N.Y. Comp. Codes R. & Regs. tit. 15 § 141.14
IPIRP Specification Document
Introduction
Background
New York State (NYS) Vehicle & Traffic Law (V&T) was amended to allow the Department of Motor Vehicles (DMV) to conduct a 5-year pilot program to assess the delivery of the Motor Vehicle Accident Prevention Course, commonly referred to as Point and Insurance Reduction Program (PIRP) via Alternate Delivery Methods (ADMs). Approved NYS classroom PIRP Sponsors may participate in the IPIRP pilot by meeting state requirements, included herein, and adhering to regulations set forth in Part 141 of the Commissioner's regulations.
To distinguish the current classroom based program from the Alternate Delivery Method (ADM) Program, NYS is naming this pilot program "IPIRP", to specifically reference the internet as described in the enabling legislation. NYS is not limiting the pilot methods to the internet, in the Commissioner's discretion, so long as providers can ensure that all the pilot program requirements are met. NYS has 13 approved public sponsors delivering classroom training. Only approved providers can participate in the IPIRP; although new sponsors wishing to participate can apply to be a IPIRP provider at any time. Application processing preference may be given to existing, approved classroom sponsors.
Requirement Overview
The enabling legislation, Chapter 751 of the Laws of 2005, charged DMV with developing a pilot program that ensures:
* Student identity is validated at registration.
* Student participation is validated throughout the course.
* The 320 minute time requirement for the course is met.
* Students successfully complete the course.
The DMV has established the following general requirements:
* Only approved, existing classroom sponsors will be eligible to participate in the pilot program.
* Approved sponsors want to participate in the pilot must follow the proposed application process.
* Sponsors shall have the responsibility of identity validation, as well as validating course participation.
* Sponsors shall be required to meet information security guidelines.
* IPIRP course delivery shall have specific requirements.
* IPIRP pilot review and study evaluation shall be required.
Goals of the Pilot
The success of the pilot will be based on the following three goals of the program; Interactive Interface, Expansion of Traffic Safety Awareness and Use of Identification Technologies. Each of these goals shall have several measures to evaluate the effectiveness of alternate delivery methods, as described below. Sponsors will use a common set of questions developed by DMV to collect this information from students.
Interactive Interface shall assess whether a course delivered in a non-classroom environment can engage the course participant. This goal shall be measured as follows:
* Participant satisfaction with the course. This will be measured using a Likert based scale where success will be determined when a participant rates the course good or excellent. Overall, it is expected that this rating will occur at least 80% of the time.
* Participant believes course was interesting. Without an instructor to engage the student, the course material presentation becomes very important. This shall be measured when the participant rates the course as interesting or very interesting using a Likert based scale. Overall, it is expected that this rating will occur at least 80% of the time.
* Participant believes ADM course was easy to use and instructions understandable. Given the independent nature of the course delivery, overall participant satisfaction will be impacted by how easy and trouble free the learning experience was. This will be measured using a Likert scale and success will be measured when the participant selects easy or very easy to use. Overall, it is expected that this rating will occur at least 80% of the time.
The goal of Expansion of Traffic Safety Awareness recognizes that if a course is made available using alternate technology and it is convenient for the participant, there will be an increase in the number of completers of Accident Prevention Courses. This goal will be measured as follows:
* Number of New Completers. This will be measured based on the number of actual completers of alternate technology. This shall be measured by the number of completers for each sponsor for both ADM and classroom based offerings. A measure of success shall be that the ADMs experience double digit growth (as a % of all offerings) each year they are available.
* Impact of Course. This will be measured by the completer's opinion on whether the course is likely to influence how they will drive in the future. This will be measured using a Likert based scale where success is determined when a participant indicates the course will improve their driving some or very much. Overall, it is expected that this rating will occur at least 80% of the time. DMV shall develop a uniform survey instrument for this purpose that all sponsors shall use.
* Impact/Improvement. This shall be measured by the sponsors when they complete their PIRP effectiveness studies at the end of the 5-year pilot, or when due, depending upon the requirements spelled out in this Part, in Vehicle & Traffic Law, article 12-B and also in Commissioner Regulations, section 138. Each sponsor will be required to demonstrate the effectiveness of its ADM course, as is also required for classroom courses, by measuring a significant impact in accident and conviction reduction in the 18 months after completing the course. Depending upon the number of completers, DMV may accept a smaller population than is required in the regulations if an insufficient number of completers is available.
The goal of Evaluate Identification Technologies is to measure usage with a variety of alternate instructional delivery methods. DMV shall measure this goal as follows:
* Number of alternate techniques employed. This shall be measured based on the number of different types of technologies employed by the various sponsors. Technology usage shall cover both the delivery method (internet, CD, etc.) as well as types of validation techniques used by each sponsor. A measure of success shall be the number of multiple media and validation techniques employed by all sponsors. The more variation employed by sponsors, the more successful the pilot will be deemed in terms of this measure.
* Robustness/reliability of various methods. This shall be measured based on whether the sponsor continues to offer a particular media or technique from the beginning of the pilot, until the end of the pilot and shall be partially based on consumer use and satisfaction. If a technology is robust enough, it is likely to be continued throughout the pilot period and over time, have more and more participants being drawn to the technology. Overall, it is expected that all approved pilot programs continue for the 5 year pilot as initially approved (except for content updates), and that consumer satisfaction with alternate techniques does not decline over the 5-year period.
Both the state and the sponsors will compile these measures during and at the conclusion of the pilot as appropriate. These goals and measures shall be the basis for the DMV's report to the Legislature and Governor at the conclusion of the pilot.
Data/Security Requirements
General Requirements
The data security of the administration of the overall Motor Vehicle Accident Prevention Course program in NYS is guided by a variety of regulations at both the Federal and State level. Generally all of the regulations and standards are consistent with each other. In any instance where they may be disparate, the more stringent standard will preempt the lesser standard. Recognizing that technology and standards evolve over time, NYS shall require sponsors to adhere to promulgated rules and regulations and state standards governing the program and strive to adhere to national standards and guidance documents related to this program. The actual standards that apply shall be based on each individual sponsor's solution. In the event conflicting requirements appear or sponsors require additional guidance as to which standards apply specifically to their solution, contact Driver Program Regulation (see contact information in closing section) for clarification.
