Auditing with GPS and onboard recording devices Global

Auditing with GPS and onboard recording devices Global Positioning Satellite 9/15/2020 1

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 P 600 9/15/2020 IRP Article 5 2

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? 9/15/2020 3

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. 9/15/2020 4

Have you conducted a GPS or on-board recording device audit? What questions do you ask about the carrier’s system? 9/15/2020 5

*P 600 ELECTRONIC DATA RECORDING SYSTEMS *P 610 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 electronicallygenerated 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. 9/15/2020 6

P 620 DEVICES USED WITH MANUAL SYSTEMS All recording devices must meet the requirements stated in IFTA Procedures Manual Section P 640 and P 660. 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. 9/15/2020 7

P 630 DEVICES USED WITH COMPUTER SYSTEMS The entire system must meet the requirements stated in IFTA Procedures Manual Sections P 640, P 650, and P 660. 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 P 640. 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. 9/15/2020 8

*P 640 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); 9/15/2020 9

. 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. 9/15/2020 10

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. 9/15/2020 11

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. 9/15/2020 12

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. 9/15/2020 13

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 P 500 (Recordkeeping) and IRP Audit Procedures Manual Article 4. See also Section P 600 in the IFTA Procedures Manual and Article 5 in the IRP Audit Procedures Manual for GPS requirements. P 640 of the IFTA Procedures Manual and Section 505 of the IRP Audit Procedure Manual both state that odometer readings are required. 9/15/2020 14

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. ) 9/15/2020 15

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? 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. 9/15/2020 16

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 P 650. 400 and IRP Audit Procedures Manual Article 5, Section 506(iii) ). 9/15/2020 17

What is an “Exception report”? IFTA Procedures Manual, Section P 650. 400 Exceptions that identify all edited data, omissions of required data (see IFTA Procedures Manual Section P 640), 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). 9/15/2020 18

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 truck’s 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? 9/15/2020 19

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? 9/15/2020 20

Has the technology of electronic recording and sending systems matured to the point where it’s fully dependable to accurately capture all vehicle activity? Is the technology and computer software able to capture a truck’s 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? 9/15/2020 21

Do you trust it? How do you test an electronic recording system? The carrier you’re 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. 9/15/2020 22

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 don’t know for sure? 9/15/2020 23

D) Apply a 4. 0 -MPG adjustment and 100% fees to cover what you don’t 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 “You’ll send a bill”…………………. Then leave………. . 9/15/2020 24

Has your jurisdiction granted a GPS waiver, or some other type of electronic device waiver? 9/15/2020 25