MCS-150 Date and Mileage: What an Old Update Tells You

The biennial schedule

Under 49 CFR 390.19T(b), a carrier files the report before it begins operations and every 24 months after. The last digit of the USDOT number sets the month: 1 is January through 9 in September, and 0 is October; the filing is due by the last day of that month. The next-to-last digit sets the year: odd digits file in odd-numbered years and even digits in even-numbered years. A carrier with an illustrative number ending in 47 files by July 31 of each even-numbered year.

Failing to complete the biennial update exposes the carrier to civil penalties and deactivation of its USDOT number. SAFER’s field definitions describe that outcome as an inactive USDOT number under 390.19(b)(4) because the biennial update was not completed. The guide to carrier authority statuses covers how that registration status differs from the status of an MC docket.

Sources: 49 CFR 390.19T: biennial registration updates; SAFER field definitions

Reading the date

A recent MCS-150 date shows when the carrier last certified its information, not that every field is current today. A date more than 24 months old means the carrier’s scheduled update has probably passed; check the USDOT status rather than inferring it, because deactivation is FMCSA’s action and appears in the registration record.

VerifyCarrier’s DOT lookup shows the MCS-150 date from the FMCSA Company Census File and marks it when it is 24 months old or older, with the note that FMCSA requires an update at least every 24 months. Treat that mark as a prompt to confirm status. Registrants now submit biennial updates and changes in Motus, FMCSA’s registration system.

Sources: DOT DataHub: FMCSA Company Census File; FMCSA: Move into Motus

Mileage carries its own year

SAFER shows MCS-150 mileage as the figure from the registration form, and the census file stores it beside a separate mileage-year field. Power units on SAFER count trucks, tractors and other units owned, term leased or trip leased by the carrier. Each is what the carrier reported when it filed.

Keep the mileage with its year and the fleet count with the MCS-150 date. The guide to the Company Census File explains why dividing recent events by older mileage produces a precise but misleading rate.

Sources: SAFER field definitions; DOT DataHub: FMCSA Company Census File

Why outdated mileage changes the SMS result

FMCSA’s SMS methodology, version 3.21, divides a carrier’s weighted violations in the Unsafe Driving and Crash Indicator BASICs by its average power units multiplied by a utilization factor. The factor uses vehicle miles traveled only where VMT from the past 24 months is available, taking the most recent positive figure. With no recent VMT information, the factor is 1.

For carriers mostly of combination vehicles, the factor rises from 1 below 80,000 miles per average power unit to 1.6 between 160,000 and 200,000 miles. For straight-truck carriers it reaches 3 between 60,000 and 200,000 miles. A high-mileage carrier whose reported mileage has aged past 24 months therefore loses that exposure adjustment, and its measure rises with no change in its driving. How BASIC percentiles are compared, and which are public, is covered in the guide to SMS and BASICs.

Sources: FMCSA: SMS methodology, version 3.21

Questions for the carrier

Record the answers with the date you asked. A carrier that has filed an update the public record does not yet show can say so; the record will confirm it later.

Recommended questions when the date or the figures look stale, to ask before relying on them:

• When did you last file your biennial update, and was it accepted?
• Does the reported number of power units match the trucks you are offering?
• Which year does the reported mileage describe?
• Has the legal name, address or ownership changed since the last filing?

Sources: 49 CFR 390.19T: biennial registration updates