FMCSA Extends Paper Medical Card Waiver (Again): What Motor Carriers Need to Know

A show of hands…who’s getting tired of hearing about the transition to digital medical cards?

In one of the messier, more confusing regulatory rollouts in recent years, the FMCSA has just issued yet another waiver extending the use of paper medical cards until April 10, 2026. This is now the fourth extension since the rule went live in June 2025.

A Slow Road to Digital Adoption

We may be firmly in the digital age, but the transition to electronic medical card transmission has moved surprisingly slowly.

For context, the original rule mandating the shift to electronic medical card transmission was published in April 2015 with a three-year implementation deadline. The idea was straightforward: instead of drivers receiving a paper card and hand-delivering it to their state licensing agency, medical examiners would upload DOT physical results directly to the FMCSA, which would then transmit the information to state agencies to be posted on the driver’s motor vehicle record. No more paper to carry, copy, or lose.

Since the rule was published, the implementation date has been pushed twice: first to 2021 and then again to 2025. The FMCSA held firm on the June 2025 deadline, although several large states still didn’t have processes in place to support electronic transmission.

Here’s the timeline over the past year:

• Rule went live on June 23, 2025
• July 2025: First 15-day waiver was issued
• August 2025: Waiver was extended to October 12
• October 2025: Waiver was extended to January 10, 2026
• January 2026: Waiver was extended to April 10, 2026

Will we see another waiver issued in April? While there hasn’t been any indication that the waiver will be extended again, it wouldn’t be surprising, given that there are still eight states that need to comply. The states still working through implementation issues include: Alaska, California, Kentucky, Louisiana, New Hampshire, New Jersey, New York, and Oklahoma.

Even Compliant States Are Having Problems

Implementation alone hasn’t eliminated problems, with transmission errors and system mismatches still occurring in compliant states. Drivers with valid certifications are being flagged during traffic stops and roadside inspections because their data didn’t transmit correctly—through no fault of their own.

In response to the confusion and technical issues, the CVSA sent a letter to FMCSA Administrator Derek Barrs on December 5, 2025, requesting guidance that paper medical cards be accepted during inspections and audits until these issues are resolved. Some of the operational headaches the letter noted included:

• Carriers having to pull drivers from service or send them for repeat exams
• No notification when a certificate successfully posts to the driver’s motor vehicle record
• More frequent MVR queries just to confirm driver status

Following that request, the FMCSA issued the most recent waiver and encouraged medical examiners to continue issuing paper certificates during the transition.

How to Stay Compliant During the Transition

The current waiver is effective from January 11 to April 10, 2026. During this time, CDL and CLP holders in compliant states can use paper medical cards as proof of medical certification for up to 60 days after issuance. The driver must carry the valid paper medical card while driving, and the motor carrier must also have a copy on file.

For drivers in noncompliant states, the old process still applies. They must receive an updated paper certificate after passing a DOT physical and then submit the updated card to their state licensing agency. This process must also be followed by drivers who get a physical in a compliant state but are licensed in a noncompliant state.

Given all the hiccups in getting this regulation implemented correctly, here are the recommended action items for all drivers and motor carriers—regardless of where they operate:

• Request a paper copy of your medical card and keep it on your person while driving.
• Make a copy of your new paper medical card and give it to your motor carrier to place in your driver qualification file.
• If your state is compliant, check your motor vehicle record two to four days after your exam to ensure proof of medical certification appears. If it’s not there, contact the examiner first and then the state agency.
• Build in plenty of buffer by scheduling physicals at least two to three weeks before expiration.
• Document everything and maintain proof that you’re taking every necessary step to operate compliantly. Until the wrinkles are fully ironed out, having a backup plan is sensible.

Why the FMCSA Is Pushing Forward

You may be asking yourself why any of this matters…are paper medical cards such a big deal? The FMCSA thinks so, which is why it’s pushing forward and working with states to achieve uniform adoption. The proposed benefits of this change include:

• Fraud reduction, since paper cards can be easily forged or altered. Over the years, enforcement actions and investigations have shown that fraudulent medical certification is a real issue—one electronic verification is designed to reduce.
• A faster verification process.
• No more worries about lost or damaged paper cards (and one less thing drivers have to worry about carrying).

Whether another waiver is imminent or not, the direction is clear: electronic verification is the end goal, and the FMCSA will continue to prioritize it until all remaining states are compliant. For motor carriers, the safest approach is to transition to a digital compliance platform that tracks expiration dates, notifies you when drivers are due for a physical, and ensures you have an up-to-date medical certificate for every driver you employ. With MVR monitoring, you also get continuous updates so you know when proof of certification is recorded on each driver’s MVR—without having to run manual checks yourself.

We hosted a webinar last year that discussed the impact of this new regulation on the driver qualification file process. You can watch the on-demand version here. If you’d like to learn more about the benefits of a paper-free electronic portal, we’d be happy to give you a demo.