FMCSA Grants Digital Medical Card Waiver Until October 12, 2025

Ah, the best laid plans. The FMCSA’s long-awaited Medical Examiner’s Certification Integration rule (also known as the National Registry II rule) was supposed to go into effect on June 23, 2025.

However, because twelve states are still transitioning to a fully electronic system, the FMCSA has issued a temporary waiver until October 12, 2025.

Below, we cover the following:

• A quick overview of the rule
• Why the FMCSA issued a waiver and what it means
• How to take advantage of this temporary waiver

What is the Medical Examiner’s Certification Rule (a.k.a. The National Registry II Rule)?

Simply put, the goal of the new rule is to move from a problematic paper process for medical certification to a faster and more reliable electronic system for all CDL and CLP holders.

Historically, issues with paper medical cards have resulted in pricey violations ($11,000 per violation), thousands of out-of-service orders, and negative impacts on CSA scores. In fact, over the past five years, medical card-related violations accounted for nearly 10% of all DOT violations.

And here’s the kicker: many of these violations stem from things that are straightforward to fix, like operating with an expired medical examiner’s certificate or not being in physical possession of it.

A fully electronic system can help solve some of these issues.

Under the updated process:

• Medical examiners must upload DOT physical exam results to the FMCSA National Registry by midnight of the next calendar day.
• The FMCSA will then automatically transmit those results directly to State Driver Licensing Agencies (SDLAs), which will add them to the driver’s Motor Vehicle Record (MVR).
• CDL and CLP holders are no longer required to submit a paper copy of their medical certificate to the state (in states that are NRII-compliant).
• Carriers no longer need to verify whether a medical examiner is certified—the FMCSA handles that through the National Registry.

PRO TIP: It’s important to note, however, that while you’ll have less paperwork thanks to this new rule, you’re still on the hook for tracking medical card expiration dates. Yes, you and your drivers have always been responsible for monitoring expirations. The difference is that if a card expires now, the consequences will be felt much faster, given that state licensing agencies will receive notifications almost immediately.

The bottom line is that you must be proactive in monitoring medical card expirations. Or better yet, use a digital system that does the monitoring for you. More on this in a moment.

Why did the FMCSA issue a temporary waiver on the medical examiner’s certification rule?

As the deadline approached, the FMCSA knew that some states were still transitioning to a fully operational electronic system and that they were unlikely to meet the deadline. These states include Alaska, California, Florida, Iowa, Kentucky, Louisiana, New Hampshire, New Jersey, New York, Oklahoma, Vermont, and Wyoming.

On July 14, 2025, the FMCSA issued a temporary waiver, stating on its website: “FMCSA has determined that it is in the public interest to issue a waiver so that drivers with valid medical certification and their employers are not negatively impacted for delays outside of their control during the transition to NRII.”

The FMCSA went on to say that the waiver allows holders of CDLs and CLPs “to continue relying [on] paper copies of medical examiner’s certificates as proof of drivers’ medical certification for up to 15 days after the date the medical examiner’s certificate is issued.”

The waiver is in effect until October 12, 2025.

Interestingly, this rule has a long history of delays. As we reported in this article, the ruling, which was published nearly a decade ago, has faced repeated delays as federal agencies worked through cybersecurity concerns and built the necessary IT infrastructure.

If needed, CDL drivers can access and print an official copy of the waiver here.

How can you prepare for a digital future?

If you haven’t done so already, now is the time to transition your driver qualification files to a fully digital system, one that not only houses electronic records but also alerts you when something is about to expire, like a driver’s medical certificate.

Another smart task? Implement continuous MVR monitoring, which will alert you in real-time whenever there’s a change to a driver’s MVR, like an expired medical card or other infraction, such as a speeding ticket or DUI.

And, of course, make sure everyone on your team is adequately trained on the systems you use and the latest DOT compliance requirements.

Got questions about the medical card rule or need help moving to a fully digital system?

If you have questions about the new medical card rule, check out our on-demand webinar, which you can watch anytime. If you need help transitioning to digital driver qualification files, get in touch, and one of our reps will be happy to help.