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pdfUnited States Government Accountability Office
GAO
Report to Congressional Committees
December 2005
FEDERAL MOTOR
CARRIER SAFETY
ADMINISTRATION
Education and
Outreach Programs
Target Safety and
Consumer Issues, but
Gaps in Planning and
Evaluation Remain
GAO-06-103
a
December 2005
Accountability Integrity Reliability
Highlights
Highlights of GAO-06-103, a report to
congressional committees
FEDERAL MOTOR CARRIER SAFETY
ADMINISTRATION
Education and Outreach Programs Target
Safety and Consumer Issues, but Gaps in
Planning and Evaluation Remain
Why GAO Did This Study
What GAO Found
The Federal Motor Carrier Safety
Administration (FMCSA) is
responsible for improving
commercial vehicle safety and uses
education and outreach as part of
its efforts. The House report
accompanying the fiscal year 2005
Department of Transportation
(DOT) appropriations bill asked
GAO to report on FMCSA’s
education and outreach programs
to the House and Senate
Committees on Appropriations.
GAO (1) describes FMCSA’s
education and outreach programs
and how they relate to FMCSA’s
goals (2) identifies the extent to
which FMCSA has evaluated its
education and outreach programs
and (3) describes the extent to
which FMCSA’s education and
outreach programs are effective.
FMCSA’s education and outreach programs—New Entrant, Non-Entrant,
Motor Coach, Safety Belt, and Household Goods— target different
audiences, including the motor carrier industry, commercial vehicle drivers,
and the public. Total funding for these programs in fiscal year 2005 was $36.3
million; the largest share (about $33 million) went to the New Entrant
program, which is designed to inform newly registered motor carriers (new
entrants) about motor carrier safety standards and regulations to help them
gain compliance with FMCSA requirements. FMCSA uses many approaches,
such as direct contact with carriers, media campaigns, distributing printed
materials, and establishing Web sites to provide information to target
audiences. FMCSA has not described how its education and outreach
program activities link expected changes in attitudes and behavior to
broader goals, such as DOT’s strategic objective of reducing transportationrelated fatalities. FMCSA officials state that the education and outreach
activities and programs link to agency goals at a high level, but this was not
evident from our review, with the exception of the Safety Belt program.
FMCSA has used a logic model as a tool in other programs to show the
relationship between program activities and broader goals.
What GAO Recommends
GAO recommends that the
Secretary of Transportation direct
the FMCSA Administrator to
describe the link between
education and outreach programs
and agency strategic objectives and
evaluate the extent to which
educational information and safety
audits are helping new carriers
learn FMCSA requirements. GAO
provided a draft of this report to
DOT for its review and comment.
FMCSA officials commented on the
link between its education and
outreach programs and its overall
goals. Based on FMCSA’s
comments, GAO acknowledged
FMCSA’s comments and clarified
the recommendations.
www.gao.gov/cgi-bin/getrpt?GAO-06-103.
To view the full product, including the scope
and methodology, click on the link above.
For more information, contact Katherine
Siggerud at (202) 512-2834 or at
[email protected].
FMCSA has begun some evaluations of its education and outreach programs,
and plans other evaluations of these programs. However, although FMCSA’s
New Entrant program has existed for over 2 years, FMCSA has no plans to
evaluate its New Entrant program until 2008. Thus FMCSA has no
information on whether information on its safety requirements, provided
through the Education and Technical Assistance package or during New
Entrant safety audits—targeted toward truckers newly entering the
industry—effectively communicate information to new entrants. This lack
of evaluation makes it difficult to determine the impact the education
portion of the New Entrant program has on commercial motor vehicle
safety.
Since FMCSA currently has little information on how its programs have
affected attitudes and behavior, it is difficult to determine the effectiveness
of FMCSA’s effort. However, the designs of two programs appear to follow
theories and research regarding media campaigns, which are intended to
influence decision making about safety. Research and behavior theory
suggest that for some types of programs—such as DOT’s Click It or Ticket
program, which is designed to increase safety-belt use by passenger car
drivers—enforcement linked to education can improve results, and FMCSA
has indicated it is linking some education and outreach programs to
enforcement efforts, where appropriate. Finally, motor carrier association
officials whom we spoke with stated that, in their view, FMCSA is doing
some positive things in its education and outreach activities. A public safety
group stated that FMCSA followed reasonable approaches in starting its
education and outreach efforts; however, they would like to see more
information on program effectiveness to help FMCSA refine the programs.
United States Government Accountability Office
Contents
Letter
1
4
9
Results in Brief
Background
FMCSA Has Established Several Education and Outreach Efforts
but Needs Specific Links to Goals
Evaluations of Specific Education and Outreach Programs Impacts
Are Still in Preliminary Stages, but the Lack of a Plan to Evaluate
How New Entrant Safety Audits Improve Knowledge and
Attitudes Raises Concern
The Effectiveness of Education and Outreach Programs Is Unclear,
but Programs Seem to be Reasonably Designed According to
Theories of Behavior Change and Industry Groups
Conclusions
Recommendations for Executive Action
Agency Comments
31
37
38
39
Scope and Methodology
42
Appendix II:
FMCSA Education and Outreach Programs
44
Appendix III:
GAO Contact and Staff Acknowledgments
51
Table 1: Overview of FMCSA Education and Outreach Programs
Table 2: How Fiscal Year 2005 Outreach and Education Funding Is
Being Used
Table 3: Hierarchy of Objective, Goal, and Indicators for FMCSA’s
Commercial Motor Vehicle Safety Objective
13
12
25
Appendixes
Appendix I:
Tables
Figures
Figure 1: Cover of Safety Belt Partnership Brochure
Figure 2: FMCSA Fiscal Year 2005 Education and Outreach
Funding
Figure 3: Program Logic Model
Figure 4: FMCSA’s Evaluations and Planned Evaluations by
Program
Figure 5: Number of New Entrant Safety Audits Completed by
FMCSA and State Agencies (first 7 months of fiscal year
2005)
Page i
18
20
15
17
24
26
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GAO-06-103 FMCSA Education and Outreach
Contents
Abbreviations
CVSA
DOT
FMCSA
GPRA
GSA
MCMIS
NHTSA
OMB
SAFETEA-LU
TAG
Commercial Vehicle Safety Alliance
Department of Transportation
Federal Motor Carrier Safety Administration
Government Performance and Results Act
General Services Administration
Motor Carrier Management Information System
National Highway Traffic Safety Administration
Office of Management and Budget
Safe, Accountable, Flexible, Efficient Transportation
Equity Act: A Legacy for Users
Technical Assistance Group
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Page ii
GAO-06-103 FMCSA Education and Outreach
A
United States Government Accountability Office
Washington, D.C. 20548
December 19, 2005
Leter
The Honorable Joe Knollenberg
Chairman
The Honorable John W. Olver
Ranking Minority Member
Subcommittee on Transportation, Treasury, Housing, and Urban
Development, the Judiciary, the District of Columbia,
and Independent Agencies
Committee on Appropriations
House of Representatives
The Honorable Christopher S. Bond
Chairman
The Honorable Patty Murray
Ranking Minority Member
Subcommittee on Transportation, Treasury, the Judiciary, Housing
and Urban Development, and Related Agencies
Committee on Appropriations
United States Senate
In 2003, large trucks represented 3 percent of registered vehicles in the
country, but nearly 12 percent of the people killed in motor vehicle
accidents died in crashes involving large trucks. The Federal Motor Carrier
Safety Administration (FMCSA), within the Department of Transportation
(DOT), is responsible for improving the safety of commercial vehicle
operations—which includes interstate truck and motor coach (bus)
companies—and has set a safety goal to reduce fatalities from an estimated
2.81 per 100 million truck vehicle miles traveled in 1996 to no more than
1.65 per 100 million truck vehicle miles traveled by the end of 2008. Among
the ways that FMCSA attempts to achieve this and other goals is through
education and outreach activities.1 For example, the agency provides
information to consumers about motor coach safety records and what to
consider when hiring a moving company. It also provides new motor
carriers with information on safety requirements and conducts safety
audits to review motor carrier compliance with these requirements. In
some cases, education and outreach efforts regarding safety audits may be
reinforced when followed-up with enforcement.
1
Other activities include working with states and contractors to enforce federal motor
carrier safety regulations.
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GAO-06-103 FMCSA Education and Outreach
In recent years, we have raised concerns about FMCSA education and
outreach efforts. In 2003, for example, we reported that FMCSA’s “Share
the Road Safely” program lacked a clear program strategy and included
activities that were only tenuously linked to program goals, and we
reported that FMCSA had not recently evaluated the program’s
effectiveness.2 In addition, our 2001 report on oversight of the household
goods moving industry noted that DOT and FMCSA had made limited
efforts to provide consumer education that would enable the public to be
more informed about hiring a mover.3 Furthermore, the Congress has
expressed concern about how FMCSA’s education and outreach programs
are meeting broader goals. In the conference report accompanying the
DOT appropriations bill for fiscal year 2005, FMCSA was asked to report by
April 2005 to the House and Senate Committees on Appropriations on
strategies linking outreach and education program initiatives to each goal.
The House report accompanying the DOT appropriations bill for fiscal year
2005 asked us to monitor and evaluate FMCSA’s education and outreach
programs and to report on the status of these programs to the House and
Senate Committees on Appropriations.4 We (1) describe the scope and
nature of FMCSA’s education and outreach programs and how they relate
to FMCSA’s goals, (2) identify the extent to which FMCSA has evaluated its
education and outreach programs, and (3) describe the extent to which
FMCSA’s education and outreach programs are effective. As discussed with
your staff, we focused on five specific education and outreach programs:
(1) the New Entrant; (2) the Non-Entrant; (3) Commercial Safety-Belt Use;
(4) Motor Coach Selection Outreach; and (5) Household Goods Outreach
programs and did not review the “Share the Road Safely” program, which
Congress transferred from FMCSA to the National Highway Traffic Safety
Administration (NHTSA) in fiscal year 2004, with FMCSA retaining a
supporting role. The recent highway reauthorization legislation5 authorizes
funding for this program to both FMCSA and NHTSA and asks us to review
the “Share the Road Safely” program by June 2006.
2
GAO, Truck Safety: Share the Road Safely Program Needs Better Evaluation of Its
Initiatives, GAO-03-680 (Washington, D.C.: May 30, 2003).
3
GAO, Consumer Protection: Federal Actions Are Needed to Improve Oversight of the
Household Goods Moving Industry, GAO-01-318 (Washington, D.C.: Mar. 5, 2001).
4
H.Rept. 108-71, 53.
5
Safe, Accountable, Flexible, and Efficient Transportation Equity Act: A Legacy for Users,
(SAFETEA-LU), Pub. L. 109-59§4127.
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GAO-06-103 FMCSA Education and Outreach
To describe the scope and nature of FMCSA’s education and outreach
programs and FMCSA’s intended results for these programs, we discussed
these programs with FMCSA officials at agency headquarters and two field
locations, and we reviewed program materials and documentation as well
as observed a safety audit for the new entrant program. We also analyzed
both the extent to which FMCSA describes how its programs lead to
agency goals and incorporates its education and outreach programs into its
strategic and program planning and performance budgeting. To identify
approaches to describing how agency programs contribute to agency goals,
we reviewed our previous work on government education programs that
showed how a program logic model—a model that links activities to goals
by analyzing program inputs, outputs, and outcomes—illustrates how
education and outreach activities can influence attitudes and behavior, and
ultimately contribute to agency goals. To identify what the agency was
doing to evaluate these programs, we discussed evaluations and evaluation
plans with FMCSA officials at agency headquarters and two field locations.
We also reviewed evaluation materials, including proposals and statements
of work for planned contracts to carry out programs and program
evaluations. Finally, to identify what is known about the effectiveness of
the programs, we conducted a literature review of media based campaigns
and reviewed the structure and evaluation of these campaigns related to
improving safety as well as behavioral theories used in designing the
campaigns. We selected two behavioral theories that were directly
applicable to the programs under this review, which are called the theory of
reasoned action6 and the general deterrence theory.7 We also discussed
what is currently known about the effectiveness of these programs with
FMCSA officials and with representatives of associations that serve the
trucking, motor coach, and household goods moving industries, as well as a
law enforcement association and public interest groups that are involved in
motor carrier safety. Our work was conducted in accordance with generally
accepted government auditing standards. Appendix I provides the details
of our scope and methodology.