Federal Regulations
Federal regulations detailing the Driver's Privacy Protection Act are contained under 18 USC § 2721 et. seq., which are available on DMV's website at www.nysdmv.com. These rules detail permissible uses of personal information that is disclosed for use in motor vehicle accident prevention courses, as well as other uses. All sponsors and their agents participating in the program shall be required to execute a Non-Disclosure Affidavit with DMV as part of the application process.
Federal regulations related to fraud and related activity in connection with computers are contained under Title 18 of the United States Code, Part 1, Chapter 47, section 1030. These rules detail types of computer related offenses that will be punishable if found to occur during the pilot period.
National Standards
National organizations that promulgate standards related to this pilot program, and specific standards, include, but are not limited to:
National Institute of Standards and Technology (NIST) www.nist.org
| 800-76 | Biometric Data Specification for Personal Identity Certification |
Inter National Committee For Information Technology Standards (INCITS) www.incits.org
| 377 | Information Technology-Finger Pattern Based Interchange Format |
| 379 | Information Technology-Iris Image Interchange Format |
| 385 | Information Technology-Face Recognition Format for Data Interchange |
| 395 | Information Technology-Biometric Data Interchange Formats-Signature/Sign Data (Project 1603) |
| 396 | Information Technology-D Hand Geometry Format for Data Interchange (Project 1643) |
| 398 | Information Technology-Common Biometric Exchange Formats Framework (Project 1622) |
| 409.1:200x | Information Technology-Biometric Performance Testing and Reporting-Part 1: Principles and Framework (Project 1602) |
| 409.2:200x | Information Technology-Biometric Performance Testing and Reporting-Part 2: Technology Testing and Reporting (Project 1602) |
| 409.3:200x | Information Technology-Biometric Performance Testing and Reporting-Part 3: Scenario Testing and Reporting (Project 1602) |
State Laws - DMV
The general legal authority for the Department of Motor Vehicles to require and implement the IPIRP pilot exists under article 12-C (Accident Prevention Course Internet Technology Pilot Program) of the New York State Vehicle and Traffic Law (V&T). Given the use of personal identification information, sponsors shall also be subject to New York State Technology Law § 208, the Information Security Breach and Notification Act, which requires notification when a person without valid authorization has acquired personal information.
State Regulations - DMV
The NYS Department of Motor Vehicles regulations are referred to as 15 NYCRR Part 138, related to the classroom course and 15 NYCRR Part 141, the PIRP Internet/ADM pilot.
State Standards - OFT & CSCIC
The NYS Office for Technology (OFT) and NYS Office of Cyber Security and Critical Infrastructure Coordination have established Information Technology and Security policies and standards as they relate to developed systems in NYS, whether done in-house or by an outside entity.
OFT policies can be found at the following URL: www.oft.state.ny.us and include the following:
G02-001-Guidelines for Internet Privacy
P04-002-Statewide Technology Policy - Accessibility of State Agency Web-based Intranet/Internet Information and Applications
S04-001-NYS Mandatory Technology Standard - Accessibility of State Agency Web-based Intranet/Internet Information and Applications
CSCIC policies can be found at the following URL: http://www.cscic.state.ny.us/lib/policies/ and include the following:
P03-002 v.2.1 "Information Security Policy"
Sponsors participating in the pilot shall comply with the entire Information Security Policy, and the DMV policies listed below, except for those elements that clearly apply to state employees only. DMV will provide copies of the confidential DMV policies to sponsoring agencies upon receipt of a signed Non-Disclosure Affidavit, so as to ensure confidentiality of information contained in these polices.
DMV Policies
The following is a summarized list of confidential DMV policies that shall be adhered to by the sponsors. DMV may, over the course of the pilot, add other DMV or NYS security requirements as new related and applicable policies are issued. These documents are not to be shared outside of the sponsor's organization or to be used for any other purpose than IPIRP.
| Modem Policy | Connecting a dial-up modem (a device computers use to transfer data using telephone lines) to a computer system on the DMV network, even when approved, can be a potential security risk. When modem usage is approved certain guidelines must be followed when technically feasible. Exemption from these guidelines may be approved in writing when it is not technically feasible to follow. This will apply to transmission of completer data if File Transfer Protocol (FTP) is utilized during phase 2 (see later section on data transmission). |
| Equipment Disposal Policy | There is a risk of disclosure of sensitive information through careless disposal or re-use of equipment. Storage devices such as tape, diskettes or CDs, containing sensitive information must be physically destroyed or securely overwritten to prevent the unauthorized disclosure of sensitive DMV information, depending on the sensitivity level of the data stored thereon. Storage Devices at the very minimum must be re-formatted before disposal or reuse by another user. |
| User Password Security Policy | Password protection ensures the integrity of the files and applications by protecting against unauthorized access to programs and data. |
| Example:If a PC is left unprotected, unauthorized persons gaining access could read, add, delete, or change data records or make changes to the data files or applications. | |
| It is the responsibility of each sponsor to reasonably protect against unauthorized activities performed by their employees' user IDs. Each user is responsible for the data that resides on his/her computer and for any activities performed through use of that computer or other password protected device. |
Guidance Documents
The following organizations have proposed related standards that are included here as recommended best practices.
