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Trucksafe's President Brandon Wiseman and Vice President Jerad Childress are transportation attorneys who have represented and advised hundreds of motor carriers (both large and small) on DOT regulatory compliance. Brandon and Jerad are regular speakers at industry events and routinely contribute to industry publications. They are devoted to helping carriers develop state-of-the-art safety programs, through personalized consulting services and relevant training resources. 

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The elusive 15-day MVR rule


Most federally regulated motor carriers are aware of their obligation to run initial and annual MVRs on their commercial drivers. Fewer appreciate that the federal safety regulations require them to run yet another MVR if they employ or otherwise engage drivers who operate vehicles that require a CDL.


Part 391 of the regulations requires these carriers to run an MVR within 15 days after a CDL driver obtains a new medical examiner certificate (a/k/a med card) to ensure his/her medical certification status has been updated on the Commercial Driver’s License Information System (CDLIS). Failing to run these so-called 15-day MVRs can cause significant problems for carriers in DOT audits and roadside inspections.


Background on Medical Certification MVRs

In 2008, the Federal Motor Carrier Safety Administration (FMCSA), the agency charged with regulating interstate highway transportation, promulgated new regulations requiring CDL drivers to provide information about their DOT-mandated medical examinations to their state driver’s licensing agencies (SDLAs) for posting on their individual driving records. A few years later, the agency established the National Registry of Medical Examiners and required that all providers performing DOT physical examinations be listed on that registry.


In 2015, the FMCSA issued yet another rule pertaining to DOT medical exams, requiring, among other things, medical examiners to directly report the results of driver medical examinations to the FMCSA who would then electronically transmit that data to SDLAs for posting on the CDLIS. If the transmitted information required it, SDLAs would then be required to take action to downgrade CDLs of drivers who were no longer medically certified.


Importantly, the 2015 rule explained that motor carriers, enforcement personnel, and other interested parties would, upon the effective date of the rule, no longer be permitted to rely on the original paper medical examiner certificate as proof of a CDL holder’s medical certification. Instead, they would have to rely on the medical certification status as reflected by the appropriate SDLA in the CDLIS (i.e., on an MVR). The rationale for these changes was to minimize medical card fraud and forgery by moving away from a paper-based and to an electronic process. At least in theory, moving to an electronic process would also make it easier for SDLAs to take prompt action against CDL drivers who either failed to renew their med cards or pass their physicals.


The 2015 rule changes were originally set to take effect in June of 2018; however, the agency has subsequently delayed that date several times due to IT issues impacting the agency’s ability to electronically transmit data to SDLAs. FMCSA highlighted these problems in its most recent Federal Register notice, through which it further delayed the rule’s effective date to June 23, 2025.


What the Rules Currently Require

Unfortunately, until the agency’s rule becomes fully effective, the medical certification process remains in a state of limbo. As a stop-gap measure, the FMCSA requires carriers to take a hybrid approach to verifying the medical certifications of CDL drivers. The agency summarized this interim requirement in its 2015 rule as follows:


Motor carriers who employ a CDL holder subject to the physical qualifications requirements under 49 CFR part 391 must place the driver's current CDLIS MVR documenting the driver's medical certification status in the driver's qualification (DQ) file before allowing the driver to operate a CMV. The [medical examiner certificate] that the driver provided to the SDLA may be used for this purpose for up to 15 days from the date the certificate was issued by the ME. The CDLIS MVR will be used to verify the driver has the necessary medical certification and the results placed in the DQ file.


This requirement is now codified in the federal safety regulations at 49 C.F.R. § 391.23(m)(2).


In short, motor carriers who employ or engage CDL drivers must, in addition to running initial and annual MVRs, run new MVRs within 15 days after each CDL driver obtains a new med card to ensure the driver has timely submitted his/her medical certification information to the appropriate SDLA and the updated information now appears on the MVR. Eventually, this process will be entirely electronic, but for the time being, carriers can continue to rely on the CDL driver’s paper med card as proof that he/she is physically qualified but only for the initial 15 days after he/she receives that card. After the 15-day time period, carriers must have a new MVR in the CDL driver’s qualification file reflecting the driver’s updated medical certification status.


Consequences of Non-Compliance

The FMCSA actively enforces the interim 15-day MVR requirement in the context of its safety audits and compliance reviews. Carriers who fail to run these MVRs risk the imposition of civil penalties and, more importantly, a downgraded safety rating. Indeed, failing to run a required MVR is considered a “critical-level” violation under the agency’s safety rating methodology in 49 C.F.R. Part 385, Appendix B, and has the potential to lead to a Conditional or Unsatisfactory safety rating.


Tips for Carriers

  • Carriers who employ or engage CDL drivers should ensure they have appropriate processes and policies in place to run the required 15-day MVRs following each CDL driver’s medical recertification.

  • Until the FMCSA’s new electronic medical certification process is fully functional, carriers who are enrolled in a continuous MVR monitoring service will need to physically run the required 15-day MVRs for CDL drivers.

  • Carriers should implement a dispatch-hold procedure to ensure that CDL drivers whose medical certification status is not updated or cannot be verified through the required 15-day MVRs do not operate a commercial vehicle unless and until such verification is made.

  • In instances where a CDL driver’s 15-day MVR does not yet reflect the driver’s updated medical certification status, his/her carrier should place the driver on dispatch hold and should continue running MVRs until one reflects the updated information. Failing to do so can result in the driver’s CDL being downgraded without the carrier’s knowledge, which can, in turn, lead to enforcement problems.

For more detailed information on the driver qualification process and other aspects of the federal safety regulations, check out our comprehensive, online compliance training courses through Trucksafe Academy. Also, be sure to check out our eBook DOT Compliance: The Basics.


NOTE: This article was originally developed for and published with SambaSafety. SambaSafety offers carriers continuous license monitoring services, DQ file management, driver training, and much more. To read more about SambaSafety's services, visit https://sambasafety.com.

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