The New Medical Card Rule Is Now in Effect. Here’s What You Need to Know
After nearly a decade of delays, the Medical Examiner’s Certification Integration rule finally went into effect this week, and with it came the end of paper medical cards for CDL drivers. This rule change was the focus of yesterday’s inaugural webinar from US Compliance Services, hosted by independent content strategist Lindsey Bergeron and Steve Harz, a compliance consultant for US Compliance Services. Together, they walked attendees through what this long‑awaited change means for motor carriers.
What came out of the discussion was more than a breakdown of digital certifications. It was a practical, forward‑looking conversation about how the industry needs to rethink how it manages driver qualification files in an increasingly digital world.
A Change 10 Years in the Making
The original medical certification ruling was published nearly a decade ago. Initially slated for 2018, it faced repeated delays as federal agencies worked through cybersecurity concerns and built the necessary IT infrastructure.
Now that it’s finally here, the process looks like this: medical examiners submit certification results directly to the National Registry, which then transmits that information to state licensing agencies. CDL drivers no longer receive a physical card to carry, copy, or file. “Your CDL drivers won’t get a paper medical card to put in their driver qualification file. Everything will be housed online,” Harz said.
While this might seem like a time‑saver, it doesn’t reduce carriers’ responsibilities. As the conversation revealed, this digital shift shines a light on existing gaps in how many companies manage their compliance.
The Current State of Driver File Compliance
The numbers shared during the webinar painted a clear picture of where the industry stands today. Over the past five years, the FMCSA has issued more than 62,000 driver qualification file violations, with average penalties exceeding $7,000 per violation. Missing Motor Vehicle Records topped the list as the most common error.
These statistics matter because they reveal a fundamental challenge: many carriers struggle with the basics of file maintenance, even before adding digital complexity to the mix.
Harz shared a telling example from his experience. About six months after the DOT Clearinghouse went into effect, he spoke with a safety manager at a construction company with 250 drivers. They hadn’t registered yet because, as she put it, “We didn’t think it was that big of a deal.”
"I quickly got out a calculator and conservatively told her that if she were audited today, she’d be looking at four and a half million dollars in fines," he recalled. The story served as a stark reminder that even seemingly administrative regulatory changes can carry very real, very costly consequences.
What Changes, What Stays the Same
The shift to digital medical cards doesn’t eliminate carrier responsibilities, but it does change how they’re fulfilled. As Harz emphasized during the webinar, “You must still verify that each driver’s medical card is valid. You have to show proof that the medical card does exist.”
With that in mind, carriers still need to:
- Track medical certification expiration dates
- Maintain complete driver qualification files
- Conduct annual MVR reviews and Clearinghouse queries
- Update files as licenses, endorsements, or employment status change
The biggest difference is that, instead of photocopying a physical card, carriers must now track and verify digital certifications through state MVR systems. For drivers, that means checking their medical status online, often through the same state DMV or MVR portals carriers use, to confirm their certification is current and properly reflected.
Harz also shared a critical insight: “A lot of companies do a great job creating a driver file for a new driver. But then they don’t take steps to maintain it on an ongoing basis.” Whether their files live in a cabinet or the cloud, this ongoing maintenance is where many carriers fall short.
Navigating the Transition
During the Q&A portion of the webinar, attendees raised practical questions about putting these changes into practice. One attendee wondered about tracking different medical certification timelines, as some drivers need renewals every two years, others annually, and some every few months based on their health conditions. The conversation revealed how challenging this can be without proper tracking systems, especially as paper reminders disappear.
Harz also fielded questions about DOT‑compliant applications, pointing out that generic employment forms often miss required elements like a 10‑year address history and three years of prior employment records. “A driver file with a non‑compliant application will render the entire driver file non‑compliant,” he explained.
The Reality of Modern Audits
Perhaps the biggest shift discussed wasn’t about medical cards at all, but about how compliance is monitored and enforced. Remote audits have become standard practice, with carriers typically receiving just 48 hours to produce the requested documents electronically.
“If you were called today and found out, ‘Hey, I’m going to be audited on Wednesday,’ you’ll have a lot of homework to do if you haven’t kept your files up to date,” Harz said. The days when carriers could count on an in‑person review with weeks of notice have largely passed, making organized, accessible documentation more critical than ever.
According to Harz, this shift began accelerating around 2018, when the sheer volume of new DOT numbers (600-700 new filings a day) overwhelmed the traditional audit system. What started as a pilot program in select states quickly expanded nationwide, forcing carriers to rethink how they approach document management.
A Split System Adds Complexity
One important distinction Harz clarified during the webinar is that the digital transition applies only to CDL drivers. "Non‑CDL drivers are still going to require paper cards," he noted. For carriers with mixed fleets, this means managing two parallel systems — digital records for CDL holders and paper files for everyone else.
Another layer of complexity is that not every state has met the June 23, 2025 implementation deadline. As of June 26, 2025, Alaska, California, Florida, Illinois, Iowa, Kentucky, Louisiana, New Hampshire, New Jersey, New York, North Carolina, Oklahoma, Vermont, and Wyoming are still in the process of adopting the National Registry II (NRII) system.
In these states, CDL and CLP holders must continue submitting a paper Medical Examiner's Certificate to their State Driver's Licensing Agency, and medical examiners must continue issuing paper cards until NRII is implemented. Carriers with drivers licensed in these states should review the official FMCSA guidance and adjust their compliance procedures accordingly.
These issues add additional challenges to an already detailed process, making it even more critical for carriers to have a systematic way to track and manage compliance.
A Larger Industry Shift
As the webinar concluded, both presenters emphasized that the medical card change is part of a bigger shift reshaping the transportation industry. From electronic logging devices to the DOT Clearinghouse and remote audits, paper‑based processes are quickly giving way to digital systems.
The message was clear: digital processes are becoming essential to managing a compliant, efficient fleet. As Harz said, "Being able to track online is going to become mission critical."
For carriers still relying on filing cabinets and manual reminders, the end of paper medical cards is both a challenge and an opportunity. Updating decades‑old processes can feel daunting, but it’s also a chance to build a more efficient, reliable system that reduces compliance risk and administrative headaches. The carriers who recognize this as a chance to modernize their approach will be better positioned for whatever changes come next.
If you missed the live webinar and want to watch the replay, you can access it here. And if you’d like help navigating these changes or moving to a digital solution, please reach out to us anytime.