Inadequate Assessment Ballot

Transcription

1 Inadequate Assessment Ballot Changes to Article X Section 1015 Heidi Crawford 1015 Inadequate Records Assessment Current language the Base Jurisdiction shall impose on the Registrant an assessment in the amount of twenty percent of the apportionable Fees paid by the Registrant, for the registration of its Fleet in the Registration Year to which the Records pertain. Proposed language the Base Jurisdiction shall impose on the Registrant an assessment in the amount of twenty percent of the apportionable Fees paid by the Registrant or found due, for the registration of its Fleet in the Registration Year to which the Records pertain. Proposed ballot correction: the Base Jurisdiction shall impose on the Registrant an assessment in the amount of twenty percent of the apportionable Fees paid by the Registrant or found owed due to unreported jurisdictions, for the registration of its Fleet in the Registration Year to which the Records pertain. 1

2 If inadequate mileage records are provided today: During an audit no miles can be added for jurisdictions that were not originally reported. If the carrier estimated miles in jurisdictions where actual travel was found, some fees were originally paid to those jurisdictions. However, if no fees were originally paid you could have the processing staff add a jurisdiction prior to completing an audit to calculate fees. If inadequate mileage records are provided under FRP: During an audit no miles can be added for jurisdictions that were not originally reported. FRP eliminates estimated miles and the fact that some fees could have originally been paid to those jurisdictions where no actual miles were reported. FRP eliminates the ability to add Jurisdictions during a registration year to calculate fees. Proposed ballot 1 st this ballot is proposed to allow an auditor to be able to add a jurisdiction that was not originally reported, and to collect fees that should have been paid at the time of renewal on the unreported jurisdiction. 2

3 Proposed ballot 2nd the auditor would then be able to assess the additional 20, 50, or 100% fees on all reported and unreported jurisdictions in the event of an inadequate records audit. Comments you may have? If you can determine activity in a jurisdiction that they didn t report, then can t you do an audit? We never looked for this before. This has always been an enforcement issue? Audit Example under FRP Carrier who travels only provides you with one months worth of distance records. This carrier doesn t meet the definition of sufficient due to the missing of 11 months of records. In the records provided there is a destination to FL but the carrier didn t originally report FL distance. 3

4 Audit Examples under FRP The jurisdiction views inspections of the carrier and sees that there are several jurisdictions that were not reported on the IRP renewal. The carrier doesn t have any distance source documents and tells the auditor that they estimate the activity that was originally reported. Audit Examples under FRP Carrier threw away all distance records and doesn t have anything to support distance traveled. They do have fuel records that were provided for the IFTA audit that was also being conducted. A fuel receipt was found in a jurisdiction that was not originally reported. Conclusion If the ballot fails and current wording of Plan Section 1015 remains unchanged, the jurisdiction that is not reported will not receive any fees even though the auditor had evidence that distance was accrued in the unreported jurisdiction. This would force the auditor to ignore the unreported jurisdiction in the event of an audit with inadequate records. Are you auditing on behalf of all jurisdictions if you ignore this? 4

5 Conclusion If this ballot passes, the unreported jurisdiction will receive fees through the audit when the overall classification is inadequate. The auditor will then be auditing on behalf of all jurisdictions the licensee reported travel in as well as any evidence that travel was found in unreported jurisdictions. Questions?????? Contact information: Heidi Crawford