Representatives from 40 of the 59 IRP jurisdictions participated in the calls; that number includes industry participation.

Transcription

1 This document combines the notes taken from each of the recently conducted Audit Committee Roundtable calls on Inadequate Records (a special thanks to Claudia Trapp for such a comprehensive job). Jurisdiction references have been removed, and the notes have been retained by region. Since the conversation was not scripted, the same questions did not come up on every call. We asked the following poll question on every call (the 1 st poll had 3 possible answers): Would your jurisdiction find a carrier s records inadequate if they had everything except odometer readings? Response by region: Yes No Unsure Region I 17% 58% 25% Region II 22% 78% Region III 44% 56% Region IV 28% 72% Representatives from 40 of the 59 IRP jurisdictions participated in the calls; that number includes industry participation. Notes: Region I Question: If registrant does not have odometer readings, but has everything else are the records inadequate? Odometer records should always be used. Assured I will capture every mile if have good odometer readings, but will missing a few miles really impact the percentages? Do they have GPS? What do they have? If not on the logs, perhaps maintenance records can be used. Sometimes depending on all other facts would say adequate. What if missing in quantity? Don t know 100% of miles. The Plan does provide leeway, and the Best Practices Guide offers ways of estimating if you have missing trips. o What if I have readings but they don t coincide with reporting period? o What about partial readings? Are they for a reasonable time frame? At least that offers a mechanism to estimate what I don t have. o If the answer is no odometers period, and I have some miles I m concerned about, I have to distribute them in some way. o If there are no odometer miles, there must be another record that supports the activity that is concerning, so can t that information be used to determine the distance of concern? Other things should be considered before an automatic inadequate rating: o Are the records generally complete? o If fuel data is available, is the MPG reasonable o If there are not significant date gaps in the records, how important is knowing total miles? If the odometer reflected 150,500 miles but only 150,000 were reported, is that going to have a measurable impact if corrected? o Odometers are not infallible. 1

2 If registrant has GPS with E-Logs and summaries, but no odometer readings, are the records inadequate? They could be viewed as adequate depending how good system is. Is it always capturing movement? Sometimes there are differences in calibration, and that can change from time to time with tire wear or changes. GPS audit the GPS failed. ECM (engine control module) failed as well. I was able to identify a gap determined it was an isolated error. Carrier s often print whatever system gives them without verification. Suggest they use some kind of odometer. We do IFTA with IRP. If they don t capture their local distance skews the whole result. I find it useful to get the detail for 1 day. Does the information in that day reconcile to the summary for the day? Look for odometer readings on other docs as a form of comparison People changing their GPS provider; can t bring the data with them. Upon audit don t have GPS data from prior provider. Is that an automatic inadequate? o Yes carrier needs to produce that; it s no records o Unfortunate they didn t download the details needed o o Can only be so flexible Changed GPS providers after reporting period. May elect to postpone that. If your jurisdiction will not elect to do that. No matter what you know about the system can t call it inadequate if you have nothing. What is my comfort level as an auditor? o The Plan provides direction, but it allows auditor discretion. What if carrier said they lost records in a flood or other disaster? Should that be an automatic inadequate? Send me the insurance claim I called them back again they had the same excuse. Carriers know they have to keep records for four years. o They really have to keep records up to six years reporting period, not registration year. o IRP is current and prior three registration years, and when the reporting period relative to those years (what is actually being audited) is factored in, it s a lot of data to keep. Electrical storm: carrier was able to prove she lost everything on computer she had current records and indicated the system had not changed. Those records were adequate, so we didn t change any of the fees. o The Plan requires that 1 quarter within the reporting period be tested for each audited IRP year. Considering the facts, we would not have called it adequate since there were no records from the reporting period to test. If the auditor is confident with the evidence of a loss that s provided, we would cancel that year, but audit a more current year not impacted by the loss, or postpone until 1 was available. Get copy of fire report. Another year. As long as carrier is being cooperative, work with them. Not as long as we have something confirming the loss. Multiple truck carrier that does not have vehicle summaries, but has great trip reports. Will have to test all of their trucks for at least 1 quarter for comparison to IFTA return. This is beyond a sample audit. Would it be inadequate, or not? We won t be the bookkeeper for the audit; we don t have the time for that. o Would tell carrier something like: We ll pick this sample quarter and give you XXX time to create summaries. Once summarized, we ll come back and do the audit. Be aware our adjustments will be based on the summaries you ve provided. 2