6
The theory of reasoned action helps explain the relationship between attitudes, beliefs,
intentions, and behavior in that people are more likely to undertake an action if they believe
that the outcomes are valued and that they have the necessary opportunities to perform the
action.
7
According to the general deterrence theory, individuals must be exposed to law
enforcement or receive information about law enforcement before they can be deterred
from behavior that may be unsafe or illegal.
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GAO-06-103 FMCSA Education and Outreach
Results in Brief
FMCSA has recently established several education and outreach programs
intended to promote motor carrier safety and consumer awareness.
Although FMCSA documents state that education activities are vital to
FMCSA’s goal of reducing fatalities, injuries, and crashes, FMCSA has not
described how most of its education and outreach programs are linked to
agency goals. Four of the programs we reviewed accounted for a relatively
small portion of FMCSA’s funding—1 percent of the agency’s fiscal year
2005 funding. However, the new entrant program accounted for almost 7.5
percent of FMCSA’s fiscal year 2005 funding. These education and outreach
programs are part of FMCSA’s overall approach to encourage safer
practices and better decision making by communicating information to
motor carriers, commercial drivers, and the public. FMCSA’s education and
outreach programs are as follows:
• The New Entrant program is designed to inform newly registered motor
carriers (new entrants) about motor carrier safety standards and
regulations to help them comply with FMCSA requirements. FMCSA
disseminates information on safety requirements in its Education and
Technical Assistance Package. In addition, FMCSA, state, or contractor
personnel visit new carriers within their first 18 months of operations
for “safety audits” to explain safety requirements and review
documentation. Although primarily informational, a carrier can fail its
safety audit if it cannot document sufficient compliance to pass at least
four of the six sections of the audit and, as a result, could lose its
operating license.
• A planned Non-Entrant program will focus on identifying carriers
engaging in interstate operations that have not registered with FMCSA
as required, making them aware of the requirements and getting them to
register. This program is still being developed but is expected to include
outreach efforts through truck sales and leasing firms.
• The Commercial Motor Vehicle Safety Belt program is aimed at
increasing safety-belt use among commercial drivers, which is lower
than safety-belt use by passenger vehicle drivers. FMCSA, in partnership
with industry, distributes brochures, posters, and bumper stickers
describing the importance of wearing safety belts. The partnership also
distributes its materials at trucking industry trade shows, through law
enforcement programs, and at truck stops.
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GAO-06-103 FMCSA Education and Outreach
• The Motor Coach Outreach program, officially known as Passenger
Carrier Safety, provides information to help organizations and
individuals who hire motor coach (bus) services make safe choices. The
primary program effort is a FMCSA Web site that makes information on
motor coach companies’ safety history accessible to the public.
• The Household Goods Outreach program provides advice to help
individuals planning a move make informed decisions on selecting and
hiring moving companies through brochures, publications, and FMCSA’s
Web site.
Research indicates that the development of education and outreach
programs should include identifying how these programs are expected to
change the target audience’s attitudes and behaviors.8 However, FMCSA
has not clearly described how most of its education and outreach programs
link expected changes in attitudes and behavior to broader goals, such as
DOT’s strategic objective of reducing transportation-related fatalities.9 In
the conference report accompanying the DOT appropriations bill for fiscal
year 2005, Congress requested FMCSA to clarify the link between the
agency’s education and outreach programs and program goals. FMCSA’s
October 2005 response to Congress states that FMCSA considers education
and outreach programs vital in achieving overall DOT and FMCSA safety
goals. However, the agency did not describe how the programs are
intended to influence knowledge, attitudes, and behaviors that will support
FMCSA’s goals. FMCSA officials told us that the agency uses logic models
in its performance budget to establish, at a high level, the link between its
education and outreach program and its goals. However, the link FMCSA
asserts was not evident to us for most of the education and outreach
programs we reviewed. For example, FMCSA’s fiscal year 2006
performance budget does describe how the Commercial Motor Vehicle
Safety Belt program10 will highlight the risks of not wearing a safety belt,
which FMCSA officials believe should improve drivers’ attitudes toward
wearing safety belts, and subsequently meet the program goal of increasing
8
Monash University Accident Research Centre, “A Review of Mass Media Campaigns in
Road Safety,” May 2004.
9
We consider DOT’s strategic objective of reducing transportation-related fatalities as one of
the agency’s broader goals.
10
We refer to the Commercial Motor Vehicle Safety Belt program as the Commercial Safety
Belt program throughout this report.
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GAO-06-103 FMCSA Education and Outreach
safety-belt usage 10 percent by 2009. However, the performance budget
does not describe similar links between other FMCSA education and
outreach programs and how those programs help achieve DOT and FMCSA
safety and productivity objectives. This lack of clarity in FMCSA’s planning,
budgeting, and program documents relating to education and outreach
programs can make it difficult for stakeholders, including congressional
oversight authorities, to see how program activities that seek to change
attitudes and behavior can relate to agency goals and whether the
programs are appropriately targeted. In contrast, FMCSA’s Research and
Technology group has used a logic model to clearly describe how program
activities support agency goals in its strategic plan. As FMCSA further
articulates the links between its education and outreach programs and its
goals, it might consider using a tool such as the one used by FMCSA’s
Research and Technology group to make those relationships clear.
FMCSA has begun some evaluations of its education and outreach
programs. Since most of these programs are relatively new and most
evaluations are still being planned, little information on results is currently
available. Therefore, FMCSA has limited information on program
effectiveness, particularly for the New Entrant program. FMCSA’s
evaluation related activities and gaps in these activities are described
below:
• For the New Entrant program, FMCSA conducted a preliminary
comparison of crash rates for new entrants who had received safety
audits during the first part of 2003 with new entrants who had not
received safety audits and found little difference in the crash rates of the
two groups. In addition, FMCSA is planning to conduct an evaluation
study beginning in 2008 to examine new entrants’ safety performance.
Although the program has been in place for over 2 years, FMCSA has not
evaluated and has not developed plans to evaluate the New Entrant
program, specifically whether the information package or safety audits
effectively communicate information to new entrants, making it difficult
to determine the effectiveness of that program in improving new motor
carriers’ knowledge of safety requirements and ultimately improving
safety.
• For the planned Non-Entrant program, FMCSA is planning to hire a
contractor to identify the target population of non-entrants, measure if
the outreach approaches it implements are reaching the target audience
through focus group studies, and measure changes in knowledge and
attitudes and changes in behavior through surveys.
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GAO-06-103 FMCSA Education and Outreach
• For the Commercial Motor Vehicle Safety Belt program, FMCSA is
installing software to monitor Web site hits, planning focus groups with
motor carrier operators on how safety belt marketing material affected
their awareness of the importance of using safety belts, and planning to
annually measure safety-belt usage by commercial vehicle drivers.
• For the Motor Coach Outreach program, FMCSA uses a web survey to
track exposure to information provided. FMCSA also expects to
evaluate the program under a contract it plans to award, which will
support surveys and other evaluations of its education and outreach
programs.
• For the Household Goods Outreach program, FMCSA has contracted
with the General Services Administration to measure the effectiveness
of its booklet on moving tips in changing consumer knowledge by
surveying the target audience. It also expects to evaluate the program
under the planned survey contract.11
It is difficult to determine the overall effectiveness of FMCSA’s education
and outreach efforts at this time; however, on the basis of behavior theory
and our discussions with industry and public safety groups, the design of
FMCSA’s programs appears to be reasonable for contributing to
commercial motor vehicle safety. Little information on effectiveness is
available, since FMCSA has not completed many evaluations of its
programs, and so it cannot be sure of the extent to which target audiences
have received the information and intend on changing their behavior.
However, two of FMCSA’s education and outreach programs and marketing
materials we reviewed appear to follow theories and research regarding
media campaigns that are intended to influence decision making about
safety. The Household Goods Outreach and Motor Coach Outreach
programs—targeted toward consumers—focus on changing consumer
attitudes by providing information about potential consequences of their
actions. For example, the Motor Coach Outreach program conveys
information on the safety history of motor coach companies. As a result,
after considering this information consumers may change their behavior
and select a motor coach company with a good safety record. In contrast,
research and behavior theory described in several studies we reviewed
suggest that industry—the target audiences of the Safety Belt, New
11
SAFETEA-LU requires GAO to review the impact state consumer protection laws have on
household goods carriers.
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GAO-06-103 FMCSA Education and Outreach
Entrant, and Non-Entrant programs—may be more likely to change
behaviors when exposed to both education and enforcement. FMCSA’s
program documentation indicates enforcement is part of the agency’s
efforts to increase safety-belt usage and will be part of the agency’s efforts
to decrease the number of non-entrants. In part because there are few
sanctions for carriers who fail certain portions of the safety audit, FMCSA
is now increasing the enforcement associated with its safety audits by
making it more difficult to pass the audit and requiring carriers to correct
deficiencies. Currently, a carrier can pass its safety audit even if it fails two
of the six sections of the audit. We found, for example, that over the past 2
years, about 40 percent of the carriers failed the “driver” section of their
safety audits, despite passing the audit overall.12 Finally, motor carrier
association officials whom we spoke with stated that, in their view, FMCSA
is doing several positive things in its education and outreach activities. In
addition, officials of one public safety group suggested that FMCSA
followed reasonable approaches in starting its education and outreach
efforts, so implementation in theory should be effective; however, the
officials would like to see more evaluations on program effectiveness in the
future to help FMCSA refine its programs. Another safety group we spoke
with emphasized FMCSA’s need for stronger enforcement in conjunction
with education and outreach programs.
Our study found that for most of the FMCSA’s education and outreach
programs we reviewed, it is unclear how the activities link to program and
agency goals. In addition, although FMCSA plans to conduct a study
beginning in 2008 of its New Entrant program, the agency has not evaluated
the effectiveness of the education and outreach of this program. To more
clearly describe and better evaluate FMCSA education and outreach
programs, we are recommending that the Secretary of Transportation
direct the Administrator of FMCSA to take two actions: (1) ensure that the
agency describes and documents how education and outreach program
activities link to and support broader program and agency goals in a
planning, program, or budget document that is available to the public and
(2) evaluate the effectiveness of the education and outreach component of
the New Entrant program, assessing the extent to which the Education and
Technical Assistance Package and safety audits are helping new carriers
learn and understand FMCSA requirements. We provided a draft of this
12
This driver section includes critical questions, such as whether the carriers reviewed
drivers’ qualifications before hiring them and whether the carriers’ drivers have been
included in a drug and alcohol testing program.
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GAO-06-103 FMCSA Education and Outreach
report to DOT for its review and comment. In responding to a draft of this
report, DOT and FMCSA officials, through the DOT liaison, provided oral
comments. Agency officials disagreed with GAO’s characterization that
FMCSA has not linked its education and outreach programs with its overall
goals. We acknowledge the FMCSA comments in our report. Because we
did not find this link evident for most of the education and outreach
programs, we retained our recommendation with some clarification. The
officials also provided technical comments, which we incorporated as
appropriate.
Background
FMCSA, established as a separate administration under DOT by the Motor
Carrier Safety Improvement Act of 1999 is responsible for improving the
safety of commercial vehicle operations on the nation’s highways. FMCSA
is engaged in several programs and activities to carry out its mission,
including developing and enforcing Federal Motor Carrier Safety
Regulations, administering Motor Carrier Safety Assistance Program grants
to states, regulating interstate household goods movers, and performing
education and outreach. FMCSA operates through its headquarters in
Washington, D.C.; four regional service centers; and division offices located
in all 50 states, the District of Columbia, and Puerto Rico.
FMCSA undertakes education or outreach while carrying out many of its
functions—for example, in posting regulations pertaining to commercial
drivers’ licensing or transporting hazardous materials on its Web site, or in
providing on-line access to motor carrier crash statistics. FMCSA is also
allocated funding for specific education and outreach programs. In fiscal
year 2005, FMCSA used education and outreach funding for activities
supporting its Safety Belt program targeted to commercial vehicle drivers,
outreach to the public on hiring motor coach services, and outreach to
consumers using household goods movers. Congress also allocated fiscal
year 2005 funding for FMCSA’s program directed at recently registered new
entrant motor carriers and funding to establish an initiative directed to
non-entrants—which are carriers in interstate operations that have not
registered with DOT.
