Before December 2015, if you were an entrepreneur starting your own trucking business, one of your first steps would be to register for your U.S. Department of Transportation (USDOT) number with the Federal Motor Carrier Safety Administration through a form called the MCS-150.

USDOT numbers are required for an entity that is authorized by state law to engage in transportation, including an individual, corporation, partnership or other business organization. 

Registering provides the government with critical information about a business, including its legal name and trade name, addresses, contact information, type of operation, cargo carried, if the business hauls hazardous materials, and number of vehicles and drivers. It’s what the government uses to track and maintain information about each company’s safety record. 

The FMCSA revised its protocol so that after December 2015, new USDOT applicants had to initially register through the Unified Registration System (URS).

However, the MCS-150 is still used by transportation businesses to file biennial updates to their USDOT number registrations.

FMCSA requires regular registration updates for entities that: operate commercial vehicles transporting passengers; haul cargo in interstate commerce (meaning crossing state lines); or transport hazardous materials that require a safety permit in intrastate commerce (within the boundaries of one state). In some cases, intrastate businesses may still need to fill out the MCS-150 even though the FMCSA itself does not enforce it; this scenario is covered more in-depth later in this article.

While it may seem clear-cut at first, the MCS-150 still stirs confusion among filers. FreightWaves sat down with J. J. Keller & Associates Inc., the transportation industry’s trusted safety and compliance experts, to find out what businesses need to know about the MCS-150, its common challenges and how to stay compliant.

When to file the MCS-150

The FMCSA requires businesses to stay current on a long list of compliance documents. As a DOT number is a transportation business’ unique identifier, the MCS-150 is one of the most important items to keep on top of. Allowing USDOT number registration to lapse comes with serious penalties, including a maximum fine of $10,000 or even deactivation of your DOT number, according to the FMCSA.

Here are the three most important things to know about when to file:

1. Biennial updates: FMCSA requires entities to provide regular registration updates — at least every other year. 

The filing schedule is based on the last two digits of a company’s USDOT number, which determines the year and month the entity pays.

The second-to-last number indicates the year. If the number is even, the entity must update in even-numbered years. If it’s odd, the entity must update in odd-numbered years.

The last number determines the month. The monthly schedule is as follows:

• 1 = January
• 2 = February
• 3 = March
• 4 = April
• 5 = May
• 6 = June
• 7 = July
• 8 = August
• 9 = September 
• 0 = October

2. Interim updates: Registration updates can be provided to the FMCSA more often than once every two years.

For scaling fleets especially, it can actually be advantageous to provide more frequent registration updates.

“The miles traveled and the number of power units a company possesses factors into the formula used to determine the Crash and Unsafe Driving CSA BASIC [Compliance, Safety Accountability Behavior Analysis and Safety Improvement Categories] measure scores,” explained Richard Malchow, J. J. Keller industry business advisor.“The update helps to ensure the carrier’s measure is compared to other carriers with a similar number of ‘at bats’ rather than the number of inspections in the last two years.”

3. Filing early: The regulation regarding biennial updates states a carrier “must file” in the proper month and year, as outlined above.

However, if a business chooses to file more often due to changes in its structure, the FMCSA has provided guidance that clarifies that a company can satisfy the biennial update requirement if it files “any time during the 12 months immediately preceding the biennial update due date.”

Common challenges with the MCS-150

Two areas on the MCS-150 that create considerable confusion for filers include how to count drivers and vehicles. While the MCS-150 form contains instructions for both of these areas, those instructions are not clear. 

More information on how to properly fill out the MCS-150 can be gleaned from the MCSA-1 form, which is the current application on the Unified Registration System for new applicants.

Counting drivers: Based on information derived from the MCSA-1, there are a couple of specifications on how drivers should be counted on the MCS-150:

• Entities should report the number of drivers operating commercial motor vehicles (CMVs) on an average workday. This includes company drivers, leased, part-time and casual drivers. 
• Additionally, driver count is filtered by drivers who typically operate CDL-required equipment; drivers who operate within 100 air miles of their normal work reporting locations, for both interstate and intrastate commerce; and drivers who operate outside of 100 air miles from their normal work reporting locations, also for both interstate and intrastate commerce.

Counting vehicles: The FMCSA provided a more concise explanation of how to count vehicles on the MCSA-1, advising those filing to include:

• The total number of CMVs owned, term-leased or trip-leased by the applicant on the day the form is submitted, and which have a weight of 10,001 pounds or more based on gross vehicle weight rating (GVWR), gross combined weight rating (GCWR), gross vehicle weight (GVW) or gross combined weight (GCW).
• The vehicles are registered under a carrier’s name, whether registered under federal or state law, or if it’s controlled under a trip lease or term agreement of more than 30 days.
• Pickup trucks that are a CMV or considered a CMV when connected to a trailer should be counted as a straight truck.

Intrastate implications

Although the FMCSA regulates interstate carriers, this doesn’t exclude these entities from being required by the state to obtain a USDOT number or file biennial updates. According to the FMCSA, 38 states plus Puerto Rico enforce USDOT numbers for intrastate-only carriers. 

“If a state has adopted the federal regulation requiring a USDOT number, technically the state also requires a biennial update,” Malchow said. “The FMCSA will not deactivate an intrastate carrier’s USDOT number due to not submitting an MCS-150 update, but the state may.”

How strictly the biennial update requirement is enforced varies by state.

Most carriers are required to submit an MCS-150 regularly, at least every other year. Right now, carriers should submit updates when the nature of their business has significantly changed. 

“At some point, the FMCSA is likely to require an updated MCS-150 to be submitted when the carrier has a structural change in operation,” Malchow said. “Intrastate carriers that may not be required to submit an MCS-150 biennially should consider submitting an MCS-150 when there is a significant change as a best practice.”

Carriers can also turn to a reliable third party, such as J. J. Keller’s Trucking Authority Service, to assist with submitting an accurate MCS-150.