3 Had that situation, but without good records. They were not giving me complete summaries. I had to issue a 20%. The records that they had were not auditable. They were not available for testing. Similar ongoing audit right now: daily odometers in and out. 400 miles on a day. Carrier doesn t put locations unless they leave the base. She s going to go through and find where they went. If they stay within 150 miles they don t have to log for DOT but that s not the case for IRP. 80% of our audits are inadequate records because of that. They often have daily odometer readings but don t say where they re going, so having total miles in this case is pointless if we don t know the portion per jurisdiction. o If you don t have IVDRs that s 20%. They re just logging trips when leaving state. Backing into the total from there. o It s a judgment call if you have odometer reading: they can be driving around in circles, doing deliveries. It s not black and white. o Every jurisdiction faces DOT dilemmas what DOT requires, versus IRP and IFTA. Back to original summary question: depends on number of vehicles one auditor would audit a quarter and use that as sample. Even that should depend on the number of vehicles 10 vs 110 we re not your bookkeeper. We suggest our staff tell the carrier create summaries from your records. I will audit that sample and project based on those findings. Although we encourage such; does every auditor do that? No. Some will attempt to plod on through if they see it as manageable (certainly not for double digit fleets). They see it as more of a hassle to go back and forth with carrier. For us, if we had good information that was not summarized, it would be hard for us to call that inadequate. If we gave them 20% for not having summaries they would contest it; we would allow them to create the summaries. Try to avoid things like that. Give them an option to make summaries. If they don t want to do that, it s inadequate. I d let them do a summary so we can audit it. If a company has daily odometer readings, does their geographic closeness to the jurisdictional border impact the adequacy rating since it makes it more difficult to determine vicinity distance? Should all carriers have to maintain the same quality records to receive an adequate rating? Would love to see that it s not happening Depending on the operation of the companies, records can still be adequate. Example: logging companies. You know the where (jurisdiction) the timber is harvested. You know what mills they send the logs to and which ones are outside the base. You have most of the requirements to determine if the distance is correct. In our jurisdiction, that s good enough for that industry. o Type of industry carrier is in can effect type of records you get from them. Not everyone in trucking business; it s a by-product of what they do, not what they do. Is that holding different carriers to different standards? Possibly. o Oil deliveries. Delivery locations and mileage factors, but routes going from customer to customer between jurisdictions. In that case, giving me odometer readings without cities and without GPS makes it s hard to determine distance per jurisdiction. o If you re close; say 50 miles from border you have full load and you come back. They have a system that can be tracked, and they have odometers I would accept. o If they have a stated route on this day of the week we go here and that can be validated in some way, isn t that ok? It basically comes back to the jurisdiction s or auditor s perspective and level of trust. 3

