If you get flagged for a Department of Transportation audit this year or in the future, there’s a good chance that it will be conducted off-site.
The DOT averaged more than 13,000 audits (both on-site and off-site) annually between 2018 and 2020, according to Dave Osiecki, President of Scopelitis Transportation Consulting. During the same period, the number of off-site audits grew from 238 in 2018 to a staggering 5,052 last year – an increase of more than 2,000%.
“Some of you may think that’s because the pandemic, because they couldn’t go on-site,” Osiecki says. “The reality is they could, and they did, go on-site in fiscal year 2020. The fact of the matter is that DOT, both federal and state, they’re doing these off-site audits much more frequently because they can.”
According to Osiecki, off-site audits take 33% less time to conduct, have been effective in improving motor carrier safety and reduce agencies’ travel costs 60%.
And off-site audits are better for companies too.
“From a carrier perspective, most carriers don’t want an auditor onsite – it’s disruptive to the business,” he says. “Off-site is not nearly as disruptive.”
EROAD partnered with Osiecki for the webinar All About DOT Audits. It’s packed with valuable information about both on-site and off-site audits (officially called “compliance investigations”) – and at less than an hour in length, it’s definitely worth watching (click here to watch). But given the upward swing in off-site audits, we’ll focus on those in this article.
On-Site vs. Off-Site Audits
What Triggers an Audit?
Elevated compliance, safety and accountability (CSA) scores trigger both on-site and off-site audits, especially hours of service (HOS), vehicle maintenance and unsafe driving, per Osiecki.
“Those are the three BASICs that drive most audits – in that order,” he says. “If a company is elevated in the hours-of-service compliance BASIC, they’re at risk of getting an audit.”
Findings from an earlier audit, substantive complaints and significant DOT recordable crashes also are potential audit triggers.
Carriers with at least two CSA scores in the 90th percentile or higher are considered high-risk and are more likely to have an on-site audit, as are companies that need a hazardous materials permit.
Comprehensive or Focused?
On-site audits can be focused, meaning they look at a particular compliance area, such as HOS or vehicle maintenance. Or they can be comprehensive and look at all compliance areas.
“Off-site audits are typically focused on one or two compliance areas,” Osiecki says, adding that COVID-19 did prompt more comprehensive off-site audits. “But for the most part, off-site audits, when they occur now and will occur in the future, they’re going to be focused.”
Comprehensive audits – whether on-site or off-site – result in a safety rating of satisfactory, conditional or unsatisfactory. Off-site audits, on the other hand, do not typically result in a safety rating. Instead, if a violation is found a carrier may be fined or notified of corrective action that needs to be taken to avoid a fine.
How Do Off-Site Audits Work?
An auditor – officially known as a safety investigator – initiates an off-site audit by contacting the carrier, according to Osiecki.
“The auditor picks up the phone and calls the company and says, ‘hey it’s your lucky day you showed up on our CSA radar and we’re going to do an off-site audit,” he says. “And they typically tell the company it’s your ‘X’ BASIC or it’s your ‘Y’ BASIC that we’re going to audit.”
Next, the auditor sends a document request letter to the carrier, typically by email. The carrier then uploads the requested documents – which may include things like dispatch records, fueling reports and information about drug and alcohol testing, in addition to ELD records – via the SMS carrier dashboard. Once the documents are provided, the auditor will review them remotely, a process that usually takes a few days.
“The auditor is usually communicating back and forth with that company,” Osiecki says. “There’s typically questions, additional information requests and information that’s going back and forth between the auditor and the company, and usually that’s via email or the phone.”
The auditor will contact the carrier about any violations they found, discussing remedies and how to improve compliance. Once the audit is completed, the auditor will conduct a “close out” call with the carrier and send an audit report to the company.
Watch the Webinar for Much More About Audits
At this point, you should be up to speed on some of the similarities and differences between on-site and off-site audits, and what off-site audits entail. But there is a lot more information about DOT audits in the webinar, including:
- Federal Motor Carrier Safety Administration rules for audits
- How auditors determine what records to request
- Audit preparation tips
- Audit Do’s and Don’ts
- And much more