMCSA 
awarded a $250,000 task order to UMTRI to evaluate the results of the 
pilot tests. UMTRI began this work in January 2008; its final report 
is due later in 2011. 

* Fiscal years 2009 through 2010: Obligations increased significantly 
in fiscal years 2009 and 2010, to $11.8 and $9.5 million, 
respectively. Although obligations for travel and the Volpe contract 
continued at comparable levels in fiscal years 2009 and 2010, total 
expenditures increased significantly as FMCSA began its information 
technology modernization effort, known as Creating Opportunities, 
Methods, and Processes to Secure Safety (COMPASS) under contract with 
Science Applications International Corporation (SAIC). FMCSA expects 
COMPASS, which includes modules specifically related to CSA, to 
facilitate investigators' ability to access carrier information. FMCSA 
obligated $5.6 million and $4.2 million in fiscal years 2009 and 2010, 
respectively, for SAIC to develop the CSA segments of this effort. 
[Footnote 8] 

* Fiscal year 2011: FMCSA requested a total of $14.3 million for 
fiscal year 2011; however, the Department of Transportation's 
appropriation has not yet been enacted. Spending has been projected to 
increase across all categories for 2011 as FMCSA provides training in 
states that did not participate in the pilot test, fully implements 
CSA for carriers, and completes regulatory analysis for the Carrier 
Safety Fitness Determination Rule. FMCSA plans to increase spending on 
travel and training to $200,000 and $250,000, respectively and 
continue developing SMS and obtain technical support under the Volpe 
contract in fiscal year 2011 at a cost of $5.9 million. FMCSA also 
plans to increase expenditures to develop COMPASS, including $8 
million on modules specifically related to CSA. 

Figure 1: FMCSA's CSA Obligations for Fiscal Years 2007 through 2010 
and Budget Request for Fiscal Year 2011[A]: 

[Refer to PDF for image: multiple line graph] 

Fiscal year 2007: 
Volpe contract to develop measurement system: $2,075,000; 
Portion of COMPASS[B] IT contract dedicated to CSA: N/A; 
Travel: $199,000; 
Training: 0; 
UMTRI contract to evaluate program: [Empty]; 
Totals: $2,274,000. 

Fiscal year 2008: 
Volpe contract to develop measurement system: $5,936,000; 
Portion of COMPASS[B] IT contract dedicated to CSA: N/A; 
Travel: $274,000; 
Training: $108,000; 
UMTRI contract to evaluate program: $250,000; 
Totals: $6,568,000. 

Fiscal year 2009: 
Volpe contract to develop measurement system: $5,819,000; 
Portion of COMPASS[B] IT contract dedicated to CSA: $5,600,000; 
Travel: $251,000; 
Training: $131,000; 
UMTRI contract to evaluate program: [Empty]; 
Totals: $11,801,000. 

Fiscal year 2010: 
Volpe contract to develop measurement system: $5,001,000; 
Portion of COMPASS[B] IT contract dedicated to CSA: $4,231,000; 
Travel: $241,000; 
Training: $74,000; 
UMTRI contract to evaluate program: [Empty]; 
Totals: $9,547,000. 

Fiscal year 2011 budget request: 
Volpe contract to develop measurement system: $5,580; 
Portion of COMPASS[B] IT contract dedicated to CSA: $8,000,000; 
Travel: $200,000; 
Training: $250,000; 
UMTRI contract to evaluate program: [Empty]; 
Totals: $14,300,000. 

Source: FMCSA. 

[A] These amounts do not include the cost of FTEs dedicated to the 
program, which was not available. (See next section for further 
information on FTEs and other staff devoted to the CSA program.) 

[B] COMPASS is an FMCSA-wide information technology program; these 
figures refer to the amount obligated on the portion dedicated to CSA. 

[End of figure] 

FMCSA Has Used A Small Number of Existing Staff to Develop CSA, 
Relying on Contractors to Conduct Much of the Work: 

To date, according to FMCSA officials, the agency has used a 
relatively small number of its staff resources to work on the CSA 
project. At most, 5 of its more than 1,000 FTE staff have worked full 
time to develop and implement CSA since 2006. Beginning in fiscal year 
2005, FMCSA dedicated two staff--one from a program office in 
headquarters and one from the field--to develop CSA. In fiscal year 
2007, FMCSA increased the number of CSA-dedicated headquarters staff 
to three, for a total of four staff dedicated to CSA. In 2009, FMCSA 
added another field staff member to work on CSA, for a total of five 
FMCSA FTE staff dedicated to CSA. FMCSA considers these assignments 
temporary and expects staff to return to their normal duties after it 
fully deploys CSA. 

