More than a decade ago, the Federal Motor Carrier Safety Administration (FMCSA) set out to streamline the process of verifying that drivers of commercial motor vehicles were physically able to operate safely.
Since then, the FMCSA has issued a waiver to the rule every three months. Earlier this month — on Oct. 9, 2025, to be exact — the FMCSA issued yet another “temporary” waiver to the rule.
The original rule was supposed to change the requirement that CDL drivers submit a paper copy of their medical examiner’s certificate card to their state driver’s licensing agency (SDLA).
In fact, drivers weren’t supposed to receive the familiar wallet medical card at all. Instead, the medical examiner was to submit the results of the driver’s physical exam — whether passed or failed — to the new National Registry of Certified Medical Examiners. Each state was supposed to check with the National Registry to make sure the driver had a valid medical certificate on file before issuing a CDL.
The idea was a sound one.
No longer could unhealthy drivers fail a medical exam … and then go to a different doctor in hopes of getting a better result. Drivers who were borderline on medical issues like blood pressure or blood sugar sometimes hoped their numbers would look better on a different day, or perhaps they’d double up on medication just before testing.
In other cases, drivers were “shopping” for doctors or clinics with a reputation of being more lenient on physical exams. After all, the goal was to obtain the coveted medical examiner’s wallet card, clearing the way for two more years of CDL driving.
Under the new system, doctors had to be certified by the FMCSA before being permitted to administer DOT physicals, with all results reported to the National Registry. If a medical issue prohibiting driving was noted, the driver had to deal with it to bring the problem back within DOT parameters.
Drivers who couldn’t get a passing grade on a physical would find their CDL suspended by the state that issued it.
Carriers caught a break, too.
The new rules absolved them of the responsibility of keeping a copy of the driver’s medical examiner’s certificate in the required driver qualification file. They could assume that if the driver had a valid, non-suspended CDL, they were medically qualified.
Individual states were required to post driver medical information on the motor vehicle report in the Commercial Driver’s License Information System (CDLIS) that law enforcement officers check during a traffic stop.
Making sure a driver is medically qualified was going to be as easy as checking for past traffic violations.
So, what’s the holdup?
One problem has been gaining the cooperation of all the SDLAs. More than 10 years after the final rule was issued, 12 states are still not in compliance. In some cases, computer systems and programs used by states can’t interact with the National Registry. In others, appropriate staff has not been hired or trained due to budget or other limitations.
Waivers merely extend the old rules for another three months, the maximum time allowed for a waiver. However, the FMCSA can issue another three-month waiver, and another, as long as is necessary.
The burden of proof falls on the driver.
Unfortunately, the driver bears the brunt of this bureaucratic bungling. The rule instructed medical examiners to stop issuing the wallet card to drivers and carriers and to use the electronic system instead. But when the examiners don’t submit the information — or the states don’t query the National Registry before issuing or renewing CDLs — drivers are left with no proof that a physical exam was ever conducted, unless they have a paper copy with them.
Several of the noncompliant states have large populations of CDL drivers. The 2025 International Roadcheck event, conducted May 13-15 by the Commercial Vehicle Safety Alliance (CVSA), placed 493 drivers out of service (OOS) for not having a medical certification. That accounts for 15.7% of driver OOS events in the U.S.
It is unknown how many of these had not had a physical exam at all vs. those who would have been qualified if the system was working properly.
The latest waiver allows the driver to continue to use a copy of the medical examiner’s certificate as proof of medical certification for up to 60 days after passing the physical. The motor carrier is also authorized to use a copy of the card in its files.
The FMCSA’s waiver also strongly recommends that, in addition to submitting the results electronically, medical examiners continue to issue paper wallet cards at the time of the examination. According to the waiver, “the paper copy allows the driver to troubleshoot and resolve issues with the SDLA while states continue to transition.”
For drivers, the instruction is clear.
- If you take a DOT physical, make sure you get a copy of the medical examiner’s certificate (wallet card), and make sure you submit a copy to the agency that issued your CDL.
- Carry your copy with you while working in case you are stopped by law enforcement for inspection or other reason.
- Make sure your carrier has a copy, too.
When the electronic system fails, that wallet card is your proof that you passed a DOT physical examination. The worst that will happen is redundancy. You’ll be protected by your record in CDLIS and by the card in your pocket.
Which states are holding things up?
States that have not yet implemented the 2015 final rule are:
- Alaska
- California
- Florida
- Iowa
- Kentucky
- Louisiana
- New Hampshire
- New Jersey
- New York
- Oklahoma
- Vermont
- Wyoming
Additionally, the state of North Carolina, after adopting the new rules on June 30, 2025, has experienced numerous system errors and has incorrectly downgraded some CDLs for not having a medical certification on file.
There is still a requirement on the books for states that have not received a driver’s medical certification to downgrade the driver’s CDL to prohibit operation of a commercial motor vehicle. Drivers from one of the non-participating states, or anyone who is unsure, can download and print a document from FMCSA directing the medical examiner to issue the certification card.
Like many government-run programs, the intention of the 2015 Medical Examiner’s Certification Integration final rule may be improved efficiency. Until it’s fully integrated in the U.S., however, the results are anything but efficient.
Cliff Abbott is an experienced commercial vehicle driver and owner-operator who still holds a CDL in his home state of Alabama. In nearly 40 years in trucking, he’s been an instructor and trainer and has managed safety and recruiting operations for several carriers. Having never lost his love of the road, Cliff has written a book and hundreds of songs and has been writing for The Trucker for more than a decade.
I didn’t get a wallet size to carry!!
medical examiners need to make sure every page of the form has the exact same name, birth date and date on it when it is submitted to the Federal Registry. My dumb PA who did my exam didn’t enter my name the same on all pages and the Registry kept kicking it back and not transferring the exam to the state. So my CDL was canceled because I didn’t have a current physical on file with the state. Trying to contact the Registry doesn’t happen because of the amount of drivers trying to get their exams registered and the FMCSA doesn’t have enough staff to handle everything on that particular department. It took me over 2 weeks to get it solved.
Great content, incisive analysis with a nice “belt-and-suspenders” workaround for the driver by linking the FMCSA FAQ on NRII for drivers and MEs – which can be utilized by the driver in all instances as long as the waiver is in effect.
yeah, this ruling is a load of crap. These drivers that fail these b.s. medical exams. Have done nothing wrong, this blood pressure garbage doesn’t prove crap. I had “high blood pressure” when I was 20 years old. BP is a horse manure arbitrary measurement. To force prescriptions, and hold your job hostage.
How do I get a wavier for me being hearing impaired exemption??
When government gets involved then things get royally screwed up and takes forever to untangle or stays screwed up forever