| Top 10 | Open Web Application Security Project available at: http://www.owasp.org/index.php/OWASP_Top_Ten |
| 17799-2005 | Information Technology-Code of Practice for Information Security Management (INCITS/ISO/IEC) available at: www.incits.org |
| 800-26 | NIST: Guide for Information Security Program Assessments and System Reporting Form available at www.nist.org |
Data Collection Requirements
ADM Participation Data
NYS is requiring all sponsors to collect and report certain standardized data on each course participant for the duration of the pilot. The data captured must be reported to DMV in an un-altered manner, based on how it was captured from the students. Data found to be altered shall result in sponsors being suspended or revoked. Data will be collected on the following:
* Sponsor & Delivery Agency Code
* Motorist Identification
* Course Start & End Date and Time
* Length of PIRP course
* Number of Sessions
* Validation Method Used
* Participant Questions and Answers
* Type of Alternate Training
* Participant Satisfaction with Training
All data listed under "IPIRP Student Participant Information" shall be required to be retained by the sponsor from the beginning of the pilot program to the end of the 5 year study, except where otherwise specified. DMV may add additional values or elements once sponsors submit applications for their unique course. The initial data dictionary of the required retained elements is below:
"IPIRP Student Participant Information"-Data Dictionary
Data/Column Name | Data Type - Length - Value | Description |
| Sponsor Code | Char (2) | Sponsor Code on License File |
| Delivery Agency Code | Char (3) | Agency Code on License File |
| Motorist Last Name | Char (25) | Last Name of motorist as appears on the photo driver license |
| Motorist First Name | Char (25) | First Name of motorist as appears on the photo driver license |
| Motorist Middle Initial | Char (1) | Middle Initial as appears on photo driver license |
| Motorist Client ID | Char (9) | ID From NYS driver's license |
| Motorist Date of Birth | Char (10) (mm/dd/yyyy) | Check DOB w/CID to ensure accurate posting of completion information to license file trailer. |
| Start Date | Char (10) (mm/dd/yyyy) | Date Motorist Started Course |
| Start Time | Char (6) (hhmm AM/PM) | Start Time of IPIRP Course |
| End Date | Char (10) (mm/dd/yyyy) | Date Motorist Ended Course |
| End Time | Char (6) (hhmm AM/PM) | End Time of IPIRP Course |
| Total Time | Num (4) | Total Time in Minutes Start to End |
| Number of Sessions | Num (2) | Total number of user sessions from start time to end time |
| Date Reported to DMV | Char (10) (mm/dd/yyyy) | Date the completer data was reported to DMV by the sponsor |
| Completed Course | Logical (1) | Y=Yes, N=No |
| Method of Validation 1 | Char (2) | Initial Acceptable Values: |
| 01=Biometric-face recognition | ||
| 02=Biometric-key stroke | ||
| 03=Biometric-fingerprint | ||
| 04=Biometric-voice print | ||
| 10=Proctored Test | ||
| 11=In person | ||
| 12=Third Party Database questions | ||
| 13=Phone contact | ||
| 14=Online/Instant messenger tools | ||
| 15=Personal questions | ||
| 16=Content questions | ||
| 17=Pay per view "remote buttons" | ||
| 18=Email | ||
| Method of Validation 2 | Char (2) | Initial Acceptable Values: |
| 01=Biometric-face recognition | ||
| 02=Biometric-key stroke | ||
| 03=Biometric-fingerprint | ||
| 04=Biometric-voice print | ||
| 10=Proctored Test | ||
| 11=In person | ||
| 12=Third Party Database questions | ||
| 13=Phone contact | ||
| 14=Online/Instant messenger tools | ||
| 15=Personal questions | ||
| 16=Content questions | ||
| 17=Pay per view "remote buttons" | ||
| 18=Email | ||
| Method of Validation 3 | Char (2) | Initial Acceptable Values: |
| 01=Biometric-face recognition | ||
| 02=Biometric-key stroke | ||
| 03=Biometric-fingerprint | ||
| 04=Biometric-voice print | ||
| 10=Proctored Test | ||
| 11=In person | ||
| 12=Third Party Database questions | ||
| 13=Phone contact | ||
| 14=Online/Instant messenger tools | ||
| 15=Personal questions | ||
| 16=Content questions | ||
| 17=Pay per view "remote buttons" | ||
| 18=Email | ||
| Valid Question 1* | Char (3) | Unique sponsor question code |
| Student Answer 1 | Char (1) | Student Answer to unique question |
| Valid Question 2 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 2 | Char (1) | Student Answer to unique question |
| Valid Question 3 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 3 | Char (1) | Student Answer to unique question |
| Valid Question 4 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 4 | Char (1) | Student Answer to unique question |
| Valid Question 5 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 5 | Char (1) | Student Answer to unique question |
| Valid Question 6 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 6 | Char (1) | Student Answer to unique question |
| Valid Question 7 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 7 | Char (1) | Student Answer to unique question |
| Valid Question 8 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 8 | Char (1) | Student Answer to unique question |
| Valid Question 9 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 9 | Char (1) | Student Answer to unique question |
| Valid Question 10 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 10 | Char (1) | Student Answer to unique question |
| Valid Question 11 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 11 | Char (1) | Student Answer to unique question |
| Valid Question 12 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 12 | Char (1) | Student Answer to unique question |
| Valid Question 13 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 13 | Char (1) | Student Answer to unique question |
| Valid Question 14 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 14 | Char (1) | Student Answer to unique question |
| Valid Question 15 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 15 | Char (1) | Student Answer to unique question |
| Valid Question 16 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 16 | Char (1) | Student Answer to unique question |
| Valid Question 17 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 17 | Char (1) | Student Answer to unique question |
| Valid Question 18 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 18 | Char (1) | Student Answer to unique question |
| Valid Question 19 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 19 | Char (1) | Student Answer to unique question |
| Valid Question 20 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 20 | Char (1) | Student Answer to unique question |
| Valid Question 21 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 21 | Char (1) | Student Answer to unique question |
| Valid Question 22 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 22 | Char (1) | Student Answer to unique question |
| Valid Question 23 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 23 | Char (1) | Student Answer to unique question |
| Valid Question 24 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 24 | Char (1) | Student Answer to unique question |
| Valid Question 25 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 25 | Char (1) | Student Answer to unique question |
| Valid Question 26 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 26 | Char (1) | Student Answer to unique question |
| Valid Question 27 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 27 | Char (1) | Student Answer to unique question |
| Valid Question 28 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 28 | Char (1) | Student Answer to unique question |
| Valid Question 29 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 29 | Char (1) | Student Answer to unique question |
| Valid Question 30 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 30 | Char (1) | Student Answer to unique question |
| Valid Question 31 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 31 | Char (1) | Student Answer to unique question |
| Valid Question 32 | Char (3) | Unique sponsor question code approved by DMV |
| Student Answer 32 | Char (1) | Student Answer to unique question |
| Course Reason Code | Char (1) | Acceptable Values |
| I=Insurance Reduction | ||
| P=Point Reduction | ||
| B=Both Points/Insurance Reduction | ||
| T=Traffic Safety Awareness | ||
| C=Court Mandated | ||
| D=Court Mandated/Point Reduction | ||
| R=Court Reduced Infraction | ||
| O=Other | ||
| ADM Delivery Method | Char (1) | Acceptable Values |
| I=Internet | ||
| 2=DVD/CD/VHS Sale | ||
| 3=DVD/CD/VHS Rental | ||
| 4=Pay Per View | ||
| 5=PC at Delivery Agent/Equivalent | ||
| Previous PIRP Experience | Char (2) Acceptable Values 0-99 | Number of Times Student has taken Accident Prevention Course Before |
| Satisfaction Code - | Char (1) | Acceptable Values |
| Method | 1=Really Like ADM Over Classroom | |
| 2=Like ADM Over Classroom | ||
| 3=No Preference | ||
| 4=Like Classroom over ADM | ||
| 5=Really Like Classroom over ADM | ||
| 6=First time attendee/not applicable | ||
| Satisfaction Code - | Char (1) | Acceptable Values |
| Course | 1=Excellent Course | |
| 2=Good Course | ||
| 3=Average Course | ||
| 4=Poor Course | ||
| 5=Worst Course Ever | ||
| Impact Code - | Char (1) | Acceptable Values |
| Course Effectiveness | 1=Will Improve Driving Very Much | |
| 2=Will Improve Driving Some | ||
| 3=Little Impact on Driving | ||
| 4=No Impact on Driving | ||
| Participant Interest | Char (1) | Acceptable Values |
| Code - Course | 1=Very Interesting Course | |
| 2=Interesting Course | ||
| 3=Average Course | ||
| 4=Boring Course | ||
| 5=Very Boring Course | ||
| Ease of Use Code - Course | Char (1) | Acceptable Values |
| 1=Very Easy to Use | ||
| 2=Easy to Use | ||
| 3=Neither easy or difficult | ||
| 4=Hard to Use | ||
| 5=Very Hard to Use |
*Valid Question X number will be obtained from sponsor provided list of unique questions asked during the course, where required.
