Sounds like they use 35MPH average as the guideline, which I seem to recall reading before. If your average speed, total miles divided by engine hours, is less than 35 then they can hassle you about excessive idling or related problems.
Using their math or miles/hours cannot tell you how long the engine has spent idling, though. I believe the ECM actually logs idle time, which is time spent below 1100 or 1000 RPM (IIRC). The truck could be a farm truck that spends its time in 4WD Low or never leaving 1st or 2nd gear, the engine running 1500+ RPM the vast majority of time, and as a result the average speed would be below 35MPH yet the truck spent very little time idling.
Can't tell actual idle time just by hours and odometer alone.