State Traffic Records Integration for National Safety Performance Management: A Common Data Model and National Data Fabric for NHTSA Trend Analysis, State Comparison, Grant Oversight, and Countermeasure Evaluation

This revision incorporates final 2024 and preliminary 2025 fatality data, corrects the document’s baseline data source characterization, updates the institutional context to reflect the current DOT administration, replaces an erroneous defense-sector data architecture reference, and amends the grant funding scale discussion.

Executive Summary

The United States recorded 39,254 motor vehicle traffic fatalities in 2024 — confirmed by NHTSA’s final data release on April 1, 2026 — representing a 3.6 percent decline from the 40,901 fatalities recorded in 2023. Preliminary estimates for 2025 project further improvement, with an estimated 36,640 fatalities — a 6.7 percent decrease from 2024 and the second-lowest fatality rate in recorded history at 1.10 fatalities per 100 million vehicle miles traveled. Those declines are materially encouraging. They do not resolve the structural fact that fatalities remain elevated relative to the pre-pandemic period: 2024 fatalities were approximately 6 percent above the 2019 level and 21 percent above 2011.

The current administration under Transportation Secretary Sean Duffy has maintained a clear commitment to reducing roadway fatalities, including the July 2025 launch of the SAFE ROADS initiative, the continuation of the Safe Streets and Roads for All grant program, and NHTSA’s first full-year grant approvals exceeding $800 million in combined Section 402 and Section 405 funding. That funding commitment, combined with the sustained fatality trend improvements now extending across multiple consecutive quarters, creates both the fiscal resources and the performance trajectory to support a meaningful investment in the data infrastructure that national safety management requires.

That infrastructure does not currently exist in the integrated form the national performance management mission demands. The most comprehensive independent assessment of state traffic safety data system quality — GAO-10-454, published in April 2010, which analyzed assessments conducted for states by NHTSA — established a baseline showing that vehicle and driver data systems met NHTSA’s six performance measures 71 percent and 60 percent of the time, respectively, while roadway, crash, citation and adjudication, and injury surveillance systems met performance measures less than 50 percent of the time. Critically, across all data systems and all states, the integration performance measure was met only 13 percent of the time — the weakest dimension by a margin of nearly four to one against the next-weakest measure.

No subsequent GAO assessment has reproduced a comparable cross-state, cross-system numerical analysis with the same methodology. NHTSA’s August 2023 report on state challenges to improving traffic safety coordination (DOT HS 813 486), which analyzed assessment data from 2018 to 2022, confirmed that the structural pattern established in 2010 persists: citation and adjudication systems remain the furthest from the ideal across all systems, and data integration and quality control remain the most frequently cited challenges in both assessment results and GO Team technical assistance requests. The 2010 percentages therefore serve as a baseline that directional evidence suggests has improved modestly but has not been fundamentally transformed. The integration gap in particular — the inability to link crash, vehicle, driver, roadway, citation, and injury records against a common event identifier — remains the most consequential structural deficit in the national traffic safety data ecosystem.

This paper proposes a national data integration architecture — the National Traffic Safety Data Fabric (NTSDF) — that can normalize state traffic records into a common data model while preserving state-specific codes, link the six core data systems through probabilistic and deterministic record linkage, and support the four primary NHTSA performance management use cases: national trend analysis, state-to-state outcome comparison, Section 402 and Section 405 grant oversight, and countermeasure evaluation. The NTSDF architecture does not require replacement of any state source system and is compatible with the BIL-funded grant structure that the current administration is actively deploying.

The integration gap in particular — the inability to link crash, vehicle, driver, roadway, citation, and injury records against a common event identifier — remains the most consequential structural deficit in the national traffic safety data ecosystem.

Executive Summary

Left column: GAO-10-454 (April 2010) compliance rates across all state assessments reviewed. Right column: qualitative findings from NHTSA DOT HS 813 486 (August 2023), covering assessments conducted 2018–2022. No comparable cross-state numerical update to the GAO 2010 percentages has been published.

Note on the 2010 baseline. GAO-10-454 remains the only published cross-state, cross-system numerical compliance analysis using NHTSA’s six performance measures. The 2023 NHTSA report (DOT HS 813 486) analyzed 2018–2022 assessment data and confirmed the directional findings — citation and adjudication furthest from ideal; integration the most cited challenge — but did not re-compute percentage compliance rates on a comparable national basis. This paper treats the 2010 figures as a structural baseline and the 2023 NHTSA findings as the most current qualitative characterization of systemic challenges.

The 13 percent integration compliance rate from 2010 is the operative structural problem that this paper addresses. The six data systems that together constitute a comprehensive traffic records program are maintained by different state agencies, governed by different legislative authorities, built on different database platforms, and linked — if at all — through bilateral interfaces that were not designed with national interoperability as a design requirement. Integration absent at the state level cannot be remedied at the national level through aggregation alone.