As per section 141.5 and 141.8 of this Part, each sponsoring agency application must include a specific plan for how instruction time will be calculated. A record of such calculations, including all instruction time, will be recorded and stored by the sponsor and made available to the third party monitor and the Department for monitoring and quality control purposes. This information, as part of each student's completion record, must clearly differentiate actual interactive instruction time from non-instruction time such as log-in procedures, administrative tasks, help functions, validation processes, and audio/visual media download times. Such record shall be maintained for five years.
Data Submission
In the event a student begins, but does not complete the course, sponsors will complete as much information as possible (for example, start date and start time). DMV strongly recommends that sponsors DO NOT collect social security numbers, as they are not needed to match to the license record. As part of pilot participation, sponsors will be expected to transmit the required data either to DMV and/or a third party under contract to DMV. Data transmission is to be achieved in a manner and frequency to be determined by DMV. A sponsor's ability to properly collect, store and report this data shall be validated during the sponsor IPIRP curriculum review and approval process. Depending upon the format selected by the sponsor (internet, DVD or other), sponsors shall be required to capture, store and report additional information such as student footprint data or monitored exam data. DMV anticipates the process for completer data transmission to be implemented in a phased approach as follows:
Phase 1 - The completer data will be sent in the existing (pre-IPIRP) format either via existing methods or via Secure FTP. The elements submitted to the DMV will be the same elements that are currently submitted to the DMV. However, the entirety of the elements listed above under "IPIRP Student Completer Information" must be retained. Sponsors shall use a unique delivery agent code to delineate the IPIRP completer from the traditional classroom completer. Failure to correctly delineate the IPIRP completer from the traditional classroom completer may result in sponsor suspension.
Phase 2 - The completer data will be submitted to the DMV or a third party approved by DMV. The elements of the data that need to be submitted shall conform to ALL of the elements listed under "IPIRP Student Completer Information". The format and data transmission specifics will be published by DMV under a separate "Technical Interface" document prior to Phase Two to all participating IPIRP sponsors.
Student Footprint Logs (Internet/Phone Based Only)
To facilitate DMV's ability to audit the 320 minute time requirement, sponsors that offer computer based training shall be required to collect and store logs of student activity as they progress through the training. Data stored for each student, during each session must include:
Data/Column Name | Data Type - Length - Value | Description |
| Motorist Client ID | Char (9) | ID from NYS driver's license |
| Start Date | Char (10) (mm/dd/yyyy) | Date Motorist Started Course |
| Start Time | Char (6) (hhmm AM/PM) | Start Time of IPIRP Course |
| End Date | Char (10) (mm/dd/yyyy) | Date Motorist Ended Course |
| End Time | Char (6) (hhmm AM/PM) | End Time of IPIRP Course |
| Total Time | Char (5) | Calculated based on End Date/Time |
| - Start Date/Time. Captures overall | ||
| time from registration through completion, including proctored testing if required. | ||
| Last Module Completed | Char (2)? | Sponsor designated code for where in application student ended session |
| Total Instruction Time in Minutes | Char (3) | Calculated based on sponsor's approved calculation method. Excludes non-instruction time such as log-in procedures, administrative tasks, help functions, validation processes and audio/visual media download times. |
Sponsors will not be required to transmit this data, but are expected to store it and make it available to DMV, upon request, as needed. The logs must be stored in the format above and must be human readable.
Proctored Exam Logs
(DVD/VHS/CD Formats
Data/Column Name | Data Type - Length - Value | Description |
| Motorist Client ID | Char (9) | ID from NYS driver's license |
| License Document Number | Char (8) | Document number on lower right hand corner of front of license |
| Date of Exam | (10) (mm/dd/yyyy) | Date Motorist Started Exam |
| Start Time | Char (6) (hhmm AM/PM) | Start Time of Exam |
| End Time | Char (6) (hhmm AM/PM) | End Time of Exam |
| Total Time | Char (5) | Calculated based on End Date/Time - Start Date/Time |
| Person Validating Identity | Char (4) | Unique code identifying person who validated student identity at time of exam |
| Testing Facility Used | Char (4) | Unique code identifying the testing facility where exam administered |
| Monitoring Method 1 | Char (1) | Type of monitoring used during proctored exam (1st method) using the following codes: |
| 1=Biometric Sample Collected | ||
| 2=Student monitored by video | ||
| 3=Student monitored by person | ||
| Monitoring Method 2 | Char (1) | Type of monitoring used during proctored exam (2nd method) |
| 1=Biometric Sample Collected | ||
| 2=Student monitored by video | ||
| 3=Student monitored by person |
Storage of any biometric samples collected, or video of the exam completion, shall be maintained by the sponsor for a minimum of 5 business days from course completion but no longer than 30 calendar days from course completion. These materials shall be made available to DMV and their representatives upon request.
