It’s not “competition”, it’s picking winners and losers, PennDOT.

At the end of 2020 (with perhaps a month or two of training left) PennDOT put out an “Emergency” RFP in order to meet the requirement to have a Pennsylvania Motorcycle Safety Program and avoid a showdown over continuing permit/license fees collections, under 18 training requirements and the statutory requirement to offer motorcyclist training in the Commonwealth via PAMSP.

With so little of the year left PennDOT decided to start “3rd party training” in 2020, in advance of requiring it for the full 2021 training season. This “3rd party” model would allow multiple Motorcyclist Skills/Safety vendors to offer training in Pennsylvania, replacing the single-vendor contracts of the past.

As of 8/31/2020 less than 30 of the +60 PAMSP sites will provide training in 2020.
It is unknown how many will offer training in 2021.

PennDOT reportedly states that they are doing this to be “competitive” – yet most of the PennDOT staff don’t ride, are not Instructors, and know nothing about operating a Motorcyclist Skills/Safety program.

In the end “competitive” will be a euphemism for the lowest cost bidder, likely measure success by the greatest number of students trained – a problematic metric we’ll address in a later post.

Curriculum:

In other States, while there may be multiple 3rd party Providers contracted to provide Motorcyclist Skills/Safety training they are typically teaching the same curricula. This allows a uniform standard to be used across the state, minimizes Instructor training and retention issues, and enables a single quality control standard to be used across a Program.

In Pennsylvania not only will multiple 3rd party training providers be utilized but they can bring with them any training curriculum they desire. There are only a few motorcyclist safety training curriculum on the market and most vendors use only one of them.

Pennsylvania in 2018, for the first time in over 30yrs, changed the curriculum to a new vendor, which required retraining of all Pennsylvania Instructors – many of which were new due to massive attrition both with the curriculum change and the problems with the PennDOT program administration necessitating a large recruitment effort.

From a competitive standpoint, there aren’t many Basic Rider curriculum choices out there.

For curriculum to be used to train riders they must be licensed, the training provider certified to use the curriculum. Due to the cost of licensing, training, quality assurance and recertification it’s typical that a vendor will select, and remain with, a single curriculum for Basic and all other levels of rider instruction.

Curriculum providers spend a lot of time developing their courseware, face many liability, legal, intellectual property, testing, research and revision issues. In PA there are those who are working on developing their “own” courses, as PennDOT did to provide M Class license waivers (without on motorcycle training) to PA minors. For these classes PA will be leveraged to provide unknowing test subjects for these types of training classes, if PennDOT approves it for use in PA.

Beginner Riders are not shopping for different curricula and don’t have an informed position to determine what is good or bad. To make matters worse they make have multiple curriculums in their area and will be limited to what locations they can retake classes based on a certain program.

Will Pennsylvania require that any curriculum in use in the Commonwealth adhere to the NHTSA standards for Motorcyclist Safety training? So far there is no such requirement in either the 2020 or 2021 RFP so again as far as competition goes with regards to curricula – what are the goals?

Instructors:

Instructors, to put it mildly, have been given the shaft over the last ~10 years. Without Instructors there will be no training, it’s that simple.

3 Program Administration Companies, 2 curricula, repeated hiring/firings, site closings, scheduling issues, attrition, retraining, the 2020 contract cancellation (and with it another firing), the 2020 season cancellation, the 2020 emergency contact RFP, the introduction of 3rd party training and multiple training curricula just to name a few. Since 2013 alone.

PAMSP used to operate with over 500 Instructors. By the time 2018 had started, there were almost zero Certified Instructors in the Commonwealth, and all who wished to teach in 2018 were required to be trained in a new curriculum, different from the old in classroom and range. By 2020 the program was back up to over 200 Instructors – then the carpet was pulled out from underneath Instructors again.

It takes a long time to recruit, vet, train and put an Instructor into operation. The vetting process can take weeks, many times waiting months for Instructor training to be offered. It takes weeks for Instructors to go through their initial curriculum training. It can take a year or two before an Instructor is comfortable enough and competent in the curricula they are teaching to be effective.