I. The Six Core Data Systems: Architecture, Standards, and Current Quality

The NHTSA Traffic Records Program Framework

NHTSA’s Traffic Records Program Assessment Advisory (DOT HS 812 601, 2018 Edition) defines six core data systems that together constitute a comprehensive state traffic records program. Each system serves distinct safety analysis functions and is governed by distinct national standards, but the systems are analytically interdependent: the full picture of a crash event — what happened, where, who was involved, how severely they were injured, what enforcement action followed, and what the eventual adjudication outcome was — requires linking records across all six systems against a common crash event identifier.

The crash system is the central repository storing law enforcement officer crash reports and the anchor to which all other systems should be linked. The national standard governing crash data content is the Model Minimum Uniform Crash Criteria (MMUCC), now in its Sixth Edition, originally published in 2024 and revised in February 2025 (DOT HS 813 525). MMUCC is a voluntary guideline — though, as discussed below, states participating in NHTSA’s Electronic Data Transfer (EDT) program face de facto standardization requirements for four mandatory standard elements. NHTSA uses crash data from state systems, via EDT protocol, to populate the Fatality Analysis Reporting System (FARS) and the Crash Report Sampling System (CRSS), which are the primary national data resources for trend analysis and policy research.

The vehicle system stores information on registered vehicles within the state. The driver system contains personal information about motor vehicle operators — licensed drivers, driver history records covering prior crashes, sanctions, convictions, administrative actions, license classes and endorsements, and restrictions. The roadway system contains information on all roadways within the state: centerline and geometric data, location reference data, GIS data, travel and exposure data. The citation and adjudication system records traffic law enforcement actions and their judicial outcomes, from the initial citation through conviction or dismissal. The injury surveillance system — the most complex from a data governance perspective — encompasses EMS records, hospital emergency department and trauma registry data, and death certificate data, spanning multiple agencies across multiple state and federal data governance frameworks.

System-Specific Quality Challenges

NHTSA’s August 2023 report on state challenges to improving traffic safety coordination (DOT HS 813 486) — which covers assessment data from 2018 to 2022 — confirmed that of the six traffic records systems, citation and adjudication systems were furthest from the ideal, with common challenges across all systems in data quality control programs and interfaces between systems. The 21 technical assistance requests submitted through NHTSA’s GO Teams program since 2015 were concentrated in strategic planning, TRCC management, data integration, and performance measure development — confirming integration as the most persistently demanded area of technical support.

The crash system, despite being the most comprehensively governed, faces its own quality challenges. NHTSA’s March 2024 Traffic Records Data Quality Management Guide (DOT HS 813 544) found that state TRCC strategic plans and Section 405 grant applications too often reflect a misunderstanding of the purpose and effective use of performance measures. Paper-based crash reporting — still used in some jurisdictions — creates data entry backlogs approaching two years in some states, fundamentally undermining the timeliness performance attribute. Inconsistency in how law enforcement officers interpret and record injury severity classifications, vehicle configuration codes, and roadway functional class attributes creates inter-state comparability problems that persist even when states nominally align to the same MMUCC standard.

Two clarifications on MMUCC’s formal status are analytically important. First, while MMUCC itself is voluntary, NHTSA requires the four S-series standard data elements (S1 through S4: State Unique Crash ID, Agency, Police-Reported indicator, and State Reportable Crash indicator) as a condition of participation in the EDT protocol. Since EDT participation is strongly incentivized through Section 405 traffic records grant criteria, states that seek those grants operate under de facto standardization requirements for these foundational elements. Second, CRSS draws from police-reported crashes and does not capture crashes below individual state reporting thresholds, a limitation that is relevant to the completeness of national injury estimates and countermeasure evaluations that rely on CRSS as an exposure denominator.

The injury surveillance system presents the most complex integration challenge. Linking crash records to EMS run records, to hospital emergency department encounters, to trauma registry records, and to death certificates requires probabilistic record linkage across data systems governed by different legal frameworks — state transportation data, HIPAA-protected health information, and vital statistics — with different custodians, different retention policies, and different identity resolution approaches. The MMUCC Sixth Edition (2024, revised February 2025) took a significant step toward addressing this by incorporating NEMSIS Universally Unique Identifiers as recommended linkage keys between crash data systems and injury surveillance data systems. This structural change, if adopted by states, creates the technical foundation for a national crash-to-care data chain that NHTSA currently lacks.