4 Do you have specific guidelines in your jurisdiction to determine inadequate? o We don t. We have an experienced reviewer that looks at all audits, so we have that consistency. Auditors, especially new staff, don t always know whether an account should or shouldn t be adequate. Operations differ and some of the required elements may be more important in certain industries, etc. There are so many scenarios. It depends on the operation, the information and/or records you get along with any secondary information. We try to give every carrier the benefit of the doubt in a 1 st audit, in a 2 nd audit, not so generous. If an unusual operation, we will tell them which items are going to be important for their activity after all, the Plan indicates records that don t have all elements may still be adequate for audit depending on the records and specific operations of the registrant. If we don t have route of travel, but can use other things like fuel to determine routing, we can be pretty sure. Has your jurisdiction s approach to determining adequacy changed since implementation of full reciprocity? No. Our approach has not changed. Have numerous carriers who have spotty records, and have seen more unreported jurisdictions than previously, but we have not changed the approach. We tell our staff, if you can take the information provided, and determine what you believe to be a fair and reasonable representation of what the carrier did, then it s adequate. On the other hand, if you have so many missing parts and pieces that any end result would be no more than a guess; don t waste your time it s inadequate. That has worked for us so far. No. We see carriers now have an opportunity to manipulate their fees and still have travel authority in all jurisdictions. We are a small enough group we can discuss. No. We haven t changed our approach, but we are looking to have more unified/standard approach. If I can conduct the audit faster, that is a benefit. Currently relying on the Plan, but in a lot of cases, the answer is it depends there s a lot of grey. We ve slowly changed the way we do things. We are not as lenient; we won t help a carrier recreate a summary. Does he have enough information? Is it adequate? No matter what they send in; it s never going to be adequate in every sense. Closing: Inadequate ratings are often determined on a case by case basis. Confidence levels different auditor s vary Human error There are a lot of variables that have to be considered Carriers shouldn t be treated differently depending on their region or jurisdiction, but standardization would not be a simple task and may not be fair to all industries either. Take auditors: go back to APM. If there is precise language on how to handle things might have some conformity. Region II Does your jurisdiction have written guidelines other than the Plan for determining adequacy? If yes, what are they? Don t have any. Still in process. A lot up to auditor discretion We have written guidelines. If auditor determines there is no way with what you re provided you can do an audit and feel comfortable, then deemed inadequate. Take appropriate measures using IFTA and IRP guidelines. 4

5 o If they don t record odometers, ask questions and use secondary evidence to determine whether reported total miles and jurisdictional miles are adequate. If there are jurisdictions with written guidelines who can share some of it (for example, odometer reading specifics) that would be great For us if there are no odometer readings, it becomes inadequate. You find you can t get a handle for how many miles there are. Have to have sufficient information too for IFTA MPG calculations having odometer readings is critical. With IRP, you re looking at mileage strictly have to have reliable odometer readings to pin exact number of miles travelled. If you have all required information on trip sheets, but don t have odometer readings, we will reduce MPG by 10% for IFTA. IRP perspective adequate can be missing an element and still be adequate. If registrant makes multiple stops in a day (20+) and gives receipts with customers address but you are unable to run trips because their customer addresses could not be found, would their records be considered inadequate? We Had to get origin and destination in receipts. ProMiles couldn t find address. GoogleMaps couldn t find address. Is that information reliable? Would you consider that to be adequate? Drivers had trip sheets and receipts to customers and used GPS. Receipts had order/ time of day. Really difficult couldn t get miles half the time. Odometers on trip sheets. Reported one state from GPS, the other from odometers. Do they not have trip records? Would want to know what other information they have or are lacking. GPS. Latitude and longitude points work well in ProMiles, making actual named locations a bit less important. Have to remember as auditors not looking for perfection; looking for reasonableness. If you have enough information; if operations are consistent; if you can check trips or have the ability to determine total distance from odometers and/or GPS, that about covers it. If records presented enables a fair and reasonable representation of the activity, despite the reporting adequate. With GPS, would test specific segments. If trip test supported the jurisdictional parameters we would be good with that. Are there specific elements that are more important than others? We look at odometer readings. Jurisdictional recaps: one vehicle or multiple Would rather have recaps. Not necessarily make it inadequate if we don t, but depending on the size of the fleet, may be necessary. Regarding the poll question, I would like to know of the 22% that stated the records are inadequate are you deeming these inadequate solely because the odometer reading is absent? Yes, that was the purpose of poll question Are there any elements that are more or less important on a trip sheet? If they don t have origins and destinations can t test them that s important. Need origin and destination at a minimum. 5