Under the Government Performance and Results Act of 1993 (GPRA),
federal programs should be designed with measurable goals that support
the agency’s overall strategic goals. Congress enacted GPRA to shift
agencies’ focus from simply monitoring activities undertaken to measuring
the results of these activities. Under GPRA, agencies develop multiyear
strategic plans, which are the starting point for their performance
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GAO-06-103 FMCSA Education and Outreach
measurement. Each strategic plan is to include a mission statement, a set of
outcome-related strategic goals, and a description of how the agency
intends to achieve these goals. To measure progress toward the strategic
goals, we have previously reported that the agency should also have a plan
for collecting data to measure and evaluate program performance.13
Without measurable goals and evaluation, it is difficult to determine
whether the program is accomplishing its intended purpose and whether
the resources dedicated to the program efforts should be increased, used in
other ways, or applied elsewhere.
Research conducted on the effectiveness of media campaigns14 indicates
that the development of an education and outreach program should include
identifying how the program is expected to change the target audience’s
attitudes and behaviors. There are several theories and models on affecting
behavior, and two in particular are the most relevant to the education and
outreach programs under this review. This is because the theories are
consistent with the structure and goals of the FMCSA programs we
reviewed. One behavioral model that researchers have developed—the
reasoned action theory—assumes that people will take a desired action if
they believe the action is beneficial, and they have the means to undertake
it. Another model that experts have developed—the general deterrence
theory—indicates that in some circumstances people will take a desired
action when they recognize that they may be punished for failing to act.
The relative roles of education and enforcement depend upon the
program’s target audience, the desired change to be achieved, and other
factors.
Since media campaigns should identify how the program is expected to
change target audiences’ attitudes and behaviors, program managers can
use a tool or framework to show how outreach activities are intended to
influence attitudes and behaviors, and thus achieve broad program goals.
Academic literature on program development and evaluation provides a
number of models. One tool we have previously used to review education
13
GAO, Executive Guide: Effectively Implementing the Government Performance and
Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996).
14
See, for example: Monash University Accident Research Centre, “A Review of Mass Media
Campaigns in Road Safety,” May 2004. This report incorporated a number of behavioral
theories and applied the theories to 11 studies on media-based safety programs.
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GAO-06-103 FMCSA Education and Outreach
and outreach programs15 is called a logic model. A logic model links
program inputs and outputs to program outcomes (see fig. 3). Agencies
have used such a model to plan, evaluate, and adjust program activities. A
logic model can facilitate planning and evaluation by (1) demonstrating
accountability through focusing on measurable outcomes; (2) linking
activities to results to prevent mismatches between program activities and
outcomes; and (3) integrating planning, implementation, evaluation, and
reporting. In addition, a program logic model can help describe a program’s
components and desired results and explain the strategy—or logic—by
which the program is expected to achieve its goals. The logic model can
help clarify the links between program components, focusing on outcomes
that are measured and under some degree of control. In some cases, it may
be difficult to show a direct link—a specific cause and effect—between
program activities and outcomes due to the influence of external factors.
For example, the Safety Belt program, although targeted toward
commercial motor vehicles operators, may have outcomes influenced by
the NHTSA’s “Click It or Ticket” program targeted to passenger car drivers.
Commercial motor vehicle operators could be affected by this program, or
other safety-belt messages, and decide to wear safety belts when driving
commercially. Thus, the Safety Belt program’s initiatives may not have been
the primary factor in determining a particular driver’s safety-belt use.
Finally, once program activities are established and linked to program
goals, organizations can use program evaluation to determine whether or
not a program is meeting its goals. Program evaluations are conducted
periodically to provide an overall assessment of how well a program is
achieving its expected results. We have reported on the value of program
evaluations to assess the impact of a particular program.16 This work
showed that results of evaluations can support decisions on resource
allocation and ways to improve program effectiveness.
15
GAO, Program Evaluation: Strategies for Assessing How Information Dissemination
Contributes to Agency Goals, GAO-02-923 (Washington, D.C.: Sept. 30, 2002).
16
GAO, Program Evaluation: Studies Helped Agencies Measure or Explain Program
Performance, GAO/GGD-00-204 (Washington, D.C.: Sept. 29, 2000). Also see the preceding
footnote.
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GAO-06-103 FMCSA Education and Outreach
FMCSA Has
Established Several
Education and
Outreach Efforts but
Needs Specific Links to
Goals
FMCSA has established several education and outreach programs, with
different purposes targeted to different audiences. Total funding for these
programs in fiscal year 2005 was $36.3 million, with the largest
share—$33.1 million—allotted to the New Entrant program. FMCSA’s
education and outreach efforts are intended to address recognized
problems by communicating information to motor carriers, commercial
drivers, and the public to encourage safer practices and better decision
making. FMCSA activities under these programs range from distributing
brochures and posting information on Web sites, to site visits to newly
registered motor carriers under its New Entrant program. Although FMCSA
officials consider these programs to be linked to agency goals at a high
level, this linkage to broader agency goals is not explicit in the agency’s
planning and budgeting documents. FMCSA officials state that they have
used a logic model in their performance budgets to illustrate the link
between education and outreach and agency goals at a high level. Although
the performance budget implies a link between the education and outreach
program and agency goals, it does not describe how the activities are
intended to support these goals. As a result, it is difficult for stakeholders
to see how education and outreach activities that seek changes in attitudes
and behavior will ultimately contribute to agency goals. Also, without a
clear link, program managers can not easily determine if program activities
are appropriately targeted or if they need to refine their programs to meet
agency goals. In contrast, we found, however, that FMCSA uses a logic
model in the strategic plan for its Research and Technology group to
demonstrate how its programs and activities support agency goals. As
FMCSA continues its efforts to develop the links between its education and
outreach activities and broader goals, it might consider using such a logic
model to make those relationships clear.
Education and Outreach
Programs Address a Range
of Safety and Consumer
Protection Concerns and
Are Targeted to Industry
and the Public
We reviewed five education and outreach programs that FMCSA has
initiated in response to either congressional direction or concerns about
motor carrier operations. FMCSA’s education and outreach programs target
a variety of audiences, including the motor carrier industry, commercial
vehicle drivers, and the public; and they involve a variety of approaches,
such as direct contact with carriers, media campaigns, distributing printed
materials, and establishing Web sites. FMCSA also works with industry and
law enforcement associations, other agencies, and safety-oriented
organizations in carrying out some of these education and outreach efforts.
Four of these programs are about motor carrier, driver, or passenger safety,
while one has a consumer information focus. Table 1 provides a brief
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GAO-06-103 FMCSA Education and Outreach
overview of the target audience, general purpose of the program, and
program activities.
Table 1: Overview of FMCSA Education and Outreach Programs
Program
Target audience
Program purpose
Activities
New Entrant
New motor carriers that have Promoting compliance with
registered with FMCSA
FMCSA safety requirements,
during new carriers’ first 18
months of operation
Non-Entrant
(Planned)
Motor carriers that are
Increasing registrations by carriers • Planned outreach through truck sales and
operating interstate but have that should register with FMCSA
leasing firms
not registered with FMCSA
• Web site on motor carrier regulations
• Education and Technical Assistance Package
• Personal contact with new carriers through
safety audits by state or federal officials, or
contractors
Commercial Motor Commercial vehicle drivers
Vehicle Safety Belt
Use
Increasing safety-belt use by
commercial vehicle drivers
• Brochures, posters, bumper stickers
distributed through trade shows and law
enforcement campaigns
• Safety belt information on Web site
Motor Coach
Outreach
Organizations such as
schools and individuals that
hire motor coach services
Enabling the public to make more • Web site information on selecting a motor
informed choices when selecting a
coach company and company safety
motor coach company
information
Household Goods
Outreach
Individuals that are planning
to move across state lines
Enabling the public to be better
informed about selecting an
interstate moving company
• Brochures distributed through moving
companies and other means
• Web site information on selecting and
contracting with a moving company
Source: GAO analysis of FMCSA information.
The five programs in this review are summarized below, and discussed in
greater detail in appendix II.
New Entrant Program
FMCSA intends the New Entrant program to inform newly registered motor
carriers (new entrants) about motor carrier safety standards and
regulations to help them gain compliance with FMCSA requirements and
improve truck safety and thus reduce crash rates.17 Studies have shown
that new carriers have higher safety violation and crash rates than more
experienced carriers. FMCSA uses its Education and Technical Assistance
Package to communicate safety requirements and other information to new
entrants when they register with DOT. This information package is also
17
According to FMCSA, as of 2004, there were over 677,000 active interstate truck and bus
companies and about 6 percent of these were new carriers.
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GAO-06-103 FMCSA Education and Outreach
available at FMCSA’s Web site, along with carrier registration forms.18 The
primary activity of the New Entrant program is safety audits conducted
through site visits to the new carriers. Safety audits are conducted by
FMCSA, state law enforcement, or contractor personnel, who review the
carrier’s compliance with FMCSA requirements, including driver
qualifications, driver records of duty status, vehicle maintenance records,
and participation in a controlled substance and alcohol use testing
program. As of April 2005, FMCSA had conducted 52,000 safety audits since
the New Entrant program began in 2003.
Non-Entrant Program
FMCSA is developing a Non-Entrant program intended to inform start-up
motor carriers who have not registered with the agency—called
non-entrants—of the requirement to register with FMCSA. FMCSA officials
are concerned that carriers that have not registered with FMCSA may
represent an increased safety risk. FMCSA expects to target motor carriers
who have not registered as interstate carriers with FMCSA, by working
through truck sales and leasing firms to inform start-up motor carriers
about registration requirements and, ultimately, to ensure that the carriers
register as new entrants. FMCSA officials expect to award a contract to
develop the Non-Entrant program before the end of 2005.
Commercial Motor Vehicle
Safety Belt Program
The Commercial Motor Vehicle Safety Belt program is intended to increase
safety-belt use by commercial truck drivers. FMCSA began this effort after
a study showed that only 48 percent of commercial truck drivers used
safety belts, compared with nearly 80 percent safety-belt use by passenger
car drivers. Working through the Commercial Motor Vehicle Safety Belt
Partnership—an organization of government, industry, law enforcement,
and safety associations—FMCSA facilitates and coordinates the
development and distribution of outreach materials, including posters,
bumper stickers, and brochures promoting safety-belt use. (See fig. 1 for an
example of a brochure describing the safety-belt partnership.) Working
through the Partnership allows FMCSA to leverage its resources and tap
into organizations that have their own communication links to the trucking
industry. FMCSA staff distribute materials through trucking industry shows
and events, and state law enforcement personnel distribute materials
during safety enforcement campaigns. FMCSA has prepared over 200,000
brochures and 50,000 bumper stickers for the 2005 “Be Ready, Be Buckled”
18
According to an FMCSA official, FCMCSA is updating the Education and Technical
Assistance package.
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GAO-06-103 FMCSA Education and Outreach
campaign. FMCSA also provides safety belt information through its Web
site.
Figure 1: Cover of Safety Belt Partnership Brochure
Source: FMCSA.
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GAO-06-103 FMCSA Education and Outreach
Motor Coach Outreach Program
The Motor Coach Outreach program provides consumers with information
to help them select and hire motor coach services. The program began
following an increase in motor coach accident fatalities. Currently,
FMCSA’s primary effort is maintaining a Web site that allows individuals to
access advice on selecting a motor coach company and safety information
on specific motor coach companies. For the “Moving Kids Safely”
campaign in 2002 that was part of the Motor Coach Outreach program,
FMCSA created 49,000 brochures; 1,200 posters; and 1,200 “toolkits” to
provide advice to school districts on hiring school bus services. FMCSA
also reaches out to the industry to inform motor coach companies of
regulations and provide safety advice through printed materials and the
agency’s motor coach specialists.
Household Goods Outreach
Program
The Household Goods Outreach program is intended to help consumers
make more informed choices in selecting an interstate moving company to
avoid unscrupulous movers. This program was begun in response to
congressional concern over increasing consumer complaints about
fraudulent moving companies. FMCSA distributes printed material through
moving companies and other means, such as its Web site and the General
Services Administration (GSA) consumer information catalog, to inform
consumers of their rights when dealing with moving companies. The
material that FMCSA has developed includes a new outreach theme:
“Protect Your Memories, Your Money, Your Move” and it includes
brochures and presentations that can be delivered by FMCSA staff. For
example, as of October 2005, FMCSA officials reported that they had
printed a total of 50,000 copies of the two brochures the agency distributes.
FMCSA also maintains a hotline to receive complaints from individuals
about problems with movers and enters them into a database. Although
FMCSA does not get involved in resolving complaints, the agency uses the
database to target firms for investigation. Also, we previously reported that
FMCSA should make the complaint information available to consumers.19
According to FMCSA officials the agency has not yet done this because of
privacy and other legal issues.