II. The Common Data Model: Normalizing State Records Without Erasing State Specificity

The Normalization Problem

The central technical challenge of national traffic safety data integration is how to make state records nationally comparable without destroying the state-specific information that gives those records their local analytical value. Every state maintains its own crash report form, its own code sets for injury severity, vehicle type, roadway classification, and maneuver type, and its own rules for what constitutes a reportable crash event. A crash coded as severity 2 in one state’s system may correspond to what another state codes as severity 3 or severity 1, depending on the injury classification framework each state has adopted.

The solution is not to require states to abandon their local code sets — that approach has failed repeatedly over the nearly three decades since MMUCC was first developed in 1998, and MMUCC itself acknowledges this through its voluntary status and its recently liberalized mapping rules. The solution is to build a canonical crosswalk layer that maps each state’s local code values to a nationally standardized equivalence class, preserving the state-specific code in the authoritative record while tagging each record with its national comparability code for cross-state analysis. MMUCC’s revised mapping approach in the Sixth Edition — which made mapping rules more flexible specifically to enable more state data elements to align with MMUCC and facilitate electronic data sharing — is the conceptual foundation for this crosswalk layer. The national data model extends this approach from the crash domain alone to all six data systems.

The Six Performance Attributes and Their Measurement Context

NHTSA’s six performance attributes for state traffic records systems are timeliness, accuracy, completeness, uniformity, integration, and accessibility. The terminology in the 2010 GAO report (which uses “consistency” in place of “uniformity”) reflects a slight difference from NHTSA’s formal nomenclature in the Traffic Records Program Assessment Advisory; subsequent NHTSA documentation uses uniformity as the preferred term. The integration attribute — the degree to which the six data systems are electronically linked to support cross-domain analysis — registered the lowest compliance rate across all states in the 2010 baseline and remains the most frequently cited challenge in technical assistance requests as of the 2023 NHTSA assessment analysis.

Key Variables for the National Common Data Model

The national common data model must capture ten categories of key variables that, together, support the four primary performance management use cases. Each variable category requires its own normalization approach because the state-specific coding challenges differ by domain.

Crash severity is defined by the highest injury outcome associated with a crash event and is the primary outcome variable for trend analysis and countermeasure evaluation. States use different injury classification scales: some use the KABCO scale (Kill, incapacitating injury, non-incapacitating injury, possible injury, no injury); others use the Abbreviated Injury Scale (AIS) or variations. The common data model maps all state severity codes to a normalized KABCO-equivalent scale while preserving the source code.

Injury severity at the person level — distinct from crash severity — requires linkage between the crash record’s officer-recorded injury assessment and the injury surveillance record’s clinical diagnosis. Officer-recorded injury severity systematically underestimates serious injury relative to clinical diagnosis. The MMUCC Sixth Edition’s NEMSIS UUID linkage creates the mechanism to replace officer-recorded injury severity with clinically confirmed injury severity for records where EMS and hospital linkage succeeds.

Roadway functional class governs exposure normalization for rate-based comparisons between states with different roadway network compositions. The FHWA functional classification system provides the national standard; states update their functional classification maps on different cycles and with different levels of completeness in local and rural coverage.

Driver status — including license status, prior violation history, impairment status, age, and distraction factor — is the central behavioral predictor in crash causation analysis and countermeasure targeting. Linking the driver record from the crash system to the driver license system requires a state-maintained identifier bridge that is absent or incomplete in a substantial fraction of states.

Vehicle configuration — including body type, model year, gross vehicle weight rating, and presence of advanced driver assistance systems — is essential for countermeasure evaluation of vehicle safety standards. Linking vehicle registration records reliably to crash records is essential for that analysis.

Enforcement action and adjudication outcome — the citation issued, the charge, and the adjudication result including conviction, dismissal, and sanction — are essential for evaluating deterrence-based countermeasures. The citation and adjudication system is the worst-performing of the six systems and is the most legally complex to integrate due to varying state court data governance frameworks.

Toxicology result — blood alcohol concentration and drug panel results from crash-involved drivers — is among the most analytically consequential variables for impaired driving countermeasure evaluation. The lag between crash event and toxicology result — often 90 to 180 days — requires a deferred-update architecture allowing toxicology records to be appended after initial entry.

EMS response characteristics — unit response time, on-scene time, transport time, and destination hospital level of care — are the primary variables for post-crash care performance measurement. NEMSIS provides the data standard; the integration challenge is building the crash-to-EMS linkage at scale across states with varying NEMSIS implementation maturity.

Fatality timing — whether death occurred at the scene, in transport, in the emergency department, or after hospital admission, and the interval between crash and death — is critical for accurate fatality attribution consistent with the 30-day FARS window, and for assessment of the preventability of deaths that occurred after initial survival. States vary substantially in how they capture post-scene fatalities. The FARS Annual Report File is particularly affected by this, as the file is released before all post-scene fatalities are fully reconciled; the Final File (released the following year) corrects the count. NHTSA notes that the 2023 FARS data, released as the Annual Report File, is subject to revision when finalized.