For vendors new to the Commonwealth it may take 8-10 Instructors to fully staff a site. It currently takes at least (2) Instructors to teach a full class of (12) Students. Due to the time to recruit and formally train Instructors many vendors, in order to get up and running quickly, will either try to recruit staff from other Companies, if their curriculum is being taught at all, or will accelerate the training cycle to get ‘certified’ Instructors more quickly. The latter decreases student safety and training quality.

Instructors normally receive regular Quality Assurance visits, are under constant review of their peers and Instructor Trainers. Curriculum minor updates need to be taught to all of the staff over time. Prior to 2018 Instructors didn’t have to face Curriculum vendor changes but as curriculum major versions would change they would occasionally face recertification training.

Those doing the training are Instructors with far more training, “Instructor Trainers”, taking years to develop the specific skills needed to train and evaluate other Instructors. There are far less “Instructor Trainers” even at a National level and their skills are highly coveted as only they can train and certify other Instructors.

One of the past benefits in PA is that any PA Instructor could teach at any other PA location. Locally, Regionally or Commonwealth-wide calls for assistance could go out to address gaps in scheduling, injury or illness of Instructors. In 2020/2021 that all ends. In 2020/2021 Instructors can’t always teach at all sites in their locality, let alone teach at all sites within their home Region or State.

Most curricula consist of Basic, Intermediate, Advanced & 3 wheel training – this means that for each curriculum there are four different attainments, each specialized, all requiring at least Basic Instructor level certification and all have competency requirements in which you must teach a certain number of each class within a fixed timeframe to retain your certification.

What will “competition” bring Instructors? If they pick a single curriculum will it be offered in their area? For how long? Given the fact that Providers only have 2yr initial probationary period will the existing curriculum remain in the area? If there are only a few sites offering the curriculum they are certified in how will they find work?

Will Instructors be able to maintain multiple certifications in multiple curricula – will they want to?

Who will provide Quality Assurance is maintained? Where will trainers come from?

Will bigger vendors with a single curriculum at more sites inherently crowd out other vendors?

These are all of the issues that PennDOT is unaware of but has introduced to Pennsylvania. Confusion, lack of clarity, instability for Instructors.

Vendors:

There are only a few Motorcyclist Safety training vendors out there. From a “competitive” standpoint this certainly rings hollow.

Likely what is happening here is that given PennDOT’s issues with a single vendor they are looking to reduce their risk in managing a single program vendor, implementing 2 year probationary periods and being able to remove vendors that they don’t want to work with more easily, without impacting the entire program as they did in 2013, 2017 and 2020.

What this process will encourage is competition between vendors – for staff, students, for PennDOT funding.

This is something the Commonwealth, in the +30yrs of PAMSP, has never experienced. PAMSP was always a cohesive whole, a common curricula, Instructor portability, single point of Administration, policy, procedure, communication – cause.

Now PAMSP will be broke into vendor factions with competing interests outside those of motorcyclist skills & safety training. It may also see higher student pass rates to ensure contract “success”, to be used for competitive purposes. In all it is the Students, and Instructors, that will be caught in the middle.

Locations:

There are currently over 60 PAMSP sites across Pennsylvania. These sites are primarily locations provided by companies, landowners or other organizations with large parking lots and/or classroom facilities to borrow or rent.

Vendors are going to target the “high value” sites initially, those sites that can generate the most revenue and train the greatest number of students, pull in the most Instructor candidates. Some vendors will only target these sites.

Some locations are based in areas where there are little students and therefore little need. PennDOT has carried forward a mandate of ‘Motorcyclist training in all counties in PA’ which is unrealistic, but a contractual imperative. Total Control had a plan to address this, as they had in California, to be launched in the 2020 season but those plans were terminated with the PennDOT contract cancellation in 2020.

Where there are no students there likely will be no training, as competition will seek to meet whatever competitive metrics they are judged on. So for those sites in underserved areas likely, there will be no training unless students wish to travel to other locations to train, or a company finds there is a financial incentive to bankroll an alternative method of training.

Locating and maintaining sites has been a traditionally difficult task. Not everyone is willing to support motorcyclist training on their sites even with Program continuity of Site Coordinators, staff, equipment, policies & procedures and range painting. In order to conduct classes ranges (where motorcycle riding occurs) must be painted – if 5 different courses are being taught there could be 3 or more painted designs and colors on a parking lot.