19
GAO-01-318.
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GAO-06-103 FMCSA Education and Outreach
Except for the New Entrant
Program, Education and
Outreach Funding
Represents a Small Portion
of FMCSA’s Budget
The five education and outreach programs represent a small portion of
FMCSA’s total funding. Fiscal year 2005 funding for the five programs
totaled $36.3 million, out of approximately $443.3 million to fund FMCSA
operations and grant programs. The New Entrant program accounted for
$33.1 million of the funding for the five programs, while funding for the
other four programs combined was $3.2 million—less than 1 percent of the
agency’s total fiscal year 2005 funding.
The first chart in figure 2 below depicts the New Entrant program, and the
combined funding for the other four programs, as their relative share of
total FMCSA funding in fiscal year 2005. The second chart depicts the
relative size of the four smaller education and outreach programs.
Figure 2: FMCSA Fiscal Year 2005 Education and Outreach Funding
Education and Outreach Fundinga (excluding New Entrant program)
FMCSA funding
0.7%
Other four programs
($3.2M)
Motor coach
($150,000)
Total New Entrant
($33.1M)
5%
7.5%
16%
Safety Belt
($500,000)
46%
91.8%
Remaining FMCSA
($407M)
33%
Non-Entrant
($1.05M)
Household Goods
($1.5M)
Sources: U.S. House of Representatives and FMCSA.
Note: Data resulted from U.S. House of Representatives Report 108-792, Making Appropriations for
Foreign Operations, Export Financing, and Related Programs for the Fiscal Year Ending September
30, 2005, and for Other Purposes (Nov. 20, 2004): and discussions with FMCSA officials.
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GAO-06-103 FMCSA Education and Outreach
a
Congressional language accompanying the fiscal year 2005 DOT appropriations requested FMCSA
to apply $50,000 to the “Safety is Good Business” program. FMCSA officials informed us that this
amount would be added to the $1.0 million appropriated for the Non-Entrant program.
The funding available for education and outreach supports a diverse range
of activities, from the costs of state personnel conducting safety audits, to
the costs of printing and distributing brochures and other materials, and
the costs of contracts being awarded to develop and evaluate education
and outreach activities. The principal activities that FMCSA is undertaking
through the five programs are shown in table 2.
Table 2: How Fiscal Year 2005 Outreach and Education Funding Is Being Used
Program
FY 2005 Funding
New Entrant
$33,100,000
Principal use of fundinga
$30,100,000 in grants to states to conduct safety audits.
$3,000,000 for FMCSA to contract for safety audits.
Commercial Motor Carrier SafetyBelt Use
$500,000
$440,000 interagency transfer to NHTSA for two studies
addressing safety belt use by commercial drivers.
$24,400 for brochures, posters, bumper stickers and other
materials prepared for “Be Ready, Be Buckled” campaign.b
Motor Coach
Outreach
$150,000
Printing and distributing brochures, Web site maintenance, and
surveys of Web-site users.
Household Goods
Outreach
$1,488,000
$900,000 for education, outreach and evaluation support
contracts.
$570,000 for complaint database development and
maintenance.
Non-Entrant
$1,050,000
$1,000,000 appropriated for a Non-Entrant program plus
$50,000 targeted for “Safety is Good Business,” will be used to
contract for development of a Non-Entrant program.
Source: FMCSA information.
a
Because these examples illustrate the principal use of components of these programs, in some cases
they do not add to the total amounts spent in the programs.
b
The Commercial Vehicle Safety Alliance (CVSA) provides additional financial support for printing and
distributing brochures under this initiative.
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GAO-06-103 FMCSA Education and Outreach
FMCSA Has Not Clearly
Articulated How Its
Education and Outreach
Initiatives Will Support
Broader Goals
Congress has expressed concern about how FMCSA’s education and
outreach activities are meeting broader goals, such as individual program
goals, or DOT’s strategic goals. The conference report accompanying the
DOT appropriations bill for fiscal year 2005, for example, asked that
FMCSA report by April 2005 to the House and Senate Committees on
Appropriations on strategies linking outreach and education program
initiatives to each goal.20 FMCSA sent its report on October 11, 2005. The
report indicates that FMCSA believes education and outreach programs
support the overall DOT safety strategic objective of “enhancing public
health and safety by elimination of transportation deaths and injuries.”
FMCSA also indicates that every education activity undertaken “is vital to
FMCSA’s goal of reducing fatalities, injuries, and crashes, and attaining a
large truck crash rate of no more than 1.65 fatalities per 100 million miles of
truck travel by the end of 2008.”
Although the report was intended to address congressional concerns about
linking education and outreach to program goals, it is unclear specifically
how this will be accomplished, since the report does not describe how
these programs are intended to influence knowledge, attitudes, and
behaviors and thus support FMCSA’s broader goals. Although the report
describes in detail the activities FMCSA is undertaking for each of these
programs, it does not describe how these activities are intended to change
attitudes and behaviors that will ultimately meet FMCSA’s goals.
In addition, although FMCSA’s fiscal year 2006 performance budget has
some discussion of how activities support FMCSA and DOT safety and
productivity goals, except for the Commercial Motor Vehicle Safety Belt
program, none of the budget or program documentation we reviewed for
FMCSA’s education and outreach programs provides detailed descriptions
about how activities link to goals. A greater level of detail in the description
of how education and outreach program activities link to goals would help
the public and other interested parties to see how program activities that
seek changes in attitudes and behavior will ultimately contribute to agency
goals. Furthermore, without this link, program managers cannot easily
determine if program activities are appropriately targeted or if they need to
refine their programs to meet agency goals.
20
H. Rept. 108-792, 1414, which refers also to H. Rept. 108-671.
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GAO-06-103 FMCSA Education and Outreach
FMCSA officials stated that information about education and outreach
programs is reported in DOT’s strategic plan and in FMCSA’s performance
budget documents.21 However, DOT’s strategic plan does not specifically
address FMCSA’s education and outreach programs and refers readers to
the performance budgets for more detailed, program-specific information.
FMCSA’s performance budget documents identify strategic objectives, such
as saving lives and reducing injuries by preventing bus and truck crashes,
that link and contribute to objectives in DOT’s strategic plan, such as
reducing transportation-related fatalities. It also identifies underlying
performance goals and indicators for each objective. For example,
FMCSA’s strategic objective for safety is illustrated in table 3.
Table 3: Hierarchy of Objective, Goal, and Indicators for FMCSA’s Commercial Motor
Vehicle Safety Objective
Strategic objective
Save lives and reduce injuries by preventing truck and bus
crashes.
Performance goal
Reduce the rate of large truck-related fatalities to no more than
1.65 fatalities per 100 million truck vehicle miles traveled by
the end of 2008.
Leading indicators
Fatalities in large truck crashes.
Intercity bus fatalities.
Injuries in large truck crashes.
Rate of large truck-related injuries.
Source: Performance Budget Estimates section of FMCSA’s Fiscal Year 2006 Budget Submission to Congress.
The performance budget documents address education and outreach
primarily under this strategic objective for safety, by stating that “educating
carriers about the benefits of operating safely, and in compliance with
safety regulations, is advantageous to both the carrier and enforcement
community.” The budget also states that the education programs are
designed to change “the knowledge, attitudes, and behaviors of commercial
motor carriers, commercial motor vehicle drivers, and passenger vehicle
drivers, driving in the vicinity of large trucks.”
21
Performance budgets are integrated budgets that tie budget items such as grants and
operational funding to outcomes that will be achieved by the funding used. The budget
requests justify and describe the intended program outputs and outcomes rather than inputs
and processes.
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GAO-06-103 FMCSA Education and Outreach
However, the performance budget does not provide specific information
for each program on how these expected attitude and behavior changes are
linked to broader goals. Of the five programs included in our review, the
description of the safety belt initiative provides the clearest information
articulating how the program is intended to affect the knowledge, attitudes,
and behaviors of its targeted audience, and consequently to improve safety.
FMCSA describes how education will highlight the risks of not wearing a
safety belt, which in turn is intended to improve drivers’ attitudes toward
wearing safety belts, and subsequently meet the program goal of increasing
safety-belt usage 10 percent by 2009 and further, meet the strategic
objective of reducing fatalities.22 The performance budget also indicates
that education will be combined with traffic enforcement of safety-belt
requirements to achieve this outcome. In contrast, the performance budget
discusses the New Entrant program in terms of staffing, funding, and the
number of safety audits to be done in fiscal year 2006, without defining a
goal for what the New Entrant program will accomplish and how that
accomplishment would contribute to the strategic objective of reducing
fatalities.
In addition, the links between the Motor Coach and Household Goods
program activities and broader strategic goals are difficult to discern.
Specifically, the performance budget document explains that the Motor
Coach program seeks to increase consumers’ knowledge about the safety
records of carriers, with a potential side benefit of encouraging motor
carriers to maintain good safety records. FMCSA does not, however,
describe how affecting consumers’ choice of a particular motor coach
company would support the overall strategic objective of reducing
transportation-related fatalities. FMCSA’s performance budget relates its
Household Goods program to DOT’s mobility and FMCSA’s productivity
objectives. The mobility objective is “to advance accessible, efficient, and
22
In October 2005, FMCSA officials informed us that the goal was a 10-percent increase in
safety-belt use by 2009. This represents a change from the goal of a 15-percent increase
stated in the fiscal year 2006 performance budget.
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GAO-06-103 FMCSA Education and Outreach
intermodal transportation for the movement of people and goods.”23 The
productivity strategic objective is “to promote efficient and economical
motor carrier operations to sustain mobility and economic growth.” The
performance budget document asserts links between these objectives and
the education and outreach program, but it does not explain how specific
activities—such as establishing its Web site on selecting moving companies
and creating brochures on consumer rights and responsibilities—support
either of these objectives.24
On the basis of our discussions with FMCSA officials, it appears the agency
is attempting to more clearly describe how education and outreach
activities link to the agency’s goals. FMCSA acknowledged that there may
have been some disconnection between the strategic planning and
budgeting processes in the past, but managers have recently received
training on defining a program’s desired outcome and then linking
inputs—such as funding—and outputs. Officials told us that as a result the
agency’s proposed fiscal year 2007 performance budget will better link
programs and goals to budget requests. FMCSA’s eventual goal is to link
program outputs to outcomes, as well as identifying measurable and
verifiable goals to the extent possible.
A Logic Model Provides a
Framework for Linking
Program Activities to
Desired Results and Goals
Although the relationships among program activities, changes in
knowledge and behaviors, and broader goals can sometimes seem intuitive,
laying a program out through a logic model can be useful for program
managers and stakeholders to demonstrate and understand these
relationships. FMCSA officials state that they use a logic model in its
performance budget to link education and outreach to agency objectives.
However, the performance budget implies a link between the education
and outreach program budget and agency goals without describing how
FMCSA intends the program to change behaviors, such as following federal
safety regulations, to support agency goals, as would be shown in a logic
23
The ICC Termination Act of 1995 transferred federal responsibilities for protecting
consumers who use commercial moving companies for interstate moves to the DOT; and the
Motor Carrier Safety Improvement Act established FMCSA. Also, FMCSA was granted
continuing oversight responsibility over household goods movers. However, the act did not
provide FMCSA with the authority to intercede on behalf of individuals seeking
reimbursement of moving company charges or recovery of their goods.
24
The Non-Entrant program has not yet been developed and is therefore not included in the
2006 performance budget.
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GAO-06-103 FMCSA Education and Outreach
model. FMCSA has used a logic model in another program area that
provides a description of how a program is intended to support agency
goals. Specifically, FMCSA’s Research and Technology group used a logic
model along with other planning tools to demonstrate how its activities
support FMCSA’s goals in its 5-Year Strategic Plan. The Research and
Technology logic model includes inputs such as staff, outputs such as
research studies, outcomes such as improved understanding of root causes
of crashes, and impacts such as fewer commercial motor vehicle crashes.25
FMCSA described the Research and Technology Logic Model as a
“mechanism to help define metrics for performance, quality, and relevance
of the program.”26
As FMCSA endeavors to describe how its education and outreach program
activities affect the knowledge, attitudes, and behaviors of its target
audiences, and link these results to broader goals, it may wish to consider a
tool such as a logic model—as the agency used in its Research and
Technology strategic plan—to clearly outline those links. In previous work
on educational and outreach,27 we used a logic model to describe the
program components—inputs and outputs—and how these support the
desired results, thus explaining the strategy—or logic—by which programs
are expected to achieve their goals. Figure 3 graphically depicts this model
and its components.