Crash underreporting by type — including the systematic underreporting of specific crash configurations such as underride crashes in state police crash reporting systems — creates biases in national injury estimates derived from CRSS that affect countermeasure benefit calculations. The NTSDF’s linkage of crash records to injury surveillance records provides an independent check: a serious injury EMS run or hospital trauma admission that cannot be linked to a police crash report in the same geographic area and time window is a candidate for a missing crash report.

III. The National Traffic Safety Data Fabric: Architecture and Implementation

Data Fabric Concept and Federal Analogues

A data fabric is an architectural approach to enterprise data integration that provides a unified data management layer across heterogeneous, distributed source systems without requiring centralized physical consolidation. It replaces point-to-point bilateral data-sharing agreements with a governed semantic layer that maps source system schemas to a common data model, applies metadata-driven transformation rules, and exposes integrated views to analytical consumers through standardized query interfaces. The fabric does not require states to replace their source systems; it requires them to publish data conforming to an interface specification that the integration layer can ingest and normalize.

The federal government has developed analogous architectures in health information exchange. The American Journal of Public Health’s 2024 analysis of the national health data ecosystem identified the CDC’s Data Modernization Initiative and the HHS Office of the National Coordinator for Health IT’s Trusted Exchange Framework and Common Agreement as the closest federal analogues to what a national traffic safety data fabric would require. Both programs address the same structural challenge: inconsistent regulations, infrastructure, and governance across federal and state levels; siloed systems; and insufficient funding blocking effective integration across custodians with different legal authorities. The public health experience also identifies the key failure mode: attempting top-down standardization before sufficient bottom-up investment in state system modernization produces a standards layer that states cannot comply with because their source systems cannot generate the required outputs.

The 21st Century Cures Act (2016) and its interoperability provisions — which mandated that certified health information technology support standardized application programming interfaces and prohibited information blocking — represent the more recent statutory model for compelling data exchange across distributed custodians without requiring system consolidation. A parallel authority model for traffic safety data integration would combine mandatory interface compliance conditions on federal grant receipts with NHTSA’s existing assessment and technical assistance infrastructure, avoiding the need for new statutory authority while using the grant leverage that Congress has already provided.

NTSDF Layer Architecture

The National Traffic Safety Data Fabric (NTSDF) is organized in four layers. The ingestion layer receives state data submissions through NHTSA’s Electronic Data Transfer protocol, extended to cover all six data systems rather than crash data alone. For each data system, the ingestion layer validates submissions against the interface specification — checking mandatory field presence, value range conformance, cross-record consistency rules, and temporal logic constraints — and generates a data quality scorecard for each submission that feeds directly into the performance measurement system.

The normalization layer applies the canonical crosswalk tables that map state-specific code values to national equivalence classes for each key variable. Crosswalk tables are maintained centrally by NHTSA’s National Center for Statistics and Analysis in collaboration with state Traffic Records Coordinating Committees and are versioned to track changes when states update their local code sets. The normalization layer appends the national equivalence class code as a derived field, preserving the original state code as the authoritative value and flagging any records where the crosswalk mapping is ambiguous — for example, where a state uses a code value that falls between two national equivalence classes — for analyst review rather than silent imputation.

The linkage layer performs record linkage across the six data systems at the event and person levels. Deterministic linkage uses exact-match keys where states maintain them: the state crash unique identifier (MMUCC element S1) links crash-level records to vehicle and person records within the same crash report; the NEMSIS UUID links crash records to EMS run records; VIN-based matching links crash vehicle records to registration records. Probabilistic linkage, using blocking-and-scoring methods that match on combinations of date, location, injury characteristics, and partial identifiers, fills the gaps where deterministic keys are absent. The linkage layer records a match-confidence score for each cross-system link and makes that score available to downstream analysts so that analyses can apply confidence thresholds appropriate to their specific use case.

The analytical and reporting layer exposes the integrated, normalized, linked data to three classes of consumers: NHTSA program analysts conducting national trend analysis and countermeasure evaluation; state highway safety offices accessing their own state’s integrated data for local program management and peer comparison; and the public performance reporting portal that the Bipartisan Infrastructure Law requires states and NHTSA to maintain with information on performance targets, progress, and program expenditures. The analytical layer includes a domain weakness dashboard that flags, for each state and each data system, the performance attribute dimensions where the most recent submission failed validation or fell below defined thresholds, enabling NHTSA to direct GO Team technical assistance to states and systems with the highest unmet need.

