Auditing with GPS and on-board recording devices

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Auditing with GPS and on-board recording devices
Global Positioning Satellite

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• The carrier has the option of using onboard
  recording devices. These devices are not
  required by either IRP or IFTA.
• If the carrier chooses to use one of these
  devices, the recording system would have to meet
  the record keeping requirements of both IFTA and
  IRP.
• IFTA P600 IRP Article 5

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When you run into a GPS system or on-board
recording device there are several things you
should know about it.

• a) What does the driver do to activate it?
• b) Are there any reviews or checks by office
  staff?
• c) How does the information get into the system?
  At what point? Reviews or checks before entry?
• d) Does their system do any automated checks?
• e) If odometers are entered, does the system
  check odometer total distance to jurisdiction
  total distance?

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Would you accept records if kept electronically
by registrant/licensee?

• The main thing to remember is what information
  do you need to test distance and fuel?
• You should ask as many questions about the
  software and procedures in order to fully
  understand them.

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Have you conducted a GPS or on-board
recording device audit?
What questions do you ask about the
carriers system?
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• P600 ELECTRONIC DATA RECORDING SYSTEMS
• P610 OPTIONAL USE FOR FUEL TAX REPORTING
• On-board recording devices, vehicle tracking
  systems, or other electronic data recording
  systems may be used (at the option of the
  carrier) in lieu of or in addition to handwritten
  trip reports for tax reporting. Other equipment
  monitoring devices that transmit data or may be
  interrogated as to vehicle location or travel may
  be used to supplement or verify handwritten or
  electronically-generated trip reports. Any device
  or electronic system used in conjunction with a
  device shall meet the requirements stated in this
  Section. On-board recording or vehicle tracking
  devices may be used in conjunction with manual
  systems or in conjunction with computer systems.

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P620 DEVICES USED WITH MANUAL SYSTEMS

• All recording devices must meet the requirements
• stated in IFTA Procedures Manual Section P640 and
• P660. When the device is to be used alone,
  printed
• reports must be produced which replace
  handwritten
• trip reports. The printed trip reports shall be
  retained for
• audit. Vehicle and fleet summaries which show
  miles
• and kilometers by jurisdiction must then be
  prepared
• manually.

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P630 DEVICES USED WITH COMPUTER SYSTEMS

• The entire system must meet the requirements
  stated in IFTA
• Procedures Manual Sections P640, P650, and P660.
• If the printed trip reports will not be retained
  for audit, the system
• must have the capability of producing, upon
  request, the reports
• indicated in IFTA Procedures Manual Section P640.
• When the computer system is designed to produce
  printed trip
• reports, vehicle and fleet summaries which show
  miles and
• kilometers by jurisdiction must also be prepared.

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P640 DATA COLLECTION REQUIREMENTS

• To obtain the information needed to verify fleet
  distance and to
• prepare the "Individual Vehicle Distance Record,
  the device must
• collect the following data on each trip.
• .100 Required Trip Data
• .005 Date of Trip (starting and ending)
• .010 Trip origin and destination (location code
  is acceptable)
• .015 Routes of travel or latitude/longitude
  positions used in lieu thereof (may be waived by
  base jurisdiction). If latitude/longitude
  positions are used, they must be accompanied by
  the name of the nearest town, intersection or
  cross street. If latitude/longitude positions
  are used, jurisdiction crossing
• points must be calculated or identified
• .020 Beginning and ending odometer or hubodometer
  reading of the trip (may be waived by base
  jurisdiction)

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• .025 Total trip distance
• .030 Distance by jurisdiction
• .035 Power unit number or vehicle identification
  number
• .040 Vehicle fleet number and
• .045 Registrant's name.

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IRP/APM Article 5 ON-BOARD RECORDING DEVICES

• 501. On-Board Recording Devices
• 501.1 On-board recording devices may (at the
  option of the carrier) be used in lieu of or in
  addition to handwritten trip reports for purposes
  of apportioned registration. On-board recording
  devices may be used alone (Section 502), in
  conjunction with an electronic computer system
  (Section 503), or in conjunction with manual
  systems.

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• 501.2 All recording devices used to generate trip
  reports or used in conjunction with manual
  systems must meet the requirements shown in
  Sections 504 and 505. When the on-board recording
  device is used in conjunction with an electronic
  computer system and reports are prepared on the
  basis of data downloaded from the recording
  device, the overall system must meet the
  requirements of Sections 504, 505, and 506.

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IRP 505. Data Collection

• 505.1 To obtain the information needed to verify
  fleet distance and to prepare the Individual
  Vehicle Distance Record (IVDR), the device must
  collect the following data on each trip
• 1. Date of trip (starting and ending)
• 2. Trip origin and destination (location code is
  acceptable)
• 3. Route of travel (may be waived by base
  jurisdiction)
• 4. Beginning and ending odometer or hubodometer
  reading of the trip (may be waived by base
  jurisdiction)
• 5. Total trip distance traveled
• 6. Distance traveled by jurisdiction
• 7. Power unit number or vehicle identification
  number.