25
U.S. Department of Transportation, Federal Motor Carrier Safety Administration, Research
and Technology: 5-Year Strategic Plan, Fiscal Years 2005-2009, (undated).
26
The Research and Technology report does refer to one education and outreach activity
done by that group—improving driver training. However, this activity is not part of the
programs we are reviewing.
27
GAO, Program Evaluation: Strategies for Assessing How Information Dissemination
Contributes to Agency Goals, GAO-02-923 (Washington, D.C.: Sept. 30, 2002).
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GAO-06-103 FMCSA Education and Outreach
Figure 3: Program Logic Model
Measured results
Inputs
Outputs
What is
invested?
Participants
Activities
●
●
Staff
Participants
Workshops
Money
Customers
Meetings
Materials
Equipment
Who is
reached?
What are the
medium term
results?
What are the
long term
results?
Awareness
Behavior
Conditions
Knowledge
Practices
Economic
Media work
Attitudes
Policies
Civic
Training
Motivations
What is
done?
What are the short
term results?
External factors
Other environmental influences on program operations or results
Source: Adapted from Ellen Taylor-Powell, "The Logic Model: A Program Performance Framework," University of Wisconsin
Cooperative Extension, Madison, Wisconsin.
The logic model illustrates how program activities such as distributing
informational pamphlets contribute to the results of a program, such as
increasing safety-belt usage, and to an ultimate goal, such as reducing
fatalities. In addition, program managers should consider the effect of
external factors when defining outcomes and recognize that the correlation
between activities and desired outcomes may not be as direct as one would
like. Without a logic model or similar tool to clearly describe the links
between education and outreach programs and broader goals, FMCSA may
have difficulty designing and evaluating effective programs.
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GAO-06-103 FMCSA Education and Outreach
Evaluations of Specific
Education and
Outreach Programs
Impacts Are Still in
Preliminary Stages, but
the Lack of a Plan to
Evaluate How New
Entrant Safety Audits
Improve Knowledge
and Attitudes Raises
Concern
FMCSA has begun some evaluations of its education and outreach
activities, including the New Entrant program, and plans to use contractors
to evaluate some programs. Surveys and studies are the primary means by
which FMCSA or its contractor will evaluate the programs. However, some
gaps in evaluation plans remain, especially for the largest of the programs
we reviewed. Specifically, FMCSA has not evaluated whether the
Education and Technical Assistance Package provided to new entrants and
the safety audits conducted under the New Entrant program effectively
communicated information to new entrants, making it difficult to
determine the impact of that program. A list of FMCSA’s evaluations and
planned evaluations are provided in figure 4.
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GAO-06-103 FMCSA Education and Outreach
Figure 4: FMCSA’s Evaluations and Planned Evaluations by Program
New Entrant
●
Completed preliminary comparison of crash rates for new
entrants who had received safety audits with those who had
not received the safety audits
●
Planning New Entrant Evaluation Study for 2008 to examine
new entrant's safety performance
Non Entrant
Planning to hire a contractor to
●
identify the target population of non-entrants
●
measure if outreach approaches are reaching target audience
through focus groups
●
measure changes in knowledge and attitudes through surveys
●
measure changes in behavior through surveys
Safety Belt
●
Tested marketing materials for appropriate message
●
Installing software to monitor Web site hits
●
Planning focus groups and surveys with carriers on how safety
belt marketing material affected their awareness of importance
of using safety belts
●
Planning to annually measure safety-belt usage by commercial
vehicle drivers
Motor Coach
●
Using a Web survey to measure experience and satisfaction with
Web site and to track exposure to information provided there
Household Goods
●
Working with GSA to survey target audience to measure
effectiveness of moving tips booklet that influence consumer
choice
Source: GAO analysis of FMCSA (data), FMCSA publications (images).
For each program, FMCSA’s evaluation efforts are described as follows.
New Entrant Program
FMCSA evaluates the performance of the New Entrant program primarily
by tracking the number of safety audits conducted of new motor carriers.
The agency has a goal of conducting a certain number of safety audits per
year, safety audits of 80 percent of new entrants within the first 6 months
they are in business, and 100 percent of all new entrants within their first 18
months of operation. FMCSA sets employee performance goals for division
office managers for conducting a particular number of safety audits of new
entrants. According to FMCSA officials, agency personnel conducted over
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GAO-06-103 FMCSA Education and Outreach
9,400 safety audits in fiscal year 2005, exceeding their goal of 8,000 FMCSA
completed safety audits. In addition, by April 2005, 52,000 safety audits had
been conducted since the program began, and the number conducted each
quarter has been generally increasing. However, FMCSA officials
acknowledge that there is a safety audit backlog in some states, and the
goals for auditing new entrants in the first 6 months, and the first 18
months, are not being met. The number of safety audits reflects the number
of new registrants that were personally informed about the carrier
requirements. Using registration data on the number of new entrants, the
agency can estimate the number of new entrants needing a safety audit and
agency progress toward the program goal. There are about 40,000 new
entrants registered per year, but officials told us that about 40 percent drop
out or discontinue business within the first year of operations.
By tracking the number of safety audits conducted, FMCSA seeks to
determine the extent to which it has provided information to its targeted
audience of new drivers. FMCSA has no process to measure whether new
entrants’ awareness of safe trucking practices was raised, which ideally
would be a consequence of an effective education and outreach effort.
Specifically, although FMCSA plans to evaluate the New Entrant program
in 2008, it has no current plan to determine how FMCSA’s safety
requirement information, such as its Education and Technical Assistance
Package and its safety audits, affect new entrants’ (1) awareness of FMCSA
requirements, such as drug and alcohol testing requirements or (2) their
motivation to change behaviors that might lead to safer operations. The
New Entrant program manager indicated that since the program is new and
still evolving, the outreach campaign does not have much historical data to
evaluate.
Although the program has not been in existence very long, FMCSA officials
stated that the agency has conducted one study of the New Entrant
program and has plans to conduct another. One preliminary analysis by
FMCSA compared the crash rates of new motor carriers registering with
FMCSA during 2002 to the crash rates of over 1,000 new motor carriers that
registered with FMCSA and had a safety audit during the first 6 months of
2003. This analysis showed that there was little difference between the
crash rates of these two groups. FMCSA officials said that they are
planning a study to be conducted after planned changes to the safety audit,
discussed later in this report, have been in place for a period of time.
Officials told us that the study planned to begin in 2008 will examine
carriers’ safety records over time, although they have not yet developed an
evaluation plan.
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GAO-06-103 FMCSA Education and Outreach
We have previously reported on the difficulties of assessing education and
outreach programs such as the New Entrant program. We have also
reported, however, that federal agencies are expected to demonstrate how
their activities contribute to achieving agency or governmentwide goals.
Additionally, the guidance that FMCSA uses when developing evaluation
efforts for education and outreach programs—a booklet entitled The Art of
Appropriate Evaluation28 —published by NHTSA—emphasizes that
evaluations should include measurements of changes in awareness,
knowledge, and behavior. If FMCSA’s planned evaluation of the New
Entrant program does not consider whether the program is actually
succeeding in effectively conveying the educational material on safe
trucking practices, FMCSA will be unable to clearly determine the
program’s impact. Or, if safety audits are having little impact, as suggested
by FMCSA’s preliminary analysis, the agency will not be able to determine
whether it is due to (1) the educational material provided, (2) how the
information is conveyed during the safety audits, (3) the lack of follow-up
on the safety audit results, or (4) other factors. Additionally, it will be
difficult to demonstrate to Congress that this program is having its desired
effect.
Non-Entrant Program
This program has not yet begun. FMCSA officials plan to award a contract
by the end of 2005 to develop, implement, and evaluate the Non-Entrant
program. The contractor is to test the effectiveness of the outreach
materials while they are being developed to determine if they will reach the
intended audience and effectively changed knowledge and attitudes.
Development of the materials will include surveying the targeted audience
and conducting outreach through truck leasing and sales firms. FMCSA’s
program plan indicated that the contractor will be expected to assess
changes in knowledge, attitudes, and behaviors of its target audience.
Commercial Motor Vehicle
Safety Belt Program
FMCSA officials stated that they plan to evaluate this initiative in several
ways once they have finalized its evaluation arrangements. According to
FMCSA officials, during program design, FMCSA tested its marketing
materials with target audiences, including truck drivers, and found that the
marketing material was appropriately targeted. Also, FMCSA is installing
software to track the number of Web-site hits on certain of its Web pages
that contain important educational elements of the Safety Belt campaign.
This system will enable FMCSA to determine how many times its
28
National Highway Traffic Safety Administration, The Art of Appropriate Evaluation: A
Guide for Highway Safety Program Managers, May 1999.
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GAO-06-103 FMCSA Education and Outreach
information has been viewed, but it will not enable FMCSA officials to
know whether that information was effectively conveyed to its target
audience or changed their attitudes about wearing safety belts.
Nonetheless, FMCSA officials believe that this software will enable
program managers to monitor and determine which Web-site pages are
viewed, and therefore are more effective, based on the number of hits and
the length of time at each site. Furthermore, FMCSA is considering focus
groups and surveys with carriers on how safety belt marketing material
affected their awareness of the importance of using safety belts.
In addition, FMCSA has an agreement with NHTSA for two efforts that
could measure progress toward the expected outcome of this initiative—a
10-percent increase in use of safety belts from 2006 through 2009. The first
effort is a study, expected to be completed in December 2005, which
updates a 2003 commercial motor vehicle study that reported that 48
percent of commercial drivers wear safety belts. The new study will update
information on the percentage of commercial drivers that wear safety belts
by replicating the methodology used in the 2003 study, according to FMCSA
officials. The second effort will investigate the feasibility of annually
collecting data on safety-belt use by commercial drivers through the
National Occupant Protection Usage Study (NOPUS) sponsored by
NHTSA. Although these efforts will measure safety-belt use, they will not
evaluate whether the education and outreach program in particular
contributed to changes in the number of individuals wearing safety belts.
Motor Coach Outreach Program
FMCSA has a Web-based, pop-up survey for its Web site which, although
focusing on consumer satisfaction in general, gives FMCSA some ideas
about Web-site usage and exposure to the information contained on the
site. The survey randomly selects visitors to the Motor Coach Web site and
asks them to answer a series of questions concerning the accuracy, quality,
convenience, and ability of finding needed information. The survey also
asks visitors about their overall satisfaction with the Web site. Although
these questions may be generally helpful to rate the Web site experience,
more specific questions on the Motor Coach program information have not
been incorporated. The pop-up survey has flexibility for use in other
FMCSA program Web pages, and FMCSA has plans to use Web-based usage
tracking as an additional tool in the future. However, with only a small
budget—$150,000 in fiscal year 2005—for the Motor Coach program, it is
reasonable to expect that FMCSA would balance the need for this type of
evaluation information with its other education and outreach program
priorities.
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As of October 2005, FMCSA officials also had plans to award a contract for
contractor support to conduct surveys, focus groups, and interviews to
evaluate its education and outreach programs, including obtaining Office of
Management and Budget (OMB) clearance for these activities.29 FMCSA
officials told us that the motor coach program would be evaluated under
this contract.
Household Goods Outreach
Program
FMCSA has identified at least two approaches to evaluate the effectiveness
of the outreach efforts for the household goods outreach program. One
effort is to survey recipients who have received the Ready to Move - Tips
for a Successful Interstate Move booklet from GSA. As of May 2005, 703
surveys had been distributed to determine whether the recipients believed
that the booklet would change their intentions about which household
goods carrier they might select. The survey asks questions regarding the
effectiveness of the booklet and its information content. Also, FMCSA
officials stated that the Household Goods program would be evaluated
under the survey support contract discussed in the preceding section on
the Motor Coach program.
An FMCSA official whom we spoke with indicated that the elderly may be
particularly targeted by unscrupulous movers. Recent data released by the
Census Bureau indicate that only about 40 percent of people age 55 years
or older have computers with Internet access in their homes.30 Although
FMCSA has an available hard-copy brochure, the Web-based outreach
efforts may not be fully reaching this population. FMCSA’s planned
evaluations of the Household Goods program do not address the
effectiveness of FMCSA’s Web-based outreach in reaching this population.
29
Under regulations that implement the Paperwork Reduction Act of 1995, federal agencies
seeking to collect information from ten or more persons are required to first obtain approval
from OMB.