Data Security Requirements
Personal Identification Information
Information that is considered personal information includes, but is not limited to, participant name, address, date of birth, motorist identification number, client identification number, social security number (if collected), credit card information, answers to personal and content questions and biometric samples. Computer systems storing this information shall be protected against data theft and loss. Financial transactions shall be conducted securely, so that theft of personal identification information is unlikely. In the event this information becomes compromised, sponsors are required to investigate the incident and determine what data has been compromised. Suspected or confirmed inappropriate access to or disclosure of personal identification data collected for IPIRP shall be reported to DMV's Director of Audit Services or designees by phone within 1 hour of detection. This notification shall be followed up in writing by fax or e-mail within 24 hours of detection. The sponsor shall fully investigate the compromise and report the circumstances as well as the steps taken or proposed to be taken to prevent similar instances in the future. Failure by the sponsor to notify DMV of disclosure of participant personal information, as specified, will result in Sponsor suspension or revocation. Notification must be made to the following individuals:
DPR - Director, Driver Program Regulation (518) 486-5572
Field Audit - Director or designee (518) 474-0881
If personal identification information has been compromised, the sponsor must provide assistance and information regarding identity theft, how the student can monitor their credit report and what resources exist for preventing and/or identifying and reporting any potential identity theft. In the event of a security breach, DMV will allow sponsors access to their bond for the purposes of breach notification and necessary follow through.
Security Reviews
Sponsors shall be required to undergo a security review as part of the sponsor approval process. DMV personnel will complete this security review, and it will involve a site visit and a series of interviews via telephone and/or e-mail.
The Division of Field Investigation site visit will focus on a review of physical security and computer system access. The sponsor shall pay all costs for travel and lodging incurred by the Department of Motor Vehicles in connection with all security reviews.
The Information Security Office interviews will, at a minimum, review:
* System Description
Diagrams of the system, including data connections.
Where and how any custom source code is stored and secured.
An inventory of data stores, such as files and databases.
An inventory of sensitive or confidential data that is stored, processed or transmitted by the system.
* Security and Risk
A list of the DMV and vendor contacts in case of a security incident.
An inventory of the system vulnerabilities and what protection will be in place for each of the vulnerabilities.
Review of how DMV private or sensitive data is secured.
Procedures if secured DMV data is compromised or lost.
* Backup and Recovery
Review of the vendor's backup plan.
Procedure for reconstructing data from other sources, if available.
Estimate of the recovery time from a disaster ("how soon do they need to come back up?") and the recovery steps.
The business continuity plan.
The disaster recovery plan for this application.
* Disposal
Procedures for disposing of confidential information, both paper and electronic.
The security review may include the release of sensitive information (e.g., a description and diagram of your system) as applicable.
Sponsors shall be provided with an opportunity to correct significant security vulnerabilities noted during the security review and a follow-up visit and/or type of confirmation will occur to confirm that deficiencies have been remediated.
Sponsors that do not pass a security review shall not be allowed to offer courses via IPIRP/ADM until they do pass a security review. DMV reserves the right, over the course of the pilot, to conduct follow-up reviews to ensure that security standards identified during the original review continue to be maintained.
User Interface Requirements
NYS desires IPIRP courses that engage the user in the learning experience. Courses that are reviewed which do not require the student to "participate" in some fashion will not be approved. The user's graphical interface must be user friendly, which is demonstrated through:
* Ease of use.
* Length of time it takes for pages to load.
* Ability to play multimedia during the course (assuming student has appropriate hardware and software installed).
* Ability to log on and off the course site (or stop and start computer or video based courses), and navigate easily and freely to material previously covered.
* Easily understood policies & procedures regarding course and usage during the signup process.
* Scrolling should be limited to up and down where appropriate, versus also requiring the user to scroll left to right.
* No advertisements (including pop-ups) will be allowed during the entire course (including sign up, login and course completion).
In an effort to encourage innovation and alternative methods, NYS will allow sponsors to choose which mandatory elements they will incorporate in their course delivery, within certain parameters, as defined below:
Audio/Visual Requirements
Participants will have varying internet connection bandwidth rates, which must be taken into account in the overall ratio of multimedia to alternate content delivery (e.g., chart with text), where possible.
Timing requirements, as outlined in the table below, are based on successful completion of the minimum course duration of 320 minutes. DMV anticipates the course to be broken into 6-10 sections that can be completed at a reasonable pace. These sections would be logical groupings of material from the approved classroom curriculum. Minimum content will be determined based on the following methods as described below:
Timing of Content to Determine Minimum Time Requirements Met
Type of Content | Types of Material/ Specifications | Amount of Time Allowed |
| Multimedia | Audio and/or visual clips, where possible. Audio/visual should be in sync. Each clip shall be no more than 6 minutes in duration, except where approved by the department. Material in written text can also be available as audio (verbatim or ad lib), to be played at the students option, which will determine course timing. The total video should not exceed 25% of allowed time for online courses. Audio/visual clip download time shall not be unnecessarily long so as to disrupt the flow of the course or diminish the student's course experience. | Actual play time of all audio/visual material. |
| Simulations & Exercises | This can be "follow along" video or interactive audio/video that engages the user to evaluate a key learning point from the training (e.g., response time, range of motion, visual acuity, etc.) | Actual time of simulation or exercise, allowing sufficient time for user to follow along at required pace. |
| Charts & Graphs | Statistics included must be the most current available, and are expected to be updated annually at a minimum. | Allow 1 minute for each chart or graph. |
| Personal Questions | Collected from 3rd party database, DMV license file (if approved), or as collected by the sponsor at time of application. | Allow 45 seconds to answer each personal question. |
| Content Questions | Test bank questions are developed by the sponsor and approved by DMV. | Allow 60 seconds to answer each content question. |
| Written Text | Including bulleted lists, captions, paragraphs and other written material. Time allowed will be a word count, when audio augmentation is not available, will be based on a physical word count. The word count shall be divided by 100 words per minute. | The result of total words divided by 100. This will be the time allowed. |
Recognizing that material on the internet can vary widely, and that the emphasis is on student learning, DMV will consider alternate time calculation methods, at their discretion, so long as sponsors can demonstrate that the course meets the 320-minute requirement.