6 Would jurisdictions request secondary evidence (dispatching record) to determine specific origin or destination? We do We normally request anything that would show where they ve travelled DOT log books all their stops and locations. A lot of them won t have them for whole audit period. We may have to look at three different documents sometimes, if they have the information. What if you had trip sheets, jurisdictional border odometer readings, jurisdictions reflected, but destination was not? Would you still find them to be inadequate? Inadequate. Can t test Consider: one drop or multiple drops. Not necessarily would look at company s internal controls As for missing destination, a little understanding of a motor carrier s operation is necessary. The company will have many source documents that could be requested to determine the destination. Too few auditors fall short on asking additional questions. If you have everything else, so that you could use the indicated routing to run trips and in doing so you confirm the accuracy of all through jurisdictions, wouldn t that go a long way in giving the auditor confidence that the delivery jurisdiction is also adequate, whether you have the actual point of delivery or not? What if you find a fuel receipt in a state not listed on the IRP bill. Should you make an extra trip to that state or should you find the taxpayer unreliable/inadequate? We will calculate miles based on that, and charge them the miles with an adequate rating. We will do the same. Assuming rest of records reliable, we would find them adequate It depends on volume of information you have Would be adequate if we are talking about an isolated instance the greater the occurrence the less likely the adequate rating. Are there any jurisdictions that would base their determination on a previous audit? You know what they rated in previous audit. They haven t implemented suggestions. First audit: not as punitive if you find issues Would that be an influencing factor? o No o Depends. New person doesn t have any clue regarding correct report. If I can see why it hasn t changed. o If I can use their information to do current audit, determination on previous audit irrelevant Any jurisdictions have a certain tolerance have 60% records; they have everything required, but they don t have other 40%. Would that be a factor in determining whether adequate or not? Jurisdictional recaps if have at least ½ of the year; can sample and accept recaps It depends. Doing audit as a sample if ask for a quarter, and IF records accurate, you re basing your projection on the sample. You might not know that they only have records for 25% of their 6

7 activity, and it happened to be the quarter you selected to sample. If it s a long haul carrier with consistent operations, can t you project that based on what you have? If the operations are not consistent, it would not be appropriate to project the findings to the 40% you don t have if there were operational changes. Auditors have to ask the right questions. I would make sure they have an entire quarter of records that are testable, and would project. Thanks for participating! Region III How does your jurisdiction determine adequacy? Do you have a defined process or policy? Audits go through different staff, have discussions Defined set of definitions as far as what sufficient and adequate equal; have a threshold at least 75% of information per quarter has to be there. Does any jurisdiction have a written policy? Or go through supervisor to get approval for the rating? We leave it up to auditors, with management input if needed. Can see where need a defined, written policy not working really well. We have something written we know there s consistency. Carrier should be treated the same no matter what auditor is doing the audit. Concerned how state will look in a hearing. Attorneys like seeing written procedures; it protects state s interest. Can demonstrate that in a hearing by pointing to a policy. There is some auditor discretion. Needs to be consistently applied by every auditor. Protects jurisdiction; treats carriers fairly and the same. Supervisor reviews. Consistency across auditors. Inadequate: discussed with reviewer and sometimes another auditor. Take into consideration: if a carrier isn t doing what supposed to be doing, are we being fair to the carriers? When we begin an audit (joint shop) start with IFTA, then IRP along with that. We find 2014 IFTA for entire year then do 2015 for IRP. We had a carrier that did a change in their system. Okay for 2014; but on their way to being inadequate. Implemented new system for 2015; so instead of auditing 2014 or 2015 for IRP, we audited 2016 make sure they re in compliance. Like to be fair. Especially if moving to GPS system. We want to make sure carrier is in compliance going forward, and the more current we can get, the better. If you do multiple audits, if you find something inadequate, would you put an assessment on a first-time audit for each year or just one year? We only do one year audits. Will do three years for IFTA. We don t have defined policy. If we don t have routes of travel don t get worried about it. Same with miles per state. As long as we can calculate and have odometer readings. Odometer readings have specific written procedures; have to be within certain time periods. They can be on maintenance or other secondary records we can use those for audit. If not able to do that inadequate. If have jurisdiction miles but don t have odometer? In our state, we need odometer readings. How can you justify distance? That s how we ve interpreted sufficient and appropriate. It depends on what they re able to provide us as records. If they have routes of travel and other components it depends what we re looking at. Same approach as other jurisdictions. We allow an opportunity to provide secondary sources for the odometer readings. Makes it more difficult for us. Challenging: carrier does have adequate 7