30
Data as of 2003, from the U.S. Census Bureau, Statistical Abstract of the United States:
2004-2005, p. 732.
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GAO-06-103 FMCSA Education and Outreach
The Effectiveness of
Education and
Outreach Programs Is
Unclear, but Programs
Seem to be Reasonably
Designed According to
Theories of Behavior
Change and Industry
Groups
Most of FMCSA’s evaluations of its education and outreach programs have
yet to be completed, and therefore little is currently known about the
effectiveness of the programs. FMCSA expects the contracts for the
evaluation programs to be finalized within months and will receive
information from the evaluations once the data are collected and analyzed.
Until that time, what is known about program effectiveness is largely based
on anecdotal information from stakeholders such as industry associations,
as well as a comparison of the education and outreach programs to the
design of other successful programs that have been implemented.
However, FMCSA’s education and outreach programs and marketing
materials appear to follow theories and research on behavior change.
Finally, a public-safety group suggests FMCSA followed reasonable
approaches in starting its education and outreach efforts, however, it
would like to see more quantitative evaluation in the future to help FMCSA
refine its programs.
Behavior Theory Indicates
Education and Outreach
Can Be Effective in
Increasing Awareness and
Changing Behavior for
Programs that Do Not Have
Regulations Governing the
Behavior of Their Target
Audiences
Studies by us, other agencies, and academics show that education and
outreach programs, such as those undertaken by FMCSA, can be effective
in creating awareness of a problem or issue and influencing some change in
behavior. One theory—the theory of reasoned action—explains the
relationship between attitudes, beliefs, intentions, and behavior. In short,
people are more likely to change their behavior if they believe the change is
valued—or that not changing their behavior has negative
consequences—and if they have the necessary opportunity to change the
behavior. For example, one antismoking advertising campaign emphasized
the negative effects of smoking on a smoker’s health. Smokers became
aware of the negative consequences, and 26 percent of respondents
indicated that they were more likely to quit smoking based on the
awareness of the negative consequences of smoking. Another study on the
effects of sun exposure showed that countering the mistaken belief that
sun tanning had a positive effect reduced the percentage of individuals who
habitually lie in the sun. These studies demonstrate that emphasizing the
consequences of a negative behavior to individuals can result in changes to
attitudes and behavior, without applying any specific sanctions.
Based on the theory of reasoned action, education and outreach can have a
positive impact through FMCSA’s two programs that have a goal of
influencing consumers to make appropriate choices of motor carriers.
FMCSA’s Motor Coach and Household Goods Outreach programs are
targeted toward consumers and do not have regulations governing the
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GAO-06-103 FMCSA Education and Outreach
consumers’ behavior, thus, according to the theory of reasoned action,
gaining knowledge about the positive consequences of choosing a safe
carrier will affect the individuals’ attitude toward this behavior. The change
in attitude will directly affect intention and the subsequent behavior. Thus,
education and outreach campaigns can provide an individual under these
circumstances with the information that is needed to make a more
educated choice. For example, the Motor Coach program follows this
approach by targeting consumers and conveying the negative
consequences of choosing an unsafe carrier. In the case of the Household
Goods program, the campaign conveys the positive consequences of
choosing a reputable carrier in the Households Goods program, although
the elderly, a group potentially susceptible to unscrupulous carriers, may
require a different delivery method other than FMCSA’s Web site to receive
this message.
A Link to Enforcement Can
Strengthen Education and
Outreach Programs’ Ability
to Change Behavior
Independent studies as well as our prior work31 indicate that the level of
enforcement in safety related programs is positively correlated with
safety-belt use, especially when coupled with public-awareness efforts.
According to the general deterrence theory, individuals must be exposed to
law enforcement or receive information about legal ramifications of their
actions before they can be deterred. The perception or expectation of
certain sanctions results in attempts to avoid committing the offense.
Studies show this theory is an effective model for strengthening the change
in behavior resulting from safety programs. Thus, this link to enforcement
would apply to FMCSA’s three education and outreach programs—Safety
Belt, Non-Entrant and New Entrant—that have existing regulations that
address their target audience’s behavior.
One study, conducted by the National Safety Council, on the state of South
Carolina’s safety-belt program, showed that while media campaigns
immediately increased awareness of the importance of safety belts, the
largest increase in safety belt-use occurred after officers enforced the
requirement to wear safety belts. Additionally, a 2002 study by NHTSA
included data from the state of Washington, which showed that the
baseline percentage of individuals wearing safety belts (81 percent)
increased slightly with advertising over a 4-week period to 82 percent.
Ultimately with the addition of enforcement efforts, the percentage of
31
GAO, Truck Safety: Share the Road Safely Program Needs Better Evaluation of Its
Initiatives, GAO-03-680 (Washington, D.C.: May 30, 2003).
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GAO-06-103 FMCSA Education and Outreach
those who wear safety belts increased to 90 percent within 2 months. The
same study showed similar results in Texas, where the effects of
advertising alone raised the safety belt percentage slightly, but the
combination of advertising with enforcement caused the number to
increase another 6 percent, from the 80-percent baseline. These studies
suggest that although publicity may increase the awareness of the need to
wear safety belts, some people are unlikely to act on that awareness unless
the enforcement component of the campaign was closely integrated with
the publicity campaign. The results of these studies suggest that education
and outreach alone can increase awareness and encourage the intended
behaviors for FMCSA’s education and outreach programs, but that
enforcement can strengthen the result of these efforts.
FMCSA Is Increasing
Enforcement in the New
Entrant Program and
Acknowledges the
Importance of Enforcement
to the Non-Entrant and
Safety Belt Programs
Three of FMCSA’s programs we examined, the New Entrant, Non-Entrant
and Commercial Motor Vehicle Safety Belt programs have regulations, such
as a requirement for motor carrier drivers to wear safety belts, affecting the
target audiences’ (motor carrier industry) behavior. This provides the
opportunity to use both enforcement and education in programs with the
goal of improving the safety behavior of the motor carrier industry. The
following sections describe how FMCSA has indicated it is using or will be
using enforcement along with education and outreach in these programs.
New Entrant Program
Enforcement has been only a minor component of the New Entrant
program, but FMCSA is currently strengthening the criteria for passing
New Entrant safety audits because of concerns of its effectiveness, based
on analysis and anecdotal information indicating that new entrants that
have been notified of the safety audit requirements may not be operating
more safely. In addition, even if a new entrant passes the safety audit, some
carriers are not yet following important safety requirements, such as
having a drug and alcohol testing program, at the time the safety audit was
conducted. This change should establish a better link to enforcement, in
keeping with behavioral research, in that it will be more difficult for new
entrants to retain their operating status unless they are following the safety
requirements at the time of the audit.
The safety audit has been considered an educational unit, with a strong
emphasis on training new entrants about the requirements to operate in
interstate commerce. For example, the federal register notice that
established the new entrant safety assurance process indicated that the
new entrant process is intended to “improve the safety performance of new
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GAO-06-103 FMCSA Education and Outreach
entrants by providing educational and technical assistance” and required
“minimum requirements to new entrant motor carriers to ensure that they
are knowledgeable about applicable federal motor carrier safety
standards.” There are few sanctions for carriers who fail critical areas of
the safety audit, although a new entrant might be subject to a more
stringent and detailed review—a compliance review—under certain
circumstances.32 However, the compliance review process occurs less
often with new motor carriers than experienced carriers.
Although FMCSA’s requirements indicate that the objectives of the safety
audit are to educate the carrier and determine areas where the carrier’s
compliance might be deficient, in practical application almost all new
entrants have passed the safety audit, and little is done to follow-up to
ensure that new motor carriers correct deficiencies identified in the safety
audits. A new entrant can fail two of six sections and still pass the audit.
Safety audit sections include areas such as driver qualifications, business
operations, and maintenance records. Over a 2-year period ending in April
2005, there were 51,681 carriers that passed the safety audit, and only 372
failed, producing a 99.3 percent passing rate for new entrant motor
carriers. Those who fail the audit must take corrective action within 45
days if they are a passenger or hazardous material carrier, or 60 days for all
other carriers, or they will lose operating status. Furthermore, for those
carriers who passed the audit despite failing multiple sections of it, FMCSA
currently has no mechanism to ensure the failed sections of the audit have
been corrected before the carrier achieves permanent status. Although
FMCSA sends letters to new entrants about the sections in which they are
not in compliance with motor carrier regulations; beyond the letter and
agency follow-up to obtain proof of insurance, the agency or its
representatives do not determine if the new entrants have in fact corrected
deficiencies identified during the safety audits.
Our analysis of critical factors within the safety audit questions revealed
that over the same 2-year period, about 40 percent of the carriers failed the
“driver” section of the audit, despite passing the audit overall. This section
includes critical questions, such as whether a carrier’s driver qualifications
have been reviewed and whether the carrier's drivers are covered by a drug
32
A compliance review is a more stringent and detailed review than a safety audit, and it is
triggered if a new entrant is (1) involved in a fatal or serious accident, (2) subject to a
nonfrivolous complaint, (3) involved in a hazardous materials accident, or (4) on a FMCSA
database that flags carriers with poor safety records for compliance reviews.
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GAO-06-103 FMCSA Education and Outreach
and alcohol testing program. Specifically, we found that about 60 percent of
the new entrant carriers that passed the safety audit had failed the
requirement to check qualifications of drivers prior to hiring them.
Checking qualifications means that before hiring a driver a motor carrier
company obtains and reviews information on an applicant’s driving history,
including accident and ticket information. In addition, we found that for the
most part, between 27 and 29 percent of carriers who passed the safety
audit had not maintained maintenance files for requested vehicles. The lack
of improvement over the 2-year period illustrates the importance of
determining if the Education and Technical Assistance Package, which the
carriers received prior to the audit, should be changed to improve these
results.
FMCSA officials agreed that the safety audit may not be improving safety
behavior of new entrants, and the agency is already tightening these
requirements. Currently, there is no one question or section of the audit
that can cause a new entrant to fail. FMCSA officials informed us that the
new federal register notice laying out stricter pass requirements—expected
to be issued shortly—identify eight critical questions that individually
could lead to failing the safety audit, thus providing more incentive for
carriers to comply with new entrant requirements. For example, carriers
would automatically fail if they do not employ a drug and alcohol program,
have insurance, or have the proper maintenance requirements. Carriers
who fail the safety audit and do not correct the deficiencies could lose their
operating status and would be required to correct deficiencies before their
operating status is reinstated.
Safety Belt Program
Similarly to the New Entrant program, there has been limited enforcement
associated with the Safety Belt program to date. The finding that 48 percent
of commercial drivers wear safety belts, compared with 80 percent of
passenger vehicle drivers, suggests that commercial motor vehicle
operators have thus far been less receptive to messages in the market place
regarding the importance of wearing safety belts while on duty.33 In light of
the studies we reviewed, an enforcement element might help strengthen
education and outreach programs’ attempts to increase awareness of the
risk to drivers of not wearing safety belts and encourage commercial
drivers to wear them. It is reasonable to assume that commercial motor
vehicle operators, similar to private operators, would be educated and
informed from the materials presented in the campaign but that some
33
As mentioned earlier, FMCSA currently has a planned study to update the data.
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GAO-06-103 FMCSA Education and Outreach
would not act on the information unless there was some risk of sanction.
The approved plan for FMCSA’s safety belt initiatives includes a third phase
of implementation that calls for increased enforcement. Although the plan
does not specify how FMCSA will enforce federal regulations regarding
wearing safety belts and how FMCSA will work with state agencies to carry
out enforcement—as this program develops, strengthening the
enforcement link may increase the effectiveness of the safety belt
education and outreach efforts. FMCSA officials indicated that this
enforcement effort had begun and included fiscal year 2005 grants to state
agencies that can be used for safety belt education and enforcement.
Non-Entrant Program
FMCSA’s program plan for the Non-Entrant program indicates it will have
some enforcement component as it is developed; however, specific
information on enforcement has not yet been developed. Literature on
safety programs and experience with similar programs indicates the
Non-Entrant program might benefit from enforcement after non-entrants
are exposed to the message about the importance of registering for a DOT
license when they buy or rent a vehicle for operation.
