Household Goods Moving Industry: Progress Has Been Made in Enforcement, but Increased Focus on Consumer Protection Is Needed

In 2009 we found the Federal Motor Carrier Safety Administration's (FMCSA) priority was the agency's safety mandate and more focus was needed to address consumer protections in the agency's household goods program. The Federal Trade Commission is a model for consumer protection efforts and could provide FMCSA with insights into overseeing the interstate household goods moving industry. Therefore we recommended FMCSA review the Federal Trade Commission's approach to consumer protection and make changes to its interstate household goods efforts. In response, FMCSA met with Federal Trade Commission officials and reviewed the Bureau of Consumer Protection's (BCP) approach to consumer protection law enforcement, including targeted federal, state, and local task forces and its consumer education programs and outreach efforts. Officials from FMCSA began meeting with Federal Trade Commission officials in June 2010 and issued a memo outlining the results of their review in October 2011. As a result of FMCSA's review, the agency applied and was accepted as a member of the Federal Trade Commission's Consumer Sentinel Network that gives FMCSA access to a consumer protection information sharing network that includes a complaint database, a directory of legal and investigative contacts, and a network that allows communications among members on specific investigations. In addition, officials from FMCSA learned and applied some of the Federal Trade Commission's investigative techniques. By applying methods learned from the Federal Trade Commission's approach to consumer protection, FMCSA will increase its ability to ensure consumer protections and improve the performance of its household goods program.

In 2009, we reported that the Federal Motor Carrier Administration (FMCSA) had taken a number of additional steps to improve its enforcement including establishing in 2008 a Household Goods Technical Assistance Group made up of eight household goods specialists and a field administrator as the group leader to increase coordination among its household goods specialists and to share best practices. The agency also established a "Top 100 List" in 2009 that prioritizes interstate household goods movers to target for investigation. However, because these efforts were recently implemented, it was too soon to know their impact and too early to understand whether they would be effective in enhancing consumer protections. Therefore we recommended FMCSA develop metrics and milestones for these consumer protection activities, including conducting an evaluation of the new strategy that uses the "Top 100 List" and leveraging the newly formed Household Goods Technical Assistance Group. The Department of Transportation Fiscal Year 2011 budget included the performance measure of household goods commercial review improvement rate with a target of reaching 20 percent in 2011. This metric and milestone includes Household Goods Technical Assistance Group efforts as outlined in FMCSA's household goods program goal and logic model. In 2012 FMCSA provided an evaluation of the use of the "Top 100 List" in enforcement. The evaluation included the number of carriers that were added to the list, received compliance reviews and were subject to enforcement actions from FY 2009 through FY 2011. Establishing metrics and milestones that include the Household Goods Technical Assistance Group and evaluating the "Top 100 List" will allow FMCSA to more effectively track and monitor the performance of its consumer protection activities.

In 2009, we reported that the Federal Motor Carrier Safety Administration (FMCSA) efforts to educate and provide information on household goods movers to consumers needed improvement. Many of the users of the education materials indicated that better information and technologies were needed to deliver information more effectively. Therefore we recommended FMCSA continue to assess education and outreach efforts by forming a task force made up of communication, industry, and consumer protection experts to monitor and make changes as appropriate to the communications strategy once baseline metrics have been established for its current education and outreach efforts to consumers. FMCSA updated the objectives and goals for the Household Goods Outreach and Education performance element in the agency's Fiscal Year 2011 Budget to support the new baseline metric "Household Goods Commercial Intervention Improvement Rate." FMCSA measures success in terms of fewer consumer complaints against household goods carriers following a commercial review intervention. In addition, rather than using limited resources to form a new task force, the agency leveraged the existing Household Goods Working Group to include communication, industry and consumer protection experts to assess, monitor and make appropriate changes to its communication strategy. The Household Goods Technical Assistance Group also provides support to the Household Goods Working Group in the form of recommendations and more subject matter expertise from the field. In addition, FMCSA has development a performance measure, program goal and logic model for the household goods program that clearly articulates the agency's goal for consumer protection. By articulating this goal and continuing to monitor, assess and make appropriate changes to its education and outreach efforts, FMCSA will improve its performance of its outreach and education efforts and its ability to ensure consumer protection.

In 2009, we reported that the Federal Motor Carrier Safety Administration (FMCSA) had fallen short in its consumer protection efforts by not establishing a comprehensive strategy or adequate performance measures and by not implementing adequate outreach to or coordination with federal and state law enforcement and regulatory officials. FMCSA officials told us that the agency had recently developed a performance measure of household goods effectiveness that as of September 2009, was under review by the Office of Management and Budget (OMB) for inclusion in FMCSA's fiscal year 2011 budget and updated strategic plan. FMCSA officials did not provide us with the details of the measure (e.g., how "improvements" would be defined and measured) since it was still under review by OMB, and we were thus unable to assess its appropriateness. In our view, any performance measures in this area would need to be clearly linked to FMCSA's full range of consumer protection responsibilities involving the household goods moving industry--including enforcement; education and outreach; establishing and maintaining partnerships; and collecting, monitoring, and reporting complaints. Therefore we recommended DOT ensure performance measures for household goods efforts are clearly linked to FMCSA's full range of consumer protection responsibilities involving the household goods moving industry including enforcement, establishing and maintaining partnerships, education and outreach, and collecting data and reporting on consumer complaints. In response, DOT updated their household goods performance measures in the FY 2011 budget to include a household goods commercial review improvement rate with a target of reaching 20 percent in 2011. In 2012, the agency documented how the performance measure linked to the full range of its household goods moving industry consumer protection responsibilities--including enforcement, establishing and maintaining partnerships, education and outreach, and collecting data and reporting on consumer complaints--by creating a household goods program goal to "contain and prevent deceptive practices in the interstate household goods industry protecting the consumer." The agency linked the goal to the range of consumer responsibilities through a logic model that identified resources, activities, outputs, outcomes and impacts that would contribute to the household goods program goal and performance measures. The development of performance measures, program goal and logic model for the household goods program that clearly outlines how FMCSA's addresses household goods consumer protection responsibilities will allow the agency to better track and monitor the effectiveness of its consumer protection efforts.