The responsibility for validating student identity, as well as student participation, shall be with the sponsors, and their delivery agents, if applicable. While DMV intends to monitor sponsor compliance through existing resources, and/or through a third party contractor, the sponsor shall be accountable for their compliance. Given that a variety of content delivery/validation methods exist today, and more are expected over the course of the pilot, DMV will set an initial, minimum threshold, which is as secure as the existing classroom course.
Customer Service Requirements
DMV shall require that:
* The cost of all services is spelled out to the motorist at the point of sale (course cost, customer service fees, certificate costs, technology costs, proctored exams, etc. where applicable). There shall be no hidden fees and fees shall not change after the student registers for the course and accepts the terms and conditions required by the regulation.
* The course delivery and participation validation method, and terms and conditions of course and course payment/refund policies shall be described to the participant prior to the sale.
* Customers shall agree to the terms and conditions, including language to be provided by DMV, by typing "I agree" prior to the course commencing (or by signing an agreement in person either at point of sale or during proctored exam after identity validated).
* Sponsors shall provide customer service telephone support, that is at a minimum, Monday through Saturday from 8 am to 4 pm EST. DMV will consider sponsor proposals to utilize an interactive voice message system in place of live contact or in conjunction with live contact. DMV will revisit this requirement after the pilot program has been operational for 6 months.
* Sponsors shall incorporate the contents of the DMV C-32A brochure, described in Part 138.11 of the Commissioner's regulations, into the course material. This can be covered during registration if desired.
* Sponsors shall make available a printable version of key learning points covered during the training to participants so that they may have a ready reference if desired.
Participant Validation
In order to meet the legislative intent, and to assure that rigorous course requirements are met (including identity validation and student participation), while allowing multiple delivery methods to be employed, DMV has assigned "point" values to the following validation techniques:
Participant Validation Technique Options Available to Sponsors in Designing Program
Method of Validation | Examples/Parameters of Validation Method | Points Assigned |
| Facial Recognition | Biometric-Hardware provided by sponsor and included in cost of course | 6 |
| Fingerprint | Biometric-Hardware provided by sponsor and included in cost of course | 6 |
| Handprint | Biometric-Hardware provided by sponsor and included in cost of course | 6 |
| Retina or Iris Scan | Biometric-Hardware provided by sponsor and included in cost of course | 6 |
| Ear Scan | Biometric-Hardware provided by sponsor and included in cost of course | 6 |
| Keystroke Analysis | Biometric-Software provided by sponsor and included in cost of course | 5 |
| Voice Print | Biometric-Software provided by sponsor and included in cost of course | 6 |
| Other Biometric | Prior DMV approval required | To be determined |
| Proctored Exam | Students must pass a multiple choice test with a correct score of 75% or better in order to obtain a certificate. Students will be permitted to bring in sponsor provided material into the exam. | 5 |
| In Person Contact | Identity validated at time of registration, or if set up as a computer based training at delivery agent site, delivery of training | 3 |
| Phone Contact | Prompting student to dial an 800 number to answer content or identity questions. | 2 |
| Third Party Database | Using individualized questions based on data stored in a credit bureau or government database (this is unrelated to and separate from a 3rd party monitoring organization) | 2 |
| Online/Instant Message | Prompting student to answer questions through an online chat discussion group or when online technical assistance requested. | 1 |
| Personal Questions | Questions aimed at authenticating identity. | 1 |
| Content Questions | Questions aimed at determining student participation. | 1 |
| Pay Per View Buttons | Using features of cable TV to have user interface for answering personal or content questions. | 1 |
| Sending technical assistance response or user names and password for site access. If both user name and password are transmitted in the same email, password must be changed when the participant first logs on. | 1 | |
| Other Techniques | Prior DMV approval required | To be determined |
Sponsors seeking approval for their IPIRP courses must have a minimum of seven or more points, using two or more of these techniques, provided, however, that one point must be for content questions. The content questions may be asked at random points throughout the course or at the end of each chapter or unit. Such questions do not need to be in the form of a final exam. Sponsors are free to suggest alternate techniques, although the actual points assigned will be based on a determination by DMV. Depending upon the robustness of the solution offered by the sponsor, DMV reserves the right to increase or decrease the point values above to reflect the quality of a particular sponsor's solution in meeting or exceeding the validation requirements. Participant private information, as defined in the personal identification section shall be encrypted. All authentication information shall be protected; for example, it should not be stored or transmitted in clear text.
Validation Requirements
This section details requirements not otherwise detailed in the previous sections, and focuses primarily on requirements for participant validation, and also data storage. Participant validation will focus on Biometrics, Proctored Exam, In Person Contact, Telephone Contact, Online Chat/Discussion Group, Personal and Content Questions, Pay Per View and Email Requirements.
Biometrics
DMV shall allow a variety of Biometric Data Formats, so long as initial sample collection and periodic validation of ongoing participation against the original sample occur throughout the course at random intervals. DMV recognizes that many biometric standards are relatively new and that some available technologies in the marketplace may not strictly adhere to the standards. DMV expects the ADM pilot will allow sponsors the opportunity to explore alternate validation techniques, in lieu of requiring a proctored exam.
If a sponsor selects Biometrics as a validation technique, they will be required to capture at least 7 biometric samples over the 320 minutes of instruction. These 7 samples shall be stored for a minimum of 5 business days from course completion, and no longer than 30 calendar days from course completion, and shall be subject to DMV review. In the event DMV elects to review samples, the sponsor must provide the appropriate hardware and software in which to allow DMV to verify that validation was correct. This information shall be considered "personal information" and must be kept securely. For each sample, the sponsor must also associate the client identification number on the motorist's driver's license, date and time the sample was collected and by whom the sample was collected and/or verified by (as appropriate). Sponsors shall ensure that their biometric validation technique(s) is calibrated to be at least 90% accurate. Students who fail to have their identity verified by the biometric technique after five attempts shall be excluded from the course.
Proctored Exam
Unless biometrics are used in the ADM course, or sponsors can prove to DMV's satisfaction that rigorous identity validation and participation techniques are employed, a proctored exam shall be required. Requirements for the proctored exam are as follows:
* Exam locations shall be approved by DMV, and can be provided as part of the sponsor application process. It is preferred that tests be administered at colleges, universities and other testing facilities that routinely offer proctored exams, however delivery agencies may also administer the proctored exam.