MMUCC Sixth Edition as Architectural Foundation

The MMUCC Sixth Edition’s most consequential structural change for the national data fabric is Chapter 10: Traffic Records Data Integration, which identifies data elements obtainable from other state data systems and recommends linkage mechanisms rather than duplicative collection at the crash report level. This design principle — link rather than duplicate — is the correct architectural approach for a national data fabric because it reduces data quality risk from double-entry inconsistencies, incentivizes states to build the system-level linkages that the fabric requires, and aligns the crash data architecture with the NHTSA EDT protocol. The MMUCC Sixth Edition’s reduced discrepancy between MMUCC data elements and FARS and CRSS elements similarly reduces the translation burden between state crash submissions and NHTSA’s analytical databases.

The GHSA MMUCC Best Practices guidance published in June 2024 documented state integration successes illustrating the scalable approach. States that have successfully integrated various systems have traditionally started with systems managed by one state agency — crash, driver, and vehicle databases housed within a single DMV or transportation department — where there are fewer technological and administrative barriers. The NTSDF implementation plan must account for this graduated integration reality: the initial submission requirement should target crash data (already partially covered by EDT), extend to vehicle and driver data as the next tier, and treat roadway, citation and adjudication, and injury surveillance as subsequent tiers with correspondingly longer implementation timelines and higher technical assistance support requirements.

This design principle — link rather than duplicate — is the correct architectural approach for a national data fabric.

§ III — MMUCC Sixth Edition as Architectural Foundation

IV. Performance Management Applications: The Four Use Cases

Use Case 1: National Trend Analysis

NHTSA’s primary national trend analysis tools — FARS and CRSS — are well-designed for their respective purposes: FARS is a census of all motor vehicle traffic fatalities; CRSS is a nationally representative sample of crash events at all severity levels. FARS’s status as a census makes it the definitive source for the fatality count, but it is important to distinguish between the Annual Report File (ARF) and the Final File. The ARF for a given calendar year is released in spring of the following year and is subject to revision; the Final File, released approximately one year later, reflects reconciled data from state submissions including post-scene fatalities and corrections. The 2023 final fatality count of 40,901 was carried in the ARF; the Final File for 2023 was not yet released as of the April 2026 final data announcement for 2024.

NHTSA’s final 2024 traffic crash data — released April 1, 2026 — confirmed 39,254 fatalities in 2024, with a fatality rate of 1.19 per 100 million VMT. Preliminary estimates for the first nine months of 2025 projected an 8.2 percent decline in fatalities compared to the same period in 2024, which NHTSA characterized as the largest first-half reduction since 2008. These consecutive-quarter improvements are the outcome data against which the NTSDF’s trend analysis capabilities should ultimately be validated: does the integrated data system produce earlier, more accurate detection of trend shifts than the current FARS annual cycle?

The NTSDF enhances national trend analysis by enabling crash-severity trend analysis at the injury surveillance level rather than the officer-field-assessment level, by linking FARS and CRSS crash records to EMS and hospital data through the NEMSIS UUID and probabilistic linkage where UUIDs are absent. Replacing officer-assessed injury severity with clinically confirmed injury severity for serious injury trend measurement reduces the systematic undercount of serious injuries that current CRSS estimates carry — a materially important improvement for the NRSS and its successor frameworks, in which the number of serious injuries is a universal core performance measure alongside fatalities.

Use Case 2: State-to-State Outcome Comparison

State-to-state fatality and serious injury rate comparisons are a fundamental tool for identifying which states face the greatest safety challenges. The January 2025 NHTSA Federal Register notice on updated performance measures established number of fatalities, rate of fatalities per 100 million VMT, and number of serious injuries as universal core performance measures that all states must report. NHTSA’s final 2024 data confirmed that 35 states experienced projected decreases in fatalities, while increases were projected for the remainder — a distribution that underscores the importance of state-level decomposition.

Cross-state comparisons are currently hampered by three sources of non-comparability that the NTSDF addresses: different injury severity definitions produce incomparable serious injury counts; different crash reporting thresholds mean that what counts as a reportable crash differs by state; and different VMT exposure measurement methodologies make rate comparisons imprecise. State-level trend decomposition — identifying whether a state’s improvement or worsening is attributable to changes in specific crash types, specific roadway contexts, or specific driver populations — requires the multi-domain linkage that the NTSDF provides.

Use Case 3: Grant Oversight and Performance Accountability

NHTSA’s FY2025 grant approvals allocated more than $800 million to states and jurisdictions: $409 million in Section 402 Highway Safety Program funds and $382 million in Section 405 National Priority Safety Program funds. Within Section 405, 14.5 percent of funds are earmarked for traffic records incentive grants, requiring states to have a Traffic Records Coordinating Committee, a designated traffic records coordinator, and a traffic records strategic plan, and to demonstrate quantifiable progress in improving their traffic records systems according to the six specific performance attributes.