In addition to the 5 staff with full-time CSA duties, up to 40 FMCSA 
staff have assisted in developing and implementing CSA on a limited 

* Beginning in 2006, 10 FMCSA staff and 2 staff from FMCSA's state 
partners--Colorado and Missouri--spent 50 percent of their time 
developing and implementing CSA. According to FMCSA officials, these 
staff served as subject matter experts. 

* From 2007 through 2009, 12 staff members from various FMCSA program 
offices participated on the CSA Steering Committee to help develop and 
implement CSA, facilitate coordination between program offices, and 
ensure availability of resources and staff. According to FMCSA, this 
effort took about 5 percent of these staff members' time. 

* Since fiscal year 2009, the number of staff involved in the CSA 
rollout has increased to about 40 staff members who have participated 
in teams of technical or subject matter experts to facilitate the CSA 
pilot test and full implementation of CSA. According to FMCSA, this 
effort has taken roughly 5 to 15 percent of these staff members' time. 

Much of CSA's staffing resources have come from contractors. In 
particular, Volpe conducted much of the work to develop SMS. According 
to FMCSA, an estimated 19 Volpe staff have provided technical support 
on an as-needed basis since 2005. In addition, beginning in fiscal 
year 2009, FMCSA hired contract staff in the pilot test states to 
assist safety investigators with the CSA interventions. These staff, 
known as program analysts, were paid under the Volpe contract to 
handle tasks such as setting up appointments with carriers for on-site 
investigations, requesting documentation from carriers for off-site 
investigations, and providing background information on motor carriers 
to be investigated. FMCSA initially hired one staff in each of the 
four original pilot states--Colorado, Georgia, Missouri, and New 
Jersey. In fiscal year 2010, FMCSA hired program analysts for some of 
the additional pilot states. FMCSA hired one program analyst each for 
Montana and Kansas, and also hired one program analyst to cover 
Maryland and Delaware. Minnesota currently does not have a program 

FMCSA Plans to Significantly Increase Resources to Fully Implement CSA: 

FMCSA's budget request for fiscal year 2012 proposes $78 million--much 
of it for 696 full time positions, including 98 new positions[Footnote 
9] to fully implement CSA.[Footnote 10] Specifically, FMCSA officials 
plan to use the funding and additional staff as follows: 

* $61 million for 696 total full-time positions, including salary and 
benefits. According to an FMCSA official, these positions represent 
most of FMCSA's existing field staff as well as 98 new full-time 
positions. FMCSA estimates the new positions to cost $4.7 million. 
Once CSA is fully implemented in all states, FMCSA expects its 
interventions and enforcement workload in the field to increase, 
resulting in the need for additional staff, which primarily will be 
comprised of safety investigators and program analysts.[Footnote 11] 
According to FMCSA officials, safety investigators hired in the future 
will perform duties related to CSA as part of their overall 
responsibilities, which would include work for other FMCSA programs. 
Staff in program analyst positions, introduced during the pilots, 
would assist safety investigators by performing administrative tasks 
and allowing safety investigators to focus on the interventions 
themselves.[Footnote 12] 

* $15 million for travel, equipment, training, and other expenses to 
support the 696 full-time positions. 

* $2 million for contracts. 

FMCSA's fiscal year 2012 budget request also includes $261.8 million 
for a new CSA grant program which is proposed to consolidate 
activities currently performed and funded under several grant 
programs.[Footnote 13] The CSA grant program would fund activities 
states and local law enforcement currently perform, such as roadside 
inspections, interventions, compliance reviews, and targeted 
enforcement and inspections. 

FMCSA also plans to develop the Notice of Proposed Rulemaking (NPRM) 
for the Carrier Safety Fitness Determination and complete the driver 
safety measurement system portion of CSA. At present, FMCSA expects to 
issue the NPRM in fall 2011 and finalize the rule in 2012. FMCSA 
officials indicated that they will finish developing the driver safety 
measurement system after completing the rulemaking for the Carrier 
Safety Fitness Determination and passage of the pending surface 
transportation reauthorization. 

