Outrage: DMV’s Internet I-PIRP Program Fails

Outrage: DMV’s Internet I-PIRP Program Fails

By William Bonds, President, Empire Safety Council

It is outrageous that the Department of Motor Vehicles is considering renewing the Internet-Point/Insurance Reduction Program (I-PIRP) based on fraudulent and flawed studies coupled with failed User/Identity Validation measures. The impact of these fraudulent research studies diminish the credibility of the Department of Motor Vehicles, as they are the ones who conducted these studies and diminish the negative impact of a program. This is bad public policy to knowingly use invalid methods that do not meet ethical standards.

The Commissioner’s Recommendation is based on the New York State Effectiveness Study of the I-PIRP Pilot, December 2013 and is severely in violation of the Department’s Rules & Regulations, Insurance Law and standard codes of scholarly conduct & ethical behavior. There also appears to be intentional distortion of the research process by fabrication, text omission and manipulation of another’s manuscript. I recently spoke with the Vice President of Research, Misconduct and Ethics from the Institute of Traffic Safety Management and Research at the University of Albany who informed me that the institute’s name, which appears on the cover page of the document alleging that the study was “conducted by” the institute, in fact did not conduct the effectiveness research of the IPIRP Pilot, December 2013.

The Vice President insisted that the University’s name should not appear on the document since they did not conduct the research and indicated that they were contracted by the department to only provide analysis and evaluation. I asked the Vice President about what appeared to be obvious omissions in the analysis and evaluation report and was told that since the institute denies that the research is their work product, the department may change the document and omit any analysis and evaluation made by the institute since it is exclusively the department’s own research however misleading the cover page may be.

The Vehicle and Traffic Law, Article 12B, Commissioner of Motor Vehicles, Part 138, states that the purposes of this article are to further highway safety by preserving the quality and efficacy of the accident prevention program and has established strict criteria for initial approval and continual course sponsorship approval. Standards for course approval require each applicant to provide proof of effectiveness that shall be verifiable research documentation showing evidence of effectiveness in terms of reduced accidents, convictions or both and shall employ accepted research principles. Furthermore, submission of any fraudulent or intentionally misleading data will disqualify an organization’s application for course approval.

In December 2007, the Department of Motor Vehicles produced the New York State PIRP Pilot Effectiveness Study (classroom) that also purports to be conducted by the Institute for Traffic Safety and Research, University at Albany, summarizes therein and states:

“In sum, the findings from this pilot study indicate that the prescribed design may not be viable for use in assessing PIRP effectiveness.”

The overall findings from the analysis conducted by the institute showed that the research was inadequate for use in measuring effectiveness of the classroom courses in terms of reduced vehicle crashes and violations. The department thereafter eliminated the requirement for I-PIRP applicants seeking course sponsorship approval to submit verifiable research documentation of proof of effectiveness. All currently approved internet course providers have not submitted any verifiable research documentation prior to their approval. Unbelievably, the department justifies doing so on the basis that the December 2007 study was not viable in assessing PIRP effectiveness.

Page 17 of the 2013 I-PIRP Research Results of Comparison, states in part:

“In sum, the comparison of the 18-month post-periods for the internet PIRP and classroom PIRP completers shows that for nine of the eleven sponsors and for the aggregate group there is effectively no difference between the two delivery methods with regard to crashes after course completion.”

This appears to be nonsense, when you consider the 2007 PIRP research analysis. How then are we able to compare the 2013 I-PIRP research with the 2007 PIRP research and conclude that both delivery methods are effective, and recommend that internet courses be made permanent law? It appears from these findings that the commissioner may not ascribe any meaningful conclusions from the 2007 study and since the 2013 study is the same prescribed design, you may not ascribe any meaningful conclusion to it and that any comparison would also be meaningless. Furthermore, on information and belief, there appears to be some analysis and conclusions that the institute has made in the2013 I-PIRP research that are omitted intentionally. Since the institute has said it is not their work product there would appear to be no plagiarism on the part of the “ghost writer” for the department’s but certainly raises a few flags about intentional misconduct in reporting. To view the departments 2007 PIRP and 2013 I-PIRP research studies go to, safetycourses. com/research.

It would appear that the Department of Motor Vehicles’ goal is to replace classroom courses with internet courses that will produce four times the amount of revenue to its coffers and will justify any means to an end. Classroom courses have shown proven effectiveness based on verifiable research documentation to the satisfaction of the Department of Motor Vehicles which has shown overall effectiveness of 18.2% reduction in vehicle crashes and 57.3% in reduction of repeat traffic offenses for participants who take and complete the classroom accident prevention course. On the other hand, internet courses have not shown any proof of effectiveness whatsoever. In fact, the U.S. Department of Transportation, National Highway Traffic Safety Administration (NTHSA), Examination of Supplementary Driver Training and Online Basic Driver Education, Final Report (October 2010) research concludes that alone online courses are not effective in reducing vehicle crashes and have the potential for low student engagement. Students will not read the material provided because the Department has eliminated the requirement that students must take and pass an exam at the end of the I-PIRP course and, therefore, will do nothing to motivate internet students to do anything else but to simply click through to the next section. NTHSA researchers have identified and gathered information on 45 online courses offered by 40 providers and found that the content was often dictated by state mandated curricula and amounted to little more than electronic textbooks.

Internet I-PIRP is bad public policy because User/Student Identity Validation technologies do not eliminate fraud since anyone can take the course for any other person. We are acutely aware that many individuals take courses for other individuals who defeat User/Identity Validation measures and sadly have been aided in doing so by some internet course sponsors themselves. All Biometric User/Identity Validation measures that would at least to some degree guarantee that the person who starts the course is the same person who finishes the course are in fact not being used by any of the I-PIRP providers. Biometric measures are replaced entirely by a telephone that the student occasionally uses to call a phone number for User/Identity Validation and then hangs up. Therefore, anyone may say they are the student and start the course and anyone else may finish the course for anyone else with a telephone. This is a system that invites fraud. The Point/Insurance Reduction Program needs to get back to proven effective classroom courses only with an instructor to eliminate fraud, encourage high standards, fair business practices and public responsibility. The whole point is safe drivers. It should also be noted, that since internet course completers are not safer drivers and will receive the insurance discount anyway, then all other insurance policy holders will pay for their discounts.

On May 18, 2014, it will be five years into the I-PIRP, which enables drivers to reduce points on their license and to receive discounts on their insurance premiums and have shown that the potential for fraud is real and are not effective in reducing vehicle crashes. The whole point of the courses, driver safety, is being compromised. Automobile insurance rate costs are not lessened since there is no improvement in safety for internet course completers. Ease of completion of internet courses does not equal a safer system nor better educated and practiced drivers. Parenthetically, the Hon. Senator Rev. Ruben Diaz, Chair, Transportation Committee along with co-sponsor Hon. Senator John L. Sampson, Senator Marcos A. Crespo, Assembly Member, have sponsored Senate Bill S3A2A-2014 and Assembly Bill A8663-2014 (identical bills) that support the discontinuance of the internet courses I-PIRP that would guarantee the proper identification of people signing up for such courses and require the physical presence of a certified instructor. In fact, our own state senate has ruled that its members and staff are forbidden to take the internet course and are required to take a classroom course instead.

These two fraudulent and flawed research studies coupled with failed User/Identity Validation measures should give Insurance Advocate® readers severe doubts about the integrity of this program and the department’s Research and Recommendations. I have asked Deputy Commissioner Terri Egan to look into this matter and requested that the Commissioner reverse her recommendations to continue I-PIRP based on this and other information.

May I suggest you do so as well.

William Bonds

President, Empire Safety Council