Top 5 Ways Your MCS-150 May Be Hurting Your CSA Score

There are not many “gimmes” in life.  I think I have one for you.

For anyone unclear on the concept: In golf, a gimme is a shot that the other players agree can count automatically without actually being played.  In other words – get a benefit from hardly any work on your part.  Sound good?  In the world of transportation safety, improving your carrier’s CSA score by submitting a new MCS-150 form qualifies as a gimme.

Let’s look at five ways you may be able to improve your CSA scores by voluntarily submitting a new MCS-150 form.

First, a quick overview of the MCS-150 form – what it is and when it should be submitted:

What is the MCS-150 Form?
The MCS-150 form is technically the “Motor Carrier Identification Report (Application for USDOT Number).”  Download the PDF version of the form HERE or complete online HERE. In short, this is the form a motor carrier can use to request a USDOT number and, more importantly for our purposes, update their previous MCS-150 information.

When to submit a new MCS-150?
This is the key question.  First of all, you are required to file the MCS-150 at least every two years (biennially for you vocabulary enthusiasts).  If it has been two years or more since you filed your last MCS-150, you need to file a new one right away.  How to check?  Use the FMCSA’s Company Snapshot page HERE.

If you are within the two years, you may choose to file an updated MCS-150 at any time.  Here are five reasons you might want to:

1) Number of Power Units is Under-Reported.

If your number of power units is artificially low – meaning you now actually have more power units than your last MCS-150 shows – then your CSA scores are likely being negatively impacted.

So what’s the problem exactly? Here’s the problem: Your reported number of power units is used in key CSA calculations in two BASICs: Unsafe Driving and Crash Indicator.  In these two BASICs, your carrier’s exposure is determined by dividing CSA Points by your average power units times a utilization factor (discussed below).  In other words, the more power units you have, the more your violation points are diluted and the lower your CSA score will be.   [NOTE: The full CSA Methodology is painfully explicit about these calculations, so consider my explanation in this post to be an overview.]

2) VMT is Under-Reported.

VMT stands for Vehicle Miles Traveled.  On your MCS-150, you report your VMT for the last calendar year.  If the last reported total is lower than it should have been OR you have results for the next calendar year that are higher than the previous year, your CSA scores are likely worse than they should be.

Why – What happens? Again, The same two BASICs – Crash and Unsafe Driving – are likely higher than they would be with the corrected information.  VMT is used to calculate “The Utilization Factor” (soon to be a game show on the FOX Network!) used in the calculation.  With a high utilization factor, you get a bonus and the FMCSA essentially pretends you have more trucks than you actually do.  This high utilization bonus can be significant: Maximum bonus allows a carrier to triple the number of power units – or in other words, eliminate two-thirds of their violation points.  Wow!  [NOTE: I plan on explaining how to calculate your utilization factor in an upcoming blog post - and on my new show on the FOX Network! I kid. I kid.]

3) VMT is Over-Reported.

Surprisingly, if you report a VMT number the FMCSA sees as too high based on your number of power units, the utilization factor for these same two BASICs, Unsafe Driving and Crash, isn’t just capped at the maximum value.  Instead, it resets to absolutely no bonus (see #2 above).  We have a technical term for that here- “No Soup For You!”

4) Incorrectly listed as HazMat / Passenger Carrier

If your carrier is listed incorrectly as a HazMat or Passenger carrier, then your CSA Percentile rankings won’t change – but your intervention threshold become much tougher than they would for a general carrier.  See chart:

Other Options: Carriers have made the decision to change their business model due to the stringent intervention thresholds when classified as a HazMat or Passenger carrier.  These options include:

• Get out of the passenger or HazMat business completely. This change is made much easier if these activities constitute a relatively small percentage of your overall business.
• Split the Carrier. Some carriers have isolated the HazMat or passenger part of their business to a new carrier, with its own USDOT number.  This allows the main carrier to be listed as a general carrier, while the new separate carrier is tagged with the HazMat or Passenger status – and the subsequent tougher intervention thresholds.

5) Number of Combo & Straight Trucks Incorrect

Yogi Berra once said “If there’s a fork in the road, take it.”  Wisdom indeed.  Under CSA, you may be on the wrong fork (or “segment” in CSA terms) if your last reported power unit count and type are not current.  There’s an important distinction made between combo and straight for carriers.  Here is, word for word, the explanation from the CSA Methodology:

The Unsafe Driving BASIC and Crash Indicator account for carrier differences by segmenting the carrier population into two groups based on the types of vehicles operated. This segmentation ensures that carriers with fundamentally different types of vehicles/operations are not compared to each other. The two segments are: (1) ―Combo or combination trucks/motor coach buses constituting 70% or more of the total power units and (2) ―Straight or straight trucks/other vehicles constituting more than 30% of the total power units.

So, what does that mean? If your carrier is classified as the wrong segment, then your CSA percentile rank is very likely different than it would be under the correct segment.  WARNING: The word different does not necessarily mean better in the previous sentence.  (I’ll entertain myself while you re-read the sentence – perhaps with a new episode of House…on FOX!)  So, you pays your money and you takes your chances, so to speak.  Ultimately, you will need to submit correct data to the FMCSA at least biennially, so if you are in this position, your main question is about timing the new MCS-150 submission.

I hope this information is helpful.   As I mentioned above, I do plan on posting a future blog on how to calculate your utilization factor.  Please feel free to comment or contact me directly if the decision to submit or not submit a new MCS-150 is on the table for you now.  Remember: Never pass up a gimme!