Agency Comments: 

We provided a draft of this correspondence to DOT officials for their 
review and comment. DOT provided technical clarifications which we 
incorporated as appropriate. 

We are sending copies of this report to the Secretary of 
Transportation and the Administrator of FMCSA. The report also is 
available at no charge on the GAO Web site at [hyperlink,]. 

If you or your staffs have any questions concerning this report, 
please contact me at (202) 512-2834 or Contact 
points for our Offices of Congressional Relations and Public Affairs 
may be found on the last page of this report. Major contributors to 
this report were Ed Laughlin, Assistant Director; Lynn Filla-Clark, 
Analyst-in-Charge; Lauren Calhoun; Elke Kolodinski; Kirsten Lauber; 
Amy Rosewarne; and Larry Thomas. 

Signed by: 

Susan Fleming: 
Director, Physical Infrastructure Issues: 

[End of section] 


[1] The program was originally titled Comprehensive Safety Analysis 
2010. FMCSA renamed it Compliance, Safety, Accountability in December 

[2] This direction is contained in the Senate Committee Report, S. 
Rep. No. 111-69, at 60 (2009), as approved by the conference committee 
in the Joint Explanatory Statement accompanying the Consolidated 
Appropriations Act, 2010, Pub. L. No. 111-117, Division A. 

[3] We are continuing this work and expect to release a full report on 
FMCSA's progress in implementing CSA later t his year. 

[4] FMCSA has developed two separate measurement systems--one for 
carriers and one for drivers--for use under CSA. 

[5] FMCSA's operational model testing involved a total of nine states. 
During Phase 1, four states (Colorado, Georgia, Missouri, and New 
Jersey) tested CSA, with 50 percent of the carriers in each state 
being subject to CSA and the other 50 percent of the carriers being a 
control group subject to SafeSTAT, FMCSA's prior enforcement model. 
During Phase 2, FMCSA added five states (Delaware, Kansas, Maryland, 
Minnesota, and Montana) to the testing, with 100 percent of the 
carriers in each state subject to CSA. For this report, we will refer 
to the operational-model test as the "pilot test." 

[6] The current authorization expired in 2009 but has been extended 
several times, the most recent of which will expire on March 4, 2011. 
Pub. L. No.111-322, 124 Stat. 3518 (2010). 

[7] FMCSA officials expect to issue an NPRM in fall 2011 and finalize 
the rule in 2012. 

[8] According to FMCSA officials, these amounts represent the amount 
allocated to the CSA segments of COMPASS. Most of the work to develop 
COMPSS began in fiscal year 2009, which accounts for the greater 
allocation in that year. 

[9] According to FMCSA, the 98 full-time positions equate to 49 FTEs 
because the positions are annualized at a rate of 50 percent since not 
all personnel will be on board at the beginning of the fiscal year and 
will instead be added incrementally. 

[10] FMCSA officials acknowledged that, under the current constrained 
budgetary environment, the agency may not receive the requested 
funding, which would result in fewer interventions with carriers. 

[11] Specifically, FMCSA is requesting 30 safety investigators and 51 
program analysts as well as 6 intervention managers, 5 investigative 
assistants, 4 litigation attorneys, 1 enforcement attorney, and 1 
adjudication attorney. 

[12] According to the FMCSA officials we met with in pilot states that 
have program assistants, this position allowed safety investigators to 
focus more time on investigations and less time handling these tasks. 
In contrast, one pilot state we visited had not yet filled the program 
analyst position, and officials reported that safety investigators 
spent considerable time following up with carriers that either did not 
provide requested documents or only provided portions of the requests. 

[13] FMCSA's fiscal year 2012 budget request proposes three primary 
grants programs: CSA, Driver Safety, and Data Technology. The CSA 
grant includes the current Motor Carrier Safety Assistance Program, 
New Entrant, Border Enforcement, and the Safety Data Improvement 
Program. According to FMCSA, consolidating these grant programs will 
provide flexibility to move funds among the grant programs to meet 
state and program needs. 

[End of section] 

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