The current measurement of quantifiable progress is self-reported through state TRCC strategic plan submissions and grant applications, which NHTSA’s 2024 Traffic Records Data Quality Management Guide explicitly identified as too often reflecting a misunderstanding of the meaning and effective use of performance measures. The NTSDF resolves this oversight gap by replacing self-reported quality claims with automated, submission-based quality measurement. Every EDT data submission from a state generates a data quality scorecard against the six performance attributes: timeliness, accuracy, completeness, uniformity, integration, and accessibility — computed by the NTSDF ingestion layer without requiring state self-assessment.

BIL’s requirement that states set triennial performance targets demonstrating constant or improved performance can be directly linked to NTSDF quality scorecard trajectories, giving NHTSA a continuous compliance monitoring tool rather than annual point-in-time assessment. States showing scorecard degradation can be flagged for targeted GO Team assistance before the degradation becomes a grant compliance issue, shifting NHTSA’s oversight posture from reactive to preventive.

Use Case 4: Countermeasure Evaluation

Countermeasure evaluation at the required level of specificity — determining whether a specific safety intervention produced a measurable reduction in fatalities or serious injuries in the target population and location — demands the full multi-domain data chain: crash event records linked to roadway geometry, driver history, enforcement citation, adjudication outcome, and injury surveillance. NHTSA’s FMVSS rulemaking impact analyses have historically relied on FARS and CRSS, supplemented by field studies and laboratory crash reconstruction.

The NTSDF enables a higher-resolution evaluation methodology: statewide administrative records analysis comparing crash, injury, citation, and adjudication outcome rates in intervention jurisdictions against matched control jurisdictions on a continuous basis, updated as new data flows through the EDT ingestion layer. This approach is analogous to the difference-in-differences methodology used in public health program evaluation and requires the same data infrastructure: a longitudinal, linked administrative record database with consistent definitions across comparison units.

The underreporting problem documented in a March 2026 comment on NHTSA’s CRSS information collection illustrates a specific countermeasure evaluation failure mode that the NTSDF addresses directly: underride crashes are underreported in state police crash reporting systems, and those missed cases bias national underride injury estimates derived from CRSS, understating the benefits of countermeasures designed to prevent those injuries. The NTSDF’s linkage of crash records to injury surveillance records provides an independent check on crash event completeness, enabling systematic identification of reporting gaps that CRSS’s sampling frame cannot detect.

V. Governance, Funding, and Institutional Barriers

The Current Institutional Context

The institutional context for national traffic safety data integration has changed materially since the Biden administration’s National Roadway Safety Strategy was released in January 2022. The Trump administration, which took office in January 2025, has not formally continued the NRSS as its governing roadway safety framework. Transportation Secretary Sean Duffy has instead pursued a distinct set of safety priorities under the current DOT leadership: the SAFE ROADS initiative launched July 1, 2025 (directing all 50 states to identify high-risk arterials for infrastructure improvements); a commercial driver safety program focused on non-domiciled CDL holders; continued deployment of the Safe Streets and Roads for All grant program (with the removal of DEI and environmental justice eligibility criteria applied under the previous administration); and a broader congestion reduction agenda.

NHTSA itself has undergone significant operational changes since January 2025. Jonathan Morrison was confirmed as NHTSA Administrator in September 2025. NHTSA’s headcount declined from approximately 780 employees to approximately 555 through a combination of voluntary buyouts, terminations of probationary employees, and retirements — a reduction of approximately 25 percent. The current administration characterized this as scaling the agency toward its size during the first Trump term. DOT leadership has stated that safety-critical roles were not cut, though advocacy groups have raised concerns about the agency’s capacity for rulemaking, enforcement, and research.

These institutional changes create both constraints and opportunities for the NTSDF proposal. On the constraint side, a smaller NHTSA with a changed leadership priority set may have reduced bandwidth for the kind of multi-year data architecture program the NTSDF represents. On the opportunity side, the current administration’s stated commitment to reducing regulatory burden and increasing government efficiency through data-driven management is fully compatible with the NTSDF’s core value proposition: replacing costly, slow, and unreliable self-reported quality assessments with automated, submission-based quality measurement. The NTSDF does not add regulatory burden to states; it creates a more transparent and objective accountability framework for grant funds that are already being distributed at over $800 million per year.