Industry Associations Offer
A Mostly Positive View of
FMCSA’s Education and
Outreach Efforts, but Public
Advocacy Groups
Expressed Some Concerns
Overall, the industry associations’ view is that FMCSA is doing several
positive things in its education and outreach activities. Officials of the
seven industry associations whom we spoke with had regular contact with
FMCSA officials and were familiar with the education and outreach
programs under this review. Many association officials cited direct contact
with FMCSA on industry issues on a regular basis and said that their
partnerships with FMCSA on education and outreach activities were
productive. Specifically, an official of one moving industry association told
us that it shared data with FMCSA regarding complaints against carriers
and often refers complainants to FMCSA for further information. Officials
representing a consortium of primarily state agencies involved in motor
carrier safety, to which FMCSA belongs, told us that the support FMCSA
was able to provide was important to the implementation of the Safety Belt
program. Lastly, some association officials said that FMCSA was doing a
good job with the resources it has, but others said FMCSA could do more
with its education and outreach efforts if the agency had more resources.
However, one of the two public safety groups we contacted believed that
although the education and outreach programs were based on good ideas,
FMCSA needs to do more quantitative evaluations of these programs. Both
public safety groups also felt that FMCSA should have stronger
enforcement. For example, one group indicated that research has shown
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GAO-06-103 FMCSA Education and Outreach
enforcement to increase the effectiveness of education programs and thus,
FMCSA should focus more on compliance and enforcement. Finally,
although industry associations emphasized the positive professional
relationships they have with FMCSA officials, a public safety group
indicated that it is wary about FMCSA’s tendency to manage programs in
alliance with industry partners, since the group believes it might affect the
agency’s objectivity.
Conclusions
Uncertainty about how FMCSA’s education and outreach activities link to
broader program and agency goals and about FMCSA’s New Entrant
program have emerged from our study. FMCSA officials have stated that
the agency’s education and outreach programs support department
objectives and that they have used a logic model to show this in the
agency’s performance budgets. However, in our review of agency
documents, we found that except for the Safety Belt program, FMCSA has
not established clear links between the education and outreach programs
and agency and departmental goals. For example, the conference report
accompanying the DOT appropriations bill for fiscal year 2005 requested
FMCSA report to the House and Senate Committees on Appropriations “a
goal, message, and coherent and explicit program strategy that clearly and
directly link FMCSA’s outreach and education program initiatives to each
program’s goals” because of its concerns over how FMCSA’s education and
outreach activities support agency goals. In the October 2005 response,
FMCSA stated that its education and outreach programs support DOT
strategic objectives. The report, however, did not clearly set out the links
between changing attitudes and behaviors that would describe how these
programs contribute to objectives. Such a step would be welcome, for
without an explanation of that link, FMCSA cannot transparently
demonstrate to stakeholders, including congressional oversight authorities
that the programs do, in fact, contribute to these broader goals.
Furthermore, without a clear statement of how these programs are
intended to support these goals, it is difficult to design evaluations to
determine if these programs are performing as intended or if changes are
needed in program design. FMCSA has used a type of a logic model for its
Research and Technology program, making it clear to all interested parties
how its research activities help the agency achieve its goals. While FMCSA
officials say they have used a logic model for its education and outreach
program, this is not evident in agency budget and program documents. The
use of a logic model, similar to the one used by the agency’s Research and
Technology group, in planning, budgeting or program for education and
outreach programs may be beneficial.
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GAO-06-103 FMCSA Education and Outreach
Second, the absence of a plan to evaluate how well the information
provided to motor carriers as part of the New Entrant program was
understood and if the information raised awareness and helped promote
safer behavior also emerges as a concern. An FMCSA official stated that
the New Entrant program is still new and has limited data to evaluate.
Further, changes to the program are planned to raise the threshold for
passing a safety audit. Thus, FMCSA is planning on starting an evaluation of
the New Entrant program in 2008. However, without an evaluation of the
effect of education on new entrants’ knowledge about safety requirement,
FMCSA is losing an opportunity to obtain information about the
effectiveness of the educational information conveyed through the
program. In addition, FMCSA cannot know whether its safety audits, which
composed almost 7.5 percent of FMCSA’s 2005 funding, are having the
desired effect; whether the Education and Technical Assistance Package
and the information conveyed during the safety audits might require some
changes to improve their effectiveness; and whether the safety audits
themselves might be achieving their purpose of improving motor carrier
safety. FMCSA has two opportunities upcoming to obtain information on
the effectiveness of the educational materials and safety audits. First, it
could use its planned contract for evaluation of education and outreach
activities to develop and conduct such an evaluation. Second, FMCSA
could include this evaluation in its plans to evaluate the New Entrant
program beginning in 2008.
Recommendations for
Executive Action
To better demonstrate how FMCSA education and outreach programs
contribute to achieving agency goals, we recommend that the Secretary of
Transportation direct the Administrator of FMCSA to take the following
two actions:
• Ensure that the agency describes and documents how education and
outreach program activities link to and support broader program and
agency goals in a planning, program, or budget document that is
available to the public, and
• Evaluate the effectiveness of the education and outreach of the New
Entrant program, assessing the extent to which the Education and
Technical Assistance Package and safety audits are helping new carriers
learn and understand FMCSA requirements.
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GAO-06-103 FMCSA Education and Outreach
Agency Comments
We provided a draft of this report to the Department of Transportation for
its review and comment. FMCSA officials, through the DOT liaison,
provided oral comments on a draft of this report. The officials did not agree
with GAO’s finding that FMCSA has not linked its education efforts with its
overall goals. FMCSA officials state they have linked their education and
outreach programs to agency goals at a high level in the agency’s
performance budgets. In addition, the officials state that they used a logic
model to make this link. We included FMCSA’s view that it has linked its
education and outreach programs to agency goals in our report. However,
we did not find this link evident for most of the education and outreach
programs. For example, Congress requested FMCSA to report on the link
between its education and outreach program initiatives to each program’s
goal. FMCSA’s report to Congress described the program activities;
however, it did not describe the link between the activities and FMCSA’s
goals. In addition, although FMCSA officials stated that they have used a
logic model in their performance budget to link education and outreach
programs to agency goals, the discussion implied a link, but does not
describe how FMCSA’s education and outreach activities are intended to
change target audience’s attitudes and behaviors that would contribute to
meeting agency goals. However, in FMCSA’s fiscal year 2006 performance
budget, we did find and report on a relatively clear discussion of how the
Commercial Motor Vehicle Safety Belt program supported safety objectives
such as reduced fatalities.
In addition, DOT and FMCSA officials were concerned that our
recommendation on documenting the link between education programs
and agency goals was too prescriptive. We recommended that FMCSA
expedite the process of describing and documenting how its education and
outreach programs link to and support overall agency goals in strategic
planning and budget documents. DOT officials said that including this
specific information on relatively small dollar projects—such as the Motor
Coach program—was not appropriate in the DOT strategic plan. In
addition, DOT officials told us that it is not appropriate to include this level
of performance information in budget requests. Since the strategic plan and
the performance budget are not the only opportunities to detail program
linkage to broad agency goals, we clarified our recommendation to provide
FMCSA with more flexibility in identifying an appropriate planning,
program, or budgeting document in which to describe and document the
link between program activities and goals, so that external stakeholders,
including congressional oversight authorities, can understand how these
programs are supporting agency goals.
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GAO-06-103 FMCSA Education and Outreach
Second, agency officials suggested that it is too early to evaluate the New
Entrant program, as we recommended; and they have not developed
evaluation plans because they do not plan on beginning an evaluation until
2008. However, after over 2 years of implementation and 52,000 safety
audits, FMCSA is losing an opportunity to conduct an evaluation of the
educational component of the New Entrant program, including the
Educational and Technical Assistance Package for new entrants and the
information conveyed during safety audits to determine if new motor
carriers increase their knowledge of motor carrier requirements and
change their behavior to better comply with these requirements. The lack
of such an evaluation is a missed opportunity for FMCSA to demonstrate
the effectiveness of its educational information and safety audits, which
represented almost 7.5 percent of its funding in fiscal year 2005. In
addition, we continue to believe this is an important component of any
evaluation FMCSA develops to determine the effectiveness of the New
Entrant program. Therefore, we retained our recommendation to evaluate
the New Entrant program and conclude that there are two opportunities for
doing so—either through contracts for evaluations of education and
outreach programs or through the evaluation FMCSA is planning to start in
2008.
Finally, agency officials provided technical comments, which we
incorporated as appropriate.
We are sending copies of this report to the Honorable Norman Mineta,
Secretary of Transportation. We will also make copies available to others
upon request. In addition, the report will be available at no charge on the
GAO Web site at http://www.gao.gov.
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GAO-06-103 FMCSA Education and Outreach
If you or your staff have any questions about this report, please contact me
at [email protected] or (202) 512-2834. 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 are listed in appendix III.
Katherine Siggerud
Director, Physical Infrastructure
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GAO-06-103 FMCSA Education and Outreach
Appendix I
Scope and Methodology
AA
ppp
ep
ned
n
x
id
e
x
Iis
To address our first objective and describe the scope and nature of the
Federal Motor Carrier Safety Administration’s (FMCSA) education and
outreach programs, we reviewed program documentation and interviewed
FMCSA officials at agency headquarters, its Eastern Service Center in
Maryland, and its New Jersey division office. We selected this division
office and service center because they were significantly involved in all
four of the currently active education and outreach programs we reviewed,
which are the New Entrant, Commercial Safety Belt, Motor Coach
Outreach, and Household Goods Outreach programs. We obtained and
reviewed information on FMCSA’s plans to initiate an additional program
targeted at non-entrant carriers.
Further, to determine how these programs relate to FMCSA’s goals, we
reviewed its strategic planning and performance budgeting documents and
how these education and outreach programs were portrayed in the current
fiscal year 2006 documents. We also discussed the performance budgeting
process with an FMCSA senior budget analyst to identify the agency’s plans
for the fiscal year 2007 and 2008 performance budgets. We also obtained
and reviewed the Department of Transportation’s (DOT) strategic plan,
which FMCSA refers to in its performance budget. In addition, we obtained
the strategic plan for FMCSA’s Research and Technology group. We
reviewed this plan to identify what one group within FMCSA uses for its
strategic and program planning. To identify other tools used for describing
how program activities relate to agency goals, we reviewed our previous
work and identified a program logic model, originally developed by the
University of Wisconsin Cooperative Extension, as a model that FMCSA
could use to clearly describe its education and outreach programs.
To address our second objective—identifying the extent to which FMCSA
has evaluated its education and outreach programs, we discussed the
status of these evaluation efforts with FMCSA officials and reviewed
proposals and statements of work for current and planned contracts to
carry out program evaluations. We also assessed the usefulness of FMCSA’s
ongoing or planned program evaluations to determine if the ealuations
would address how program activities affected target audiences’ attitudes,
knowledge, and behavior. We did not thoroughly assess the evaluation
design.
We took several approaches to assess what is currently known about the
effectiveness of programs like FMCSA’s education and outreach programs.
Finally, to identify what is known about the effectiveness of the programs,
we conducted a literature review of media based campaigns and reviewed
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GAO-06-103 FMCSA Education and Outreach
Appendix I
Scope and Methodology
the structure and evaluation of these campaigns as well as behavioral
theories used in designing the campaigns. We selected two behavioral
theories that were directly applicable to the programs under this review—
the theory of reasoned action and the general deterrence theory. We then
directly compared the characteristics of the two theories with the
characteristics of FMCSA’s programs. Additionally, through our literature
search, we also identified additional research that discusses the
importance of the relationship between education and enforcement in
changing behavior. We used this research to help assess the potential for
using enforcement to augment FMCSA’s education and outreach efforts. We
obtained aggregated data from safety audit results from FMCSA’s Motor
Carrier Management Information System (MCMIS) to examine results for
individual elements within a safety audit. We used these data to identify the
failure rates for key elements of the safety audit. We conducted a reliability
assessment of MCMIS data by (1) reviewing documentation related to
system development, (2) interviewing knowledgeable agency officials, and
(3) reviewing FMCSA’s internal controls, and we determined the data was
sufficiently reliable for our use. Finally, we interviewed officials from
several motor carrier, law enforcement, and safety organizations, including
the American Trucking Associations; the National Private Truck Council;
the American Bus Association; the United Motorcoach Association; the
American Moving and Storage Association; the Commercial Vehicle Safety
Alliance; Advocates for Highway and Auto Safety; and Public Citizen for
their perspective of the effectiveness of FMCSA’s education and outreach
efforts.
In accordance with congressional direction, we did not extend our review
to include “Share the Road Safely” which is targeted to passenger car
drivers. In fiscal year 2004, Congress transferred funding for the program
from FMCSA the National Highway Traffic Safety Administration (NHTSA).