8 records, still can t get total miles reported correctly. How can I trust someone without odometer readings if I can t even trust people with odometer readings? Since each year stands on its own and must be sampled independently, the rating should be applied as appropriate to each. If inadequate, we often limit to 1 year (in a 1 st audit situation) if the carrier has been cooperative. When odometer is unable to be provided, what are some acceptable documents that jurisdictions have, or use, to compensate for that information vs. automatically deeming inadequate? We will accept odometer from anything for example, service tickets. Anywhere they can document an original odometer, but if we can t get at least 2 readings (beginning / end of year), the rating will be inadequate. We would not find a carrier inadequate if they had everything except odometer readings. Try to look at it if records provided are consistent. Not looking for perfection. IF records are consistent and continuous; no significant date gaps we would call that adequate. We will accept other things. Odometer on fuel invoices. Regarding the inadequate rating if don t have odometers, it s not automatically called inadequate. Similar to others. Look at operations. If can properly determine where they went, we re good. We will look at maintenance document, fuel invoices. If they have everything else we will give them the benefit of the doubt. Are there specific elements that are more important or less important for determining adequacy? We look carefully: can we track that trip where does it go? Can we track that trip to a recap? To a monthly or annual summary? What happens if you find the recaps don t add up? We would add up based on acceptable documents Example carrier reported distance, but doesn t have source documentation to support those figures, although source documentation is fairly good. How it gets from source documentation to IRP annual: that s the mystery. o How do we apply that to be fair to other member jurisdictions? How do you make an adjustment when nothing makes any sense? We allow them to use their IFTA miles if the fleets are common. We find less errors. Definitely times they can t explain what they did. We only audit current year. Most only remember less than one year. Situation: Carrier didn t report miles in jurisdictions traveled. Records were border-line adequate. Six jurisdictions that didn t get fees; said audit was adequate to get other jurisdictions their money. There was still an assessment, but was that the right message? If jurisdictions haven t gotten anything collected. If you called adequate what you re doing is okay. With that kind of situation, we would not fix the records to give other jurisdictions money. You rewarded that carrier for not doing paperwork properly, yet the carrier didn t get the proper assessment out of that. We are similar. If auditor is not confident that records reasonably represent what they did we would rate them inadequate and those jurisdictions would get nothing since there is no Plan provision for them in an inadequate situation. 8

9 Does any jurisdiction have a program to re-audit carriers rated as inadequate? We are starting to do that for those found inadequate two years ago. They know what they need to do; they re on notice that we ll be back in two years. Next level 50%. Going back to revisit. Started in No results yet. We will follow up with a records review. IF you fail records review, we will automatically do another audit. We do give carrier opportunity to make amends. All staff instructed when the rating is inadequate to put the carrier on their calendar 3 years down the road give carrier opportunity to adjust. We are giving them time to improve and if they don t, hoping the 50% will get their attention. If carrier is being cooperative, won t go back and re-audit them if we think they learned. If uncooperative, will be re-assessed down the road. If carrier made good faith effort to get it right. You can see whether they re getting it or not. We do a lot of education audits LOL. What if I don t have summaries? We give them the opportunity to recreate summaries letting carrier reconstruct them. Summaries suggests we re assuming carriers have source documents. Setting someone down to take those trip sheets (which would have been done before reporting); otherwise how did they come up with numbers for summaries? Recreating summaries loose term records were already there. Reconstructing what they probably had at some time, otherwise can t report. If had summaries, did away with them allow them to reconstruct them. Most of the time when they reconstruct it never matches. What if summarized by driver instead of unit. Sometimes easier to do it yourself. Depending on fleet size; here s your records, you have 30 days, send them to us. Same thing: if it s messy, we can t reconstruct it, we hand it back to carrier. If only a couple of vehicles. The auditor will usually opt to summarize themselves after all, what s the point of returning? If you re talking about 100 vehicles, that s different. If we re looking at 4 or 5 vehicles, we do it ourselves. Anything over 10 tell them what they need to do. I ll look at what you have. o How much time would be allotted for that? If they can do in a couple of hours do it themselves. If a day or two, should probably send back we try to limit to 20 hours per audit total. If a carrier uses dispatch records to report distance and has source documents but doesn t use them would you allow dispatch records as adequate or make them go to source documents? Example: dispatch records used. The records were flawed (routing, etc.) We would use only dispatch records gingerly. 90% of the time unless going back to include additional points for proper routing; routing from dispatch system completely different from what they re actually doing. Need source data. Use of GPS. I would trust the GPS. Auditing hard copies happening less. ELDs coming along; set a precedent for electronic recording. Dispatch records only as good as what computer will generate. Often shortest route, and not the actual route. Region IV Do you have written guidelines for determining adequacy? For us, the carrier has to provide 100% of the summaries. 50% of the source documents. 9