The Legal and Interagency Governance Challenge

NHTSA’s legal authority to mandate state data system improvements is constrained. The agency can condition Section 405 traffic records grant funding on demonstrated progress in traffic records system quality, and it can provide technical assistance through the GO Teams program, but it cannot require states to adopt specific data systems, link specific databases, or share data in specific formats beyond what grant conditions authorize. This authority structure creates a voluntary-compliance incentive landscape in which resource-constrained states may prioritize grant-eligible improvements over integration investments that are analytically necessary but not directly required for grant qualification.

The national health data ecosystem offers a parallel. AJPH’s 2024 analysis found that inconsistent regulations, infrastructure, and governance across federal and state levels significantly impede health data exchange, and that siloed systems and insufficient funding block effective integration. The resolution in the health domain has relied on three mechanisms: financial incentives under the HITECH Act (2009), which drove substantial initial adoption of electronic health records; interoperability mandates under the 21st Century Cures Act (2016), which compelled standardized data access interfaces and prohibited information blocking; and governance infrastructure through the Trusted Exchange Framework. For traffic safety data integration, the analogous mechanisms are BIL grant conditions (financial incentive), potential NHTSA rulemaking to define data interface requirements as grant eligibility criteria (the closest available interoperability mandate), and the TRCC network (the governance infrastructure).

Resource Constraints and Current Grant Leverage

NHTSA’s FY2025 grant approvals — more than $800 million across Section 402 and Section 405 programs — represent the current operational scale of the highway safety grant program, substantially larger than the $260 million initial BIL cycle announcement from December 2021 that represented only a partial-year first distribution. The BIL authorization expires September 30, 2026. Congress will reconsider NHTSA’s roles, resources, and authorities in the next surface transportation reauthorization, which creates both risk (that traffic records improvement funding levels could change) and opportunity (that the reauthorization could include strengthened data integration requirements that would give NHTSA the authority it currently lacks).

Despite the expanded funding authority, state resource constraints remain binding. Data integration projects require sustained multi-year investment in system architecture, interface development, staff training, interagency data-sharing agreement negotiation, and governance structure maintenance — a cost profile poorly suited to the annual grant cycle that governs most NHTSA funding flows. BIL’s triennial performance target cycle creates some planning stability, but the annual grant application and reporting cycle still incentivizes states to pursue discrete, near-term improvements over the multi-year integration investments that the NTSDF requires.

The Assessment System Quality Problem

NHTSA’s traffic records assessment system has its own documented quality problems. Of the 51 assessments reviewed in GAO-10-454, 49 had insufficient information to fully determine the quality of at least one data system, and an updated assessment format introduced after 2012 resulted in more frequent instances of insufficient information. NHTSA has since used three different assessment approaches — NHTSA-facilitated assessment, state self-assessment using a state-created tool, and state self-assessment using a NHTSA-created tool — producing results that are not directly comparable across approaches and making longitudinal trend tracking unreliable. The 2023 NHTSA assessment analysis (DOT HS 813 486) confirmed that these methodological variations persist and that assessment results must be interpreted with awareness of which approach was used for a given state.

The NTSDF’s submission-based automated quality scoring addresses the assessment system quality problem directly: rather than relying on assessment teams asking states a common set of questions and evaluating narrative responses, the scorecard is computed from the data itself. This approach produces a continuous quality signal rather than a point-in-time assessment conducted at five-year intervals, enabling both states and NHTSA to detect data quality degradation as it occurs.

VI. Recommendations

1. Establish a National Traffic Safety Data Fabric Program Office within NCSA

NHTSA’s National Center for Statistics and Analysis should establish a dedicated NTSDF Program Office responsible for developing and maintaining the technical specifications, crosswalk tables, and quality scoring algorithms that constitute the national data fabric. The program office should be staffed with data architects, statisticians with record linkage expertise, and state liaison coordinators. It should operate in close collaboration with the MMUCC Committee, the GHSA, the National EMS Quality Alliance, and the state TRCCs. Given NHTSA’s current staffing constraints following the 2025 workforce reduction, the program office should be stood up in a lean initial configuration and staffed incrementally as the BIL reauthorization process provides clarity on long-term resource levels.

2. Extend the EDT Protocol to All Six Data Systems with Tiered Implementation Requirements

NHTSA should publish interface specifications for NTSDF-compliant submissions from all six data systems, using the MMUCC EDT protocol as the crash system baseline and developing analogous specifications for vehicle, driver, roadway, citation and adjudication, and injury surveillance submissions. Adoption requirements should be tiered: crash and vehicle data within two years; driver and roadway data within four years; citation and adjudication and injury surveillance within six years. Section 405 traffic records grant criteria should be updated to award incremental credit for each data system whose submission meets the NTSDF interface specification, creating a financial incentive that rewards multi-system integration rather than siloed crash-only improvement.

