Estimating and Invoicing Software
To advance the use of information and communication technologies, the Bureau of Automotive Repair (BAR) adopted regulations in 2018 to allow electronic estimates and authorizations in automotive repair transactions. The regulations allow consumers to authorize repairs to their vehicle conveniently by text message, email, or phone call. Since this regulatory change, numerous vendors have marketed estimating and invoicing software to automotive repair dealers (ARDs) to streamline repair transaction documentation. However, in the process of investigating and mediating consumer complaints, industry and BAR representatives have identified certain issues with some software applications that inadvertently put the ARD at risk of violating estimating, authorization, and invoicing requirements. Following is a summary of software issues that BAR has identified and potential solutions.
Note: References to Business and Professions Code sections are identified as BPC. All regulation references to Title 16 of the California Code of Regulations and are identified as CCR.
|The software limits the number of characters allowed for estimates, work orders, or invoices.
|BPC § 9884.9 and CCR § 3353(a) require the ARD to provide an estimate for parts and labor for a specific job. If needed, create a separate line item to adequately define a specific job.
In addition, BPC § 9884.8 and CCR § 3356 require the invoice to include comprehensive descriptions of the parts used. To provide an adequate description, a separate line item may be necessary.
|The software limits the number of additional authorizations that can be documented.
|Create a separate document with a unique identifier as described in CCR § 3358(e) to record the authorization and link it to the transaction. A copy of any authorization documents must be provided to the consumer.
|The software overwrites or omits required information from the estimate on the final invoice.
|Retain, either electronically or in a physical document, a copy of the estimate in a format that cannot be changed or overwritten.
|Use of two incompatible software applications.
|Carefully review documentation to ensure all required information is included. If software incompatibility causes the omission of required documentation, consider migrating to one software solution.
|Software-generated parts descriptions may differ from the actual part installed.
|Verify parts installed are correctly invoiced and described.
|The software applies acronyms that staff or consumers may not know.
|Create a legend or key to define acronyms.
Examples: “R&R” means remove and replace; “Reman” means a rebuilt part.
|The software restricts access to repair records.
|Pursue an option to store records locally (either digitally or printed) so as to not be dependent on the software provider for record storage or retrieval.
It should be noted that software providers are not subject to BAR jurisdiction and, as such, BAR does not review, recommend, or approve software solutions. ARDs choosing to use software solutions to increase business efficiency are responsible for providing employee training on the use of the software and verifying its compliance with the Automotive Repair Act and associated laws and regulations.
For information on automotive repair transaction requirements, review BAR’s Write It Right guide. You also may contact your local BAR field office to schedule an in-person Write It Right presentation.