Overview
The Registry of Motor Vehicles (RMV) did not effectively ensure that only eligible people were allowed to retain and use disability parking placards and did not ensure that its database of information regarding people who had been issued disability parking placards was accurate and complete. As a result, there is a higher-than-acceptable risk that these placards may be abused and deprive people with disabilities of needed parking.
On December 6, 2016, RMV entered into a partnership with the Massachusetts Department of Public Health (DPH) whereby DPH sends RMV a file listing people who have died and RMV runs a program to check the “deceased indicator” in the RMV master file, which is visible when RMV is preparing to issue a disability parking placard. If a deceased person is not already marked as such in RMV’s records, the program updates the deceased indicator.
Although RMV uses the Vital Statistics File that it obtains from DPH to identify deceased individuals’ placards and remove them from its database, using only this source of information may not be effective. For example, we compared the names and Social Security numbers (SSNs) of all individuals with active permanent disability parking placards during our audit period to the Social Security Administration’s Death Master File and found that RMV had processed 10,145 requests for disability parking placards from individuals who, according to this file, were deceased.
In addition, RMV does not properly administer the return and destruction of placards belonging to deceased individuals. Rather than requiring placards to be returned to RMV for destruction, it allows the placard holders’ estates to destroy or discard canceled placards themselves. Unless a placard is returned to RMV, it will remain unaccounted for.
According to RMV’s Medical Affairs Department, 60,690 unique letters were mailed during the audit period requesting the return or destruction of placards by estate holders. Our reconciliation of these letters showed that 4,056 (7%) of the placards related to the letters were retrieved for destruction by RMV and 8,461 letters (14%) were returned as “undeliverable” by the post office and stored in bins. The remaining 48,173 placards related to the letters (79%), according to RMV officials, were presumed to have been discarded by estate holders.
Many letters never receive appropriate follow-up, leading to a higher number of placards that are unaccounted for. For example, in many cases RMV has two addresses (mailing and residential) for one customer. RMV typically uses the identified mailing address to mail correspondence; if the letter comes back as undeliverable, RMV resends it to the residential address of the estate holder, requesting the return of the placard. However, if the second letter is delivered but there is no response, RMV does not take any follow-up measures to facilitate the return of the placard.
In addition, we performed a separate analysis of RMV’s placard holders and found that some other information about placard holders in RMV’s database may be inaccurate. Specifically, according to the information in this database, as of December 31, 2016, 12,694 active placard holders were age 100 years or older. This number is significantly higher than the 1,520 individuals that made up Massachusetts’s entire centenarian population as of the 2010 census.
Authoritative Guidance
According to Section 17.05(1) of Title 540 of the Code of Massachusetts Regulations,
The use of a disability placard, or the special parking privileges associated with a disability plate, is restricted to the person to whom the placard or plate has been issued.
RMV management is responsible for ensuring compliance with this regulatory requirement by establishing effective internal controls within its administrative process over the issuance, use, and return of placards and the maintenance of complete and accurate information in its database.
Reasons for Noncompliance
DPH’s Vital Statistics File includes only individuals whose deaths occurred in Massachusetts. In contrast, the Death Master File is composed of data provided by sources beyond those DPH uses, such as post offices, financial institutions, other states’ vital record agencies, and federal agencies. As a result, the Death Master File is more comprehensive than DPH’s file in some ways, which may have contributed to the higher number of deceased placard holders we identified in the Death Master File compared to that in the DPH Vital Statistics File.
In addition, RMV’s practice of automatically renewing permanent placards every five years limits its ability to ensure that it does not mail renewal placards to deceased people. RMV renews permanent placards every five years indefinitely unless it cancels them, as it does when it identifies deceased placard holders. If RMV does not identify a person as deceased, it will automatically continue to send them a new placard every five years. We reviewed a selection of other states’ renewal requirements and noted that some require people to periodically submit new applications and certifications of their disabilities. For instance, Florida and Michigan require placard holders to reapply every four years.
RMV officials could not explain why some of the information in its database regarding handicapped placards was inaccurate.
Recommendations
- RMV should use the Death Master File, which identifies individuals who have died in other states as well as Massachusetts, to improve its efforts to identify and cancel deceased individuals’ placards.
- RMV should require all individuals with permanent placards to reapply every five years.
- RMV should take the measures necessary to ensure that its database of information regarding individuals who have been issued disability parking placards is accurate and complete.
Auditee's Response
The RMV does use the Social Security Administration’s Death Master File and used it throughout the audit period. The RMV supplemented the use of this file in 2016 with the use of the Massachusetts Department of Public Health’s Vital Statistics File that includes death records. These files are run against the RMV database and any matching records, including placard holders, are marked as deceased.