Funding for this program is being returned to FMCSA in fiscal year 2006. In
fiscal years 2004 and 2005, Congress provided FMCSA with funding for
another outreach effort entitled “Safety Is Good Business.” The SAFETEALU requires GAO to review this program by June of 2006.
Our work was conducted in accordance with generally accepted
government auditing standards, from December 2004 through October
2005.
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GAO-06-103 FMCSA Education and Outreach
Appendix II
FMCSA Education and Outreach Programs
Appendx
Ii
The following provides a more detailed discussion of the five education and
outreach programs we reviewed.
New Entrant Program
The New Entrant program is intended to ensure that new motor carriers
are knowledgeable about federal motor carrier safety standards and
applicable hazardous material regulations. The program is focused on the
safety audits conducted through site visits to the new carriers’ offices by
personnel from the state law enforcement agency, the FMCSA division
office, or a FMCSA contractor.
In 1998, a FMCSA commissioned study1 found that new entrants to the
motor carrier industry have a substantially higher level of safety regulation
violations than more experienced carriers. Other, earlier research had also
indicated that new entrant carriers had crash rates higher than more
experienced carriers.2 The Motor Carrier Safety Improvement Act, which
established FMCSA, also directed the Secretary of Transportation to
establish regulations specifying minimum requirements for applicant motor
carriers seeking federal interstate operating authority and to require that
new entrants undergo a safety audit within the first 18 months of
operations. Effective January 1, 2003, FMCSA established its New Entrant
program to improve the safety of new entrant motor carriers by providing
them with educational and technical assistance as they begin their
businesses. Under FMCSA’s New Entrant program, any new motor carrier
that registers with DOT is designated a “new entrant” and will be subject to
a new entrant safety audit and increased roadside performance monitoring
for an 18-month period.
The safety audit’s purpose is to provide educational and technical
assistance to the new entrant by reviewing the carrier’s compliance with
FMCSA requirements, including driver qualifications, driver records of duty
status, vehicle maintenance records, accident registers, and controlled
substances and alcohol use and testing requirements. Education and
technical assistance information is also available to new entrants through
FMCSA’s Web site. A carrier that passes the safety audit is informed of any
1
John A. Volpe National Transportation Systems Center, New Entrant Safety Research Final
Report, April 1998.
2
Thomas M. Corsi and Philip Fanara, Jr., “Deregulation, New Entrants, and the Safety
Learning Curve,” Journal of the Transportation Research Forum, Vol. XXIX, No. 1, 1988.
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GAO-06-103 FMCSA Education and Outreach
Appendix II
FMCSA Education and Outreach Programs
deficiencies and what it must do to be in compliance. A carrier that fails the
safety audit has 60 days3 to take necessary corrective action, and ultimately
if the deficiencies are not corrected, its registration can be revoked. At the
end of the 18-month period, if the carrier has passed its safety audit, does
not have an unsatisfactory safety rating, and is not subject to an “out of
service” order or any notice to remedy safety management controls, the
“new entrant” designation will be removed from its registration, and it will
be monitored like any other carrier.
In most states, new entrant safety audits have been done by both state law
enforcement agency and FMCSA division office personnel. Contractors
conduct safety audits in four states (Florida, Maine, Oregon, and Wyoming)
that are presently doing few or none of their own. When the New Entrant
program began, FMCSA staff performed most of the safety audits, but
states now carry out the majority of these audits, as indicated by figure 5.
3
Forty-five days, in the case of passenger or hazardous material carriers.
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GAO-06-103 FMCSA Education and Outreach
Appendix II
FMCSA Education and Outreach Programs
Figure 5: Number of New Entrant Safety Audits Completed by FMCSA and State
Agencies (first 7 months of fiscal year 2005)
Number of safety audits
2,000
1,500
1,000
500
0
Oct.
Nov.
Dec.
Jan.
Feb.
Mar.
Apr.
Month
FMCSA officials
State officials (including contractors)
Source: GAO analysis of FMCSA data.
Non-Entrant Program
FMCSA’s Non-Entrant program will target motor carriers that operate
interstate but have not registered with DOT. The purpose of the program
will be to raise awareness of registration requirements, and to increase the
number of registrations among these non-entrant motor carriers. This
program has not yet begun, but FMCSA officials told us it will include
information disseminated through truck sales and leasing firms to nonentrants.
The number of non-entrants is unknown, but a FMCSA official estimates it
may be in the tens of thousands. FMCSA officials whom we spoke with
believe that non-entrants may represent an even higher level of risk than
new entrants, because they do not get exposure to FMCSA safety
information through registration. The officials believe that, in general,
motor carriers that do not register with DOT are unaware of the
requirement to do so, rather than intentionally avoiding registering. FMCSA
will be awarding a contract for the development of the Non-Entrant
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GAO-06-103 FMCSA Education and Outreach
Appendix II
FMCSA Education and Outreach Programs
program; the contract is expected to include a requirement to identify the
target population of non-entrants, develop informational material, with
follow-up monitoring of non-entrants that are identified.
Commercial Safety Belt
Program
FMCSA’s Commercial Safety Belt Program is intended to improve upon the
low rate of safety-belt use by commercial truck drivers. In 2003, a study
commissioned by FMCSA reported that only 48 percent of commercial
truck drivers wear safety belts, compared with 80 percent of passenger car
drivers wearing safety belts. In December 2003, FMCSA established the
Commercial Motor Vehicle Safety Belt Partnership with 16 other
organizations, including trucking industry and law enforcement
associations, commercial drivers associations, and safety organizations,
with the goal of increasing commercial safety-belt use by commercial
motor vehicle drivers. With its safety belt partners, FMCSA produces
materials including posters, bumper stickers, and brochures for
distribution at trucking industry shows and events, and through law
enforcement campaigns. In 2004, as part of the Partnership, FMCSA helped
distribute informational brochures developed by the Commercial Vehicle
Safety Alliance (CVSA).4 In 2005, FMCSA introduced and distributed new
materials with the theme “Be Ready. Be Buckled.” for distribution at
national and regional trucking industry shows and events, and through the
CVSA-sponsored Road Check 2005. This was a 3-day truck and motor
coach inspection effort in June 2005 that involved over 9,900 inspectors,
conducting more than 60,000 vehicle inspections in the United States,
Canada, and Mexico. Through the Commercial Motor Vehicle Safety Belt
Partnership, FMCSA also communicates its message through information
displayed at truck stops and satellite radio programming oriented to truck
drivers.
Motor Coach Outreach
Program
FMCSA’s objective for the motor coach industry is to reduce injuries and
save lives through increased compliance with safety regulations and
promotion of safe operations by motor coach owners and operators.
FMCSA’s approach is two-fold—(1) reaching out to the industry to inform
motor coach companies of regulations and provide safety advice and (2)
providing consumers with information to help them in selecting and hiring
4
The Commercial Vehicle Safety Alliance is an association of North American law
enforcement agencies that enforce commercial vehicle safety. Membership includes
representatives of all 50 states, all Canadian provinces, and Mexico.
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GAO-06-103 FMCSA Education and Outreach
Appendix II
FMCSA Education and Outreach Programs
motor coach services. FMCSA’s motor coach outreach activities include
communication with the carriers through printed material and
participation in trade shows, and Web-based information for the public. For
the purposes of our review, we focused on FMCSA’s outreach to members
of the public that hire motor coach services.
Motor coaches have been one of the safest forms of commercial
transportation, but an increase in motor coach occupant fatalities since
2001 led FMCSA to increase its focus on motor coach companies. In 2002,
FMCSA developed “Moving Kids Safely” a toolkit of reference materials
targeted to school districts and others who contract for bus services. In
2004, FMCSA introduced a motor coach safety Web site within the FMCSA
Web site, which provides guidance to consumers on selecting a motor
coach company and allows consumers to access safety data on specific
interstate motor coach companies.
FMCSA’s most direct outreach to motor coach companies is through the
agency’s Technical Assistance Group (TAG), consisting of about 12 FMCSA
staff with motor coach expertise, primarily in FMCSA’s field offices. TAG
personnel staff information booths and give presentations at industry
conventions and events, and serve as agency contact points for carriers.
Also, a FMCSA contractor developed a series of brochures aimed at motor
coach companies that describe guidelines and regulations for motor coach
companies (for instance licensing and insurance, hours of service,
inspection and maintenance, and specific requirements for operators of
school buses). In 2004 and 2005, FMCSA also conducted mass mailings to
motor coach companies, advising them of their reporting requirements
under the Americans with Disabilities Act.
Household Goods Outreach
Program
Most households need to hire moving services infrequently, and therefore
consumers may be unaware of what their rights and protections are in
hiring a commercial mover. The overriding objective of FMCSA’s
Household Goods program is to help consumers make better informed
choices in selecting and negotiating with a moving company, primarily
through printed material distributed through moving companies and other
sources, as well as providing information through its Web site. FMCSA also
maintains a complaint hotline to receive complaints about movers from
individuals.
The ICC Termination Act of 1995 transferred federal responsibilities for
protecting consumers who use commercial moving companies for
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GAO-06-103 FMCSA Education and Outreach
Appendix II
FMCSA Education and Outreach Programs
interstate moves to DOT; and the Motor Carrier Safety Improvement Act
granted FMCSA continuing oversight responsibility over household goods
movers. However, the act did not provide FMCSA with the authority to
intercede on behalf of individuals seeking reimbursement of moving
company charges or recovery of their goods. FMCSA officials whom we
spoke with acknowledge that when the agency was established in January
2000, its mandate was commercial vehicle accidents and fatalities and, as a
result, the household goods industry received little attention. Also, in 2001,
we reported that complaints about movers were on the rise and that DOT’s
lack of action had created a vacuum that allowed unscrupulous carriers to
take advantage of consumers.5 At that time, our report noted that FMCSA
had just begun planning to increase both consumer education and
enforcement effort of household goods carriers.
FMCSA distributes three consumer-oriented publications. Interstate
movers are required by law to provide a copy of one FMCSA publication—
“Your Rights and Responsibilities When You Move” to prospective
customers. A second brochure, “Ready to Move? Tips for a Successful
Interstate Move” is available through the General Services Administration’s
Pueblo, Colorado Information Center. A third brochure “Protect your
Memories…Protect Yourself from Moving Fraud” and the “Your Rights and
Responsibilities” publications are available on FMCSA’s Web site.
In March 2005, FMCSA awarded a contract for the development of a
household goods education and outreach program. FMCSA and the
contractor have developed a new outreach theme: “Protect Your Memories,
Your Money, Your Move”; and the contractor will be developing brochures,
presentations that can be delivered by FMCSA staff, and other materials. In
June 2005, FMCSA launched its redesigned household goods Web page,
designed around the “Protect Your Memories…” theme, which incorporates
new content, including a checklist for moving and information on
protecting against moving fraud. In November 2005, FMCSA officials
informed us that they were in discussions with the U.S. Postal Service to
have the Postal Service Web site provide a link to FMCSA’s Web site when
registering a change of address with the Postal Service.
FMCSA officials told us they do not arbitrate complaints that the agency
receives, but they maintain a national consumer complaint database that is
5
GAO, Consumer Protection: Federal Actions Are Needed to Improve Oversight of the
Household Goods Moving Industry, GAO-01-318 (Washington, D.C.: Mar. 5, 2001).
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GAO-06-103 FMCSA Education and Outreach
Appendix II
FMCSA Education and Outreach Programs
used to identify problem movers for investigation by FMCSA field staff. Our
2001 report on DOT and FMCSA oversight of the household goods industry
recommended that FMCSA make information on the number and general
nature of complaints against carriers be made available to the public.6
FMCSA officials whom we spoke with said the agency intends to do this,
but Privacy Act and other issues need to be resolved beforehand.
6
GAO-01-318.
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GAO-06-103 FMCSA Education and Outreach
Appendix III
GAO Contact and Staff Acknowledgments
GAO Contact
Katherine Siggerud, (202) 512-2834
Staff
Acknowledgments
In addition to the person named above, Cathy Colwell, Assistant Director;
Colin Fallon; Eric Fielding; Donald Kittler; Sara Ann Moessbauer; and
Elaine Vaurio also made major contributions to this report.
(542051)
Page 51
Appendx
iI
GAO-06-103 FMCSA Education and Outreach
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File Type | application/pdf |
File Title | GAO-06-103 Federal Motor Carrier Safety Administration: Education and Outreach Programs Target Safety and Consumer Issues, but G |
File Modified | 2005-12-20 |
File Created | 2005-12-19 |