10 What source documents? o Source documents that support the summaries. 50% of the source documents for all the vehicles in the fleet. What if they have no summaries? o Not adequate for us. o They are allowed to create summaries. They have 30 days. If need to, will send source documents back. If 30 days have lapsed, we give them two additional days. If not, give them the assessment that gives them another 30 days to recreate the summaries. o We can t create the summaries for them. They have plenty of opportunities. o They provide us with source documents, but source documents aren t summarized, we won t summarize them for them. They need to summarize the source documents. o We sample a quarter; 50% is two quarters. o We are doing our audits based on a sample. What if a single vehicle fleet? Would you still require the same information, or would you use IFTA returns as a summary. o No, could not use IFTA tax returns as summaries. Don t differentiate between one unit and multiple units. o We are a joint shop, so we will use the reported IFTA data as a vehicle summary if only 1 vehicle and as a fleet summary if there are multiple vehicles. If we have adequate records to audit, we will calculate adjustment factors and apply them to the reported data instead of summary, since there is no summary. If the fleet is manageable (10 or less vehicles). The auditor will have to schedule all vehicles for the sample quarter. I more than 10 vehicles, we would only be auditing a sample of vehicles, and summaries would be required so as to have something to compare to for the adjustment calculations. Our auditors have summarized the docs when just one or two vehicles Our auditors might have done the same on occasion. Limited to one or two units smaller. Similar here. o We don t have official written policies. Use our past policies to get to the same place. One of our internal policies auditors have to turn in an audit within 90 days of start, or let management know if will take longer. o If the auditor finds really simple audit; they choose to recreate summaries, they can do that. o Auditor is accountable for saying why if longer than 90 days. We have recreated summaries that are simple. Write-up and recommendations include that summaries must be provided. o If larger, give it back to them. $500 admin fine. Most carriers will do it. o Do not recreate summaries for large carriers. Audit went to hearings. It doesn t pay to do summaries that s their job. We do it sometimes if it s a small shop. Will also write them up and say to do it in the future. At what point do records become inadequate? Whether they accept or reject miles; auditors have to make notes on internal spreadsheets, adding accountability. If missing them for two months, have to say why still accountable. Extensive review before out the door. Goes into audit report. Carrier with great summaries everything there except for odometer readings. I said send me source documents source documents did not match the summary. Obvious that making up the summary. I gave them inadequate records. Let them figure it out. 10