In the past +30yrs ranges were repainted infrequently, typically only when ranges were repaved or sealed, or there was a curriculum modification. 2018 saw the greatest number of ranges painted as there was a new curriculum requiring the repainting of +60 ranges across PA.

Now as contract holders are on a 2-5 year cycle ranges could be repainted every few years, site staff can rotate regularly and training providers can change. What used to be continuity of care and contact for site holders can degrade into more frequent change.

For locations that own their own dedicated ranges, such as motorcycle dealerships, will have the opportunity to select programs that benefit their motorcycle sales or general revenue directly, even to the point of developing their own training systems to do so.

With different locations teaching different curricula it is inevitable that the fiefdoms of the past will again be seen across PA. Gatekeepers at private companies, such as dealerships, can prevent other Instructors from working at their sites, provide preference to known associates. Certification boundaries will prevent Instructors from working at sites near them, lack of transition training will chill the process of moving between providers as they change in the area.

In the past PAMSP had sites that would lock out Instructors. That practice was finally ended years ago. Now PennDOT has created the perfect formula to stifle competition, bring back the closed training site.

Selection Process:

The PennDOT vendor selection process is not an open one. The selection process is not public, is not publicized and does not appear in the RFP with any specificity.

We are seeing that now with the “Emergency” RFP where there are conflicting reports of who is being awarded what and when, even if an existing vendor with existing painted ranges and certified Instructors could immediately start training students in 2020 that appears to not be a PennDOT consideration.

Vendors have until September 30th to get their 2020 training up and running. Training generally ends at the end of October although in past years to assist students Total Control has been training until the end of December for the last few years due to student demand – a time where students are ill-prepared, weather is questionable and training is taken day by day to ensure student safety.

This will mean there will be a month of training in 2020 and perhaps 1/3 the number of sites in PAMSP – all to generate numbers, pilot the 3rd party model for 2021.

How will the 2020 selection process impact the 2021 selections? Currently ranges painted for Total Control Clinics at the start of 2020 will now be painted for MSF RiderCourses at the end of 2020 and repainted again for Total Control Clinics at the start of 2021? This is a needless waste of time and money, and may generate ill will between the Program and site owners.

How is the selection process competitive?
Price, capacity to train.

Metrics:

What will be the metrics used to measure program “Success” as well as the quality and effectiveness of different vendors and curriculum?

In the past PennDOT used to publish PAMSP metrics. That ended during the Cape Fox era and left the Public and Instructor Corps without a way to gauge program “effectiveness” based largely on customer service satisfaction & total numbers of students trained.

As dead riders doesn’t seem to be a factor to the Commonwealth (and is difficult to assess) in the past “number of riders trained” was a metric used. This can also be known as “more people sent into harms way”. Is this the metric to be used to determine the benefit of “competition” or will it simply be based on cost per student trained or both?

Cost:

What will all of this cost?

Is competition to reduce cost or will it increase costs?

Will PennDOT staff need to increase to manage the number of contracts (from one to ?), other financial administration tasks?

How will costs be managed, audited? With so many vendors this will make the financial reconciliation even more difficult.

Keep an eye out for some reviews of PAMSP funding and finance that will explore these aspects of PAMSP in more detail.

Summary:

PennDOT has not explained why they are making the changes to the Program publicly, but one of the reasons given by PennDOT staff is to increase “competition” – a reason with no clear metrics for success, to implement the change.

Yes, there may be more curriculum options – instead of one perhaps two or a few more. For Beginner Riders they’re not going to pay attention to that, for intermediate and experienced riders there are even less options – and even less demand.

Instructors will be the hardest hit, yet again. The Instructor community is small, used to be very cooperative, now silos will be built across the Commonwealth and as PennDOT chooses different vendors and they bring in different curriculum it’s going to make things more complicated for Instructors, limit their choices and options.

With regards to PAMSP PennDOT is picking winners and losers. That’s not competition.

If PennDOT wanted to make PAMSP more competitive they could have started by selecting a curriculum and simply invited certified providers to teach – like they do in California or New Jersey. They’re not, they’re creating a free for all in which Instructors face additional hardships and students additional confusion.

Change for change sake isn’t always beneficial. In this case it removes the possibility of addressing the significant issues with PennDOT’s management of PAMSP due to the foundational changes and massive amounts of disruption that will take years to work out.

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