* To the degree possible, proctors shall be independent of the sponsor, as well as with those taking the test. Typically, exam proctors are educators, law enforcement personnel, supervisory administrative staff, lawyers, engineers, etc. that have no stake in the outcome of the exam. Delivery agencies may also administer the proctored exam.
* Students taking the proctored exam must present two forms of identity, with one being their NYS driver's license photo identification. These must be validated against the schedule (name, motorist ID) and also visually against the photograph. Students must sign in, indicating agreement with the test requirements. Signatures must be validated against signatures on the student IDs. Students without proper identification, or who appear to be presenting false identification must be refused entrance into the test.
* During the exam, proctors must monitor student exam completion by either being in the room, in a different room separated by a glass window or via video monitoring.
* The exam location must be closed to the public and be free from distractions.
* Students will be given a sponsor developed multiple-choice exam. These exams will be uniquely generated from a random pool of 100 test questions, which are developed by the sponsor and approved by DMV. When submitting test questions for approval, sponsors shall identify where in their course curriculum the answer is contained. Sponsors are required to refresh questions every 6-12 months. Students must receive a passing score of 75% correct to pass the course. Students that fail the exam, will be allowed one additional opportunity to pass the exam, which will be considered a "retest". Students will be allowed up to 60 minutes to take the exam and will be allowed to bring in materials printed from the sponsor's course.
* Students shall complete the proctored exam within 30 calendar days from completing the course, although within 1-14 days is preferable. Retests can be completed within 30 calendar days from the date of initial completion.
In Person Contact
This identity validation method refers to face-to-face contact between the student and either the sponsor staff or the delivery agency staff, identified in the sponsor's application. This can be at the point of sale or course delivery (computer based training). During this contact, sponsor staff is required to:
* Ask students to present two forms of identity, with one being photo identification in the form of a government issued driver's license or non-driver ID.
* The motorist must be validated visually against the photograph.
* Students must sign an agreement, indicating willingness to comply with course guidelines.
* Signatures must be validated against signatures on the student's government issued drivers license or non-driver ID.
* Students without proper identification, or who appear to be presenting false identification must be refused entrance into the course.
Phone Contact
Phone contact, for the purpose of this identity validation method, does NOT include customer service phone support described earlier in this document. This phone contact is selected by the sponsor as an additional validation/participation method. This method can either be the sponsor contacting the student while the course is being delivered, or by prompting the student to contact the sponsor at a toll free number.
Once the student contacts the sponsor, the student's identity is validated using personal questions and/or the student's participation is validated using content questions. These questions would be in addition to the proctored exam. In addition, the questions used for phone validation cannot be the same as those included in a proctored exam. It is preferred that when phone contact is initiated by the student, when prompted, that a live operator be available to answer the phone within a minute. Recognizing that 24/7 service may not be practical, sponsors can elect to utilize an automated service outside of the core customer service hours. See personal and content questions for more guidance on these requirements.
Sponsors shall be expected to capture specific data on each of these contacts, including participant identity information, date/time of contact, operator guiding the call and answers to personal/content questions as part of ADM participant information. This information should be stored electronically and be available for the entire 5 year pilot period. Sponsors shall implement security measures to ensure that personal validation information cannot be retained by operators or by contracted services, such as outsourcers in other countries.
Third Party Database Questions
This method refers to the sponsor's use of data elements from a third party database, primarily that of a credit bureau or a government agency, to develop individualized questions to be used in validating the identity of a student. Data sets may be made available to the sponsor for direct verification but the sponsor assumes the risks and responsibilities associated with securing this data, so it is preferable that the sponsor utilize the services of the data provider where verification can be made without the sponsor accessing the personal data from the third party database. At least one of the national credit bureaus is known to provide an identity verification service where verification is made without personal information being released by the credit bureau. Sponsors are expected to capture each third party validation question and whether the question was answered correctly, including a date and time stamp. Verification transaction information must be stored electronically and available to the department for the five years of the pilot study. Sponsors must implement security measures to ensure that personal validation information is secured.
DMV reserves the right to review and approve the use of a third party database information for the purpose of validating student identity, including any contracts, agreements, security protocols and policies, and may consult the third party credit bureau or government data provider without permission from or knowledge of the sponsor.
Personal/Content Questions
Should sponsors opt to utilize phone contact, online personal or content questions or utilize "pay per view" cable buttons, students will be required to answer authentication questions correctly and within the prescribed timeframes as follows:
Proposed Validation of Student Identity & Participation
Type of Question | Number In Test Bank | Minimum # in Course | Correct Responses Required | Amount of Time to Read & Answer - PC Format | Amount of Time to Ask & Answer - Phone Contact |
| Personal identity | 30 | 10 | 7 | 45 seconds | 30 seconds |
| Content/environment | 100 | 20 | 14 | 60 seconds | 45 seconds |
Personal questions may be asked throughout the course, and at a minimum, at the beginning of each session logon. Students are limited by the number of times they can incorrectly answer personal identity and content/environment questions. Questions will be asked as they relate to material presented in each section, and can either be after video clips or at the end of each sub-section or section. Students that fail to answer the minimum number of content/environment questions correctly can have additional questions asked (adding to the minimum time requirement) so as to proportionally be able to answer a correct number of questions in a subsequent attempt as appropriate. Students will have up to 3 complete opportunities (for a total of 10 personal or 20 content questions each) in order to "prove" participation.
E-mail Contact
Should sponsors opt to use email as a validation method, they will need to confirm that the email was "received", by providing to the student both the hyperlink to "confirm" registration or to link to the course upon acceptance of payment. Email contact can also be used to transmit user sign-ons and passwords in order to access the course. The purpose of email contact is to send information necessary to access the course to a participant provided address. The preferred method is for the user name and password to be transmitted in separate emails, but mailing both in a single email is acceptable if a password change is required upon initial log on to the sponsor site.
Online Contact
In the event sponsors wish to use some form of online contact with participants, the requirements of this option are:
* Participants must identify themselves in a manner that will allow them to be linked to the student participation database.
* Online contact can utilize participatory tools available on the internet including but not limited to instant messaging, online whiteboards and collaboration software.
* During online contact, sponsors can ask personal/content questions or use this to provide online help.
* Sponsors must clearly demonstrate how they plan to implement and use this option, as well as how they plan to protect the information that is transmitted. Sponsors must not transmit private data using clear text; all private data must be encrypted and secured.