11 For us, if the auditor cannot take the records and determine a reasonable picture of the activity due to missing information or other mitigating factors, it s inadequate. If the records are imperfect, but the degree of imperfection still allows a representative determination of the jurisdictional operations, it will be adequate. Even if the summaries are wrong? o Yes, the fact they are wrong will not automatically result in an inadequate rating if the source data is representative. We won t call inadequate just because the two don t mirror each other. o 4 other jurisdictions indicate they are similar o Plan allows jurisdiction to do what they think is right. If a jurisdiction wants to have a harder line, the Plan allows that What if you had GPS but no odometer? We would use GPS. Can put into mapping program. We would accept if we have everything else If it s a second audit, does that effect how you assess versus if first-time audit? No, it doesn t matter. Same. Generally won t do inadequate if only missing odometer readings whether 1 st or 2nd. If missing records the first time. You go back another time, expecting a change. We are stricter the second time. There s a fine line. We generally allow more leeway the 1 st time, if we can. If nothing changed the 2 nd time, we would be less inclined to accept. We see that as giving the carrier the benefit of the doubt, but who s to say they may purposefully not make changes using the adequate rating as the rationale. We go out, talk with carrier. Say what missing. If we do come back penalties will be stiffer. Here s my number if you have questions. How many auditors do pre-audit work before you talk with carriers? 3 jurisdictions say yes. In pre-audit work, do you find travel in jurisdictions they have not paid fees to? o 2 said yes o 1 said: if we find travel in jurisdictions that didn t pay fees, trying to make records adequate so can make those jurisdictions whole. We try to utilize what they have and add those jurisdictions. If you do inadequate, can t do anything now unless ballot passes (ballot failed since this roundtable was held). o Other said: we do not do what we can to make it adequate if there is not enough info, it is inadequate, regardless. If unreported jurisdictions are added, we are taking fees away from reported jurisdictions, based on guess not appropriate. We do mention those jurisdictions in the report, and send them a copy through the exchange so they can bill in some way if they want. We don t look that far. If they re inadequate, they re inadequate. When doing preliminary work we do research. Don t have any way to see if traveled in unreported jurisdictions. o We review Fed inspection data prelim, and then look at records during audit. If we get no records, we still know they traveled there. o We look at inspection reports to see what our risk is. 11

12 If missing a trip or two, would that be inadequate? Or would you try to recreate the trip? Our auditors have to explain why. If you had a large chunk of miles auditor would have to explain that this is what I thought it was. Would recreate the trip. If you have a reason. Otherwise wouldn t be able to recreate the trip. Depends on size of the gap. If local travel can t get out. Would do estimate edge of province if could get out of province, if next trip started at same point. Once you have a large gap we then do a split between them, depending on how much distance involved. It depends on how much is missing. Does the missing activity cover a minor or major portion of the total distance? If a minor portion with location differences we would run a connecting trip. If not location differences, we would look at the amount and carrier s location to determine how to properly allocate. Missing trips would not be an automatic inadequate it would depend on all other facts. If we are going to the trouble to allocate, it will necessarily be adequate. Same way case by case basis. If a particular vehicle allocate based on their operations. If missing for one trip. It s adequate. Does everybody have as many problems with getting carriers to submit records? Yes. If one truck or two truck operations hard to get them to submit records. Especially if there is local travel DOT says don t need to keep. Those carriers don t keep summaries. Try to get them to give up records promptly. Sparks them to create summaries from other documents. Do you have a lot of re-considerations? No. Even through tax preparer: example with no travel logs. Reconsiderations a handful last few months. Less than 10 in past year. We send a warning letter with estimated amount due not yet closed, then get good response to that. Some jurisdictions send 10-day demand letter. o Do you have an internal policy for the 10 day demand? o Yes, in statute. Only do it if they don t provide anything. Sometimes they won t even call you back. Give them opportunity. It s a last resort. o We don t have a written policy, but it is a verbal policy among audit staff. Try to reach them by phone. Send letter. If no response, send a letter giving 10 more days: We notified you, you didn t respond. If we don t hear from you, you re looking at potential liability of $. That gets attention. If not, we Issue the report, but if they call within the appeal period and say I have those records, we have to do revision. o We do that too. What do other jurisdictions do when they border another jurisdiction a city or highway split into two jurisdictions? What would you do for allocating distance? Crossing jurisdiction line maybe 10 times a day. How do you do allocate? Some small carriers are using paper. We have local carriers on borders operating a delivery service that takes them in both jurisdictions. We treat them the same as any other carrier. We have to be able to assign the miles to correct jurisdiction. Will need more detail on their routes than someone on highway. We recommend to our carriers. Tighter controls. Recommend GPS. Deal with some carriers that are towing companies on borders. If using paper recommend that they have to keep origin and destination of all their stops. We all have this they need to maintain odometer readings when they cross. In Summary: It appears we may not be as far apart in many respects as we thought we were. Thank you! 12