The RMV does not require people with permanent medical conditions, as certified by a licensed healthcare provider as part of the placard application process, to reapply for their permanent placard. The RMV considers the re-application a burden to customers with identified, permanent, disabling medical conditions, such as blindness or paralysis. These customers have already proven, through medical documentation, their condition and their demonstrated need for a permanent parking placard.
An application for a disability parking placard or plate must include certification from a licensed healthcare provider that the customer has a medical condition that impacts mobility, such as a chronic lung disease, cardiovascular disease, blindness, or loss of a limb or loss of the use of a limb. The RMV relies on the healthcare provider for details of the customer’s condition that would warrant the issuance of a placard.
The Auditor’s report asserts that the RMV does not have a system to track placard replacements. This is incorrect. During the audit period, this information was available in the ALARS system through notes associated with each customer’s account. Because those notes were free form text, the auditors may have found it difficult to search that data systematically. The new ATLAS system provides improved reporting and search capabilities related to individuals requesting permanent replacement placards and temporary replacement placards. The reporting and search function will help support the RMV’s new policy related to replacement placard requests. The RMV is able to track replacement placard requests submitted online as of March 26, 2018. Systematically, replacements may only be requested online once in a 12-month period. Now that ATLAS offers the technical ability to more clearly label the status of a particular placard, the RMV is working with the Department of Criminal Justice Information Services (CJIS) to transmit specific placard attributes. When a CJIS authorized user queries a placard, the goal is that the user will receive more actionable information that could lead to the issuance of a citation and or confiscation of a placard being used improperly. . . .
The RMV . . . with the implementation of its ATLAS system has initiated the following policy:
When a replacement placard is requested, the original placard is canceled and invalidated. Continued use of a canceled placard is against the law and carries fines and loss of license. The Medical Affairs Department may take the following actions for individuals requesting more than 1 replacement placard over the course of 12 months, or more than 3 during the 5 year period of validity of a permanent placard, and may deny requests for replacement placards based on the results of its findings:
- Review all history of placard issuances and replacement requests with the agency, including requests for both temporary and permanent placards.
- Review RMV records for evidence that original placard was misused by the placard holder or by anyone else, including those residing at the same address as the customer.
- Review original documentation/applications presented to the RMV that resulted in the issuance of the original placard.
- Request updated medical information on the customer's condition and ability to operate a motor vehicle safely.
- Request confirmation of application and condition directly from the customer’s healthcare provider.
- Request information from customer’s local city/town office on disability.
- Request customer attestation on proper placard use prior to replacement, attestation may be requested in the form of a notarized letter or notarized affidavit. Letters and/or affidavits may also be requested from others residing with the customer or others involved in instances of confirmed or suspected abuse.
Auditor's Reply
During our audit, RMV management told us it had previously used information from the Death Master File to determine whether a placard holder had died. However, these officials stated that in December 2016, RMV switched to using the Vital Statistics File that it obtains from DPH to identify deceased individuals’ placards and remove them from its database. Regardless of which information RMV is currently using to update this information, it appears that RMV’s process for ensuring that the information is updated is ineffective, as evidenced by the fact that our review of the Death Master File showed that RMV processed 10,145 requests for disability parking placards from individuals who, according to this file, were deceased.
We do not necessarily agree with RMV’s assertion that simply having placard holders periodically reapply for their placards would be an undue burden to them. Placard holders should have several ways to accomplish that. For example, RMV currently allows individuals with qualifying disabilities to apply for their original placards online and to apply for replacement placards online, indicating that such a process does not present a significant barrier to these individuals. Further, as stated above, our research showed that a number of other states require individuals with handicapped placards to periodically reapply for their placards. In the opinion of the Office of the State Auditor (OSA), instituting a reapplication process for placards would not only better ensure that RMV’s information about these placards is accurate but also reduce the possibility of misuse.
Although there may have been a means for RMV to manually track replacement placards, based on the results of our audit testing, the agency was not using this means, as we found significant problems in this area, including many placards that were unaccounted for. During our audit, on several occasions we asked RMV officials to give us any reports they could generate regarding replacement placards, and they told us that there were none. RMV officials did point out that it was possible to review the text of the application for a placard, which would usually allow the reviewer to determine whether it was a replacement, on a case-by-case basis, but RMV could not use this process to effectively monitor its inventory of placards.
Based on its response, RMV is taking measures in policy areas to address our concerns about monitoring replacement placards. Further, RMV points out that its new ATLAS system provides improved reporting and search capabilities, which OSA believes will help RMV improve its administration of this process. However, as noted above, RMV did not properly administer the return and destruction of placards belonging to deceased individuals. Consequently, we again urge RMV to take the measures necessary to address this problem.
| Date published: | September 6, 2018 |
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