Web TV/Pay Per View
Given the advent of interactive TV and the ability to "vote" using digital cable, sponsors who opt to deliver their course as a pay per view option, can use this technology to validate participation. This can be done through the remote control by having students answer multiple choice personal questions or content questions. Participants must be identified in a manner that will allow them to be linked to the student ADM participant database. Sponsors can also consider participants being prompted to call a toll free number to answer personal and content questions at selected intervals during the course.
Other Portable Devices (Cell Phones/PDA)
Although we do not know of an accident prevention course being delivered through a PDA or cell phone, the features and functions of today's devices seem to support the delivery of a course, albeit the screen display is limited. Sponsors that opt to deliver their courses using this methodology can couple the device with interactive use of phone buttons to have students answer both personal and content questions during the course.
Future Technologies
Recognizing the explosion of portable personal devices, DMV remains open to alternate delivery methods over the duration of the pilot. DMV will continue to accept sponsors' applications, including technologies not specified herein, for alternate delivery methods throughout the duration of the 5-year pilot.
Sponsor Application Process
Participation in the IPIRP is voluntary; existing sponsors are not required to participate in the pilot. The two-step application process is designed to minimize development costs and potential delays during the review and approval process, while ensuring that the finished product adheres to the mandated requirements.
Step 1
Approved sponsors that desire to participate in the pilot must:
* Complete an IPIRP application form (to be provided by DMV to all approved classroom sponsors when Part 141 Commissioner's regulations are approved).
* Include a one time, $7,500 non-refundable application fee in the form of a certified check or money order, payable to the Commissioner of Motor Vehicles - IPIRP Fund.
* Mail the application and fee to:
NYS Department of Motor Vehicles Bureau of Driver Program Regulation, Rm. 412 6 Empire State Plaza Albany, NY 12228
The application will be carefully reviewed by DMV associates to ensure completeness and adherence to the IPIRP requirements. It is anticipated that several follow-up discussions with appropriate sponsor staff will occur as a result of the application submitted and that these subsequent discussions will take at least one month. NYS reserves the right to return incomplete applications to sponsors for more information. Sponsors that have their application returned can resubmit their updated application at any time. The $7,500 non-refundable application fee only needs to be paid once during the pilot program.
Step 2
Once DMV associates have reviewed the application, and all necessary questions have been addressed, the DMV will notify sponsors in writing that they have been approved to proceed with development. Once the sponsor has completed their IPIRP development, they must submit the finished product to DMV as follows:
* If internet based, sponsors should submit the URL (web address) of the training, and 10 unique user names and passwords that can be used by DMV staff to review the curriculum.
* If an alternate delivery methodology is used, sponsors should submit 10 copies of the alternate medium that can be used by DMV staff to review the curriculum.
* Regardless of method, DMV will be testing the sponsors proposed validation and participation methodologies, so sponsors must submit appropriate materials (hardware, software, phone numbers, questions and answers, etc.) necessary for validation by up to 10 different associates.
* A bond, or letter of credit, in the amount of $100,000, naming DMV as a beneficiary. Applicants need not provide the bond or letter of credit with their initial application materials, though this requirement must be satisfied before DMV will grant final approval to conduct an ADM course. Sponsors that do not provide the bond or letter of credit with application materials will be advised in writing by DMV when all other application requirements have been satisfied and approval is imminent. The sponsor must then submit the bond or letter of credit in order to be finally approved. DMV will notify the sponsor when course delivery may commence. The sponsors must submit proof of bond renewal on an annual basis.
* The physical location(s) of the data server used to either deliver the course and/or store student participation data (detailed in data collection requirements section) and the responsible person (and their contact information) at this location. If the data server is out of state, NYS reserves the right to require sponsors to reimburse the state for the cost of travel to this site, and to any other site where related data may be stored, to verify security requirements are being met.
DMV anticipates that this review and approval process could take upwards of 60 days to complete. The length of time will be dependent upon the number of curriculums being reviewed at one time; DMV plans to assign the review to multiple individuals, and will assign based on a first in, first reviewed order.
DMV Review & Approval Process
All applications will be logged-in based on when received and tracked during the various reviews completed (curriculum, security, background, etc.). As stated previously, these will be reviewed in a first in, first out order. Cooperation by the sponsor in answering questions, scheduling and hosting the security review, and providing follow up or supplemental materials requested (if necessary) will assist in getting the application processed as quickly as possible. Continuous delays, errors and omissions in the application package will result in the application process slowing down.
Communication about application and programmatic deficiencies will be reported to the application contact person. If the sponsor would like this communication to go to multiple people, this must be noted on the application form. DMV plans to review both steps of the submission completely, and will note all items found non-compliant upon completion of the review, in writing to the contact person. Once a sponsor has successfully met all pilot requirements described herein, DMV will provide written approval allowing the sponsor to start the IPIRP/ADM course.
DMV reserves the right to deny participation in the ADM pilot if adverse material uncovered during the review indicates that sponsors are not of the high moral and financial character required to operate an ADM program. In the event DMV reaches this decision, written notice will be provided to the sponsor explaining or decision. This decision will be subject to appeal.
Existing approved NYS sponsors are allowed to partner or create a co-venture with another company to provide the ADM course, so long as they have exclusive rights to deliver the course in NYS. In the event the partnership is with a non-NYS approved PIRP provider, the non-NYS provider would not be eligible to offer the same PIRP course, in the event they opted at a future date to apply to become a NYS classroom and/or ADM sponsor.
To the degree possible, DMV prefers to have at least two approved ADM sponsors before authorizing the start of the pilot. The start date selected will be provided in writing to all approved ADM sponsors, and will likely indicate a future date (approximately 14 days from the notice). Once the pilot officially starts, all subsequently approved ADM sponsors can start as soon as course approval has been received. The five year pilot will being once the start date selected occurs.
Questions About Appendix A
Appendix A will be updated as needed to address DMV's and the sponsors' concerns. Questions about the specification can be put in writing and mailed to:
DPR - Room 412 6 Empire State Plaza Albany, NY 12208 Fax: (518) 473-0160 Email: IPIRP@dmv.state.ny.us
The sponsor question and DMV response will be mailed to all sponsors with a pending application on file (sponsor is at step 1 or later). In the event the specification document is updated as a result of clarifications (or technology advancements), it will be mailed to all approved public sponsors.
N.Y. Comp. Codes R. & Regs. Tit. 15 § 141.14