3. Replace Self-Reported Performance Assessment with Submission-Based Quality Scoring

NHTSA should update the Section 405 traffic records grant eligibility and quantifiable progress criteria to replace self-reported performance claims with automated quality scores computed from the NTSDF ingestion layer’s validation results. The six performance attributes — timeliness, accuracy, completeness, uniformity, accessibility, and integration — should each have defined quantitative scoring algorithms applied uniformly across all state submissions. Integration, which registered only 13 percent compliance in the 2010 GAO baseline and which the 2023 NHTSA assessment confirmed remains the most cited challenge, should receive a double weighting in the overall quality score for the first three grant cycles to create an explicit incentive for states to prioritize cross-system linkage.

4. Pursue Traffic Records Data Integration Provisions in the Surface Transportation Reauthorization

With BIL authorization expiring September 30, 2026, Congress and NHTSA have a timely opportunity to include stronger traffic records data integration provisions in the next surface transportation reauthorization. Specifically, the reauthorization should define NTSDF interface compliance as a condition of traffic records incentive grant eligibility rather than as merely a factor in performance scoring; authorize multi-year traffic records modernization grants for states undertaking comprehensive data integration projects; and direct NHTSA to produce a bi-annual national traffic safety data quality report using NTSDF submission-based scoring, replacing the current point-in-time assessment approach. The reauthorization also presents the opportunity to address the NHTSA authority gap by explicitly permitting NHTSA to establish data interface requirements as grant conditions across all six data systems.

5. Establish National Privacy and Data Governance Standards for Multi-Domain Traffic Safety Linkage

NHTSA, in coordination with HHS and relevant state health and transportation agencies, should develop model data governance standards for multi-domain traffic safety record linkage that address the HIPAA and state health privacy law constraints impeding crash-to-injury surveillance integration. The model standards should specify minimum de-identification requirements for linked records, data-sharing agreement templates for crash-to-EMS and crash-to-hospital linkage, and security and access control requirements for linked datasets at NCSA. These standards should draw on the precedents established by the 21st Century Cures Act’s interoperability framework and the Trusted Exchange Framework, and should be developed with state attorney general offices and state privacy officers as co-developers rather than compliance targets.

6. Publish a National Data Quality Dashboard

NHTSA should develop and publicly publish a National Traffic Safety Data Quality Dashboard displaying, for each state and each data system, the most recent NTSDF quality scorecard results across all six performance attributes. The dashboard should display trends in each state’s quality scores over time to make progress and regression visible, and should be accessible to researchers, state highway safety officials, advocates, and the public. The BIL’s requirement for a public website for highway safety plans and state performance information provides the statutory mandate; the NTSDF quality scorecard provides the specific data content. The current administration’s emphasis on data-driven management and government efficiency makes a transparent, objective quality dashboard a compelling argument for executive branch support, independent of any political preference on the NRSS’s specific Safe System framing.

Conclusion

With 39,254 people confirmed dead in traffic crashes in 2024 — approximately 107 people every day — and 2025 early estimates projecting approximately 36,640 fatalities, the national trajectory is improving. The consecutive-quarter declines beginning in mid-2022 and extending through 2025 are the most sustained period of fatality reduction in more than a decade. Sustaining and extending that reduction requires, among other things, the ability to understand which interventions are working, in which states and roadway contexts, and for which populations. That understanding requires data that the current state traffic records system, in its fragmented and poorly integrated state, cannot reliably produce at national scale.

The structural problem is clear and its contours have not changed materially since 2010, when GAO established the baseline showing integration compliance at 13 percent across all states. The 2023 NHTSA assessment analysis confirmed that integration remains the dominant challenge in technical assistance requests and the most cited gap in state assessment findings. The technology to address the problem exists: electronic data transfer protocols, probabilistic record linkage methods, crosswalk-based data normalization, and the NEMSIS UUID linkage mechanism introduced in the MMUCC Sixth Edition. The governance levers exist: Section 405 grant conditions, the TRCC network, and NHTSA’s GO Teams program. What has been missing is a coherent national data architecture that connects those elements into a system capable of producing the integrated, normalized, continuously updated national performance picture that effective safety management demands.

The administration change in January 2025 and NHTSA’s subsequent workforce restructuring are material institutional factors that affect the feasibility of implementing the NTSDF in the near term. They do not change the underlying argument. Whether the governing framework is the NRSS’s Safe System approach or the current administration’s SAFE ROADS initiative, the analytical foundation is the same: traffic safety decisions — on grant allocation, countermeasure deployment, and regulatory priority — should be informed by the best available evidence. The NTSDF is the mechanism by which that evidence becomes available. Its case rests on operational efficiency and objective performance management, not on any particular policy preference for how roadway safety should be governed.

Integration absent at the state level cannot be remedied at the national level through aggregation alone.

Executive Summary