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• Under the International Fuel Tax Agreement -
  (IFTA) and the
• International Registration Plan (IRP), you are
  required to keep the
• information as stated in the IFTA Procedures
  Manual Section P500
• (Recordkeeping) and IRP Audit Procedures Manual
  Article 4.
• See also Section P600 in the IFTA Procedures
  Manual and Article 5
• in the IRP Audit Procedures Manual for GPS
  requirements.
• P640 of the IFTA Procedures Manual and Section
  505 of the IRP
• Audit Procedure Manual both state that odometer
  readings are
• required.
•  

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Additional questions you could
ask-1.  What type of system do you have?2.
How often does the system record and send a
signal? For GPS, are all pings recorded?
If not, why not?3. What information is the
system recording? (i.e. date, location
points, odometer reading, fuel stops, when the
engine is turned off, some sort of event,
etc.)
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• 4. If your system records odometer readings, at
  what points are the odometer readings being
  captured?
• 5. How does your system calculate miles?
• 6. Do you use other computer software that
  calculates miles?
• If so, what type of software is used and
  what is its function?
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• 7. Can the following reports be generated?
•  
• _____ Fleet mileage summaries listing
  total miles and juris.
• miles per unit and for the
  entire fleet.
• _____ Unit mileage summaries listing
  total miles and juris.
• miles.
• _____ Total and jurisdictional miles
  per trip.
• _____ Routes of travel (detail of
  location points) by trip.
• List any other reports generated by the
  system that would be
• useful for a mileage and
  fuel audit.

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• 8.    What reports do you use to prepare your
  IFTA returns?
• 9.    What reports do you use to prepare your IRP
  renewals?
• 10. How long are you retaining your printed
  system reports?
•  
• 11. How long are you able to retrieve printed
  and non-printed reports?
• 12. Are you able to generate and print exception
  reports?
• (See IFTA Procedures Manual Section
  P650.400 and IRP Audit Procedures Manual Article
  5, Section 506(iii) ).

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What is an Exception report?

• IFTA Procedures Manual, Section P650.400
• Exceptions that identify all edited data,
  omissions of required data (see IFTA Procedures
  Manual Section P640), system failures,
  noncontiguous life-to-date odometer readings,
  travel to noncontiguous jurisdictions, and trips
  where the location of the beginning trip is not
  the location of the previous trip must be
  identified.
• Similar wording can be found under IRP Audit
  Procedures Manual, Article 5, Section 506 (iii).

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• 13. Is the system information being edited? Why
  would someone edit the system information? What
  specifically is being edited?
•  
• 14. Can the driver defeat or tamper with the
  recording and sending parts of the system?
• 15. Does your system rely on the trucks battery
  for power?
•  
• 16. How would you know if the truck was being
  towed (moving but not accruing miles)?
• 17. Are you alerted when the system is not
  receiving a signal from a unit or if there is a
  problem with the signal?
• 18. What is your procedure or policy of
  recording mileage information if the system were
  to malfunction?
•  
•  

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• 19. Do you have units that are not equipped with
  the
• electronic recording system? Please
  provide a listing of
• these units, (by unit number).
•  
• 20. If you operate units without an electronic
  recording
• system, what records are being kept for
  these units?
•  
• 21. Are there any other functions or internal
  controls that we
• maybe unaware of that would help with our
  understanding
• of your electronic recording system?

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• Has the technology of electronic recording and
  sending systems matured to the point where its
  fully dependable to accurately capture all
  vehicle activity?
• Is the technology and computer
  software able to capture a trucks signal and
  produce the reports that the IFTA and IRP
  require?
• Are we moving from the old geological Lat,
  Long ping systems, to real time monitoring via
  a road map system?
• Will makers like Tom-Tom, Garmin, and Magellan
  take the place of the traditional hand prepared
  driver source documents?
• Are electronic recording systems more accurate
  than driver recorded odometer readings and routes
  of travel?
• Are they more accurate than PC-Miler or Pro Miles
  mapping software?

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Do you trust it?

• How do you test an electronic recording system?
• The carrier youre about to audit does not have
  driver prepared source documents. No unit
  odometers, routes of travel or beginning and
  ending destinations. They did however, maintain
  their bills of lading for the audit scope and
  their last 6 months of D.O.T. logs which have
  odometer readings recorded on them.
• The owner states he uses his electronic recording
  system reports which show routes of travel,
  captured by their 5 minute pings. They use
  these reports with Pro Miles to complete the IFTA
  returns and IRP renewal.

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• How would you handle this type of situation?
• Would you-
• A) Tell the carrier that since he did not have
  his system checked and was not given a wavier
  from using driver source documents, that you will
  be back in 1 year to check for compliance? Start
  informing the carrier of the IFTA and IRP
  requirements.
• B) Trust the system and accept the reports?
• C) Apply a reduction in MPGs to cover what you
  dont know
• for sure?

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• D) Apply a 4.0-MPG adjustment and 100 fees to
  cover
• what you dont know for sure?
• E) Use the last 6 months of D.O.T. logs and bill
  of lading
• to check against the electronic recording
  system.
• F) Roll your eyes and laugh hysterically as you
  mumble to
• the owner that Youll send a bill.
  Then
• leave..

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• Has your jurisdiction granted a GPS waiver, or
  some other type of electronic device waiver?